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SECTION 24G APPLICATION FOR RECTIFICATION

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SECTION 24G APPLICATION FOR RECTIFICATION Powered By Docstoc
					                     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:               jdouglas@knysna.gov.za            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
                                 / mel@cape-eaprac.co.za
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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