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Cape Environmental Assessment Practitioners (Pty) Ltd Reg. No. 2008/004627/07 Telephone: (044) 874 0365 First Floor, Eagles View Building Facsimile: (044) 874 0432 5 Progress Street, George Web: www.cape-eaprac.co.za PO Box 2070, George, 6530 SECTION 24G APPLICATION FOR RECTIFICATION SEDGEFIELD SEAWATER DESALINATION PLANT In terms of the National Environmental Management Amendment Act (NEMAA, Act 62 of 2008), In conjunction with NEMA (Act 107 of 1998) Regulations 385, 386 & 387 of 21 April 2006 Prepared for the Applicant: Knysna Municipality By: Cape Environmental Assessment Practitioners (Cape EAPrac) Ref: KNY058/19 DEA Ref: 12/12/20/884/11 Case Officer: Ms Pumeza Skepe-Mngcita Submitted for: DEA COMPLIANCE Date: 20 May 2010 D.J. Jeffery Directors L. van Zyl Sedgefield Desalination Plant Ref: KNY058/19 SECTION 24G APPLICATION FOR RECTIFICATION SEDGEFIELD SEAWATER DESALINATION PLANT In terms of the National Environmental Management Amendment Act (NEMAA, Act 62 of 2008) In conjunction with NEMA (Act 107 of 1998) Regulations 385, 386 & 387 of 21 April 2006 Submitted for: DEA Compliance This report is the property of the Author/Company, who may publish it, in whole, provided that: That written approval is obtained from the Author and that Cape EAPrac is acknowledged in the publication; That Cape EAPrac is indemnified against any claim for damages that may result from any publication of specifications, recommendations or statements that is not administered or controlled by Cape EAPrac; The contents of this report, including specialist/consultant reports, may not be used for purposes of sale or publicity or advertisement without the prior written approval of Cape EAPrac. Cape EAPrac accepts no responsibility by the Applicant/Client for failure to follow or comply with the recommended programme, specifications or recommendations contained in this report. Cape EAPrac accepts no responsibility for deviation or non-compliance of any specifications or recommendations made by specialists or consultants who‘s input/reports are used to inform this report. All figures, plates and diagrams are copyrighted and may not be reproduced by any means, in any form, in part or whole without prior written approved from Cape EAPrac. Report Issued by: Cape Environmental Assessment Practitioners Tel: 071 603 4132 PO Box 2070 Fax: 086 653 2873 5 Progress Street Web: www.cape-eaprac.co.za George 6530 Cape EAPrac Section 24G Application for Rectification Sedgefield Desalination Plant Ref: KNY058/19 TABLE OF CONTENTS 1 EXECUTIVE SUMMARY ........................................................................................................ ii 1.1 INTRODUCTION ............................................................................................................. II 1.2 LEGISLATION ................................................................................................................ III 1.2.1 National Environmental Management Amendment Act (Act 62 of 2008) ...................... iii 1.2.2 National Environmental Management: Integrated Coastal Management Act (Act 24 of 2008) ................................................................................................................................... iv 1.2.3 National Water Act (NWA, Act 36 of 1998) ................................................................. iv 1.2.4 National Environmental Management: Waste Act (NEM:WA, Act No 59 of 2008) ........ v 1.2.5 National Heritage Resources Act (NHRA, Act No 25 of 1999) ..................................... v 1.3 SITE DESCRIPTION ....................................................................................................... V 1.3.1 Plant ............................................................................................................................ v 1.3.2 Intake System ............................................................................................................. vi 1.3.3 Discharge System....................................................................................................... vi 1.3.4 Water Supply and Reticulation .................................................................................... vi 1.3.5 Bulk Electrical Supply ................................................................................................. vii 1.4 PLANNING CONTEXT ................................................................................................... IX 1.5 PROCESS TO DATE ..................................................................................................... IX 1.6 CONCLUSIONS AND RECOMMENDATIONS ............................................................... IX FIGURES Figure 1 Aerial map showing the location of various aspects of the Plant APPENDICES Appendix A: Location Plan Appendix B: Public Participation: Issues and Responses Table APPOINTED ENVIRONMENTAL ASSESSMENT PRACTITIONER: Cape EAPrac Environmental Assessment Practitioners PO Box 2070 George 6530 Tel: 044-874 0365 Fax: 044-874 0432 Report written & compiled by: Melissa Mackay (NDip Nature Conservation). Ms Mackay has three years experience as an environmental practitioner. Report reviewed by: Louise-Mari van Zyl (MA Geography & Environmental Science [US]; Registered Environmental Assessment Practitioner with the Interim Certification Board for Environmental Assessment Practitioners of South Africa, EAPSA); Chairperson of the Southern Cape Internal Association for Impact Assessments (IAIA). Ms van Zyl has eight years experience as an environmental practitioner. Cape EAPrac Section 24G Application for Rectification Sedgefield Desalination Plant ii Ref: KNY058/19 1 EXECUTIVE SUMMARY 1.1 INTRODUCTION Cape Environmental Assessment Practitioners (Cape EAPrac) have been appointed as the independent Environmental Assessment Practitioner (EAP) responsible for facilitating the legally required Section 24G Application for Rectification process for the Sedgefield Desalination Plant. The Applicant, responsible for undertaking the activity is Knysna Municipality. Due to the location of Sedgefield within the Lakes Area the delegated authority for the environmental application process is the National Department of Environmental Affairs (DEA). A Location Plan has been provided in Appendix A of this Application Form. Sedgefield is a coastal town situated halfway between George and Knysna in the Garden Route along the Southern Cape. It has an estimated permanent population of 5 000 people that increases to approximate 25 000 people during the peak holiday period (StatsSA – CS 2007). In 2005/2006 the Municipality was compelled to implement water restrictions mainly due to the limited capacity and flood risk of the water treatment works. Despite interim and emergency water supply schemes the town of Sedgefield‘s‘ water supply failed in December 2008 / January 2009 due to abnormally low rainfall. Although the Municipality has a comprehensive long term water supply plan up to 2030, the project requires a total budget of approximately R130 million, and due to a lack of funds the implementation thereof did not start as planned in 2007/2008. As a result of the 2008 / 2009 water shortage, the daily operations such as restaurants, hair salons, car washes, Laundromats and every household were seriously affected. With no other option available, water was supplied by the George Municipality (trucked in at high cost) in order to supply the basic needs of households and businesses. This operation was halted once an emergency scheme could be implemented. The emergency scheme consisted of the drilling of nine boreholes below Cloud Nine and abstraction from the Hoogekraal River. It is evident that the current water supply source is insufficient and unsustainable and cannot continue to supply in the present and future needs of Sedgefield. The Knysna Integrated Development Plan (IDP 2007) states that “…until water supplies for Sedgefield have been secured and assured, the Council is not able to approve water supplies for any new developments in Sedgefield”. Therefore the IDP specifically includes ‗ upgrading additional water supply‘ and also ‗ of the waste water treatment works‘ as projects to be funded and implemented. In order to avoid the crises condition of December 2008 / January 2009, the Municipality proposed interventions to be very rapidly implemented to prevent interruptions to the town‘s water supply over the 2009 / 2010 peak holiday period. Of the three components proposed for the overall Bulk Augmentation Scheme, the Seawater Desalination Plant offers the fastest assurance of water with potentially the least impact. According to SSI an important aspect of the desalination option, is the assurance‘ against peak season failure in the short to medium term. ability to provide ‗ A meeting held with DEA and the Applicant (Knysna Municipality) led to the interim agreement for the implementation of the Desalination Plant at Myoli Beach as early as November 2010. Implementation of the desalination plant was considered an emergency procedure in order to Cape EAPrac Section 24G Application for Rectification Sedgefield Desalination Plant iii Ref: KNY058/19 address the serious water shortfall being experienced due to the severe drought gripping the Southern Cape. Testing for the beach wells commenced on 17th October 2009 and the Plant and its associated infrastructure was installed from end October 2009 and came into operation on 23rd December 2009. The agreement was reached to continue with construction in terms of Section 24F(3) of NEMAA that makes allowance for an activity to commence or continue ― response to ...in an emergency so as to protect human life, property or the environment”. The NEMAA Section 24F3 process was informed using specialist impact assessments, engineering advice and recommendations, construction management recommendations and monitoring requirements. Although a „normal EIA‟ process (vs a Section 24F3 process) was not undertaken for the desalination plant, the environment was still being considered and additional care was taken to minimise and/or mitigate foreseeable impacts. All construction related activities were monitored and constantly overseen by a suitably qualified Environmental Control Officer (ECO). Future maintenance and repair work of the Plant and its associated infrastructure will also be subjected to environmental monitoring where necessary. A Motivation Report (Ref: KNY058/10) was submitted to DEA on the 9th November 2009 which included all the baseline information obtained from the various specialists, and a Completion Report (Ref: KNY058/17) was submitted to DEA: Marine and Coastal Management on the 18th March 2010 in terms of their Permit conditions for Vehicle Use in a Coastal Zone for the construction activities on Myoli Beach. This 24G Application must therefore be read in conjunction with these reports as they contain a comprehensive summary of process and actions already undertaken since the activity commenced. 1.2 LEGISLATION The Desalination Plant has been constructed and implemented without prior environmental authorisation. Section 24F(3) of the National Environmental Management Amendment Act (NEMAA Act 62 of 2008) makes provision for emergency scenarios where an activity will not be subjected to a ‗normal‘ Environmental Impact Assessment (EIA) process. Due to the crises of water shortages expected for December/January, DEA has determined that the desalination plant will be implemented in terms of Section 24F(3) of NEMAA (see below for explanation). The legislation that has been considered for this proposal is briefly outlined below. These environmental requirements are not intended to be definitive or exhaustive but serve to highlight key environmental legislation and responsibilities only. 1.2.1 National Environmental Management Amendment Act (Act 62 of 2008) Section 24F(3) of NEMAA deals with activities that commence without prior Environmental Authorisation given special circumstances (i.e. emergency water supply). Section 24F allows the competent authority the right to legally penalise an offender, unless the activity is commenced in terms of Section 24F(3). This clause states ― is a defence to a charge in terms of subsection (2) It to show that the activity was commenced or continued in response to an emergency so as to protect human life, property or the environment.” Due to the extreme drought that has been experienced in the Southern Cape recently, the water resources for the area are under severe pressure and unlikely to meet the peak demand for the holiday period. Sedgefield has already been in the situation of having to depend on George Cape EAPrac Section 24G Application for Rectification Sedgefield Desalination Plant iv Ref: KNY058/19 Municipality to provide water when the Karatara River ran dry in December 2008 / January 2009. Estimations for this year are even more dire, in that George will not be able to assist if and when the Karatara runs dry again this December. The Knysna Municipality has already declared an emergency and in an attempt to redress this for the coming influx of visitors to Sedgefield, made an urgent appeal to DEA to consider the Desalination Plant component of this EIA in terms of Section 24F(3). DEA agreed and as such, the impacts of the Desalination Plant will be investigated and reported on through this Motivation Report submitted to DEA in terms of Section 24F3. Formal environmental authorisation is likely to be considered in terms of a NEMAA Section 24G application to DEA following implementation of the Plant. All attempts will be made to ensure that environmental damages are limited during the implementation and operation of the plant. The relevant listed activities in terms R386 of the National Environmental Management Act (NEMA, Act 107 of 1998) are as follows: Activity 2 Construction or earth moving activities in the sea or within 100 meters inland from the high water mark of the sea, in respect of:g) infrastructure. [Abstraction and Discharge points and infrastructure associated with Desalination Plant at Moyli Beach]. Activity 6 The excavation, moving, removal, depositing or compacting of soil, sand, rock or rubble covering an area exceeding 10 square metres in the sea or within a distance of 100 metres inland of the high water mark of the sea. [Earth works on Moyli Beach as well as within the surf zone in order to lay the necessary desalination infrastructure up to 8 meters below the surface level]. 1.2.2 National Environmental Management: Integrated Coastal Management Act (Act 24 of 2008) The Integrated Coastal Management Act (ICMA) specifies that „no person may discharge effluent1 that originates on land into coastal waters except in terms of a General Authorisation‟. Although the President assented the Act on 11 February 2009, it has however not come into effect yet. Therefore a Coastal Waters Discharge Permit will only be a legal requirement (for the discharge of brine) once the Act is enacted which is likely to be post implementation of the Desalination Plant. This was confirmed with the Department Environmental Affairs (DEA&DP) confirmed in a meeting held on 6 November 2009. 1.2.3 National Water Act (NWA, Act 36 of 1998) In terms of the NWA abstraction of water from a water resource, and discharge of wastewater into a water resource requires authorisation. In a meeting held with the Provincial Department of Water Affairs (DWA) on 6 November 2009, it was confirmed that the definition of a ‗ water resource‟ excludes the sea, therefore there is no legal obligation to obtain authorisation (for abstraction of seawater and the discharge of brine back into the sea) in terms of the NWA. 1 "effluent" means— (a) any liquid discharged into the coastal environment as waste, and includes any substance dissolved or suspended in the liquid; or (b) liquid which is a different temperature from the body of water into which it is being discharged; Cape EAPrac Section 24G Application for Rectification Sedgefield Desalination Plant v Ref: KNY058/19 1.2.4 National Environmental Management: Waste Act (NEM:WA, Act No 59 of 2008) In short NEM:WA deals with the handling, treatment, processing, recycling, re-use and/or storage of both ‗ hazardous‘ waste products. This Act was assented by the President on 10 general‘ and ‗ March 2009 enacted on 3 July 2009. Subsequently all waste related activities are omitted from NEMAA and must be authorized in terms of NEM:WA. In a meeting/teleconference held with the Provincial Department Environmental Affairs: Waste Division it was confirmed that the discharge of brine (concentrated sea water) back into the sea via beach wells does not require authorisation in terms of the NEM:WA. This was also confirmed with Mr Obed Baloyi from the National DEA office. In the event however that it becomes evident in future that hazardous substances are required to clean the plant/membranes/beach wells, consideration must be given to the applicability of the NEM:WA. 1.2.5 National Heritage Resources Act (NHRA, Act No 25 of 1999) The protection and management of South Africa‘s heritage resources are controlled by the National Heritage Resources Act (Act No. 25 of 1999). South African National Heritage Resources Agency (SAHRA) is the enforcing authority and in the Western Cape, SAHRA have, in most cases, delegated this authority to Heritage Western Cape (HWC). The National Heritage Resources Act requires relevant authorities to be notified regarding this proposed development, as the following activities are relevant: the construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300m in length; any development or other activity which will change the character of a site exceeding 5 000 m² in extent; the re-zoning of a site exceeding 10 000m² in extent. The product water pipeline that connects the Plant with the town‘s reservoir exceeds 300m in length and therefore requires consideration in terms of the NHRA. The necessary application and investigations on this line was performed prior to construction commencing. 1.3 SITE DESCRIPTION 1.3.1 Plant The Desalination Plant is a single pass reverse osmosis (RO) system with a design capacity to produce a final permeate flow (fresh / product water) of 1,5 million litres/day (Ml/d). The plant consists of two 0,75Ml/day modules, in two separate 12m long steel shipping containers, placed next to the ablution block at the Myoli Beach municipal parking area. Seven 10 000lt tanks are positioned within the area between the containers to temporarily store the intake water, potable Cape EAPrac Section 24G Application for Rectification Sedgefield Desalination Plant vi Ref: KNY058/19 water and brine before it is pumped to its relevant location. The area has been fenced-off for security purposes. 1.3.2 Intake System A series of nine (9) beach wells were installed with five (5) intake beach wells containing submersible pumps and considered ― active‖, and four (4) blanked off ― inactive‖ wells. Five active wells are the required number needed to ensure the maximum intake flow rate. The four inactive wells will only be used should a problem occur with any of the active wellpoints. 1.3.3 Discharge System The design provides for two (2) discharge well points. Two vertical wells were installed, but were removed as they became exposed. Currently the brine (water with higher salinity levels) is being discharged via a shallow water diffuser which is placed just in the surf zone. Connecting the two well fields to the plant are HDPE pipes perpendicular to the contours of the base of the dune. The route follows the base of the dune to the existing pathway to the parking area. The pipelines are buried to a minimum depth of 1,5m below the natural ground level. Several repairs and changes have been made to the discharge system since its initial installation in order to optimize the functionality of the plant. DEA: Marine and Coastal Management, SANParks and I&APs were notified each time beach works were being undertaken. 1.3.4 Water Supply and Reticulation A pipeline was constructed to transport the product water (clean water) from the Desalination Plant to the Blombosnek Reservoir where it is blended with other potable water. The route is approximately 2,5kms long and follows existing road reserves and the sewer line servitude across private property where there is a municipal sewage pump station. This pipeline is below threshold and does not require environmental authorisation. Construction of the pipeline commenced end of October 2009. The product water pump station is housed in one of the steel shipping containers at the plant site. Cape EAPrac Section 24G Application for Rectification Sedgefield Desalination Plant vii Ref: KNY058/19 1.3.5 Bulk Electrical Supply In order to supply sufficient electricity to the Desalination Plant, the cables of the existing overhead 11kV electrical line along Leervis Street have been upgraded. A new 500kV mini- substation was constructed at the Plant location. The line upgrade and new substation do not require environmental authorisation and the necessary upgrading commenced end of October 2009. Figure 1 below is an aerial map indicating the location of the various components of the Desalination Plant, with particular emphasis on the beach area. Cape EAPrac Section 24G Application for Rectification Sedgefield Desalination Plant viii Ref: KNY058/19 Cape EAPrac Section 24G Application for Rectification Sedgefield Water Supply Augmentation Scheme ix Ref: KNY058/14 1.4 PLANNING CONTEXT Knysna Municipality, in the 2007 – 2011 Integrated Development Plan (IDP) recognised that water scarcity in Sedgefield was a reality, especially during peak holiday seasons and confirmed that various options to provide the town with water were being investigated. The Knysna Town Council has since put an embargo on all new developments in the town, citing water shortages as the main reason. The current Urban Edge has been kept to the confines of the town of Sedgefield to preclude any additional developments on the outskirts of the town. However, Knysna Municipality has commitments to provide / upgrade housing for local inhabitants currently living in poor communities. The shortages in water prevent this goal from being achieved. 1.5 PROCESS TO DATE A Section 24F3 Motivation Report (Ref: KNY058/10) was submitted to the DEA on 11 November 2009. The report contained Baseline Marine Specialist input, an Acoustic Statement, an Archaeological Impact Assessment and an Engineering Report. These reports were made available to the public for information purposes. An Issues and Responses table summarizing the comments and concerns raised by the public during the extensive public participation on this project has been included as Appendix B of this report. The construction phase has been closely monitored by the appointed Ecological Control Officer (ECO) and a report was submitted to DEA: Marine and Coastal Management in compliance with their conditions contained in their Permissible Use Permit (MCM Completion Report, Ref: KNY058/17). The Permit was obtained to allow access to the beach for an excavator and a 4 x 4 bakkie. A copy of the report was submitted to DEA:MCM and DEA on 18th March 2010. Marine Water Quality monitoring has been ongoing since 16 December 2009 and a final report will be submitted to DEA once instructions are received to continue with the 24G process. In addition an Acoustic Report has been completed and the final Asbuilt Drawings and Report will also be completed. These will all be included in later submissions to DEA. 1.6 CONCLUSIONS AND RECOMMENDATIONS The construction on the beach for the Sedgefield Desalination Plant commenced on 17th October 2009 with the implementation of the test wells. The latest repairs were carried out on the 18th May 2010. As the appointed ECO for the site, a Cape EAPrac representative was on site to oversee all beach construction activities at all times. The ECO has expressed satisfaction with the adherence of the contract teams to general duty of care and the EMP. No issues were raised by the ECO or any members of the public regarding the actual activities or potential impacts on site. Based on the project information available, as well as the specialist feedback to date, the indication is that operation of the Plant is unlikely to cause harm to the receiving environment on condition that the various specialist recommendations be implemented to ensure minimal impact in the long term. Cape EAPrac Final Scoping Report Sedgefield Water Supply Augmentation Scheme x Ref: KNY058/14 Since the submission of the Motivation Report (Ref: KNY058/10) to DEA, a final Acoustic Report, up to date Marine Monitoring Report and the final Asbuilt Report have been drafted and will be submitted to DEA as part of the 24G Environmental Report, once instruction has been received. APPLICANT: KNYSNA MUNICIPALITY DEPARTMENT REFERENCE: 12/12/20/884/11 SUBMISSION DATE: 20 MAY 2010 Cape EAPrac Final Scoping Report Application for Rectification Form APPLICATION TO RECTIFY UNLAWFUL COMMENCEMENT OR CONTINUATION OF LISTED ACTIVITIES IN TERMS OF SECTION 24G OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NO 107 OF 1998) Kindly note that: 1. The application form is current as of 16 January 2008. It is the responsibility of the applicant to ascertain whether subsequent versions of the form have been published or produced by the competent authority. 2. Incomplete applications will be returned to the applicant for revision and re-submission. 3. The use of “not applicable” in the form must be done with circumspection as if it is used in respect of material information that is required by the competent authority for assessing the application. 4. Lodging an application for rectification does not necessarily imply that the activity will be authorized. In terms of the Act the activity may either be conditionally authorized or a directive may be issued for the activity to cease and for the environment to be rehabilitated. 5. No faxed or e-mailed applications will be accepted. 6. Unless protected by law, all information filled in on this application will become public information on receipt by the competent authority. Any interested and affected party should be provided with the information contained in this application on request, during any stage of the process. 7. A separate form must be completed for each unlawful activity. 8. Applicants and environmental consultants are responsible for the accuracy of the information supplied and are therefore required to complete the checklist fully and honestly. 9. This application form must be completed by an Independent Environmental Assessment Practitioner. For official use only: File reference number: Date received: Departmental Details Postal address: Department of Environmental Affairs and Tourism Attention: Director: Environmental Impact Evaluation Queries should be directed to the Directorate: Private Bag X447 Environmental Impact Evaluation at: Pretoria Tel: (012) 310 3268 0001 Fax (012) 320 7539 Physical address: Please note that this form must be copied to the Department of Environmental Affairs and Tourism relevant provincial environmental department. Fedsure Forum Building (corner of Pretorius and Van der Walt Streets) 2nd Floor North Tower 315 Pretorius Street Pretoria 0002 View the Department’s website at http://www.deat.gov.za/ for the latest version of the documents 1 Application for Rectification Form SECTION A: BACKGROUND INFORMATION AND CONTACT DETAILS Applicant: Knysna Municipality Company/ Closed Corporation Registered Name (if applicable): Company / Closed Corporation Registration Number (if applicable): Contact Person: Johnny Douglas Position in Company: Municipal Manager ID Number of Contact Person / Applicant: Postal Address: PO Box 21 Knysna Code: 6570 Physical Address: Main Building, Clyde Street Knysna Code: 6570 Telephone No: 044-302 6300 Cell: Not available E-mail address: email@example.com Fax: 044-302 6333 Registered Land Dave Sharpe (servitude is held by Knysna Municipality for sewer and Owner: water pipelines) and SANParks (manage Myoli Beach). Contact Person: See attached list for details. Postal Address: Code: Physical Address of land Owner: Code: Telephone No: Cell: E-mail address: Fax: Where there is more than one landowner, a list of landowners with their contact details must be attached to this application form. Tick box if list is attached In instances where the landowner is not the applicant, attach landowner consent form Tick box if consent is attached Project Environmental Cape EAPrac Assessment Practitioner: Company/ Closed Corporation Cape Environmental Assessment Practitioners (Pty) Ltd Registered name (if applicable): Company / Closed Corporation Registration Number (if applicable): Contact Person: Louise-Mari van Zyl / Melissa Mackay 2 Application for Rectification Form Position in Company: Director / Senior Consultant ID Number of Contact Person / 7806080098083 / 7103070033084 Applicant: Postal Address: PO Box 2070 George Code: 6530 Physical Address: 5 Progress Street George Code: 6530 Telephone No: 044-874 0365 Cell: 084 584 7419 E-mail address: Louise@cape-eparac.co.za Fax: 044-874 0432 / firstname.lastname@example.org EAP Qualifications MA Geography and Environmental Science / ND Nature Conservation Professional affiliation(s) Director certified as an Environmental Assessment (if any) Practitioners with the Interim Certification Board for Environmental Assessment Practitioners of South Africa (EAPSA). The Environmental Practitioner’s Curriculum Vitae (CV) must be attached. Tick box if CV is attached SECTION B: DETAILS OF UNLAWFUL OF ACTIVITY Indicate hereunder the activity for which you are applying for rectification. The relevant number should be reflected as it appears in the government notice. Activities listed in GNR 386 requiring a basic assessment: Item #: Item description: 2 Construction or earth moving activities in the sea or within 100 meters inland from the high water mark of the sea, in respect of: g) infrastructure. [Abstraction and Discharge points and infrastructure associated with Desalination Plant at Moyli Beach]. 6 The excavation, moving, removal, depositing or compacting of soil, sand, rock or rubble covering an area exceeding 10 square metres in the sea or within a distance of 100 metres inland of the high water mark of the sea. [Earth works on Moyli Beach as well as within the surf zone in order to lay the necessary desalination infrastructure up to 8 meters below the surface level]. Activities listed in GNR 387 requiring a Scoping Report and Environmental Impact Assessment: Item #: Item description: 3 Application for Rectification Form Details of property on which unlawful activity is taking place: Farm Portion: Suburb name: Myoli Beach Erf number: Erf 3517 and Myoli Beach Municipal area: Knysna Municipality GPS Co-ordinates Desalination Plant at Myoli Beach Parking Area: 34⁰ 1‟ 58,108” S 22⁰ 48‟ 4,398”E Beach wells from: 34⁰ 2‟ 1,553” S 22⁰ 48‟ 0,126” E To: 34⁰ 2‟ 6,406” S 22⁰ 48‟ 12,79” E Product water Pipeline from: 34⁰ 1‟ 58,108” S 22⁰ 48‟ 4,398” E To: 34⁰ 1‟ 24,732” S 22⁰ 48‟ 41,788” E A full list of co-ordinates for the pipeline is attached. If supplying the co-ordinates using Geographic Co-ordinate System: Co-ordinates to be supplied in decimal degrees, with precision up to 6 (six) decimals. Spheroid to be used: WGS 84 Datum: Hartebeesthoek 1994 If supplying the co-ordinates using Projected Co-ordinate System: Co-ordinates to be supplied in meters, with precision up to 2 (two) decimals Spheroid to be used: WGS 84 Projection: Transverse Mercator Central Meridian: 29 Degrees East Where a large number of properties are involved, please attach a full list to this application. A LOCALITY PLAN MUST BE ATTACHED Description of activity: Please provide a brief description of the nature and extent of the activity. Extent to include but not be limited to: Area covered by the activity; Capacity of the facility (if applicable); Throughput of the facility (if applicable) The Desalination Plant is designed to produce an output of 1,5Ml/day fresh water supply. The required feed (seawater intake) flow rate is 160m3/hr, with approximately 55% - 60% of this volume being returned as concentrated seawater and the remainder (40% - 45%) as potable water directly into the municipal water reticulation network. In order to achieve the 1,5Ml/day supply, the Plant must operate for 21 hrs per day. The plant is made up of a single pass Reverse Osmosis (RO) system with a series of beach 4 Application for Rectification Form wells that abstract seawater through the sand and discharges brine back through sand into the surf zone of the sea. In both cases the sand acts as a filtration system to prevent larger particles entering the plant. The plant itself consists of two 12m x 2.5m and one 6m x 2.5m shipping containers laid out in a U shape. It is a mobile system and will consist of two 0,75Ml per day RO modules, one in each container. The 6m container contains the pump station and operations control. The containers have been placed next to the ablution block at the Myoli Beach parking area. Seven holding tanks are placed within the U shape to hold intake-, discharge- and product water. The tanks are fitted with cut off valves which activate the pumps when full. The pumps then draw seawater into the RO units, pumps the product water to the reservoir, and the brine to the beach. A 500KvA mini substation has been constructed in proximity to the Plant to provide electricity Date when activity was commenced with for the first time: 2 November 2009 Tick box if activity is continuing: Please indicate the current status by ticking the appropriate boxes: Construction completed Activity operational Property / ies transferred to Construction ceased prior to finalization new owners Operation / activity ceased Activity has been decommissioned and pending outcome of property rehabilitated to original state application 5 Application for Rectification Form SECTION C: AUTHORISATIONS / PERMITS OBTAINED FROM OTHER ORGANS OF STATE: Please complete the table below with regard to authorizations / permits obtained from other organs of state (if applicable). Certified copies of permits / authorizations / certificates must be attached Name of Authority: Legislation / Date of authorization / Applicable Regulations / By-law permit / certification: authorization / permit / in terms of which certificate number: authorization was obtained: DEA: Marine and Regulation 44(d) in 9 – 30 November 2009 A25/7/8/3/2/3 Coastal Management terms of Section 44 of 1 – 9 December 2009 NEMA (Control of Use 15 – 19 December 2009 A25/7/8/3/2/2 of Vehicles in a Coastal 26 February – 31 March 2010 Zone). SECTION D: ENFORCEMENT ACTION BY DEAT Please complete the table below with regard to any enforcement action taken against you for this development by this Department. Copies of the relevant pre-compliance notice / compliance notice / pre- directive/ directive must be attached to this rectification application. Pre-compliance Date issued: Reference Number: Copy attached? y/n notice / compliance notice / pre- directive/ direct: SECTION E: MOTIVATION FOR SECTION 24G APPLICATION Please explain why this activity commenced in contravention with the National Environmental Management Act, Act 107 of 1998 (as amended). As a result of the 2008 / 2009 water shortage, the daily operations such as restaurants, hair salons, car washes, laundromats and every household were seriously affected. With no other option available, water was supplied by the George Municipality (trucked in at high cost) in order to supply the basic needs of households and businesses. This operation was halted once an emergency scheme could be implemented. The emergency scheme consisted of the drilling of nine boreholes below Cloud Nine and abstraction from the Hoogekraal River. It is evident that the current water supply source is insufficient and unsustainable and cannot continue to supply in the present and future needs of Sedgefield. The Knysna Integrated Development Plan (IDP 2007) states that “…until water supplies for Sedgefield have been secured and assured, the Council is not able to approve water supplies for any new developments in Sedgefield”. Therefore the IDP specifically includes „additional water supply‟ and also „upgrading of the waste water treatment works‟ as projects to be funded and implemented. In order to avoid the crises condition of December 2008 / January 2009, the Municipality proposed for interventions to be very rapidly implemented to prevent interruptions to the town‟s water supply over the 2010 peak holiday period. Of the three components proposed for the overall Sedgefield Augmentation Scheme, the Desalination Plant offered the fasted 6 Application for Rectification Form assurance of water with potentially the least impact. According to SSI an important aspect of the desalination option, is the ability to provide „assurance‟ against peak season failure in the short to medium term. The Knysna Municipality declared an emergency in terms of natural disasters and in an attempt to redress this for the 2009 / 2010 influx of visitors to Sedgefield, made an urgent appeal to DEA to consider the Desalination Plant component of this EIA in terms of Section 24F(3). DEA agreed and as such, the impacts of the Desalination Plant were initially investigated and reported on through a Motivation Report submitted to DEA in terms of Section 24F3. After construction and implementation of the plant, monitoring of both Acoustic and Marine impacts have been ongoing and these reports will be submitted as part of the next phase of the 24G process. Please motivate why your application in terms of Section 24G of the National Environmental Management Act should be considered favourably: The Desalination Plant provides assurance of water to the town of Sedgefield in order to accommodate the influx of visitors to the area during the peak holiday seasons. For a period of approximately 6 weeks from 6 March 2010, the RO Plant has been the only source of water for the town while maintenance and repair work to the town‟s Water Works is underway. Ongoing monitoring of the brine discharge in the marine environment is recommended to ensure that no long term impacts are experienced. Final placement of the discharge mechanism should also be re-evaluated in terms of the results of the monitoring data obtained by Anchor Environmental to date. Details of previous offences committed in terms of environmental legislation None SECTION F: Certified copies of the following documents must accompany your application: 1. Identification page from ID document of the applicant in cases where an individual is the applicant or of the contact person where a company / close corporation apply. 2. Registration certificate of the Company / Close Corporation. 3. Proof of ownership of the land or alternatively, proof of owner’s consent to undertake activity on the relevant land. 7 APPENDIX A: LOCATION PLAN AND CO-ORDINATES C ape E nvironm ental A ssessment P ractitioners (Pty) Ltd Blombosnek Reservoirs Swartvlei Pipeline Route on existing Servitude Desalination Plan Site Myoli Beach Beach well area ® 0 125 250 500 750 1,000 Meters Location Map for Sedgefield Desalination Plant Sedgefield Map scale is 1 : 6000 when printed on A3. Ref: KNY058 Data Source: Aerial Image courtesy of Google Earth Pro 2008 Date: November 2009 Degrees Decimal Minutes for Pipeline Route Start Myoli Beach Parking 22 48.085 -34 1.984 22 48.083 -34 1.987 22 48.114 -34 2.002 22 48.153 -34 1.939 22 48.302 -34 2.002 Manhole 22 48.32 -34 1.995 22 48.323 -34 1.987 22 48.365 -34 1.997 22 48.377 -34 1.989 22 48.378 -34 1.914 22 48.388 -34 1.904 22 48.406 -34 1.901 22 48.52 -34 1.904 22 48.523 -34 1.872 22 48.53 -34 1.84 22 48.542 -34 1.837 22 48.551 -34 1.831 22 48.64 -34 1.81 22 48.691 -34 1.785 22 48.758 -34 1.758 22 48.776 -34 1.754 Smutsville 22 48.774 -34 1.724 22 48.722 -34 1.731 22 48.734 -34 1.657 22 48.748 -34 1.657 22 48.759 -34 1.594 22 48.739 -34 1.592 22 48.768 -34 1.419 Blombosnek Reservoir 22 48.71 -34 1.416 Lo23 WGS84 WGS84 WGS84 East North Easting Northing Longitude Latitude Longitude Latitude deg E deg S Deg Min Sec Deg Min Sec WELL 1 18495.89 3767422.67 666144.41 6232641.68 22.7997160 34.0337454 22 47 58.9776 34 2 1.4834 WELL 2 18487.18 3767427.58 666153.02 6232636.60 22.7998102 34.0337899 22 47 59.3167 34 2 1.6436 WELL 3 18478.47 3767432.49 666161.63 6232631.52 22.7999044 34.0338343 22 47 59.6558 34 2 1.8035 WELL 4 18469.75 3767437.39 666170.25 6232626.45 22.7999987 34.0338786 22 47 59.9953 34 2 1.9630 WELL 5 18461.04 3767442.30 666178.87 6232621.37 22.8000929 34.0339230 22 48 0.3344 34 2 2.1228 WELL 6 18452.33 3767447.21 666187.48 6232616.29 22.8001872 34.0339674 22 48 0.6739 34 2 2.2826 WELL 7 18443.61 3767452.11 666196.10 6232611.22 22.8002815 34.0340118 22 48 1.0134 34 2 2.4425 WELL 8 18434.90 3767457.02 666204.71 6232606.14 22.8003757 34.0340562 22 48 1.3525 34 2 2.6023 WELL 9 18426.19 3767461.93 666213.32 6232601.07 22.8004699 34.0341006 22 48 1.6916 34 2 2.7622 DISCHARGE 1 18143.61 3767561.86 666493.88 6232495.64 22.8035278 34.0350064 22 48 12.7001 34 2 6.0230 DISCHARGE 2 18099.42 3767585.26 666537.60 6232471.38 22.8040058 34.0352181 22 48 14.4209 34 2 6.7852 APPENDIX B: PUBLIC ISSUES AND COMMENTS SEDGEFIELD BULK WATER SUPPLY AUGMENTATION SCHEME ISSUES RESPONSES Richard Batson – Sedgefield Resident Biological fouling of the Reverse Osmosis (RO) membranes is GrahamTek has extensive experience with this technology and have 16’ generally irreversible, necessitating replacement of some or all of membranes fitted with flow distributors that have been operating well over the membranes. 5 years without significant fouling. The expected replacement time (every five years) is based on this. Water samples taken during the installation of the test wells were Water from Myoli Beach may contain dissolved organics and even analysed (see Design Report in Appendix 4). Even if there is partially Pre-Treatment partially treated sewage in the feed water. treated sewage in the feed water, it will have no negative effect on the system and everything harmful will be removed during pre-treatment. Are acidification and the use of any anti-scalant included in the pre- The Plant will not be using anti-scalant. GrahamTek has many years treatment process? experience with the 16” technology operating successfully without the use of anti-scalant. A decision will however be made during commissioning, if “acidification” is required. Should further studies be required at that point, it will be undertaken to evaluate potential impacts. The quoted costs of R5 per kl and R3 per kl can only be true if they This is not energy costs only, but is indeed the costs of operation. The represent the energy costs only and should be explained by technology used is more economical than the standard 8” membrane GrahamTek. based systems. Treatment Costs The cost of replacing the membranes, based on a 5 year life span According to GrahamTek Systems the cost of membrane replacement is appears to be close to R2 per kl of treated water. The implication included. is that the membrane costs are not included in the quoted water production costs. The power consumption is apparently 3kWh/m³ with a total power These costs are average costs and are based on 15 years’ of data logging of 185kW. Is this power consumption based upon the flux rate and and collection and Grahamtek’s extensive experience with the use of our feed pressure of new membranes or does it include a fouling factor membrane technology. that takes into account the inevitable reduction in flux that occurs with time? What is the total installed power and what will be the power Preliminary calculations of the load from the desalination plant, and the Power consumption? product water pumpstation, indicate that the peak demand will be in the order of 350kVA. Allowing for additional starting currents and for upgrading of other users, a 500kVA miniature substation is required. The main factor in the reduction of costs is the recovery of energy This information is confidential as it will make public some of used to drive the seawater feed pumps. No information has been GrahamTek’s design and methods. provided. It is understood that the Water Treatment Plant will take the base GrahamTek has a preservation program that is designed to “mothball” the load and that the RO plant will be used only to meet emergencies plant. This will ensure longevity of the plant and will have no effect on the and peak demands. What effect will this degree of discontinuous production capability of the plant. The Plant can be shut down for a period operation have on the production of potable water and what steps during which time the membranes are protected in a fluid. will be taken to “mothball” the plant when it is not required? Operation What membrane cleaning procedures and frequencies does GrahamTek recommend? The plant is designed to do an Auto Rinse a few times per day with fresh product water. The frequency will be decided during the commissioning period. We also anticipate a Cleaning in Place (CIP) at least twice a year. Output from the RO plant is dependent upon the temperature and According to Anchor Environmental Consultants the sea temperature viscosity of seawater. What temperature did GrahamTek use in measured in October ranged from 17,3ºC – 18,2ºC. The specs used their design? ranged from 16ºC - 21ºC. Output RO permeate is highly corrosive. A correctly designed and sized GrahamTek confirmed that they will stabilise the product water during stabilisation section must be added to prevent corrosion of copper treatment. piping in the roof space and built into the walls of nearly every Sedgefield home. Reports suggest that the desalination plant will be “Proudly South All claims are true. GrahamTek have not claimed to have developed African”. This is far from true. We should make certain that any seawater desalination using a membrane base system, but they do own technology claims are genuine. unique and innovative 16” Membrane (fitted with Flow Distributors). These technologies are GrahamTek’s and have patents registered that are recognised internationally. General GrahamTek claim to have sold about 100 desalination plants in This is correct. The necessary contacts and background on other Plants Africa and about 200 worldwide. Have they provided any have been provided to the Municipality as part of the tender process. information on these plants to enable contact with these operators. Victor Bantjes – Sedgefield Resident Will the water be treated for bacteria after desalination, and if so, The objective of Post Treatment of the product water is to ensure that it is how? safe to drink, and non-corrosive. Disinfection will be achieved by controlled dosing of hypochlorite (NaOCl), and the correct pH maintained by controlled dosing of hydrated lime (Ca(OH)²). These are normal water treatment processes and will provide water suitable for immediate consumption. How much water can a membrane treat before it becomes clogged or otherwise unusable? How will the operator determine when a GrahamTek has extensive experience with this technology and have 16’ Output membrane needs to be replaced? membranes fitted with flow distributors that have been operating well over 5 years without significant fouling. Indicators are in place to warn of membrane malfunction. How great is the risk of water coming through the system without The process of Reverse Osmosis will remove all dissolved solids, even if the dissolved solids being removed to an acceptable level? there is partially treated sewage in the feed water, it will have no negative effect on the system and everything harmful will be removed. How much expertise is required to run such a plant, and can you GrahamTek will monitor and operate the plant for the first year and for the always guarantee that such expertise is available? contract time period of the Operational and Maintenance Contract, whilst training municipal staff to operate the plant. It is anticipated that the Sedgefield Water Treatment operators will be responsible for maintenance. GrahamTek will be available for expertise and can monitor General and operate the Plant remotely. Dave Edge – Knysna Environmental Forum How much electric power will the desalination plant require? Preliminary calculations of the load from the desalination plant, and the product water pumpstation, indicate that the peak demand will be in the order of 350kVA. Allowing for additional starting currents and for upgrading of other users, a 500kVA miniature substation is required. The municipality can only offer electricity that is available to it from Eskom. Has provision been made for the necessary power supply, and do The assumption is that Eskom knows what capacity it has available. The Eskom have the capacity to supply? Municipality has undertaken to limit operation of the Plant in order to avoid additional pressure during the peak electrical demand periods. Will the plant run continuously or only when other sources of water The plant is designed to operate discontinuously and can be “mothballed” have failed? when not required. Its function is to provide water at peak and emergency Power times in order to provide water assurance for Sedgefield. It will make up part of the total Augmentation Scheme in the long run. We understand that there are other far more energy-efficient GrahamTek has indicated that it can provide up to 40% saving on power technologies relating to desalination involving evaporator grilles usage with this design. and condensation processes instead of forced filtration and reverse osmosis – were these even considered? Are the costs quoted in the press release of R3 per kilolitre at The price of R3/kl is the current operational cost for producing water from current electricity prices? What will be the effect of Eskom’s this plant. The pricing of this water in the long term will also be dependant proposed tariff increases of 45% per annum for each of the next on the quantities used by the consumer, as well as the running periods three years? required by the plant to supplement the Sedgefield water supply. How is the construction and more importantly the operations of the It is not expected that the Municipality will carry the capital costs of the Costs plant being financed? What will be the effect on the Knysna plant due to the water crisis. Municipality’s budget? How much brine will be produced as effluent and at what The plant is designed to abstract up to 160m³ per hour of which 45% will concentration and temperature? become product water and 55% discharged as brine. The concentration of the brine will be approximately 1,7 times that of seawater and the temperature at the discharge point is expected to be 0,5⁰C more than the intake water. What chemicals will have been used and thus contaminated the No Biocides will be used as anti-scalants / anti-fouling agents for the brine – chemicals are apparently used during the filtration process. membranes. If it does become necessary to use such agents, the Marine Specialists has provided mitigation measures. Should it become evident that further investigations are required it will be done by suitably qualified specialists. What effect will this brine have on marine organisms? A Marine Biology Assessment was commissioned in order to assess the potential impacts from the brine discharge. This included a baseline survey of the Myoli Beach area. A monitoring regime has been identified by Anchor Environmental in order to measure potential impacts against this baseline study. The specialist confirmed that discharge of the brine is unlikely to cause significant damage to the receiving environment. Discharge Will sludge also be a waste product in addition to brine? Sludge is the accumulation of solid particles and it is not expected that there will be any large concentration due to the beach sand filtration design. Has any consideration been given to rather making use of the brine Alternative uses for the salt would be welcomed. Please not however, through evaporation ponds etc so that the salt could be utilised that evaporation ponds require large areas currently not available in instead of “filtering” concentrated brine back into the sensitive Sedgefield in any close proximity. This system can very easily adapted sandy beach system? should alternative uses be identified. Can the suppliers give some examples of where the proposed The Marine Biology Assessment has identified that the impact of the brine brine disposal method has been used and demonstrate that there discharge will be medium to low at this particular site. This plant has been are no harmful environmental consequences? designed for the factors applying to it such as beach wells and mobile containers. There is none other to compare at this stage. What will be the visual impact of the plant and its ancillary facilities The plant is made up of three (3) shipping containers set in a U shape on at Myoli Beach and will this spoil the ambience of Sedgefield’s the northern side of the parking area adjacent to an existing ablution most popular beach? Being 12m high it presumably has a major facility. The containers are 12m long, not 12m high and are standard Visual visual impact and what kind of precedent does this set? shipping containers. The Knysna Municipality asked Cape EAPrac to conduct a survey for the colour of the containers and the water tanks in order to choose the most acceptable colour. The visual impact is expected to be low. What will be the noise level of the plant during operation, and will The noise level of the pumps is expected to be 85dBA 1m from the source this be a public nuisance? within the container. An Acoustics Report is being prepared based on a similar plant on the West Coast. Furthermore, relevant mitigation measures will be implemented into the containers within which the pumps Noise are housed, before the containers are brought to site. The Acoustic Engineer will evaluate the Plant whilst under construction in Cape Town in order to recommend noise reduction measures. Will there be possible damage to the structure and functioning of No. The construction envelope for the implementation of the beach wells Construction the primary dunes caused during construction and operations. will use the existing beach access (used by SANParks heavy machinery for breaching the Swartvlei mouth) and will remain off the primary dunes. An Ecological Control Officer has been appointed and will remain on site for the duration. What other water supply options for Sedgefield were considered The Desalination Plant was originally part of an EIA for the total before making this decision? Is desalination the cheapest, most Augmentation Scheme for Sedgefield. This Scheme will be made up of secure and environmentally least detrimental option? Borehole supply, river abstraction, re-use of wastewater and desalination. The desalination was fast tracked as it provides the best assurance for water supply for Sedgefield in the quickest time to provide water for the coming festive season. The Augmentation Scheme EIA is still in process. Will the Municipality be able to recruit the necessary skills to GrahamTek will monitor and operate the plant for the first year and for the contract time period of the Operational and Maintenance Contract, whilst operate and maintain what appears to be a technically training municipal staff to operate the plant. It is anticipated that the sophisticated plant? They seem to have enough difficulties with operating and maintaining the relatively low-technology systems Sedgefield Water Treatment operators will be responsible for that they currently have. maintenance. GrahamTek will be available for expertise and can monitor and operate the Plant remotely. General Water conservation / water efficiency / water demand management should always be prioritised above increased supply. What water All municipalities are required to have Water Demand Management conservation measures and strategy have been planned / policies in place. This comment is noted. implemented? Has any comparative study been done regarding the provision of water tanks to every household, the retrofitting of municipal toilets with waterless urinals, water-saving taps versus the cost (both monetary and to the environment) of constructing and operating a desalination plant? Why has there been no public participation process during the Please see the section on Public Participation of the Environmental period since July while this decision was being evaluated by the process in the report. Municipality. The Municipality claims that this situation is an emergency and The Desalination Plant was originally part of an EIA for the total therefore exempts their actions from complying with 24F of NEMA. Augmentation Scheme for Sedgefield. This Scheme will be made up of We would dispute this since there are a number of other options Borehole supply, river abstraction, re-use of wastewater and desalination . that could have been considered that would have been far less The desalination was fast tracked as it provides the best assurance for costly, environmentally less harmful, and intrinsically less risky and water supply for Sedgefield in the quickest time to provide water for the flexible. coming festive season. The Augmentation Scheme EIA is still in process. Investigations and monitoring of the plant are ongoing to determine any environmental impacts. Andre Gauche – Neighbouring Resident at Myoli Beach Noise pollution from the plant and pumps affecting the An Acoustics Report is being prepared based on a similar plant on the neighbouring guesthouse. West Coast. Furthermore, relevant mitigation measures will be implemented into the containers within which the pumps are housed, before the containers are brought to site. The Acoustic Engineer will evaluate the Plant whilst under construction in Cape Town in order to Noise recommend noise reduction measures. Leonie Meyer – Shearwater on Sea Guesthouse at Myoli Beach Shearwater on Sea will be affected by construction activities. The municipality has been informed of the request. Cape EAPrac has Please advise us on when our guests will be affected by these been appointed as the Ecological Control Officer on site and will monitor Construction activities and give advance warning. construction activities. Please be aware that an alternative access to the beach from Blacktail Str will be provided during beach construction. According to ZLH Consulting Engineers construction is not expected to exceed 1 week in total (weather/tide depending). This construction period is temporary and falls outside of the peak holiday period. Malcolm Osborne – Sedgefield Resident The Scoping report mentions noise being generated by the The noise level of the pumps is expected to be 85dBA 1m from the source desalination plant but gives no details. Can estimates of sound within the container. An Acoustics Report is being prepared based on a pressure levels be provided, e.g. in the parking area and in the similar plant on the West Coast. Furthermore, relevant mitigation Noise street outside the nearby hotel? measures will be implemented into the containers within which the pumps are housed, before the containers are brought to site. The Acoustic Engineer will evaluate the Plant whilst under construction in Cape Town in order to recommend noise reduction measures. SANParks SANParks supports the Desalination Plant in general. Noted. The Desalination Plant must be seen as a mechanism to alleviate Noted. the pressure on the Karatara Hoogekraal rivers. SANParks requires the implementation of a Construction Phase A Construction EMP will be provided to SANParks and implemented on Environmental Management Plan. site. Cape EAPrac has been appointed as the Ecological Control Officer on site during construction and will maintain a comprehensive record of all activities and ensure compliance with both the EMP and Best Practise principles. General SANParks requests to be involved in the monitoring programmes SANParks will be notified of the commencement of monitoring and their for both the Groundwater Monitoring (of the spikes) and the Brine input will be greatly valued. Discharge Monitoring. Lilith Seals – Sedgefield Resident Have all the options for disposal of brine been looked at? Please Not all options have been considered for the immediate implementation of contact Alison Lewis, she specialises in disposal of salt brines. the plant, however, alternative uses for the brine should be investigated. General The details were forwarded to the relevant engineers and the Municipality. Mr Wietsche Roets – Land Use Advice, CapeNature CapeNature supports the comments from SANParks. Would like to The water assurance of the Desalination Plant is to provide assurance of see that water demand management remains in place. water for the immediate needs of the coming festive season. It forms part of the overall Augmentation Scheme which is being developed to support General water usage in Sedgefield in the medium to long term. Sue Swain - Private Water Demand Strategies should be implemented. Noted. General Concern regarding use of Biocides in the Desalination Plant. No Biocides will be used as anti-scalants / anti-fouling agents for the membranes. If it does become necessary to use such agents, the Marine Specialists has provided mitigation measures. Should it become evident that further investigations are required it will be done by suitably qualified specialists. Mr Anton Valks –Sedgefield Resident Concern regarding the effect of the desalination plant on the quality A Monitoring Programme is being put in place by Knysna Municipality to and quantity of water of existing well points nearby. identify if any impacts occur. The Marine Specialist has indicated that the likelihood of this occurring from the discharge point is very slim, unless a pipe containing brine is broken closer to the surface of the beach. The Monitoring programme will be overseen by SANParks. Brine Discharge What will the effect be of the brine water on the quality of the well It is unlikely that there will be a negative impact, however potential points? impacts will be monitored and identified through continuous monitoring. Site selection is inherent to the function of the activity and would not be Suggest moving the plant further west to the other side of the mouth. viable west of the mouth. Possible remuneration for affected well points such as free water. This possibility has been presented to the Municipality. What effect will the plant in the parking area have on the surrounds An Acoustics Engineer is considering the impacts of noise on the area and in terms of noise, waste etc. will be following up with monitoring in order to identify any negative impacts. Mitigation measures will be implemented up front in order to pre- empt any impacts. Noise Noise reduction and waste management mitigations must be This is being put in place. provided. Mike Young – Sedgefield Resident RO plants are known to be noisy. Information must be provided An Acoustics Engineer is considering the impacts of noise on the area and which includes a detailed schedule of the sources of noise. will be following up with monitoring in order to identify any negative impacts. Mitigation measures will be implemented up front in order to pre- Noise empt any impacts. His research will include noise generated by the Plant whilst under construction (to inform design already) and readings from a similar plant on the West Coast at Shelley Point. GrahamTek states that in normal operation the cleaning of clogged GrahamTek remains certain that no biocides will be necessary for the membranes will not require the use of biocides. I suggest that it is operation of the plant. Should one be required either Rocide DB5 or Biocides necessary to provide a great detail about what biocides would be Rocide IS2 will be used. The Marine Specialist conducted his assessment used and in what circumstances, what the ultimate biodegraded on the impact on the marine environment with biocides and without. The compounds would be and how they would be disposed of. report covers the breakdown, disposal and impact in more detail. The use of biocides is not recommended. Disposal of brine effluent is another potential concern. A Marine Biology Assessment was commissioned in order to assess the Brine Discharge potential impacts from the brine discharge. This included a baseline survey of the Myoli Beach area. A monitoring regime has been identified by Anchor Environmental in order to measure potential impacts against this baseline study. The specialist confirmed that discharge of the brine is unlikely to cause significant damage to the receiving environment. Whilst all official comments to date state that an adequate supply of The municipality can only offer electricity that is available to it from Eskom. electricity will be available, there needs to be confirmation that the The assumption is that Eskom knows what capacity it has available. The Power cumulative demand of all such plants does not place unacceptable Municipality has undertaken to limit operation of the Plant in order to avoid demands on the electrical network. additional pressure during the peak electrical demand periods. Possible impact on tourism in Sedgefield due to noise and possible The noise issues regarding the plant are being very carefully evaluated sea water contamination. and an Acoustics Engineer has been appointed to provide mitigation measures and recommendations for noise reduction. The impact on the seawater by the brine discharge is considered medium to low by the Marine Specialists. General Aesthetics need to be considered. The derelict ablution block is The plant will be housed in three shipping containers which will be placed adjacent to the ablution block and parking area. The colour of the facility not attractive and the plant needs to improve on the local scene. has been surveyed with the local residents and vegetative screening will be undertaken to minimise the visual impact of the plant.
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