Integrated Water Use Licence Amendment Application (IWULA ... · Duvha Power Station is located on Portion 0 of the farm Duvha Kragstasie 337, approximately 12 km south east of Emalahleni

Zitholele Consulting

Reg. No. 2000/000392/07 PO Box 6002 Halfway House 1685, South Africa Building 1, Maxwell Office Park, Magwa Crescent West c/o Allandale Road & Maxwell Drive, Waterfall City, Midrand Tel + (27) 11 207 2060 Fax + (27) 86 674 6121 E-mail : [email protected]

Directors : Dr. R.G.M. Heath, S. Pillay, N. Rajasakran

REPORT ON

Integrated Water Use Licence Amendment Application (IWULA)

and

Integrated Water and Waste Management Plan (IWWMP)

Report No : 15008-46-Rep-001-Duvha WULA

Amendment IWWMP-Rev0

Submitted to:

Eskom Holdings SOC Limited

PO Box 2199 Witbank

1035

DISTRIBUTION:

4 Copies - Department of Water and Sanitation

1 Copy - Eskom Holdings SOC Limited

1 Copy - Zitholele Consulting (Pty) Ltd – Library

02 March 2018 15008

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ZITHOLELE CONSULTING

EXECUTIVE SUMMARY

Duvha Power Station is located on Portion 0 of the farm Duvha Kragstasie 337,

approximately 12 km south east of Emalahleni (Witbank), within the Emalahleni Local

Municipality (ELM) in the Mpumalanga Province. The project area falls within quaternary

catchment B11G of the Olifants Water Management Area (WMA).

Zitholele Consulting (Pty) Ltd (Zitholele) was appointed to undertake an assessment of water

uses as well as an amendment of the Integrated Water Use Licence Application (IWULA) at

Duvha Power Station. This includes an application for water uses that exist at the power

station but which have not been licensed previously.

This report serves as both an IWULA and Integrated Waste and Water Management Plan

(IWWMP) and intends to replace the current Water Use Licence (WUL) at Duvha Power

Station to reflect all the water uses currently taking place at the power station.

The water uses as summarised in the table below are being applied for:

Water Use Description Applicable Water Uses to this project

S21 (a) Taking of water from a water resource.

Taking water from Driefontein Dam (3 650 000 m

3/annum (10 000 m

3/day)). Eskom currently

has excess water and as a result, they are not taking water from the Driefontein dam but they are required as per existing WUL condition to undertake monitoring at Driefontein dam. An amendment is therefore, required in terms of the monitoring frequency. Eskom Duvha Power Station proposes that monitoring by Eskom at Driefontein dam only be undertaken during the period when Eskom have taken water from Driefontein dam - Amendment

S21 (c) Impeding or diverting the flow of water in a water course.

Power station and the associated existing infrastructures including - New Application:

Power Station and the associated infrastructure

ADF;

Coal Stockyard;

Low level AWRD including silt traps;

High level dams;

Station drains; and

Sewage plant.

S21 (i)

Altering the bed, banks, course, or characteristics of a watercourse. This includes altering the course of a watercourse (previously referred to as a river diversion).

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S21 (g) Disposing of waste in a manner which may impact on a water resource.

The WUL authorised the disposal of 10 000 m

3/day

water containing waste from the

Driefontein dam into the AWRD. Eskom proposes the amendment of the above to the following: “disposal of water containing waste from the Driefontein dam into the ash disposal facility” – Amendment.

Coal Stock Yard - New Application.

Dust suppression of unrehabilitated areas with dirty water (Coal Stock Yard) – cooling water


High level dams;

Station drains;

Maturation ponds

The Public Participation Process (PPP) to announce the project has been undertaken during

the period December 2016 to February 2017. The announcement phase was undertaken for

a 30-day period which included placement of site notices in the vicinity of Duvha Power

Station, newspaper advertisements and distribution of the Background Information

Document (BID). Further PPP in terms of IWULA and IWWMP review will be undertaken for

60 days, starting from March 2018 as per the Section 41 reading with 52 of the National

Water Act (Act No 36 of 1998) as amended (NWA).

Two (2) specialist studies were undertaken for this particular amendment and new licensing

of existing water uses application, namely; Stormwater Management Plan and Wetland

survey. The Stormwater Management Plan (SWMP) study revealed that Duvha Power

Station has an effective stormwater management system in place and with proper operations

and maintenance of it will ensure environmental compliance.

The findings and/or recommendations for the Wetland survey are summarised as follows:

The wetlands that surround the power station facility are influenced by the management

practices of the facility as well as those activities of the surrounding land users. They are

therefore subject to a multitude of pressures and drivers of ecological change;

Overall, the wetland units were found to have retained relatively good ecological

functionality;

The capacity of the surrounding wetlands to purify contaminated water depends on the

protection of the ecological integrity of the systems. This includes vegetation density and

structure as well as geomorphological features (protection from erosion and factors that

will enhance erosion features). At present, erosion features are being enhanced through

defining the watercourses through excavations as well as activity of livestock within the

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wetland zones. These are two aspects that should be addressed, which will require

coordination with surrounding land users/owners;

It is recommended that any effluents that are discharged into the surrounding wetland

units be tested for harmful contaminants to ensure that no significant impacts to the

supported biodiversity will take place. Cross referencing the effluent quality to the

present Department of Water and Sanitation (DWS) target water quality guidelines

should be undertaken;

Management strategies have been highlighted for each wetland unit that will aid in

sustaining ecological integrity of the surrounding wetland units;

It is recommended that any alien invasive vegetation be managed; and

The use of the wetlands for water volume and quality management pertaining to the

Duvha Power Station can be possible in a sustainable way and these wetlands can offer

ecological services and functions that can reduce the costs of artificial water purification

and volume management.

Duvha Power Station currently undertakes Surface, Groundwater and Biomonitoring at

different sites surrounding Duvha Power Station. The existing Surface, Groundwater and

Biomonitoring are in line with the Power Station’s existing WUL that was issued in 2007.

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TABLE OF CONTENTS

SECTION PAGE

1 INTRODUCTION............................................................................................. 1-1

1.1 Background ................................................................................................. 1-1

1.2 Purpose of IWWMP ..................................................................................... 1-1

1.3 Contact detail ............................................................................................... 1-2

1.4 Environmental Assessment Practitioner ....................................................... 1-2

1.5 Regional setting and location of activity ....................................................... 1-3

2 CONCEPTUALISATION OF ACTIVITY ......................................................... 2-1

2.1 Description of activity ................................................................................... 2-1

2.2 Extent of activity ........................................................................................... 2-4

2.3 Key activity related processes and products ................................................ 2-4

2.4 Activity life description .................................................................................. 2-5

2.5 Activity infrastructure description .................................................................. 2-5

2.6 Key water uses and waste streams .............................................................. 2-5

2.7 Organisational structure of water and waste related activities ...................... 2-8

2.8 Business and corporate policies .................................................................. 2-9

3 REGULATORY WATER AND WASTE MANAGEMENT FRAMEWORK ...... 3-1

3.1 Summary of all water uses ........................................................................... 3-1

3.2 Existing lawful water uses ............................................................................ 3-4

3.3 Relevant exemptions ................................................................................... 3-7

3.4 Generally authorised water uses .................................................................. 3-7

3.5 New water uses to be licensed .................................................................... 3-7

3.6 Waste management activities (NEMWA) ..................................................... 3-7

3.7 Waste related authorisations ........................................................................ 3-7

3.8 Other authorisations (EIAs, EMPrs, Environmental Authorisations, Regulations) ................................................................................................ 3-7

4 PRESENT ENVIRONMENTAL SITUATION .................................................. 4-1

4.1 Climate ........................................................................................................ 4-1

4.2 Topography ................................................................................................. 4-2

4.3 Geology and Soils ........................................................................................ 4-4

4.4 Surface Water .............................................................................................. 4-7

4.5 Groundwater .............................................................................................. 4-20

4.6 Socio-economic environment ..................................................................... 4-27

5 ANALYSES AND CHARACTERISATION OF ACTIVITY ............................... 5-1

5.1 Site delineation for characterisation ............................................................. 5-1

5.2 Water and waste management .................................................................... 5-1

5.3 Storm water ................................................................................................. 5-1

5.4 Operational Management............................................................................. 5-5

5.5 Monitoring and control ............................................................................... 5-10

5.6 Risk assessment / Best practice assessment............................................. 5-18

5.7 Public consultation process ........................................................................ 5-21

5.8 Matters requiring attention / problem statement ......................................... 5-24

5.9 Assessment of level and confidence of information .................................... 5-24

6 WATER AND WASTE MANAGEMENT ......................................................... 6-1

6.1 Water and waste management philosophy (process water, storm water, groundwater, waste) .................................................................................... 6-1

6.2 Strategies (process water, storm water, groundwater and waste) ................ 6-1

6.3 Performance objectives / goals .................................................................... 6-3

6.4 Measures to achieve and sustain performance objectives ........................... 6-3

6.5 IWWMP action plan ..................................................................................... 6-3

6.6 Control and monitoring ................................................................................. 6-7

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7 CONCLUSION ................................................................................................ 7-1

7.1 Regulatory status of activity ......................................................................... 7-1

7.2 Statement on water uses requiring authorisation, dispensing with licensing requirement and possible exemption from regulations ................................. 7-3

7.3 Section 27 Motivation ................................................................................... 7-3

7.4 Licence Condition ........................................................................................ 7-7

8 REFERENCES ................................................................................................ 8-1

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LIST OF FIGURES

Figure 1-1: Locality Map of the Project ........................................................................... 1-4

Figure 1-2: Cadastral Map ............................................................................................. 1-5

Figure 1-3: Municipal Boundary Map .............................................................................. 1-6

Figure 2-1: Duvha Power Station Layout Map ................................................................ 2-2

Figure 2-2: Duvha Power Station Organisation Structure for water and waste related

activities ......................................................................................................................... 2-8

Figure 4-1: Long-term monthly average evaporation (mm) across Mpumalanga ............ 4-2

Figure 4-2: Topography Map .......................................................................................... 4-3

Figure 4-3: Geology Map .............................................................................................. 4-5

Figure 4-4: Soils Map ..................................................................................................... 4-6

Figure 4-5: Quaternary Catchment Map ......................................................................... 4-8

Figure 4-6: The wetland habitat units pertaining to the study area (EnviRoss, 2017) ... 4-14

Figure 4-7: Locality of study area in relation to the regional vegetation types ............... 4-17

Figure 4-8: Locality of study area in relation to the regional vegetation Conservation

Status .......................................................................................................................... 4-18

Figure 4-9: Study area in relation to the Mpumalanga Biodiversity Sector Plan (2014) . 4-19

Figure 4-10: Hydro-census sample locations in relation to surface water and

groundwater monitoring (GCS, 2009) ........................................................................... 4-21

Figure 4-11: The concept geohydrological model –plan view indicating the identified

pollution sources and dams/reservoirs of Duvha Power Station ................................... 4-26

Figure 5-1: Water Balance Connectivity Diagram (Zitholele, 2017) ................................ 5-3

Figure 5-2: Waste management hierarchy (DEA, 2011) ................................................. 5-5

Figure 5-3: Location of the surface water quality monitoring points around Duvha

Power Station - WUL (LMC, 2016) ............................................................................... 5-12

Figure 5-4: Locations of the groundwater quality monitoring points around Duvha

Power Station - WUL (LMC, 2016) ............................................................................... 5-15

Figure 5-5: Duvha Power Station study area indicating streams and selected

monitoring sites (Eskom, 2016a) .................................................................................. 5-17

LIST OF TABLES

Table 1-1: Applicant’s contact details ............................................................................. 1-2

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Table 2-1: Section 21 Water Uses (NWA) applicable to the project ................................ 2-6

Table 3-1: Detailed information for S21a water uses applied for .................................... 3-2

Table 3-2: Detailed information for S21 c and i water uses applied for ........................... 3-2

Table 3-3: Detailed information for S21g water uses being amended and applied for .... 3-3

Table 3-4: Water use licences issued to the Duvha Power Station ................................. 3-5

Table 4-1: Long-term mean monthly rainfall figures (mm) for various stations within the

Emalahleni region (Airshed, 2015) ................................................................................. 4-1

Table 4-2: Surface water chemistry results for Ash Return Water Quality as compared

to WUL (LMC, 2016) .................................................................................................... 4-10

Table 4-3: Surface water chemistry results for the Emergency Pond and Witbank Dam

as compared to the WUL (LMC, 2016) ......................................................................... 4-10

Table 4-4: Surface water Quality results for the final Sewage Effluent as compared to

the WUL (LMC, 2016) .................................................................................................. 4-10

Table 4-5: RWQOs for Upper Olifants Management biophysical node HN9 (DWS,

2015) ........................................................................................................................... 4-11

Table 4-6: Land use and land cover in the Olifants Water Management Area (Source:

CSIR 2003) .................................................................................................................. 4-13

Table 4-7: The hydrogeomorphic wetland types of the regional wetlands associated

with the site and the ecological services they provide within the landscape as adapted

from Kotze, et al, 2009 (EnviRoss, 2017) ..................................................................... 4-15

Table 4-8: The hydrogeomorphic forms of the wetland units that were surveyed for

Duvha Power Station (EnviRoss, 2017) ....................................................................... 4-15

Table 4-9: Categories of the Mpumalanga Biodiversity Sector Plan (2014) .................. 4-16

Table 4-10: Groundwater quality results for Duvha Power Station boreholes as

compared to WUL Limits (LMC, 2016) ......................................................................... 4-24

Table 4-11: Groundwater quality results for Duvha Power Station boreholes as

compared to the groundwater reserve quality set in Duvha Power Station WUL (LMC,

2016) ........................................................................................................................... 4-25

Table 5-1: Existing surface water quality monitoring points around Duvha Power

Station - WUL (LMC, 2016) .......................................................................................... 5-11

Table 5-2: Existing groundwater quality monitoring points around Duvha Power Station

- WUL (LMC, 2016) ...................................................................................................... 5-14

Table 5-3: Duvha Power Station Biomonitoring locations (Eskom, 2016a) ................... 5-16

Table 5-4: Summary of the possible impacts related to the operational activities at

Duvha Power Station ................................................................................................... 5-18

Table 5-5: Mitigation measures .................................................................................... 5-19

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Table 5-6: List of Comments and Responses from public consultation process ........... 5-22

Table 6-1: Duvha Water Balance Results ....................................................................... 6-2

Table 6-2: Performance objectives for Duvha Power Station .......................................... 6-3

Table 6-3: IWWMP action plan ....................................................................................... 6-4

Table 7-1: Water uses to be licenced ............................................................................. 7-2

Table 7-2: Summary of water requirements (units: million m3/year) (DWS, 2011b) ........ 7-4

Table 7-3: Water Use Projections of the Olifants Catchment for 2035 (DWS, 2011b)..... 7-5

Table 7-4: Summary of WUL (Ref No. 24013693) conditions requiring amendment ....... 7-7

LIST OF APPENDICES RELEVANT TO IWULA and IWWMP

Appendix A: IWULA Application forms

Appendix B: Existing WUL

Appendix C: Public Participation Incl. DWS Consultation

Appendix D: Wetland Survey and Rehabilitation Plan

Appendix E: SWMP and Water Balance

Appendix F: Surface and Groundwater Monitoring Report

Appendix G: Masterplan

Appendix H: Eskom Integrated Report 2016

Appendix I: Eskom Duvha ISO Certificate

Appendix J: Routine Biomonitoring Network for Eskom 2015/16

Appendix K: Hydrocensus Report

Appendix L: Waste Classification Reports

Appendix M: Groundwater Pollution Plume Modelling

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LIST OF ACRONYMS

ADF Ash Disposal Facility

AWRD Ash Water Return Dam

BID Background Information Document

CBA Critical Biodiversity Area

CER Centre for Environmental Rights

CRR Comments and Responses Report

DEA Department of Environmental Affairs

DWS Department of Water and Sanitation

EAP Environmental Assessment Practitioner

EAPASA Environmental Assessment Practitioners Association of South Africa

EC Electrical conductivity

ECO Environmental Control Officer

EIA Environmental Impact Assessment

EIS Ecological Importance and Sensitivity

ELM Emalahleni Local Municipality

EMC Environmental Monitoring Committee

EMPr Environmental Management Programme Report

EMS Environmental Management System

GDP Gross Domestic Product

GIS Geographic Information Systems

GISSA Geo-Information Society of South Africa

GPS Global Positioning System

HGM Hydrogeomorphic

HLD High Level Dam

I&AP Interested and Affected Party

IAIA International Association for Impact Assessment

IDP Integrated Development Plan

IUA Integrated Units of Analysis

IRHI Index of Reservoir Habitat Impairment

IWULA Integrated Water Use Licence Application

IWWMP Integrated Waste and Water Management Plan

LLD Low Level Dam

LM Local Municipality

LMC Lefatshe Minerals and Consulting

mamsl metres above mean sea level

MAR Mean Annual Runoff

Mbgl Metres below ground level

MBCP Mpumalanga Biodiversity Conservation Plan

MBSP Mpumalanga Biodiversity Sector Plan

MCM/a Million cubic meters per annum

MU Management units

NACA National Association for Clean Air

NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998)

NEM:WA National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008)

NFEPA National Freshwater Ecosystem Priority Area

NGO Non-Governmental Organisation

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NMWS National Management Waste Strategy

NWA National Water Act, 1998 (Act No. 36 of 1998)

NWRS National Water Resource Strategy

OMM Operations and Maintenance Manual

PCD Pollution Control Dam

PDCA Plan-Do-Check-Act

PES Present Ecological State

PGM Platinum Group Metal

PLATO South African Council for Professional and Technical Surveyors

PPP Public Participation Process

PS Present water quality status

RDM Resource Directed Measures

REC Recommended Ecological Category

RWQO Resource Water Quality Objectives

SACNASP South African Council for Natural and Scientific Professions

SANBI South African National Biodiversity institute

SANS South African National Standards

SASS5 Southern African Scoring System version 5

SHE Safety Health and Environmental

SHEQ Safety Health and Environmental Quality

SWB Sluice Water Booster

SWMP Stormwater Management Plan

TDS Total Dissolved Solids

WMA Water Management Area

WMO Waste Management Officer

WQO Water Quality Objectives

WUA Water Use Area

WUL Water Use Licence

ZLED Zero Liquid Effluent Discharge

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GLOSSARY OF TERMS

Construction

Means the building, erection or establishment of a facility, structure or

infrastructure that is necessary for the undertaking of a listed or specified activity

but excludes any modification, alteration or expansion of such a facility, structure or

infrastructure and excluding the reconstruction of the same facility in the same

location, with the same capacity and footprint.

Disposal The burial, deposit, discharge, abandoning, dumping, placing or release of any waste into, or onto, any land.

Environment

In terms of the National Environmental Management Act (NEMA) (No 107 of 1998), “environment” means the surroundings within which humans exist and that are made up of:

i. the land, water and atmosphere of the earth; ii. micro-organisms, plant and animal life; iii. any part or combination of (i) of (ii) and the interrelationships among and

between them; and iv. the physical, chemical, aesthetic and cultural properties and conditions of

the foregoing that influence human health and well-being.

Environmental Assessment Practitioner (EAP)

The individual responsible for planning, management and coordination of environmental impact assessments, strategic environmental assessments, environmental management programmes or any other appropriate environmental instrument introduced through the EIA Regulations.

Environmental Control Officer (ECO)

An ECO is an independent quality controller and monitoring agent regarding all environmental concerns and associated environmental impacts. Compliance monitoring, implementation and enforcement, ensuring legal compliance, advising and/or consulting, communicating, reporting and raisings awareness are the key roles of an ECO.

Environmental Impact

A change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation’s activities, products or services.

Environmental Impact Assessment (EIA)

A study of the environmental consequences of a proposed course of action which involves the process of collecting, organising, analysing, interpreting and communicating information.

Interested and Affected Party (I&AP)

Any person, group of persons or organisation interested in or affected by an activity; and any organ of state that may have jurisdiction over any aspect of the activity.

Mitigate The implementation of practical measures designed to avoid, reduce or remedy adverse impacts or enhance beneficial impacts of an action.

Public Participation Process

A process in which potential interested and affected parties are given an opportunity to comment on, or raise issues relevant to, specific matters.

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Waste1

Any substance, whether or not that substance can be reduced, re-used, recycled

and recovered—

a) that is surplus, unwanted, rejected, discarded, abandoned or disposed of;

b) which the generator has no further use of for the purposes of production;

c) that must be treated or disposed of; or

d) that is identified as a waste by the Minister by notice in the Gazette, and

includes waste generated by the mining, medical or other sector, but—

i. a by-product is not considered waste; and

ii. any portion of waste, once re-used, recycled and recovered, ceases to

be waste.

Watercourse

A watercourse is:

a) a river or spring; b) a natural channel in which water flows regularly or intermittently; c) a wetland, lake or dam into which, or from which, water flows; and d) any collection of water which the Minister may, by notice in the Gazette,

declare to be a watercourse, and a reference to a watercourse includes, where relevant, its bed and banks as defined in the NEMA.

Wetland

Land which is transitional between terrestrial and aquatic systems where the water table is usually at, or near the surface, or the land is periodically covered with shallow water, and which land in normal circumstances supports or would support vegetation typically adapted to life in saturated soil (National Water Act ([NWA] Act No 36 of 1998)).

1 This definition of waste is taken from the National Environmental Management Waste Act, 2008 (Act No. 59 of

2008) “NEM:WA”. An amendment Act with a new definition of waste has come into effect in 2014. This application will be submitted under the original Act and Regulations, and therefore we retain the original definition of “waste”

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1 INTRODUCTION

This document serves as both an Integrated Water Use Licence Application (IWULA) as

well as an Integrated Water and Waste Management Plan (IWWMP). It has been compiled

in the format prescribed in the Operational Guideline issued by the Department of Water

and Sanitation (DWS) in 2010.

1.1 Background

Eskom Holdings SOC Limited (Eskom) has appointed Zitholele Consulting (Pty) Ltd (Zitholele)

to undertake an assessment of water uses as well as the amendment of the IWULA at Duvha

Power Station. It also includes an application for existing water uses that have not been

previously licensed.

The current Duvha Water Use Licence (WUL), which was issued in 2007 requires revision and

updating. Recent compliance audits have revealed that certain water uses must be included in

the licence.

Eskom therefore intends to update the current WUL at Duvha Power Station to reflect all the

water uses currently taking place at the power station. The power station and its associated

infrastructure are located within close proximity to the wetlands which necessitates the

application for Section 21 (c) and (i) water uses in terms of the National Water Act (Act 36 of

1998), as amended (NWA).

1.2 Purpose of IWWMP

The Integrated Water and Waste Management Plan (IWWMP) in support of the IWULA is to

demonstrate to the Department of Water and Sanitation (DWS) that water and waste on-site will

be managed in an integrated manner and that there is a plan of action in place to ensure that

water and waste related issues are addressed in a structured, progressive and environmentally

responsible manner.

All relevant water and waste issues associated with the water use activities has been identified

as part of this IWWMP, while the action plan has also been formulated to address shortcomings,

outstanding information and proposed commitments by the applicant to ensure significant

impacts are mitigated and monitored to acceptable levels.

This IWULA and IWWMP are therefore developed for the following objectives:

To characterise the present status of the site;

To formulate measures to address the management of storm water, process water,

groundwater and waste;

To formulate measures to obtain outstanding information, and

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To compile an action plan to ensure that management of storm water, process water,

groundwater and waste will take place to the satisfaction of the regulatory authority.

The purpose of the IWWMP is to provide a planning framework that will achieve site specific

objectives related to the management of water and waste. These objectives will be set to relate

to corporate environmental policy, regulatory requirements and legal compliance.

1.3 Contact detail

Eskom is the South African utility that generates, transmits and distributes electricity. Eskom

supplies about 95% of the country's electricity and about 60% of the total electricity consumed

in Africa. Eskom plays a major role in accelerating growth in the South African economy by

providing a high-quality supply of electricity.

The contact details of the relevant persons representing the applicant are given in Table 1-1

below.

Table 1-1: Applicant’s contact details

APPLICANT Eskom Holdings SOC Ltd (Duvha Power Station)

ADDRESS P O Box 2199, Witbank, 1035

CONTACT PERSON Anthony Kuzelj

DESIGNATION Duvha Power Station Manager

TEL 013 690 0240 (w) 082 338 2579

FAX 013 690 0448

EMAIL [email protected]

1.4 Environmental Assessment Practitioner

Zitholele is an empowerment company formed to provide specialist consulting services primarily

to the public sector in the fields of Water Engineering, Integrated Water Resource Management,

Environmental and Waste Services, Communication (public participation and awareness

creation), and Livelihoods and Economic Development.

Zitholele has no vested interest in the proposed project and hereby declares its independence

as required by the Environmental Impact Assessment (EIA) Regulations. The details of the

Environmental Assessment Practitioners (EAP) representatives are listed below:

Virginia Ramakuwela - Project Manager

Name: Virginia Ramakuwela

Company Represented: Zitholele Consulting (Pty) Ltd.

Address: P O Box 6002, Halfway House, 1685

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Telephone: 011 207 2061

Fax: 086 676 9950

E-mail: [email protected]

Ms Virginia Ramakuwela is the designated Project Manager on behalf of Zitholele. Virginia

holds a BSc (Hons) degree in Environmental Analysis & Management from the University of

Pretoria (2010). She is registered as a Candidate Natural Scientist with the South African

Council for Natural Scientific Professions (SACNASP), (Cand. Sci. Nat. 100150/14) as well as

the South African Council for Professional and Technical Surveyors (PLATO) as a GISc

Technician (GT1494). Virginia is also a member of the International Association for Impact

Assessments (IAIA), National Association for Clean Air (NACA) and Geo-Information Society of

South Africa (GISSA).

Virginia has in excess of 4 years’ experience in environmental consulting, Environmental

Management, WUL applications, Geographic Information Systems (GIS) and Environmental

Impacts Assessment processes in South Africa. Her experience spans both the public and

private sector. She is ideally skilled and experienced to manage this project to its conclusion.

Tania Oosthuizen - Project Associate

Name: Tania Oosthuizen

Company Represented: Zitholele Consulting (Pty) Ltd.

Address: P O Box 6002, Halfway House, 1685

Telephone: 011 207 2060

Fax: 086 674 6121

E-mail: [email protected]

Tania has thirteen (13) years working experience in the Environmental Management field. She

is certified by the Interim Board of Environmental Assessment Practitioners of South Africa

(EAPASA) and registered as Certified Natural Scientist, Level B with SACNASP. She holds a

Master’s Degree in Environmental Management from the North West University. Tania Manages

many large scale environmental authorisation projects and specialises in water use licence

applications.

1.5 Regional setting and location of activity

Duvha Power Station is located on Portion 0 of the farm Duvha Kragstasie 337, approximately

12 km south east of Emalahleni (Witbank), within the Emalahleni Local Municipality (ELM) in the

Mpumalanga Province. The project area falls within quaternary catchment B11G of the Olifants

Water Management Area (WMA). Refer to Figure 1-1, Figure 1-2 and Figure 1-3 for the locality

map of the power station in relation to water features in the area, property and municipal

boundaries.

mailto:[email protected]

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Figure 1-1: Locality Map of the Project

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Figure 1-2: Cadastral Map

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Figure 1-3: Municipal Boundary Map

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2 CONCEPTUALISATION OF ACTIVITY

2.1 Description of activity

Eskom intends to update their current WUL that was issued in 2007 to reflect all the existing

water uses currently taking place at the power station, which include licensing the existing

unauthorised water uses. The power station and associated infrastructure are within close

proximity to the wetlands. This includes the power station footprint and the associated

infrastructures such as dams, coal stockyard and sewage treatment plant (refer to layout of

Duvha Power Station). It should be noted that there is no new proposed construction at the

power station, the current IWULA process is for the existing activities and/or infrastructures

listed below. Please refer to Figure 2-1 for a layout map of the power station.

Ash Disposal Facility (ADF);

Low Level Ash Water Return Dam (AWRD);

High Level Dam (HLD);

Station Drains Complex;

Raw Water Reservoirs;

Coal Stock Yard;

Water Purification Plant;

Dust Suppression; and

Sewage Treatment Plant.

2.1.1 Ash Disposal Facility

The ADF is located on the northern side of Duvha Power Station with approximately 485 ha

footprint area. The ADF operates as a wet ashing facility comprising of a slurry mix of

approximate ratio 1:10 (ash to water). The slury mix (ash and water) is hydraulically

disposed to the ADF. The ash is allowed to settle out of solution (in the slurry) and is

decanted via concrete penstocks located at various points on the facility (Zitholele, 2017).

The penstock or concrete pipe discharge to concrete lined perimeter drains located at the

toe of the facility. This channel then discharges to the Low Level AWRD.

02 March 2018 2-2 15008


Figure 2-1: Duvha Power Station Layout Map

02 March 2018 2-3 15008


2.1.2 Low Level Ash Water Return Dam

The Low Level AWRD has an approximate capacity of 855 Mℓ. It consists of two (2) silt traps

with one silt trap remaining in operation at all times. The silt traps allow ash (or silt) to settle

out (by gravity) before entering the dams. Water from the Low Level AWRD is pumped back

to the plant for reuse in the ash hydraulic deposition process. The Low Level AWRD

operates in tandem with the HLD by pumping water to it when it reaches its maximum

storage level (Zitholele, 2017).

2.1.3 High Level Dam

The HLD has a capacity of 133 Mℓ, comprising of four (4) compartments. This is designed for

storing water to be used in both cooling system as well as the ash plant (slurry make-up

water). This dam does not have a catchment draining to it and receives water from the Low

Level AWRD, the Maturation Ponds and final effluent from the Water Treatment Plant

located on site (Zitholele, 2017).

2.1.4 Station drains complex

All drains are diverted to this system. These drains collect water from following systems:

cooling water systems

storm water within the station and terrace

drainage of boilers and condensers

The oil separation system is a tilted weir separation system. Any spilled oil is retained in the

oil ponds. An overflow weir system allows for the cascading of contaminated drains to the oil

separation system. Oil absorbent pillows and booms are kept as a stock item in the stores.

The water quality is therefore always equal or better than the cooling water systems quality

requirement and the water is then recovered back into the main cooling water system.

2.1.5 Raw Water Reservoirs

The raw water reservoirs exist on site, on the south of the ADF. This is consisting of two (2)

compartments and is designed to store approximately 884 000 m3 of water.

2.1.6 Coal Stockyard

The Coal Stockyard is located on the eastern side of the power station terrace. The footprint

of the Coal Stockyard area is approximately 36 ha. Concrete lined perimeter drains around

the facility intercept runoff generated in this area and convey it to the station drains (dams)

located to the immediate north-east of the stockyard (Zitholele, 2017).

02 March 2018 2-4 15008


2.1.7 Water Purification Plant

The water purification plant is located within Duvha Power Station, in the close proximity to

the southern cooling towers. The raw water is pumped into the raw water reservoirs which

then splits into three major lines, namely; the cooling water south system, the cooling water

north system and the water purification plant (to the raw water clarifiers). The clarified water

is then used for demineralisation and potable water production.

2.1.8 Dust Suppression

Duvha Power Station currently undertakes dust suppression on unrehabilitated areas viz.

Coal Stockyard with dirty water. Water used for dust suppression on coal stock yard is

sourced from the cooling towers.

2.1.9 Sewage Treatment Plant

All sewage effluent from the power station is sent to the Sewage Treatment plant, which is

located to the west of the power station terrace. The plant consists of maturation ponds and

a digester. The sewage treatment plant receives sewage from the station complex, hostel

and married quarters. The sewage is treated using an activated sludge type process. The

treated sewage effluent is then returned to the station ashing system.

2.2 Extent of activity

The existing water uses at the Duvha Power Station takes place on the farm Duvha

Kragstasie 337 JS, portion 0. Duvha Kragstasie 337 JS, Portion 0 is owned by the applicant.

2.3 Key activity related processes and products

The key activities and/or infrastructures associated with the water uses currently taking place

at Duvha Power Station are:

ADF;

Low Level AWRD;

High Level Dam (HLD);

Station Drains Complex;

Raw Water Reservoirs;

Coal Stockyard;

Dust Suppression; and

Sewage Treatment Plant.

The above-mentioned activities are described in detail in Sections 2.1.1 - 2.1.9 above.

02 March 2018 2-5 15008


Ash is generated during the power generation operational activities and is disposed off into

the ADF.

2.4 Activity life description

All activities described in details in Sections 2.1.1 - 2.1.9 will remain operational for the

lifespan of the Duvha Power Station, i.e. 2044.

2.5 Activity infrastructure description

The activities and infrastructures related to this IWULA are described in detail in Section 2.1

above.

2.6 Key water uses and waste streams

The key water uses identified as applicable at the Duvha Power Station site are tabulated in

Table 2-1 below.

02 March 2018 2-6 15008


Table 2-1: Section 21 Water Uses (NWA) applicable to the project




3/annum (10 000 m





Power Station and the associated infrastructure;

ADF and the associated infrastructure;

Coal Stockyard and the associated infrastructure;

Low level AWRD including silt traps and the associated infrastructure;

High level dams and the associated

infrastructure;

Station drains and the associated

infrastructure; and

Sewage treatment plant and the associated infrastructure..

S21 (i)




3/day



Coal Stockyard - New Application.

Dust suppression on Coal Stockyard with dirty water from Cooling water - New Application.

Low level AWRD including silt traps - Amendment.

High level dams - Amendment.

Station drains - New Application;

Maturation ponds - New Application

02 March 2018 2-7 15008


The waste streams consist of:

Solid ash;

Cooling tower sludge;

CL sludge;

Sewage solid waste; and

Run-off from the ADF, coal stockyard and dirty areas within the power station, which

drains into the station drains and flow to the Low Level AWRD.

02 March 2018 2-8 15008


2.7 Organisational structure of water and waste related activities

Figure 2-2: Duvha Power Station Organisation Structure for water and waste related activities

Eskom GenerationDuvha Power Station

Power Station Manager

Engineering Manager Environmental MonitoringWater Management Forum

Authorities, I&APs, Specialists, Eskom

Environmental Manager

Environmental Officer

Section Chemist

Compliance Monitoring

Chemical Services Manager

Coal Manager

02 March 2018 2-9 15008


2.8 Business and corporate policies

Eskom have published a Safety, Health and Environmental (SHE) Policy in which they state

that their operations are underpinned by six values, as follows:

Zero Harm - Eskom will strive to ensure that zero harm befalls its employees,

contractors, the public and the natural environment;

Integrity - Honesty of purpose, conduct and discipline in actions, and respect for people;

Innovation - Value-adding creativity and results oriented. Lead through excellence in

innovation;

Sinobuntu – Caring;

Customer Satisfaction – A commitment to meet and strive to exceed the needs of the

receivers of products and services; and

Excellence - Acknowledgement by all for exceptional standards, performance and

professionalism.

It further states that Eskom will integrate safety, health, environment and quality requirements into activities, so that decisions made ensure the consideration of economic development, environmental quality and social equity to continually improve performance and achieve stakeholder requirements. It is achieved through:

Implementation of management systems in accordance with ISO 9001, ISO 14001,

and OSHAS 18001 requirements;

Achieving compliance with applicable legislative and other requirements to which

Eskom subscribes and, in the absence of these, setting standards to meet the intent

of this policy;

Addressing the needs and expectations of Eskom’s electricity customers and stakeholders;

Setting Safety, Health and Environmental Quality (SHEQ) objectives and measuring

performance against these with the objective of continual improvement;

Conducting risk-based medical surveillance;

SHEQ training and awareness for employees;

Engaging stakeholders by promoting open communication and engagement that is

SHEQ purpose driven;

Ensuring that Eskom’s suppliers and service providers meet Eskom’s SHEQ requirements;

Ensuring that adequate resources are available for SHEQ management; and

A Proactive drive in managing Eskom’s environmental footprint, prevention of pollution, pursuing a low carbon future, and prioritising energy and water efficiency

and conservation within and outside Eskom by transitioning to a cleaner energy mix.

02 March 2018 3-1 15008


3 REGULATORY WATER AND WASTE MANAGEMENT FRAMEWORK

3.1 Summary of all water uses

In terms of Section 22(1) a person may only use water on the following conditions:

22(1) a person may only use water

(a) Without a licence -

(i) If that water use is permissible under Schedule 1;

(ii) If that water use is permissible as a continuation of an existing lawful use;

or

(iii) If that water use is permissible in terms of a general authorisation issued

under section 39;

(b) If the water use is authorised by a licence under this Act; or

(c) If the responsible authority has dispensed with a licence requirement under

subsection (3).

Refer to Table 3-1 to Table 3-3 for all the water uses to be applied for.

02 March 2018 3-2 15008


Table 3-1: Detailed information for S21a water uses applied for

Ref Description of the

use Property

Name & type of water resource

Abstraction point ref no.

Method of abstraction Reliability of water resource

Period of water use

Volume abstracted, Start date

Co-ordinate of Abstraction

Point

Abraction pattern (January – December) in

m3 or % per month

Date of first use

End date

Taking water from Driefontein Dam (3 650 000 m3/annum (10 000 m

3/day)). Eskom currently has excess water and as a result, they are not taking water from the Driefontein dam but they are required as per existing WUL condition to

undertake monitoring at Driefontein dam. An amendment is therefore, required in terms of the monitoring frequency. Eskom Duvha Power Station proposes that monitoring by Eskom at Driefontein dam only be undertaken during the period when Eskom have taken water from Driefontein dam - Amendment

Table 3-2: Detailed information for S21 c and i water uses applied for

Ref Description of the

use Description of the use Property

Co-ordinates (Degrees, Minutes, Seconds)

Start


Centre


End

1.

Duvha Power Station and associated infrastructures – New Application

Duvha Power Station and the associated infrastructure.

Duvha Kragstasie 337 JS, Portion 0

25°56'59.67"S 29°20'8.25"E 25°57'40.64"S 29°20'21.27"E 25°58'6.85"S 29°20'28.96"E

ADF and the associated infrastructure. 25°56'34.95"S 29°19'17.40"E 25°56'30.09"S 29°20'26.03"E 25°55'59.41"S 29°21'7.74"E

High level dams and the associated infrastructure. 25°57'13.99"S 29°20'34.86"E 25°57'13.97"S 29°20'39.35"E 25°57'15.64"S 29°20'43.34"E

Station drains and the associated infrastructure.

25°57'10.79"S 29°20'52.15"E 25°57'12.18"S 29°20'51.78"E 25°57'14.79"S 29°20'50.28"E

Low level AWRD including silt trap and the associated infrastructure.

25°55'30.43"S 29°20'31.15"E 25°55'43.23"S 29°20'41.19"E 25°55'57.14"S 29°20'41.82"E

Coal Stockyard and the associated infrastructure.

25°57'21.26"S 29°20'45.02"E 25°57'45.62"S 29°20'36.19"E 25°57'57.98"S 29°20'30.34"E

Sewage treatment plant and the associated infrastructure.

25°57'30.68"S 29°19'21.03"E 25°57'35.12"S 29°19'22.94"E 25°57'38.21"S 29°19'24.53"E

02 March 2018 3-3 15008


Table 3-3: Detailed information for S21g water uses being amended and applied for

Ref Description of the use Property Co-ordinates

(Degrees, minutes, seconds) Centre

Capacity / Volume (m3) Size (ha) Liner Average Through Flows

1.


3/day

water containing waste from the Driefontein dam into the AWRD. Eskom proposes the amendment of the above to the following: “disposal of water containing waste from the Driefontein dam into the ash disposal facility” – ADF - Amendment

Duvha Kragstasie 337 JS, Portion 0

2. High level dams – Amendment

25°57'13.97"S

29°20'39.35"E

94 400 4 Clay

3. Station drains – New Application

25°57'12.18"S 29°20'51.78"E -

0.300 Clay

4. Maturation ponds – New Application

25°57'35.00"S 29°19'23.65"E 19 620

1 Clay

5. Low level AWRD and Silt traps – Amendment.

25°55'43.23"S 29°20'41.19"E 850 000

25 Clay

6. Dust Suppression on the Coal Stock Yard – New Application.

-

- Clay

7. Coal stock yard disposal - New Application.

25°57'45.62"S 29°20'36.19"E -

25 Clay

02 March 2018 3-4 15008


3.2 Existing lawful water uses

Duvha Power Station has licenced water uses issued by the DWS under the NWA. The existing

WUL are recorded in Table 3-4 below and attached as Appendix B.

02 March 2018 3-5 15008


Table 3-4: Water use licences issued to the Duvha Power Station

Issu

e D

ate

Lic

en

ce

nu

mb

er

Wate

r u

se

descri

pti

on

Lo

cati

on

/

Catc

hm

en

t

Pu

rpo

se

Pro

pe

rty

Qu

an

tity

to

be t

aken

/

sto

red

/

dis

po

sed

Exp

iry d

ate

21 (a)

07 December

2007

24013693 Taking of water from Driefontein dam – require amendment

Olifants river Catchment (upstream of Witbank Dam on farm Speekfontein 33 JS)

Industrial purpose at Duvha Power Station

Farm Duvha 337 JS, Portion 2 & 3; Farm Driefontein 338 JS, Portion 1, 9 & 10; Farm Speekfontein 336 JS, Portion 2, 7, 29, 30 and the Remainder Portion 4, 12 & 13.

3 650 000 m

3/annum (10

000 m3/day)

2027 (Validation period: 20 yrs with review every 2 yrs)

17 July 2009

27/2/1/C211/1/1

Taking of a maximum quantity of 360 300 000 m

3/a

from a water resource (Vaal River Eastern Sub-system)

Vaal River Eastern Sub-system

Power generation purpose at Duvha Power Station

Remainder of the farm Duvha Power Station 337 JS

360 300 000 m

3/a (Duvha

Power Station volumes per annum = 49.56 million m

3/a

31 October 2025

21 (b)

07 December

2007

24013693 Storage of water in two dams on Farm Speekfontein 337 JS (for water not containing waste)

Olifants river Catchment

Industrial purpose at Duvha Power Station


884 000 m3 2027 (Validation period:

20 yrs with review every 2 yrs)

Storage of water in ten dams (for water containing waste) - - require amendment

72 000 m3

21 (g)

02 March 2018 3-6 15008


07 December

2007

24013693 Disposal of water containing waste (slurry) into ash dam

Olifants river Catchment

To retain the precipitated solids in the ash dam and prevent it from entering the downstream storage dams.


36 000 000 m

3/annum

2027 (Validation period: 20 yrs with review every 2 yrs)

Disposal of water containing waste from the Driefontein dam into the ash return water dam - require amendment

Ash water make up.

10 000 m3/day

Disposal of domestic waste water (sewage effluent) into ash return water dam

180 000 m

3/annum

02 March 2018 3-7 15008


3.3 Relevant exemptions

Not applicable.

3.4 Generally authorised water uses

Duvha Power Station has no existing General Authorisations.

3.5 New water uses to be licensed

The water uses to be licenced or amended are illustrated in Table 3-1 - Table 3-3 above.

3.6 Waste management activities (NEMWA)

Duvha Power Station was constructed and operated prior to the National Environmental

Management Waste Act, 2008 (Act No. 59 of 2008) (NEM:WA) and the regulations

thereunder. Therefore, this is not applicable to the existing operational activities at Duvha

Power Station.

3.7 Waste related authorisations

Refer to section 3.6 above for details.

3.8 Other authorisations (EIAs, EMPrs, Environmental Authorisations, Regulations)

There are no other authorisations and Environmental Management Programme (EMPr)

related to the existing operational activities associated with this application.

02 March 2018 4-1 15008


4 PRESENT ENVIRONMENTAL SITUATION

4.1 Climate

This section provides a description of the biophysical, socio-economic and cultural/historical

environment of the study area.

The description of this section has been extracted from the ELM Integrated Development

Plan (IDP) 2012/2013 (2012) and IDP 2016/2017 reports (2016), Numerical Pollution Plume

Model compiled by GHT Consulting Scientists (GCS) in 2015 and wetland ecological survey

prepared by EnviRoss CC (EnviRoss) in 2017.

4.1.1 Regional Climate

The study area falls within the Highveld climatic region with warm summers and cold winters

(ELM IDP; 2012). Frost is experienced in the area for approximately 30 days per year on

average. The average daily temperature in the area varies from 27˚C - 13˚C during summer

(in January) to the minimum of 17˚C - 0˚C during winter (in July). In extreme cases,

temperatures may rise to 38˚C in January and 26˚C in July (GSC, 2015). Temperatures as

low as 1˚C in January and -13˚C in July have also been recorded in extreme conditions

within the study area (GCS, 2015). Frost in the area may occur in the period between May to

September and usually lasts for approximately 120 days (GCS, 2015).

4.1.2 Rainfall

A long-term precipitation records for Middleburg and Bethal are presented below in the

absence of precipitation records for Duvha Power Station. Long-term total annual rainfall

figures for various stations within the Emalahleni region (Middelburg ~20km north east and

Bethal ~ 50km south of Duvha Power Station) are in the range of 730 mm to 750 mm (Table

4-1). Rain falls mainly in summer from October to April, with the peak for the region being in

January. The rainfall in the area is received in the summer mainly in the form of acid rain.

Strong winds are experienced during the month of July and August before the first rainfall.

Table 4-1: Long-term mean monthly rainfall figures (mm) for various stations within the Emalahleni region (Airshed, 2015)

Station Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Ann

Middelburg (1904 – 1950)

132 103 88 42 19 7 9 8 22 63 124 118 735

Bethal (1904 – 1984)

134 94 78 46 19 7 8 10 25 78 128 120 747

02 March 2018 4-2 15008


4.1.3 Evaporation

Long-term monthly average evaporation across the Mpumalanga province is presented in

Figure 4-1. The annual range varies between 1 537 and 2 335 mm. Maximum evaporation is

expected in December and January, while the minimum is expected in June. Variation within

months is lowest in winter months (June, July and August).

Figure 4-1: Long-term monthly average evaporation (mm) across Mpumalanga

4.2 Topography

The topography of the area has been described using the 1:50 000 government topo-

cadastral maps for the area, namely 2529CD and 2629AB. This information was obtained

from the Chief Directorate: Surveys and Mapping (2011). Contours were combined from the

two (2) mapsheets (2529 and 2629). Using Arcview GIS software the contours information

was used to develop a digital elevation model of the region and a Topography map as

shown in Figure 4-2.

The site is located in a gently undulating landscape at an elevation ranging between 1 237 to

1 883 meters above mean sea level (mamsl). The power station is situated at a high point

between 1 580 mamsl and 1 600 mamsl on a minor watershed, which is orientated from

northwest to southeast. The Ash Disposal Facility (ADF) is located on the northern side of

the watershed on a northeast-facing slope.

02 March 2018 4-3 15008


Figure 4-2: Topography Map

02 March 2018 4-4 15008


4.3 Geology and Soils

The area is underlain by the Ecca Formation of the Karoo sedimentary sequence. The Ecca

Formation consists of a mixture of shale, shaly sandstone, grit, sandstone, conglomerate

and coal. The geology is dominated by shale in the low-lying areas close to the Witbank

Dam and higher up near the power station the geological formation varies from sandstone

(aslo known as Arenite), Rhyolite and Norite (Figure 4-3). There are sandstone outcrops

along the western boundary of the power station close to the ash dams.

The soils in the area belong to a plinthic catena, which means that they are characterised by

concretions of iron and/or manganese caused by fluctuating water tables (Figure 4-4). The

soils are generally dystrophic and/or mesotrophic, implying that nutrients in the soils are

moderately to very well leached. The soil texture varies from clayey to sandy, depending on

the parent material.

02 March 2018 4-5 15008


Figure 4-3: Geology Map

02 March 2018 4-6 15008


Figure 4-4: Soils Map

02 March 2018 4-7 15008


4.4 Surface Water

The surface water data was obtained from the WR90 database from the Water Research

Council; the National Freshwater Ecosystem Priority Area (NFEPA) database from DWS,

and wetland survey undertaken by EnviRoss in 2017 (Appendix D) for this application. The

data used includes dams, wetlands, catchments, river alignments and river names. Surface

water bodies present in the area are shown in Figure 4-5.

4.4.1 Water Management Area

Duvha Power Station is located in the Upper Olifants Catchment which falls within the

Olifants WMA (WMA B1). The area falls within the quaternary catchment B11G (Figure 4-5).

The Upper Olifants Catchment (B1) mainly includes the local economy of eMalahleni

(Witbank), which includes the towns of Middelburg, Hendrina, Douglas, Kriel and Kinross.

Evander, Secunda and Bethal towns are located south of the Upper Olifants Catchment (B1)

boundary. The catchment comprises of upper Olifants River and the Klein Olifants, Witbank

Dam, Middelburg Dam, and the Klip River. The Upper Olifants Catchment (B1) is extensively

used and impacted due intensive coal mining and associated energy and manufacturing

economy (Golder, 2011).

The catchments in the Olifants are further divided into Management Units (MU) and the

Duvha Power Station is located within MU 9b.

02 March 2018 4-8 15008


Figure 4-5: Quaternary Catchment Map

02 March 2018 4-9 15008


4.4.2 Surface Water Hydrology

The study area falls within the Olifants North (B) Primary Catchment, within the Highveld aquatic

ecoregion in the upper Olifants WMA. The area falls within B11G quaternary catchment (Figure

4-5). The main watercourses draining the quaternary catchment are Tweefonteinspruit and the

Noupoort River that drain toward the Olifants (North) River, with Witbank Dam having been

constructed at the confluence of these three rivers within the WMA. All of the major rivers within

the region are shown to have a largely modified state i.e. PES – D (EnviRoss, 2017).

There are limited defined channels and watercourses associated with the survey area, but the

region is rich in endorheic (a pan wetland with no outlet) and exorheic (a pan wetland with external

drainage) pan-type wetlands (EnviRoss, 2017). The Olifants River drains northwards and then

eastwards through the Kruger National Park and eventually through Mozambique to ultimately

drain into the Indian Ocean.

4.4.3 Surface Water Quality

The water quality in Upper Olifants sub-area is under threat from the coal mines. The management

of mine water decant volumes is being addressed by the mining industry with a number of projects

addressing treatment and irrigation management options (Golder, 2011).

Duvha Power Station surface water monitoring is undertaken quarterly and the results analysis are

compared against the WUL and waste disposal effluent limits (Lefastshe Minerals and Consulting

(LMC), 2016). The results for surface water monitoring for the October 2016 are presented in

Table 4-2, Table 4-3 and Table 4-4.

The water quality results for most of the samples indicate poor water quality. The results suggest

most contamination from the ADF as most of the samples are located downstream of the ADF.

However, when compared to the SANS limits the effluent sample (PE01), Witbank dam (AP08),

seepage north of Low Level AWRD near R03 (AS04) and storm water canal (AC02) are the only

sample which indicate parameters which fall well within the SANS limits (LMC, 2016).

02 March 2018 4-10 15008


Table 4-2: Surface water chemistry results for Ash Return Water Quality as compared to WUL (LMC, 2016)

Location

Parameters pH EC mS/m

TDS mg/l

Ca mg/l

Mg mg/l

Na mg/l

K mg/l

Cl mg/l

SO4 mg/l

NO3-N mg/l

F mg/l

Fe (mg/l)

Mn (mg/l)

Al (mg/l)

Total Alkalinity as CaCO3 (mg/l)

Total Hardness as CaCO3 (mg/l)

WUL Waste effluent disposal limit

4.5-9.5 2578 1225 930 1213 127 65 150 2359 15 1.5 2 2 2 200 1225

Ash Water Return Area

PP04 11.5 218 1320 250 0.12 131 31.2 91 623 1.24 0.767 <0.05 <0.05 0.22 270 422

PP09 11.3 186 1210 212 0.12 131 33.1 92.7 642 0.549 0.71 <0.05 <0.05 <0.05 - -

Table 4-3: Surface water chemistry results for the Emergency Pond and Witbank Dam as compared to the WUL (LMC, 2016)

Location Parameters pH

EC mS/m

TDS mg/l

Ca mg/l Mg mg/l

Na mg/l

K mg/l

Cl mg/l

SO4 mg/l

NO3-N mg/l

F mg/l

Fe (mg/l)

Mn (mg/l)

Al (mg/l)

WUL Limits 5.0-9.5 70 - 80 70 100 - 100 200 6 - - - -

Emergency Pond PP03 7.01 157 - 164 3.17 168 - 117 589 0.587 - - - -

Witbank Dam AP08 7.67 65.4 - 64.8 489 35.8 - 20 282 0.133 - - - -

Table 4-4: Surface water Quality results for the final Sewage Effluent as compared to the WUL (LMC, 2016)

Location

Parameters Faecal Coliforms

PH

Electrical Conductivity (EC mS/m)

Chemical Oxygen Demand (COD mg/l)

Chlorine as free chlorine (mg/l)

Ammonia as Nitrogen (mg/l)

Nitrate/ Nitrite as Nitrogen (mg/l)

Suspended Solids (mg/l)

Ortho-phosphate as Phosphorus (mg/l)

Fluorite as F (mg/l)

WUL – Sewage Treatment

1000 5.5-9.5

70-150 75 0.25 3 15 25 10 1

Final Sewage Effluent

PE01 1000 8.71 38.3 64 No Value reported

6.43 0.24 30 5.38 0.397

02 March 2018 4-11 15008


4.4.4 Mean Annual Runoff (MAR)

The maximum Mean Annual Runoff (MAR) recorded on quaternary catchment B11G is 36.2 mm.

4.4.5 Resource Class and River Health

The DWS has completed the classification process for the significant water resources of the

Olifants WMA (DWS, 2016). The management class for the Upper Olifants River catchment was

set at Class III with an overall ecological category of D. Class III implies heavy usage of the water

resource in future and configuration of ecological categories of the water resource is significantly

altered from its pre-development condition.

The status quo in the river system has to be at least maintained. The impacts are primarily water

quality related and require an integrated management strategy to deal with the upstream

wastewater discharges and mine water impacts. The influence of the tributaries causes significant

water quality deterioration in the Upper Olifants River. However regular routine in-stream water

quality monitoring of the Upper Olifants River is required to monitor and better understand the

situation. Results thus indicate that for the biophysical node HN9 which is quaternary catchments

B11G, an Ecological Water Requirement (EWR) of 4.70 % of the natural MAR (164 million m3/a)

must be maintained in order to maintain a PES of D.

4.4.6 Receiving Water Quality Objectives and Reserve

The project falls within MU 9b, biophysical node HN9. The Resource Water Quality Objectives

(RWQOs) for biophysical node HN9 are stipulated in Table 4-5.

Table 4-5: RWQOs for Upper Olifants Management biophysical node HN9 (DWS, 2015)

Component REC RQO Indicator / Measure Numerical Limits

River Water Quality: Nutrients

D

Nutrient concentrations must be maintained in the river at mesotrophic or better levels.

Phosphate (PO4)- ≤0.125 mg/L P

Nitrate (NO3) & Nitrite (NO2)*

≤4.00 mg/L N

Total Ammonia* ≤0.100 mg/L N

River Water Quality: Salts

D

Salts concentrations need to be maintained at levels where they do not render the ecosystem unsustainable.

Sulphates* ≤500 mg/L

Electrical Conductivity* ≤111 mS/m

River Water Quality: System Variables

D

Alkalinity must be maintained at concentrations which do not allow for a dramatic rise in acidity.

Alkalinity* ≥60 mg/L CaCO3

Turbidity* ≤10 NTU

Dissolved Oxygen* ≥4 mg/L O

River Water Quality: Toxins

D Toxins should not be allowed to negatively impact on ecosystem.

F* ≤ 3.00 mg/L

Al* ≤ 0.150 mg/L

As* ≤ 0.130 mg/L

Cd hard* ≤ 5.0 µg/L

Cr(VI)* ≤200 µg/L

Cu hard* ≤ 8.0 µg/L

Hg* ≤ 1.70 µg/L

Mn* ≤ 1.300 mg/L

Pb hard* ≤ 13.0 µg/L

Se* ≤ 0.030 mg/L

Zn * ≤ 36.0 µg/L

Chlorine* ≤ 5.0 µg/L free Cl

02 March 2018 4-12 15008



Endosulfan* ≤ 0.20 µg/L

Atrazine* ≤ 100.0 µg/L

Dam Water Quantity

D

The dam must be managed to provide sufficient releases for the protection of ecosystem function downstream as well as for other users.

Flow releases: Olifants in B11G; VMAR = 164.05x10

6m

3; PES-D

category*. (Releases from Witbank Dam monitored by B1H010.)

Maintenance low flows (m

3/s)

(Percentile)

Drought flows (m

3/s)

(Percentile)

Oct 0.128 (60)

0.085 (99)

Nov 0.245 (90)

0.197 (99)

Dec 0.332 (90)

0.254 (99)

Jan 0.415 (90)

0.291 (99)

Feb 0.514 (80)

0.291 (99)

Mar 0.401 (80)

0.244 (99)

Apr 0.323 (80)

0.216 (90)

May 0.218 (70)

0.094 (99)

Jun 0.147 (90)

0.16 (90)

Jul 0.108 (99)

0.141 (90)

Aug 0.084 (99)

0.113 (99)

Sep 0.073 (90)

0.085 (90)

Dam Water Quality: Nutrients

-

The system must be maintained in a mesotrophic state to avoid cyanobacteria blooms and the associated algal toxins..

PO4-P- ≤0.025 mg/L P

TIN ≤1.00 mg/L N

Chl-a:phytoplankton

≤20.0 µg/L

Dam Water Quality: Salts

-

Salt concentrations must be maintained at levels where they allow for sustainable ecosystem in the dam and downstream and do not compromise users.

Sulphates* ≤200 mg/L

Electrical Conductivity*

≤85 mS/m

Dam Water Quality: Toxins

-

The system must be maintained in a mesotrophic state to avoid cyanobacterial blooms and the associated algal toxins. Metal concentrations in the dam must be maintained at levels which allow for a sustainable ecosystem.

F ≤ 2.50 mg/L

Al ≤ 0.105 mg/L

As* ≤ 0.095 mg/L

Cd hard ≤ 3.0 µg/L

Cr(VI) ≤121 µg/L

Cu hard ≤ 6.0 µg/L

Hg ≤ 0.97 µg/L

Mn ≤ 0.990 mg/L

Pb hard ≤ 9.5 µg/L

Se ≤ 0.022 mg/L

Zn ≤ 25.2 µg/L

Chlorine ≤ 3.1 µg/L free Cl

Chl-a:phytoplankton ≤ 20.0 µg/L

Biota Fish -

The wellbeing of the fish community of this artificial ecosystem must be maintained in a suitable condition to contribute to regional biodiversity and to support local recreational angling industry. Consumption of fish must not pose a health risk to

Implementation of Index of Reservoir Habitat Impairment (IRHI) by Miranda and Hunt (2011).

Habitat suitability and fish wellbeing in a state which is equivalent to a D or better ecological category.

02 March 2018 4-13 15008



local communities.

Groundwater Aquifer

-

Medium to long-term water trends should not show a negative deviation from the natural trend.

Depth to Groundwater Level according to Groundwater Monitoring Guidelines.

At least one NGwQl MP monitoring site that is representative of the aquifer. Water level fluctuations in Dolomitic aquifers should not exceed 6 m.

4.4.7 Surface Water User Survey

Land use in the Olifants WMA is diverse and consists of irrigated and dryland cultivation, improved

and unimproved grazing, mining, industry, forestry and urban and rural settlements (DWS, 2013).

A breakdown of land use and land cover is given in Table 4-6.

Table 4-6: Land use and land cover in the Olifants Water Management Area (Source: CSIR 2003)

Land Use Area (ha) %

Natural vegetation 3 474 159 63.69%

Grazing 1 689 0.03%

Plantations 64 347 1.18%

Wetlands & Water 56 422 1.03%

Degraded 552 267 10.12%

Permanent commercial cultivation 18 126 0.33%

Temporary commercial cultivation 828 495 15.19%

Subsistence cultivation 244 989 4.49%

Urban (formal residential) 110 820 2.03%

Urban (informal residential) 47 509 0.87%

Urban (smallholdings) 6 841 0.13%

Urban (commercial) 1 524 0.03%

Urban (industrial) 5 247 0.10%

Subsurface mining 26 0.00%

Surface mining 36 618 0.67%

Mine tailings 5 693 0.10%

Total 5 454 772

Eskom has 11 coal-fired power stations in South Africa and eight of these stations are found in the

Olifants WMA (DWS, 2013). The 8th, Kusile, is still under construction. These eight stations will

produce approximately 70% of South Africa’s electricity.

02 March 2018 4-14 15008


4.4.8 Sensitive Areas Survey

4.4.8.1 Wetlands

The wetland units within the region incorporate an azonal vegetation unit of the Freshwater

Wetlands biome, namely Eastern Temperate Freshwater Wetlands, which in terms of conservation

status is regarded as a Least Threatened unit due to limited transformation having occurred

(EnviRoss, 2017).

The following wetlands types were identified within the study area (EnviRoss, 2017), also refer to

Figure 4-6 and Table 4-8:

Artificial;

Channelled Valley Bottom wetlands;

Depression (Pan);

Seepage; and

Unchanneled Valley Bottom

The artificial units, although mapped, are not included within the overall ecological ratings of the

wetland units associated with the area (EnviRoss, 2017).

Figure 4-6: The wetland habitat units pertaining to the study area (EnviRoss, 2017)

Table 4-7 provides the theoretical functioning of a pan-type wetland with a purely self-contained

catchment.

02 March 2018 4-15 15008


Table 4-7: The hydrogeomorphic wetland types of the regional wetlands associated with the site and the ecological services they provide within the landscape as adapted from Kotze, et al, 2009 (EnviRoss, 2017)

Wetland HGM type

Regulatory benefits potential provided by wetland

Flood attenuation Stream flow

regulation

Enhancement of water quality

Early wet season

Late wet season

Erosion control

Sediment trapping

Phosphates Nitrates Toxicants

Depression (pan)

Low relevance

Low relevance

- Low

relevance Low

relevance Low

relevance Low

relevance Low

relevance

Valley bottom –

channelled

Medium relevance

Low relevance

Low relevance

High relevance

High relevance

Medium relevance

Medium relevance

Medium relevance

According to EnviRoss (2017), these regulatory benefits provided by the wetland Hydrogeomorphic

(HGM) units are theoretical and are based on “ideal” situations. Very often the wetland units are

actually representative of a combination of HGM forms.

EnviRoss (2017) further delineated the HGM forms of wetland units on site as indicated in Table

4-8.

Table 4-8: The hydrogeomorphic forms of the wetland units that were surveyed for Duvha Power Station (EnviRoss, 2017)

Wetland unit Wetland HGM unit Connected to watercourse

A Depression pans Yes, but only under exceptional circumstances

B Channelled valley bottom Yes

C Hillslope seep zone Yes

D Channelled valley bottom Yes

E Hillslope seep zone Yes

F Channelled valley bottom Yes

G Hillslope seep zone No

The photographs of wetland types identified on the site are shown in Figure 6-11 of Appendix D.

The Present Ecological Status (PES) assessment (which excluded wetland units C and G)

indicates that the wetlands on site are moderately modified in some systems and are thus placed

in a PES category of C. This is considered as systems where “moderate loss and change of

natural habitat and biota have occurred, but the ecosystem functions are still predominantly

unchanged” (EnviRoss, 2017).

02 March 2018 4-16 15008


4.4.8.2 Ecology (Terrestrial)

Information pertaining to the terrestrial ecology of the study area was sourced from the South

African National Biodiversity institute (SANBI), 2011 data and Mpumalanga Biodiversity Sector

Plan (MBSP), 2014 data. The study area is in the Eastern Highveld Grassland and Rand Highveld

Grassland and Eastern Temperate Freshwater Wetlands vegetation types in the grassland biome

(Figure 4-7).

Both Grasslands types are classified at a regional scale as Endangered (Figure 4-8).

According to the MBSP (2014) Duvha Power Station footprint consists of three (3) of the province’s biodiversity categories. These are listed and summarised in Table 4-9 and their distribution shown

in Figure 4-9.

Table 4-9: Categories of the Mpumalanga Biodiversity Sector Plan (2014)

Category Description and Motivation

Heavily Modified Modified areas are those that have undergone a significant and often irreparable degree of transformation that has led to a near-complete loss of biodiversity and ecological functioning. Common agents of modification include mining, arable agriculture and infrastructure development.

Moderately Modified – Old lands

This sub-category of Modified relates to areas that have been altered by cultivation and other activities within the last 80 years and subsequently abandoned. The biodiversity and ecological functioning in such areas is compromised but may still play a role in the provision of ecosystem services.

Critical Biodiversity Area (CBA) - Optimal

CBA – Optimal are areas selected to optimally meet biodiversity targets. Although these areas have a lower irreplaceability value than the CBA – Irreplaceable category, collectively they reflect the smallest area required to meet biodiversity conservation targets.

02 March 2018 4-17 15008


Figure 4-7: Locality of study area in relation to the regional vegetation types

02 March 2018 4-18 15008


Figure 4-8: Locality of study area in relation to the regional vegetation Conservation Status

02 March 2018 4-19 15008


Figure 4-9: Study area in relation to the Mpumalanga Biodiversity Sector Plan (2014)

02 March 2018 4-20 15008


4.5 Groundwater

Information relating to groundwater associated with the Duvha Power Station was taken from the

surface and groundwater report compiled for Duvha Power Station by Lefatshe Minerals and

Consulting (LMC) in October 2016. Refer to Appendix F for the full report.

4.5.1 Aquifer Characterisation

The aquifers in the area are unconfined to semi-confined and the groundwater follows the

surface topography;

The groundwater levels around the power station vary between 1531 and 1606 mamsl with the

direction of groundwater generally flow to the northerly direction; and

The groundwater levels for October 2016 range from 1.16 to 5.8 meter below ground level

(mbgl).

4.5.2 Groundwater Quality

The chemistry results for the October 2016 indicate slight improvement in groundwater quality for

boreholes located within and around Duvha Power Station. The chemistry results indicated higher

total iron (Fe) and manganese (Mn) for some of the groundwater samples. The most common

sources of iron and manganese in groundwater are naturally occurring, e.g. from weathering of iron

and manganese bearing minerals and rocks (LMC, 2016). However, poor conditions of some of the

boreholes (rusted casing, etc.) might be contributing to the increased total iron concentrations

(LMC, 2016).

4.5.3 Hydro-census

An in-depth hydro-census survey for Duvha Power Station was undertaken by GCS in 2009; refer

to Appendix K for details. The aim of the survey was to identify water users, usage within the

possible impact zone of the Power Station and determine the possible impact of the Power Station

activities on the groundwater of the region. GCS (2009) identified four (4) different monitoring

areas at the Power Station, including (refer toFigure 4-10):

The Power Station Area;

The Coal Stock Yard Area;

The Ashing Area; and

The Sewage Plant.

The results of the hydro-census survey showed that groundwater pollution could be traced

approximately between 1 and 2 Km from the Ashing area and at much lower concentrations (GCS,

2009).

02 March 2018 4-21 15008


Figure 4-10: Hydro-census sample locations in relation to surface water and groundwater monitoring (GCS, 2009)

02 March 2018 4-22 15008


The following recommendations were made by GCS (2009) during the hydro-census survey:

Contaminant movement away from pollution point sources can be reduced, or prevented

entirely, through the construction of cut-off trenches and sub-soil drains to the confining

layer at the base of the aquifer; and

An early detection system must be installed downstream from the major pollution sources

to detect possible seepage or drainage from these areas.

4.5.4 Potential Pollution Source Identification

The potential pollution sources and dams/reservoirs of Duvha Power Station include:

ADF;

Low Level AWRD;

High Level Dam;

Raw Water Dam;

Coal Stockyard;

Maturation ponds at Sewage treatment plant; and

Mike Fell Pan.

The pollution sources in relation to Witbank dam are also shown in Figure 4-11.

02 March 2018 4-23 15008


4.5.5 Groundwater Quality

Duvha Power Station groundwater monitoring is undertaken quarterly and the results analysis are

compared against the Duvha Power Station’s WUL limits and groundwater reserve quality set in

Duvha Power Station WUL (LMC, 2016). The results for groundwater monitoring for the October

2016 are presented in Table 4-10 and Table 4-11.

The groundwater monitoring results for October 2016 indicated only one (1) exceedance of Duvha

Power Station’s WUL limits on ADF area (AB05) as shown in Table 4-10 (LMC, 2016). Few

exceedances in terms of groundwater reserve quality set in Duvha Power Station WUL have been

observed on the four (4) points around the ADF area (refer to Table 4-11), while the rest of the

samples were within the SANS limits. In addition, the chemistry results for October 2016 indicated

elevated total iron (Fe) and manganese (Mn) for some of the groundwater samples, refer to Table

4-10 (LMC, 2016).

Groundwater samples obtained from boreholes at the sewage treatment plant indicate

improvement in water quality when compared to the WUL limits.

02 March 2018 4-24 15008


Table 4-10: Groundwater quality results for Duvha Power Station boreholes as compared to WUL Limits (LMC, 2016)

Locations

Parameters pH EC mS/m

TDS mg/l

Ca mg/l Mg mg/l Na mg/l K mg/l

Cl mg/l SO4 mg/l NO3-N mg/l

F mg/l Fe (mg/l)

Mn (mg/l)

WUL WQOs 5-9.5 2578 1225 930 1213 127 65 150 2359 15 1.5 2 2

Power Station Area

PB09 6.41 13.1 100 1.48 0.66 30.8 0.64 10.8 11.3 <0.13 <0.042 0.77 0.23

PB10 6.64 10.6 68 10.5 4.13 4.93 2.05 3.4 4 <0.13 0.145 0.28 0.23

ADF Area

AB01 6.8 25.2 162 8.32 5.16 46.3 4.08 25.4 12.4 <0.13 0.474 <0.05 -

AB02 7.06 23.8 182 23.2 4.5 32.3 1.32 2.49 4.68 <0.13 1.92 0.13 -

AB03 6.83 48.6 262 6.42 7.15 97.9 2.19 132 4.07 <0.13 0.099 <0.05 -

AB04 6.66 71.6 465 45.9 32.7 77.8 3.38 75.2 184 <0.13 0.043 0.23 -

AB05 6.8 25 163 11.6 4.43 36.3 3.27 16.7 3.89 0.51 2.55 0.08 -

Coal Stockyard Area

CB06 6.69 6.59 42.8 6.44 3.97 4.21 2.86 3 3.43 <0.13 0.463 0.31 0.07

CB07 7.12 13.8 89.4 16.1 7.65 10.3 2.96 2.43 10.1 <0.13 0.136 0.12 <0.05

Sewage Plant Area

PB12 7.58 33.2 216 20.6 6.77 15.3 9.26 14.9 3.17 1.99 0.35 <0.05 0.13

PB13 6.51 21.8 142 7.7 5.15 19.6 5.56 19.2 11.6 0.763 0.05 <0.05 0.45

PB18 7.43 21.9 142 18.5 7.62 17.8 4.92 14.9 20.4 0.581 0.15 <0.05 0.28

Notes:

Non-compliance with WUL WQOs

02 March 2018 4-25 15008


Table 4-11: Groundwater quality results for Duvha Power Station boreholes as compared to the groundwater reserve quality set in Duvha Power Station WUL (LMC, 2016)

Locations

Parameters pH TDS mg/l Ca mg/l Mg mg/l Na mg/l K mg/l Cl mg/l SO4 mg/l

Groundwater reserve quality

5-9.5 462 45 24 36 6.5 23 152

Power Station Area

PB09 6.41 100 1.48 0.66 30.8 0.64 10.8 11.3

PB10 6.64 68 10.5 4.13 4.93 2.05 3.4 4

ADF Area

AB01 6.8 162 8.32 5.16 46.3 4.08 25.4 12.4

AB02 7.06 182 23.2 4.5 32.3 1.32 2.49 4.68

AB03 6.83 262 6.42 7.15 97.9 2.19 132 4.07

AB04 6.66 465 45.9 32.7 77.8 3.38 75.2 184

AB05 6.8 163 11.6 4.43 36.3 3.27 16.7 3.89

Coal Stockyard Area

CB06 6.69 42.8 6.44 3.97 4.21 2.86 3 3.43

CB07 7.12 89.4 16.1 7.65 10.3 2.96 2.43 10.1

Sewage Plant Area

PB12 7.58 216 20.6 6.77 15.3 9.26 14.9 3.17

PB13 6.51 142 7.7 5.15 19.6 5.56 19.2 11.6

PB18 7.43 142 18.5 7.62 17.8 4.92 14.9 20.4

Notes:

Non-compliance with Groundwater reserve quality

02 March 2018 4-26 15008


4.5.6 Groundwater Model

Duvha currently undertakes the groundwater pollution modelling as per DWS requirement

(Appendix M). The concept geohydrological model indicating the identified pollution sources

and dams/reservoirs of Duvha Power Station is shown in Figure 4-11.

Figure 4-11: The concept geohydrological model –plan view indicating the identified pollution sources and dams/reservoirs of Duvha Power Station

The numerical modelling was performed to simulate both the operational phase (from 1989

to 2036) as well as to 100 years after decommissioning.

02 March 2018 4-27 15008


4.6 Socio-economic environment

The site is located in a predominantly agricultural area and there are therefore no major

population concentrations within 5 km of the site. The largest population concentrations are

the Lesedi village (a staff village for Middelburg South Mine) and Ikageng, a staff village for

the Duvha Power Station on the western boundary of the power station. The closest large

settlement to the site is Witbank, which lies approximately 15 km to the west. The site lies

within the area of jurisdiction of the ELM, which includes Witbank.

02 March 2018 5-1 15008


5 ANALYSES AND CHARACTERISATION OF ACTIVITY

5.1 Site delineation for characterisation

This IWULA and IWWMP report is for the existing Duvha Power Station and associated

infrastructures. The location of the Duvha Power Station and the associated infrastructures

is shown in the locality map in Figure 1-1, while the Masterplan is attached as Appendix G.

5.2 Water and waste management

5.2.1 Process water (water supply, water balance, reuse and recycling, water conservation

and demand management, sewage management, point source discharges

Duvha Power Station has effective water and waste management system (including water

supply, re-use and recycling, water conservation and demand management, sewage

management and point source discharges) in place. With monitoring as per the WUL and

addressing any identified defects, proper operations and maintenance of the above

mentioned system, Duvha Power Station will safeguard environmental compliance. Refer to

section 2.1 and 5.3 for additional details.

5.3 Storm water

In support of the IWULA, Zitholele Consulting was tasked to compile the Stormwater

Management Plan (SWMP), including the assessment of and compilation of a detailed water

balance and drafting of a Masterplan. The Storm Water Management Plan is appended to

this IWULA as Appendix E and the Master Plan in Appendix G.

5.3.1 Stormwater Management Plan

All impacted stormwater generated on-site is contained and managed on site whilst clean

water is diverted around the site to a tributary which ultimately drains to the Witbank Dam.

The stormwater management system at the power station complex can be delineated into

three main areas as follows (Refer to Appendix E for details):

Power Station terrace which includes the main power generating units and the power

island;

Coal stockyard and associated infrastructure; and

Ash Disposal Facility and associated infrastructure.

5.3.2 Water Balance

In order to undertake a water balance, a 50-year daily time-step model was built using

Microsoft Excel. The existing pollution control dams (PCDs) need to be in compliance with

Government Notice 704. More specifically, Clause 6 (d) of the regulation indicates that:

02 March 2018 5-2 15008


Design, construct, maintain and operate any dirty water system at the mine or activity

so that it is not to spill into any clean water system more than once in 50 years.

The model takes into consideration daily recorded rainfall closest to the site under

investigation as well as the operating flows (Zitholele, 2017). Refer to Figure 5-1 for the

water balance diagram.

02 March 2018 5-3 15008


Figure 5-1: Water Balance Connectivity Diagram (Zitholele, 2017)

02 March 2018 5-4 15008


5.3.3 Groundwater (identification of potential sources of pollution, source term

characterisation, impact prediction)

Potential groundwater impacts have been identified in the hydro-census investigation

undertaken for Duvha Power Station by GCS (2009). The assessment considered

parameters such as topography, drainage, runoff and filtration, geology, water levels and

ground and surface water chemistry (GCS, 2009). The survey recommended that:

Contaminant movement away from pollution point sources can be reduced, or

prevented entirely, through the construction of cut-off trenches and sub-soil drains to

the confining layer at the base of the aquifer; and

An early detection system must be installed downstream from the major pollution

sources to detect possible seepage or drainage from these areas.

Groundwater monitoring that is currently undertaken quarterly at the different sites located in

and around Duvha Power Station. In addition, the groundwater pollution modelling is also

undertaken as per the WUL. Refer to sections 4.5 and 5.5.2 for additional details.

5.3.4 Waste (waste stream identification, characterisation, reuse, recycling, minimisation)

The optimal goal in establishment of a waste disposal facility and associated infrastructure

(such as pipelines and return water dams) is to effectively minimise the negative

environmental and social impact while ensuring safety, reliability and cost savings for the

facility.

Duvha Power Station takes into account the waste management hierarchy (National

Management Waste Strategy (NMWS), [(Department of Environmental Affairs (DEA), 2011],

when dealing with their ash waste on-site (Figure 5-2).

The essence of the approach is to group waste management measures across the entire

value chain in a series of steps, which are applied in a descending order of priority. The

foundation of the hierarchy, and the first choice of measures in the management of waste, is

waste avoidance and reduction. Where waste cannot be avoided, it should be re-used,

recycled, treated, recovered, or treated (DEA, 2011). Waste should only be disposed of as a

last resort. Remediation on the other hand is part of the rehabilitation process and is on-

going until the decommissioning of the power station.

02 March 2018 5-5 15008


Figure 5-2: Waste management hierarchy (DEA, 2011)

The following alternative solutions to the ash waste stream exist:

Avoidance and Minimisation:

- None. Duvha Power Station has been in operation since 1975, therefore the generation of the ash waste stream is unavoidable.

Recovery / Recycling / Re-use:

- Use of ash in construction activities i.e. as aggregate in road construction, or as a cement extender;

- Other applications include cosmetics, toothpaste, kitchen counter tops, floor and ceiling tiles.

Treatment

- No information on the treatment of ash waste is currently available.

Disposal

- Disposal to a suitably designed facility.

Remediation

- Concurrent rehabilitation and capping of the new facility at the end of life.

5.4 Operational Management

5.4.1 Organisational Structure

Duvha Power Station is committed to the implementation of the management measures as

outlined in this IWWMP. To effectively implement the water and waste management

measures the various roles and responsibilities of the different role-players need to be

understood and respected.

02 March 2018 5-6 15008


For the action plan to be effective, a workable institutional structure with lines of

communication, roles and responsibilities must be in place on site. Duvha Power Station

already has several existing environmental management plans and structures in place aimed

at management in different areas. This includes management of waste, stormwater,

wetlands and groundwater.

An organisational structure for the Duvha Power Station operational activities is provided in

Figure 2-2..

5.4.2 Business and corporate policies

The Duvha Power Station’s IWWMP will endorse the Operational Policy that categorises and

classifies activities based on levels of acceptable risk.

Eskom’s SHEQ Policy and its implementation aim to ensure alignment to the Eskom’s vision,

values and other sustainable business imperatives, where Zero Harm means ensuring that

harm is not inflicted on the environment, Eskom’s assets, its employees, contractors, and service providers, as well as members of the public affected by its operations, infrastructure

and operational activities.

Eskom’s commitment is to ensure protection of human lives and well-being, environmental

duty of care, protection of assets, and customer satisfaction by applying the plan-do-check-

act (PDCA) quality cycle in Eskom’s activities. This is achieved through implementation of

management systems in accordance with ISO 9001, ISO 14001, and OHSAS 18001

requirements, which include:

Achieving compliance with applicable legislative and other requirements to which Eskom

subscribes and, in the absence of these, setting standards to meet the intent of this

policy;

Addressing the needs and expectations of Eskom’s electricity customers and stakeholders;

Settling SHEQ objectives and measuring performance against these with the objective of

continual improvement;

Conducting risk-based medical surveillance;

SHEQ training and awareness for employees;

Engaging stakeholders by promoting open communication and engagement that is

SHEQ-purpose driven;

Ensuring that Eskom’s suppliers and service providers meet Eskom’s SHEQ requirements;

Ensuring that adequate resources are available for SHEQ management; and

A proactive drive in managing Eskom’s environmental footprint, prevention of pollution, pursuing a low-carbon future, and prioritising energy and water efficiency and

conservation within and outside Eskom by transitioning to a cleaner energy mix.

02 March 2018 5-7 15008


5.4.3 Resources and competence

Eskom Duvha Power Station is ISO 14001 certified. ISO 14001 ensures that management

provides resources essential to the implementation and control of the environmental

management system. Resources include human resources and specialised skills,

technology and financial resources.

5.4.4 Education and Training

Formal training is identified and undertaken by the employees according to the need to

enhance the working knowledge and understanding related to the environment. Education

and training is a requirement in accordance with the ISO 14001 certification. Therefore,

conforming to this requirement ensures compliance with ISO 14001.

5.4.4.1 Induction Training

All new employees and contractors who will be working on site will undergo induction

training. This will include basic environmental training.

The induction training will provide a broad introduction to what the environment is and the

reasons why it is important to conserve the animals, plants, water and other natural

resources. The training will include topics such as:

What activities can impact on the environment;

Type of impacts associated with power generation activities;

Employees’ responsibility and role in conserving the environment; Actions that will be needed to prevent or minimise the impacts;

Waste management;

Water conservation; and

Emergency response and preparedness procedures.

5.4.4.2 Ongoing Environmental Awareness Training

Environmental awareness training is conducted in the form of the Friday SHE discussions

(discussions are undertaken when necessary and not necessarily monthly).

These discussions will summarise an issue and/or an incident that occurred during the

previous month e.g. a PCD overflowed due to poor maintenance. This method will also be

used to disseminate information at the grass root level in an effective and sufficient manner.

02 March 2018 5-8 15008


5.4.4.3 Other Training

Once the employees are trained in the basic environmental aspects, more detailed training

will be provided on other aspects as they are required. This could include:

Waste management (recycling, reusing);

Spill kit training; and

Conservation of natural resources (water, electricity, oil).

This training will be applicable to employees working in areas where these topics are of

importance.

5.4.5 Internal and external communication

5.4.5.1 Internal Communication

Recognised formal and informal communication methods are used internally to ensure

effective communication on all significant issues related to the environment. Internal

reporting from management to employees and contractors make use of the following:

SHE meetings;

Telephones;

E-mails;

Notice boards / memoranda / letters/ internal post;

Information sharing sessions (morning meetings/departmental meetings etc.);

Internal audit reports;

Management review feedback;

Formal training and awareness courses; and

Awareness drives through posters.

Communication from employees and contractors to management will be through any of the

following channels:

Line Management Reporting;

Daily SHE briefings;

Incident Reports;

E-mails / phone calls; and

Meetings.

Internal communication will be in any of the following three forms:

Upward communication, from employee and contactor to management level;

Downward communication, from management level to employee and contractor; and

Lateral communication, amongst sections and employees at the same level.

02 March 2018 5-9 15008


5.4.5.2 External Communication

Effective communication with all external interested parties is a vital component of

maintaining acceptance in the local community and a positive working relationship with

regulatory bodies, farmers and other interested and affected groups. External

communication includes, but is not limited to, any communication with one or more of the

following parties:

Government Departments;

Local Authorities;

Organised forums;

Public;

Complainants;

NGO’s; and

Media representative / reporters.

5.4.6 Awareness raising

Eskom will adhere to their existing environmental awareness plan. This plan is in line with

the ISO 14001 and includes the following key objectives:

Inform employees and contractors of key environmental issues associated with the

project;

Inform employees and contractors of how the significance of the environmental impacts

associated with the project can be reduced.

Make employees and contractors aware of the potential environmental impacts that

could arise from their duties and activities during the execution of the project;

Inform the local community of environmental initiatives related to Eskom;

The plan is implemented through various teaching and communication initiatives such

as:

- Daily toolbox talks;

- Posters promoting themes such as water conservation and waste minimisation, among others;

- Recognition of initiatives by employees to manage environmental issues, for example, through a monthly or annual prize; and

- Environmental articles in newsletters.

The nature and frequency of these initiatives, as well as the budget, will be outlined in the

detailed plan and signed off by the Eskom’s Project Manager.

02 March 2018 5-10 15008


5.5 Monitoring and control

Quarterly surface and groundwater quality monitoring is being carried out at the Power

Station since June 2006 (LMC, 2016). The sampling sites are divided into five (5) regions of

possible impact, namely;

The Power Station Area;

The Coal Stock Yard Area;

The ADF;

The Sewage Plant; and

Non-perennial streams around the power station.

The existing monitoring programme is summarised in the Sections to follow.

5.5.1 Surface water monitoring

Eskom Duvha Power Station is currently undertaking surface water monitoring at different

locations/sites around the power station (Table 5-1 and Figure 5-3). Refer to Appendix F

for the latest monitoring report.

The following constituents are monitored at Duvha Power Station surface water monitoring

network:

pH;

Electrical Conductivity (EC) (mS/m);

Total Dissolved Solids (TDS) (mg/l);

Alkalinity as CaCO3 (mg/l);

Nitrate (NO3) as N (mg/l)

Sulphate (SO4) (mg/l)

Carbonate as CO3 (mg/l)

Aluminium (Al) (mg/l);

Calcium (Ca) (mg/l);

Chloride (Cl) (mg/l);

Fluoride (F) (mg/l);

Iron (Fe) (mg/l);

Magnesium (Mg) (mg/l);

Manganese (Mn) (mg/l);

Potassium (K) (mg/l); and

Sodium (Na) (mg/l).

02 March 2018 5-11 15008


Table 5-1: Existing surface water quality monitoring points around Duvha Power Station - WUL (LMC, 2016)

Sampling Points

Location

Coordinates ((Degrees, Minutes, Seconds) decimal degrees) Sampled

Current State

Latitude Longitude

AP08 Witbank Dam 25° 55' 45.588" S 29° 18' 19.836" E Y Satisfactory

AP09 Ash Water Return Dam (Low Level) 25°57'34.57"S 29°20'39.77"E Y Satisfactory

PE01 Final effluent (Sewage Treatment Plant) 25° 57' 30.672" S 29° 19' 23.736" E Y (C & B) Satisfactory

PP03 Emergency pan 25° 57' 39.920" S 29° 20' 51.220" E Y Satisfactory

PP04 Ash water return dams (High Level) 25° 57' 16.270" S 29° 20' 39.230" E Y Satisfactory

PP20 Driefontein Dam 25°57'34.57"S 29°19'53.29"E N -

02 March 2018 5-12 15008


Figure 5-3: Location of the surface water quality monitoring points around Duvha Power Station - WUL (LMC, 2016)

02 March 2018 5-13 15008


5.5.2 Groundwater Monitoring

Eskom Duvha Power Station undertakes groundwater monitoring at the locations/sites

shown in Table 5-2 and Figure 5-4.

The following constituents are monitored at Duvha Power Station surface water monitoring

network:

pH;

Electrical Conductivity (EC) (mS/m);

Total Dissolved Solids (TDS) (mg/l);

Alkalinity as CaCO3 (mg/l);

Nitrate (NO3) as N (mg/l)

Sulphate (SO4) (mg/l)

Carbonate as CO3 (mg/l)

Aluminium (Al) (mg/l);

Calcium (Ca) (mg/l);

Chloride (Cl) (mg/l);

Fluoride (F) (mg/l);

Iron (Fe) (mg/l);

Magnesium (Mg) (mg/l);

Manganese (Mn) (mg/l);

Potassium (K) (mg/l); and

Sodium (Na) (mg/l).

02 March 2018 5-14 15008


Table 5-2: Existing groundwater quality monitoring points around Duvha Power Station - WUL (LMC, 2016)

Sampling Points

Location/ Description Location Coordinates

Sampled Current State Latitude Longitude

PB09 Borehole upstream from the upper Ash Return Water Dam 25° 57' 20.160" S 29° 20' 38.220" E Y Satisfactory

PB10 Borehole downstream from the upper Return Water Dam 25° 57' 13.428" S 29° 20' 32.885" E Y Satisfactory

PB11 Supply borehole on Mr Gouws farm 25° 57' 29.880" S 29° 20' 55.644" E N No access

PB12 (B) Borehole at Sewage Plant West 25° 57' 37.908" S 29° 19' 20.532" E Y (C & B) Satisfactory

PB13 (B) Borehole at Sewage Plant West 25° 57' 34.416" S 29° 19' 20.460" E Y (C & B) Satisfactory

PB18(B) North of Sewage Plant 25° 57' 30.348" S 29° 19' 22.764" E Y (C & B) Poor no cap & pole

CB06 Borehole outside power station area East of coal stockyard 25° 57' 29.304" S 29° 20' 49.452" E Y Satisfactory

CB07 Borehole outside power station area East of coal stockyard 25° 57' 38.520" S 29° 20' 45.384" E Y Satisfactory

CB08 Borehole outside power station area East of coal stockyard 25° 57' 50.868" S 29° 20' 43.368" E N Blocked

AB01 Borehole near old farmhouse 25° 56' 2.976" S 29° 19' 33.564" E Y Satisfactory

AB02 Borehole near AB01 towards Witbank Dam 25° 55' 54.516" S 29° 19' 33.816" E Y Satisfactory

AB03 Borehole near AB01 and AB02 25° 55' 54.732" S 29° 19' 38.568" E Y Satisfactory

AB04 Borehole at pump station of Ash Dam 25° 55' 29.892" S 29° 20' 42.540" E Y Poor condition, no pole

AB05 Borehole north of ash dam near ash return water dam 25° 55' 51.816" S 29° 20' 56.148" E Y Satisfactory

02 March 2018 5-15 15008


Figure 5-4: Locations of the groundwater quality monitoring points around Duvha Power Station - WUL (LMC, 2016)

02 March 2018 5-16 15008


5.5.3 Biomonitoring

Eskom undertakes biomonitoring assessments at the selected biomonitoring sites

(Appendix J).The objectives of the bio monitoring assessments were to:

Detect or identify any deterioration in ecological integrity by conducting the specialist

assessments on the aquatic ecosystems;

To build a strong reliable database that can be used for trend analysis and other

analysis; and

Maintain, review and/or refine the integrated biomonitoring program (protocols) for

different power stations.

Two (2) sites are monitored at Duvha Power station and details are provided in Table 5-3

and Figure 5-5 below.

Table 5-3: Duvha Power Station Biomonitoring locations (Eskom, 2016a)

Monitoring site

River / Stream

Associated Power station

Description Biomonitoring protocols

GPS coordinates

Pro

toco

l

Fre

qu

en

cy

per

an

nu

m

Lati

tud

e

(So

uth

)

Lo

ng

itu

de

(East)

DV-trib-US

Unnamed Northern tributary

Duvha

Unnamed tributary, downstream site to the north of the power station

SASS5 Twice, if flowing

25° 55' 28.920" S

29° 20' 45.600" E

Fish Once

Toxicity testing

Twice

DV-trib-DS

Unnamed tributary, downstream site to the north of the power station

SASS5 Twice, if flowing

25° 55' 23.880" S

29° 20' 40.560" E

Fish Once

Toxicity testing

Twice

02 March 2018 5-17 15008


Figure 5-5: Duvha Power Station study area indicating streams and selected monitoring sites (Eskom, 2016a)

Eskom Sustainability Department (2016a) recommended to Duvha Power Station to

continue with macro-invertebrate monitoring and toxicity testing at the two tributary sites. It

was also recommended to continue with fish assessment once per annum at the selected

sites to allow for analyses of seasonal variation and in order to confirm the absence of

deteriorating biotic integrity.

EnviRoss also conducted biomonitoring sampling in December 2013 followed by another

survey in May-June 2016 and the following were observed:

Electro-narcosis and cast-netting along the peripheral areas was undertaken, but no fish

were noted, which is similar to the results gained following the December 2013 survey.

However, this does not unequivocally preclude the presence of fish within the system;

Low observations of amphibians were noteworthy, but the survey was undertaken during

the inactive season and therefore these results are expected;

A rich diversity of birdlife was observed utilising the wetland area for breeding and

foraging purposes;

No Red Data Listed species were noted, but species such as Phoenicopterus ruber and

Phoenicopterus minor (Greater and Lesser Flamingo), Circus ranivorus (African march

Harrier) and Tyto capensis (African Grass-owl) (Ansara, 2004) would very well utilise the

habitat;

Aquatic macro-invertebrates sampled included species from the following families:

Gyrinidae, Hydraenidae, Culicidae, Chironomidae, Belostomatidae, Corixidae,

Dytiscidae, Notonectidae and Pleidae; and

02 March 2018 5-18 15008


Micro invertebrates included species from the families of Daphniidae (Branchiopoda) and

the class of Ostracoda.

All of these observed species are regarded as having a medium tolerance to poor water

quality. Again, these results were similar to those gained during the previous survey,

indicating the overall ecological integrity of the wetland unit has not significantly degraded

since the initial survey. As a result, no further aquatic biodiversity monitoring has been

recommended by the specialist.

5.5.4 Waste monitoring

The Waste assessment for the Duvha Power Station was carried out in terms of the National

Norms and Standards for the assessment of waste for landfill disposal (R635 of 23 August

2013), SANS 10234 and SANS 10324 (ISO-Q); refer to Appendix K for detailed reports.

The ash sludge and sewage solid waste are classified as a Type 3 waste (low hazard

waste). Therefore, these wastes require disposal on a landfill with a Class C barrier system.

This classification was the result of the leachable concentration of boron and the total

concentration of barium and fluoride in the ash and sludge.

5.6 Risk assessment / Best practice assessment

5.6.1 Possible Impacts / Risks

No new activities or construction is included in this IWULA for Duvha Power Station. As a

result, there was no EIA process undertaken in terms of the EIA regulations, 2014 for this

proposed project. Therefore, this report will focus mainly on the management measures for

the operational activities related to the existing water uses to be amended and licensed.

The potential project impacts due to Duvha Power Station operational activities are identified

and summarised in Table 5-4 below. This report only focused on the water-related impacts.

Table 5-4: Summary of the possible impacts related to the operational activities at Duvha Power Station

PROJECT PHASE ACTIVITY POSSIBLE IMPACTS

Operational Phase

Routine cleaning, repair and

maintenance of infrastructure

Soil compaction and increased erosion.

Increase in hydrocarbon concentrations.

Daily operational activities (including

operations of the water treatment

plant, coal stockyard, ash dams,

emergency pan, service roads, etc..)

at Duvha Power Station

Modification of biota’s and animal ‘s habitats

Dust generation

Deterioration of water quality

Change in water flow regime

02 March 2018 5-19 15008


5.6.2 Mitigation Measures

Mitigation measures have been identified in terms of the proposed project’s Operational phase since there are no construction and closure activities proposed for this WUL

amendment and licensing process. In addition, best practices were considered in identifying

mitigation and management measures for potential impacts from the existing operational

activities at the power station relating to water uses as well as the natural environmental

(refer to Table 5-5).

Table 5-5: Mitigation measures

Item no.

Aspect Operational

1 Surface water Ensure full containment of dirty water from the ADF through successful implementation of the dirty water containment system;

Minimise area of vegetation clearing;

Where practical, undertake the clearing of vegetation during the dry season to minimise erosion;

Maintain sediment traps as part of the storm water management plan where necessary and especially upstream of discharge points where erosion protection measures and energy dissipaters should be in place;

Clean spills as quick as possible;

Store and handle potentially polluting substances and waste in designated, bunded facilities;

Monitoring of water quality within the receiving environment must also be routinely undertaken. This should be undertaken before the onset of any construction activities both upstream and downstream of the impact area to gain baseline data. Routine monitoring at the same points must be undertaken to gain comparative data to determine trends to water quality emanating from the construction activities;

Waste should be frequently removed from the site by suitably equipped and qualified operators and disposed of in approved facilities; and

Locate temporary waste and hazardous substance storage facilities out of the delineated wetland sites.

2 Groundwater Any waste and spills (during operation) need to be managed according to the departmental (DEA) requirements;

The monitoring network should be kept update in terms of the activities taking place at the power station and according to the DWS requirements;

Authorities need to be notified in the event of a spill or leachate should they occur;

Proper operation and maintenance of contaminated water trenches and dams; and

All pollution control facilities (dams, trenches) must be operated to have a minimum freeboard above full supply level as recommended by GN 704 in terms of the National Water Act (36 of 1998).

4 Aquatic ecology

Ensure that PCDs are designed according to strict safety requirements and are regularly inspected for leaks, damage or maintenance requirements. Where irregularities are detected, they should be speedily remedied to avoid the risk of structural failure;

Road crossings of wetlands should be regularly inspected for erosion, mechanical problems, leaks or spillages. These should be timeously repaired;

Should larger spillages occur due to malfunctioning of the any infrastructure or for any other reason on-site, clean-up of the spillages should be undertaken as soon as possible following the incident. In this regard regular inspection of all infrastructure on-site that have potential to spill should be undertaken;

02 March 2018 5-20 15008


Item no.

Aspect Operational

An emergency response plan should be compiled to address structural failures and major accidental spillages;

Storm water should be used for dust suppression on-site if required to avoid the need for abstraction from natural water resources;

Sediment trapping mechanisms should prevent soils from being washed into wetlands; and

Movement of machinery and vehicles must be strictly controlled to prevent disturbance to wetland areas.

5 Wetlands Water management infrastructure should be regularly inspected and maintained fully functional at all times;

An emergency response plan for handling large spills or leaks due to infrastructure failure on-site must be compiled and put in place, with regular practice drills to ensure its effectiveness;

All discharge points should incorporate sediment barriers or sediment traps designed to cope with the flow velocities and volumes at the point of discharge;

All discharge points should be regularly inspected for signs of erosion, sediment deposition or obstructions;

Implement corrective measures to address any water quality impairment that may be observed; and

A suitably qualified specialist should be appointed to monitor wetland ecological functionality as well as to interpret water quality trends, with report feedback being provided at least monthly for a three-month period, and thereafter at a six-monthly (biannual) interval. A final sign off of rehabilitation works can be considered after 12 months following completion of any civil works. This end-point must be determined by the ECO or otherwise suitably-qualified specialist as dynamics of the system may also evolve due to local site conditions

6 Sewage treatment Plant

It is recommended that regular testing of effluent water be undertaken in order to manage the performance of the water treatment works that will ensure that the quality of the effluent is of adequate quality so as not to have a significant impact to the receiving environment.

8 Soils and land capability

If soils have been removed (for example during excavations or entrenchment) then soil layering must be observed, removed and stored in such a way that the same layer can be preserved during reinstatement;

The surface of the impacted soils must be lightly ripped to a depth of at least 150 mm in order to aid in revegetation;

Re-vegetation of the disturbed area must be done using species that occur naturally and appropriate zonation of wetland species must be observed. The ECO must approve the process as well as the appropriate seed mixtures;

Routine monitoring of success of re-vegetating disturbed soils must be undertaken and remedied if seen to be unsuccessful;

Routine monitoring of emerging erosion must take place and remedied is necessary;

Minimisation of the area that can potentially be impacted (eroded, compacted, sterilized or de-nutrified);

Effective soil cover and adequate protection from wind (dust) and dirty water contamination;

Regular servicing of all vehicles in well-constructed and bunded areas;

Regular cleaning and maintenance of all haulage ways, conveyancing routes and service ways, drains and storm water control facilities; and

Containment and management of any spillage.

9 Social Create a grievance mechanism, e.g. complaints register, to ensure nuisances can be reported and dealt with quickly;

Create an employment policy and communicate it to the stakeholders. Employ local people where possible; and

02 March 2018 5-21 15008


Item no.

Aspect Operational

Compile a stakeholder communication strategy and appoint a community liaison officer.

5.7 Public consultation process

5.7.1 Identification of Interested and Affected Parties

The identification of key stakeholders was done in collaboration with Eskom and other

organisations in the study area. The stakeholders’ details were captured in an electronic database management software programme (Maximizer). A database of interested and

Affected Parties (I&APs) were kept by the public participation practitioner.

The proposed application process and opportunity to participate and/or register as I&APs

was announced in December 2016 as follows:

Advertisements were placed in the following newspapers: The Herald - Middelburg and

Mpumalanga News on 9 and 15 December 2016;

Site notice boards were positioned at prominent, public locations and on all roads

leading to the study area on 9 December 2016;

A Background Information Document (BID) containing details of the proposed project,

was sent to all I&APs;

Stakeholders were also invited to visit the Zitholele/Eskom websites where all documents

for public review were made available: http://www.zitholele.co.za/duvha-wula-

amendmentii. Note that Zitholele Consulting’s website has been migrated and

documents can now be viewed at http://www.zitholele.co.za/environmental/ under

the heading “Duvha IWULA Amendment” and

Emails were sent to all potentially affected stakeholders.

http://www.zitholele.co.za/duvha-wula-amendment

http://www.zitholele.co.za/duvha-wula-amendment

http://www.zitholele.co.za/environmental/

02 March 2018 5-22 15008


5.7.2 Comments and Response from public consultation process

Table 5-6 include Comments and Responses Report (CRR) from the public consultation process.

Table 5-6: List of Comments and Responses from public consultation process

No. I&AP Comment Commentator Form & Date of

Comment Response

1

Please can you advise why the 60 day time

period for comment (in terms of section 41

of the NWA reading with section 52) is not

being applied?

LOSER, Nicole

Centre for

Environmental

Rights (CER)

Email

20 January 2017

Duvha Power Station has undertaken a gap analysis to

determine if their water licence fully aligns with the activities

on site.

This analysis showed that there are some water uses that

require amendments and others which must be added. All

these activities are existing and no construction is proposed.

The power station was constructed between 1975 and

1984.

Because of the nature of the application, we have decided

to make the public participation only 30 days.

2

In terms of section 52 of the NWA, an

application for the renewal or amendment

of a water use licence must be dealt with

according to the procedure as set out in

section 41 of the NWA.

Section 41(4)(ii) states that at least 60 days

must be given for the lodging of written

objections against an application.

In the circumstances, and in keeping with

the public participation requirements of the

LOSER, Nicole

CER

Email

27 January 2017

Thank you for your comments. Kindly note that your

comments are hereby acknowledged and duly considered.

Please be informed that Zitholele Consulting in discussion

with the DWS case officer have reached a decision that the

public review period and/or notifications for the proposed

application for Duvha Power Station will be amended to

provide interested and affected parties with at least 60 days

to submit their comments. This will include newspaper re-

advertisements and other forms of notifications to all

stakeholders.

02 March 2018 5-23 15008


No. I&AP Comment Commentator Form & Date of

Comment Response

NWA, we ask that you amend the

notification to provide interested and

affected parties with at least 60 days to

submit comments on the amendment

application.

02 March 2018 5-24 15008


5.8 Matters requiring attention / problem statement

All issues raised regarding this IWULA for Duvha Power Station have been addressed

during the public consultation period.

5.9 Assessment of level and confidence of information

In broad-spectrum, the level and amount of information available is sufficient to support the

development of the IWULA and IWWMP for the Duvha Power Station.

02 March 2018 6-1 15008


6 WATER AND WASTE MANAGEMENT

6.1 Water and waste management philosophy (process water, storm water,

groundwater, waste)

Eskom’s environmental management philosophy aims to implement mitigation measures to minimise the negative aspects and enhance the positive aspects of the project as well as to

inform, involve and improve the local communities in the process. Duvha Power Station

endeavours to comply with the following principles and practices:

Modify, remedy, control or stop any action, activity or process which causes pollution or

environmental degradation;

Contain or remedy the cause of pollution or degradation and migration of pollutants; and

Comply with any prescribed waste standard or management standards or practices.

6.2 Strategies (process water, storm water, groundwater and waste)

6.2.1 General Storm Water Management

Stormwater at Duvha Power Station is managed through the Power Station Terrace, Coal

stockyard and associated infrastructure; and ADF and associated infrastructure (Zitholele,

2017). Refer to Appendix E for details. Water areas within the terrace are confirmed to be

contaminated; however, this water is managed accordingly. The concrete lined perimeter

drains around the facility intercept runoff generated in this area and transfer it to the stations

the station drains located on the north-eastern side of the coal stock yard. The station drains

overflow gravitates to the Low Level Dam. Runoff from the side slops of the facility are

intercepted by bench drains which eventually drain to the toe perimeter drains (Zitholele,

2017). The Low Level Dam is located at the lowest point of the power station operations and

essentially turns out to be the ultimate interception of dirty water runoff from the power

station. The Low Level Dam operates in tandem with the High Level Dam by pumping water

to it when it reaches its maximum storage level. Overflow from the High Level Dam

discharges to a concrete lined channel draining to the Low Level Dam and innately forms a

closed circuit with it (Zitholele, 2017).

Duvha Power Station has an effective stormwater management system is place and with

proper operations and maintenance of it will ensure environmental compliance.

6.2.2 Water Balance

The existing PCDs are in compliance with Government Notice 704. More specifically, Clause

6 (d) of the regulation which indicates that:

02 March 2018 6-2 15008


Design, construct, maintain and operate any dirty water system at the mine or activity

so that it is not to spill into any clean water system more than once in 50 years.

The water balance model produced the following results as shown in Table 6-1

Table 6-1: Duvha Water Balance Results

Dam Name Dam Volume % Full Spills (no of

times)

Low Level Dam 769 766 100% 1

HLD 94 450 100% 17,179

% Siltation of Low Level Dam 10%

The water balance modelling is provided in Figure 5-1.

6.2.3 Process Water

The process water (including cooling water systems and drainage of boilers condensers) at

Duvha Power Station enters the station drains located at the eastern corner of the site and

flows to the ADF. There are concrete stormwater channels of various sizes on site which

intercept and convey dirty water. All dirty stormwater channels discharge into the station

drains, which is then diverted to the low level AWRD.

6.2.4 Groundwater

The groundwater quality will be protected from impacts from the Duvha operational activities

by means of continuing with the implementation of the management / mitigation measures

currently followed at the Power Station as well as those included in this report in section

5.6.2. The storm water management philosophy (as described in 5.3) is also critical in

preventing groundwater impacts.

6.2.5 Waste

The waste classification was carried out in terms of the National Norms and Standards for

the assessment of waste for landfill disposal (R635 of 23 August 2013), SANS 10234 and

SANS 10324 (ISO-Q). The ash is classified as a Type 3 waste (low hazard waste).

Therefore, the ash requires disposal on a landfill with a Class C barrier system. This

classification was the result of the leachable concentration of boron and the total

concentration of barium and fluoride in the ash, sludge and sewage solid waste.

02 March 2018 6-3 15008


6.3 Performance objectives / goals

Duvha Power Station is ISO 14001 certified. Therefore, they have an Environmental

Management System (EMS) which enables them to set performance objectives and track

their performance against it.

The performance objectives for Duvha Power Station (water and waste) are set out in Table

6-2 below.

Table 6-2: Performance objectives for Duvha Power Station

Theme Performance Objective

Surface Water

Prevent clean water contamination through clean and dirty water separation

Prevent pollution of surrounding water resources through AWRDs

Manage air quality and dust nuisance through dust suppression

Prevent downstream pollution and erosion impacts through controlled releases from the dams

Groundwater

Prevent deterioration of groundwater quality through effective design, management and monitoring

Prevent aquifer contamination through active management, monitoring and implementation of mitigation measures, if needed

Waste Ensure legally compliant waste disposal operations

6.4 Measures to achieve and sustain performance objectives

Measures to achieve and sustain performance objectives for surface water, groundwater and

waste are detailed in the action plan in section 6.3, which deals with control and monitoring

of potential identified impacts.

6.5 IWWMP action plan

The water and waste related matters requiring attention will be implemented in accordance

with the action plan stipulated in Table 6-3.

02 March 2018 6-4 15008


Table 6-3: IWWMP action plan

Theme Objective / Aspect Area / activity Risk Identified Task Commencement

Date Expected Completion date

Budget Requirement

Responsible Person

General site management

Management of operational activities

Entire Duvha Power Station

- Legal non-compliance with WUL - Lack of onsite supervision may lead to incorrect management of environmental aspects

An internal Waste Management Officer (WMO) will be appointed to monitor and ensure compliance and correct implementation of all conditions and provisions stipulated in the WUL.

Immediately End of Operational Phase (ashing)

Opex

Eskom Operations Manager: appointment of WMO, and implementation of Eskom OMM

The WMO must report any non-compliance with conditions or requirements or provisions of the NEMWA to the DEA and the DWS.

Work per Eskom Operations and Maintenance Manual (OMM).

Management of closure activities

Entire Duvha Power Station

- Residual impacts resulting from ineffective closure (wetlands, air quality, surface and ground water pollution, water quality and turbidity)

Detailed Closure Plan should be developed and submitted for approval prior to closure

Start preparing plan six years prior to closure

Finalise and submit plan for approval five years prior to closure

Opex Eskom Operations Manager

Closure activities should be undertaken as per the approved Closure Plan and/or relevant legislation at that time.

At start of closure End of Rehabilitation

Continuously rehabilitate sideslopes after every 8m height completed.

Immediately Continuously after completion of each 8m height completed

Storm Water Management

Management of the Clean Water System

Clean water diversion channel at clean area

-Inability to meet the DWS Water Quality Objectives (WQO) from point of release

Maintain the clean water diversion channels which discharges clean water to the environment.

Immediately End of Rehabilitation Capex Eskom Operations Manager

Management of dirty water system - Dirty water run-off from open ashing areas

PCDs including dirty stormwater channels

-Siltation of PCDs over time resulting in decrease of design storage capacity - Non-compliance with GN704

Inspect water management infrastructure to ensure optimal functioning.

Twice a year Ad hoc after rehabilitation is complete

Develop and Implement a programme of desilting of the PCDs.

Twice a year Ad hoc after rehabilitation is complete


ADF

-Stability issues that could result in the rapture of the barrier system will cause groundwater contamination -Ineffective dust suppression and concurrent rehabilitation will cause air quality impacts and result in dust fallout with a detrimental impact on water resources

Implement dust suppression mitigation measures on the open ash area.

Immediately End of ADF Rehabilitation Opex Eskom Operations Manager

Inspect / monitor ADF ensure optimal functioning (as stipulated in the Eskom OMMl).


Emergency measures should be included in the OMM and dealt with per this plan as well as S19 and S20 of the NWA and other relevant legislation.


Keep dirty water area as small as possible through continuously rehabilitating the completed ash areas of the ADF.


Capacity requirements

Dirty stormwater channels

Erosion and siltation impacting on natural water resources

Desilt water conveyance and storage infrastructure.

At start of ashing Until ADF rehabilitation is complete


Surface water

Water Quality Water quality monitoring points

- Inability to meet the WQO (GN466) - Toxins could impact negatively on the ecosystem and agricultural users

Monitor water quality to meet the following quality objectives: - Phosphate (PO4) ≤ 0.125 mg/L - Nitrate (NO3) & Nitrite (NO2) ≤ 4 mg/L - Total Ammonia ≤ 0.1 mg/L.

Immediately End of closure period Opex Eskom Chemical Services Department

Water Quantity Downstream Catchment B11J

- Inability to meet the WQO (GN466) - Low flows not being improved in order to maintain river habitat and the Ecosystem.

Work together with other water users in the catchment to maintain low and drought flows: Olifants EWR1 in B11J VMAR = 184.5 x106m

3 PES = D category.


Groundwater Water Quality ADF and PCDs Seepage and groundwater contamination

Undertake a groundwater monitoring programme for the

Immediately Continue at least 5 years post closure unless the monitoring

Opex Eskom Chemical Services Department

02 March 2018 6-5 15008




Budget Requirement

Responsible Person

variables of concern. indicates a deterioration in water quality that may require additional mitigation

Water Quantity Downstream catchment B11G

- Inability to meet the WQO (GN466) - Inability to maintain the natural trend over the medium to long-term

Measure groundwater levels for: - At least one NGwQI MP monitoring site that is representative of the aquifer. - Water level fluctuations in Dolomitic aquifers should not exceed 6m.


Management of soils Erosion Control Topsoil Stockpiles used for closure activities

Run-off causing erosion and sedimentation of the surface water resources and wetland areas

Separate topsoil from bulk excavation where possible.

Start of closure phase

End of closure period Consider the incremental development of the ADF

Opex Eskom Environmental Officer

Store topsoil within the demarcated topsoil storage areas and outside of the 1:100 year flood plain.

Allow for the natural vegetation of topsoil stockpiles as to protect the soils against wind and water erosion

Should additional topsoil be required , it should be sourced during the final closure phase. This aspect should be included into the Closure Plan

Five years prior to closure

Aquatic / Wetland components

Aquatic Condition Aquatic monitoring points

- Inability to meet the WQO (GN466) - Inability to maintain instream habitat in largely modified (D) or better condition to sustain biota

Monitor aquatic points for the following: - Instream Habitat Integrity category ≥ D (≥42) - Fish ecological category ≥ D (≥42) - Macro-invertebrate ecological category ≥ D (≥42) - Instream Ecostatus category ≥ D (≥42) - Hydrological category ≥ D (≥42) - Water quality category ≥ D (≥42)

Immediately End of closure period Opex Eskom Environmental Officer

Riparian Zone Aquatic Monitoring points

- Inability to meet the WQO (GN466) - Inability to maintain habitat integrity in largely natural or better condition (C) - Inability to maintain riparian ecostatus in a moderately modified condition (C) - Inability to maintain low and high flows in a moderately modified or better condition and high flows to sustain the riparian zone habitat (B)

Monitor aquatic points for the following: - Riparian Zone Habitat Integrity category ≥ C (≥62) - Riparian ecostatus category ≥ C (≥62) - Hydrological ecological category ≥ C (≥62)

Immediately End of closure period Opex Eskom Environmental Officer

Waste management Management of Construction and Operational Waste

Generation of hazardous and general waste - General Waste i.e Office waste, food waste, scrap metal ect - Hazardous waste i.e. hydrocarbons, paints, batteries ect

Inadequate management of both hazardous and general waste could result in surface and groundwater contamination

- Remove all waste off-site through an approved waste management contractor. - Ensure that waste is segregated and stored correctly. - Obtain safe disposal certificates and Ensure correct record keeping.

Immediately End of close period Opex Eskom Environmental Officer

Additional licensing commitments Update of IWWMP, Water balance and

Documentation - IWWMP, Water Balance and monitoring programme might

Review IWWMP and water balance every five years

First review 2022 End of closure period Opex Eskom: PM

02 March 2018 6-6 15008




Budget Requirement

Responsible Person

monitoring programme

become outdated with changes in project -This may lead to uninformed decision-making which could lead to technical failures and environmental incidents

Audit of licence Documentation Non-compliance with WUL conditions

Undertake external audit of WUL every 2 years

At start of construction

End of closure period Opex Eskom Environmental Officer

02 March 2018 6-7 15008


6.6 Control and monitoring

6.6.1 Monitoring of change in baseline (environment) information (surface water,

groundwater and bio-monitoring)

Surface water, groundwater and bio-monitoring programme have been conducted to

establish baseline information and comply with the conditions of the existing WUL for Duvha

Power Station.

6.6.2 Aquatic Biodiversity Monitoring

Biomonitoring of the aquatic ecosystem at Duvha Power is undertaken according to

condition 3.4 of the existing WUL.

6.6.3 Surface and Groundwater Monitoring

Refer to section 5.5.1 and 5.5.2 for details about the surface and groundwater monitoring

programme.

6.6.4 Waste Monitoring (facility operations)

Monitoring of the Duvha Power Station operational activities is crucial to ensure potential

impacts resulting from the operation, maintenance and emergency incidents are identified

and remedied within an adequately short timeframe.

6.6.5 Audit and report on performance measures

In terms of condition 12.4 of the existing WUL for Duvha Power Station received in July

2007, all audit reports shall specifically state whether conditions of the licence are adhered

to and must include an interpretation of all available data and test results regarding the

operation of the sites and all its impacts on the environment. Condition 12.5 further states

that all audit reports shall contain recommendations regarding non-compliance or potential

non-compliance and must specify target dates for the implementation of the

recommendations by the Licensee.

In addition, Duvha Power Station is subject to regular 3rd party audits by recognised

companies that comply with the requirements of the standards for certification laid down by

appropriate Accreditation Federation to maintain ISO 14001 certification.

Reports outlining the results of the sampling are to be compiled after each sampling activity.

These reports will highlight any negative impacts on the water due to operations as well as

determine the sources of the impacts. The reports should also discuss possible actions

which can be used to mitigate any negative impacts. Relevant results will be graphed so that

trends may be visually observed.

02 March 2018 6-8 15008


6.6.6 Audit and report on relevance of IWWMP action plan

The IWWMP action plan is to be regularly updated and reviewed to monitor progress and

ensure that implementation of goals is on track. The existing surface and groundwater

monitoring programme must also be reviewed and revised annually to identify its relevance

to alterations the area and to update any changes necessary if there have been any to the

monitoring programme as set out initially. The water quality monitoring data should be

included in the audit to identify and review any new and existing impacts.

02 March 2018 7-1 15008


7 CONCLUSION

Duvha Power Station has undertaken a gap analysis to determine if their existing WUL fully

aligns with the activities on site. This analysis showed that there are some existing water

uses that require amendments and new licensing. No construction is proposed nor any

activities triggered in terms of NEMA regulations. The power station was constructed

between 1975 and 1984. The proposed amendment of, and licensing of new, existing water

uses is, therefore, being undertaken to ensure that the existing WUL is a true reflection of

the current state of the Power Station.

7.1 Regulatory status of activity

Water uses considered in this IWULA and IWWMP that requires amendment and licensing

at Duvha Power Station are included in Table 7-1 below.

02 March 2018 7-2 15008


Table 7-1: Water uses to be licenced




3/annum (10 000 m



S21 (b) Storing of water.

The 2007 WUL refer to the storage of 884 000 m

3 of water in two dams. Eskom proposes the

amendment of the above to the following: “the storage of 884 000 m

3 of water in raw water

reservoirs” - Amendment.



Power Station

ADF;

Coal Stockyard;


High level dams;

Station drains;

Maturation ponds; and

Sewage plant.

S21 (i)




3/day



Coal Stock Yard - New Application.

Dust suppression of un-rehabilitated areas with dirty water.


High level dams;

Station drains;

Maturation ponds

02 March 2018 7-3 15008


7.2 Statement on water uses requiring authorisation, dispensing with licensing

requirement and possible exemption from regulations

This IWWMP has been compiled in support of the application for amendment and licensing

of a new existing water uses at Duvha Power Station. The existing Duvha Power and its

related operational activities impact several water uses as identified in Table 7-1 above,

which will require licensing as per the regulations of the NWA.

All impacts on the identified water uses has been considered and mitigated to acceptable

levels to ensure the operations of Duvha Power Station is undertaken in an environmentally

responsible and sustainable manner.

No possible exemptions from certain regulations are applied for.

7.3 Section 27 Motivation

The National Water Act (NWA) includes considerations set out in Section 27(1) that must be

applied in the assessment of licence applications for water use. Although the Act states that

this is a DWS responsibility, the objective of this report and the next section are to provide

the necessary information required in terms of Section 27(1) to allow the DWS official to

evaluate this application.

7.3.1 The Need to Redress the Results of Past Racial and Gender Discrimination

Eskom have issued an Integrated Report for 2016 (Eskom, 2016b). This report explains in

detail how much Eskom have invested into transformation and social responsibility. Refer to

Appendix H for a 4-page extract from the report, focussing specifically on this aspect.

7.3.2 Efficient and Beneficial Use of Water in the Public Interest

The National Water Resource Strategy (NWRS) has declared the generation of electricity to

be of strategic importance. This project is aimed at the efficient use of water for the good of

the country from a social, economic and environmental perspective.

7.3.3 Socio-economic Impact – If the water use is authorised; or of the failure to authorise

the water use or uses

Duvha Power Station and the associated infrastructures related to this proposed amendment

and licensing of new existing water uses are existing. No construction is envisaged on this

proposed application. Therefore, the current impacts resulting from Duvha Power Station

activities will remain the same. However, granting authorisation on this application will lead

to enhanced use of water at the Power Station through necessary monitoring and

implementation of the water related management measures in ensuring compliance with the

WUL. This will in the long run, improve the condition of water in the surrounding areas

02 March 2018 7-4 15008


through the said water monitoring and implementation of water related management

measures.

Formal economic activity in the WMA is highly diverse and is characterised by commercial

and subsistence agriculture (both irrigated and rain fed), diverse mining activities,

manufacturing, commerce and tourism. Large coal deposits are found in the Emalahleni and

Middelburg areas (Upper Olifants). The WMA is home to several existing large thermal

power stations, which provide energy to large portions of the country.

The development of the Olifants WMA economy is to a large extent, dependent upon the

agricultural and mining sectors. South Africa’s National Development Plan identifies South

Africa’s mineral wealth as a key driver of economic development and also identifies the Agriculture sector as the key sector for developing an inclusive rural economy. Both these

sectors, and their respective value chains, are dependent on water as an input to production.

Economic production activities use water as an input to their production processes.

Production outputs are the gross income or turnover of each user activity. The Agriculture,

Mining, Electricity and Water, and other sectors are all significant value adding sectors, with

significant multiplier effects into the rest of the economy. The Gross Domestic Product

(GDP) of economic sectors directly dependent upon WULs in the Olifants Water Use Area

(WUA) in 2010 was R72 billion. This was 55% of the WUA GDP. Thus, more than 50% of

the GDP produced in the Olifants WUA are dependent upon WUL.

The water balance for the Olifants River catchment as a whole indicates a small surplus in

2010, but a deficit from 2016. The future demand for water by mining and rural communities

precipitated the De Hoop Dam development. However, even the additional yield provided by

the De Hoop Dam and the raised Flag Boshielo Dam, will not be sufficient to supply future

demand.

Table 7-2: Summary of water requirements (units: million m3/year) (DWS, 2011b)

Sub-area Irrigation Urban Rural Industrial Mining Power

Generation Total

Upper 249 93 4 9 26 228 609

Middle 81 56 22 0 28 0 187

Lower 156 29 3 0 32 0 220

Total 486 178 29 9 86 228 1016

Irrigation is the largest consumer of water within the WMA. The total irrigated area in the

Olifants River catchment is 88,772 ha requiring 486 million m3 per year. Of this, 39,378 ha

form part of irrigation schemes, while the remainder are defined as diffuse schemes

irrigation.

Urban water demand encompasses industrial, commercial, institutional and municipal use.

The total water use within the urban areas is 178 million m3/a.

02 March 2018 7-5 15008


Rural water demand includes all domestic water requirements outside of urban areas and

includes stock watering and subsistence irrigation on small rural garden plots. Rural water

use comprises 29 million m3/a.

Mining activities are dominated by coal mining, particularly in the Highveld, and platinum

group metals, but also include copper, gold, tin, platinum, phosphate and diamonds in the

Lowveld. The mines use water for the processing of ores. The number of active mines in the

catchment was estimated to be 93 (DWS, 2011a).

Refer to Table 7-3 for a summary of water use projections of the Olifants for 2035. Future

demand for irrigation, power generation and heavy industrial use are expected to remain

stable. Urban and Rural water requirements are expected to grow with population growth.

The largest increase in water demand is expected within the Mining sector, and especially

the Platinum Group Metal (PGM) mining sector.

Table 7-3: Water Use Projections of the Olifants Catchment for 2035 (DWS, 2011b)

Sector Current requirement (2010) Future requirement (2035)

High growth Low growth

Irrigation 486 486 486

Urban 178 255 221

Rural 29 51 39

Industrial 9 9 9

Mining 86 140 128

Power Generation 228 229 229

TOTAL 1,016 1,170 1,112

7.3.4 Catchment Management Strategy

The Olifants Catchment Management Agency has been established in July 2014 but to date

no strategy has been developed.

7.3.5 The Effect of the Water Use to be authorised

The power station was constructed between 1975 and 1984. The proposed amendment of,

and licensing of new, existing water uses is, therefore, being undertaken to ensure that the

existing WUL is a true reflection of the current state of the Power Station. All the

infrastructures associated with Duvha Power Station’s operational activities are existing and

there is currently no intended construction. No new impacts are anticipated at the Power

Stations as a result of this application. However, the impacts related to existing water uses

as the Power Station have been identified and summarised in Section 5.13 of this report. No

significant negative impacts on the surface and/or ground water are anticipated if all

proposed mitigation measures are undertaken.

02 March 2018 7-6 15008


7.3.6 Class and Resource Quality Objectives of the Water Resource

The Resource Water Quality Objectives for the Olifants Catchment was gazetted on 22 April

2016 (GN 466). The Upper Olifants Catchment (B11G) is classified as having an Ecological

Category D. RWQO have been set for various aspects, i.e. quantity, quality etc..

7.3.7 Investments Already Made and to be Made by the Water User

The water uses infrastructures at Duvha Power Station are existing. Eskom will therefore,

not significantly invest in terms of the water use infrastructures for the station. However,

Eskom has invested to the amendment and licensing of water uses by initiating the gap

analysis, water balance update and stormwater management plants update.

To date, the water user has invested in the following manner:

WUL gap analysis including specialist studies and water balance compilation; and

Tendering and appointment processes for undertaking this application process

including the Public Participation process and compilation of stormwater

management plan.

Investments will also be made in terms of human resources development through training,

skills development and capacity building.

7.3.8 Strategic Importance of Water Use

The proposed amendment and licensing of existing water uses is required to reflect the

actual water uses taking place at the Duvha Power Station. This project is needed to

continue ensuring compliance with the NWA while generating electricity, which has been

declared by the NWRS as a strategic water use. In addition, this will also ensure use of

water in an environmentally responsible and sustainable manner, promoting the water

conservation and management in the Power Station water use activities.

7.3.9 Failure to Authorise the Water Uses

Failure to authorise the water use will result in Duvha Power Station labelled as non-

complier to the NWA and could results in cessation of Duvha Power Station’s activities. Duvha Power Station’s activities i.e. power generation is a national importance. Therefore,

this will affect electricity supply nationally, with major detrimental impacts on South Africa as

a whole.

02 March 2018 7-7 15008


7.3.10 The quality of water in the water resource which may be required for the Reserve and

for meeting international obligations

DWS is mandated to undertake Reserve Determination in support of each licence

application. However, after consultation with DWS and experience from other applications,

DWS only conduct the study after the IWULA has been lodged.

In light with the above, Duvha Power Station has applied for, and obtained water uses in the

past few years. Refer to Table 7-4. Therefore, it is assumed that some work has already

been undertaken by the Resource Directed Measures (RDM) in determining reserves for the

catchment.

7.3.11 Probable Duration

The total operation or lifespan of the Duvha Power Station is estimated to be until 2044.

However, the lifespan of Duvha Power Station may be extended or decommissioning of the

power station may require authorisations to be in place. It is therefore, recommended that

the water use be authorised for the maximum period as allowed for in the NWA S.28 (1)(e),

namely; 40 years and be subjected to a review every 5 years.

7.4 Licence Condition

Amendments of the conditions stipulated in the existing WUL (Ref no. 24013693) for Duvha

Power Station are required as summarised in Table 7-4.

Table 7-4: Summary of WUL (Ref No. 24013693) conditions requiring amendment

Clause no.

Condition in exiting WUL

Required amendment

Motivation

Appendix II: 1.2.8

The quality of the water containing wastes from the Driefontein Dam shall be monitored for the following constituents by taking grab samples at the indicated frequencies:

Monthly

Electrical Conductivity in (mS/m);

Total Dissolved Solids in (mg/l);

Total Suspended Solids in (mg/l);

Chloride as Cl in (mg/l);

Fluoride as F in (mg/l);

Nitrate as NO3 in (mg/l);

Sulphates as SO4 in

Monitoring for quality of the water containing wastes from Driefontein Dam in terms of condition 1.2.8 to be undertaken only during the period when water has been taken/extracted from the Driefontein dam. Constituents to be monitored to remain the same as stipulated in condition 1.2.8 of the existing WUL.

In terms of authorised water use ‘taking water from Driefontein Dam (3 650 000 m

3/annum (10 000

m3/day))’; Eskom Duvha Power

Station currently has excess water. As a result, they have not been taking water from the Driefontein dam for the past three (3) years. However, they are obliged to undertake monthly monitoring and bi-annual monitoring at Driefontein Dam as per condition 1.2.8 read with condition 3.1 of the existing WUL. An amendment is therefore, required to change the monitoring frequency Eskom Duvha Power Station will inform the Department when they resume taking water from the Driefontein dam and will undertaking monitoring and reporting accordingly.

02 March 2018 7-8 15008


Clause no.


Required amendment

Motivation

(mg/l);

Total Inorganic Nitrogen as N in (mg/l);

Calcium as Ca in (mg/l);

Magnesium as Mg in (mg/l);

Potassium as K in (mg/l);

Sodium as Na in (mg/l);

Iron as Fe in (mg/l); and

Manganese as Mn in (mg/l).

Bi-Annually

Chrome Hexavalent as Cr6 (mg/l);

Chrome Total as Cr in (mg/l);

Copper as Cu in (mg/l);

Cadmium as Cd in (mg/l);

Iron as Fe in (mg/l);

Manganese as Mn in (mg/l); and

Vanadium as V in (mg/l).

Appendix III: 5.4

The impact of the ash return water dam facility on the groundwater and the model of the pollution plume submitted with the application shall be investigated, verified, updated and submitted to the Regional Director in March every year.

Amendment is requested on the frequency of undertaking the groundwater pollution plume as follows:

Groundwater pollution plume modelling to be undertaken and/or submitted in March every two (2) years instead of every year.

The groundwater pollution plume modelling should be undertaken every two (2) years for the following reasons:

Contamination migration in the shallow geology:

The pollution source influences the shallow geology directly below the source of pollution.

Groundwater migration and contamination transport is most rapid on the highly weathered rhyolites, but contamination migration away from the pollution source takes place at a relatively slow rate. The spatial extent of the contaminant plumes in the shallow aquifer remains limited, even at the end of the ashing operations in 2036.

02 March 2018 7-9 15008


Clause no.


Required amendment

Motivation

The dolerite at the intrusion north of the Low Level Ash Return Dam acts as preferential pathway along the weathered sides of the intrusion or as a barrier where it is fresh. The barrier effect is reflected in the uncontaminated chemical results of borehole AB04 just north of the lower ash water return dam.

Contamination migration in the deep geology

Pollution from the upper Ash Water Return Dams, the Coal Stockyard and the Emergency Pan to the deep geology within the fresh un-weathered Karoo rocks is limited. Pollution from the sewage plant and water from the Raw Water Dam has almost unnoticeable effect on the deeper geology.

Contamination migration will also occur along the weathered zones of the intrusive diabase body in the direction of the Witbank dam, the intrusion may acts as a barrier preventing migration to the north.

By 2086 the sulphate concentration of the groundwater that reaches the Witbank dam are predicted to be less than 500 mg/l, and the groundwater will be classified as water of good to marginal quality.

Once the concentration of pollution source is removed from the system (coal stockyard) the pollution source associated with the pollution source become diluted over time.

Model results after decommissioning phase until 2136

The pollution plumes in the shallow and deep geology are expected to continue their migration to the north in the years after decommissioning.

02 March 2018 7-10 15008


Clause no.


Required amendment

Motivation

By 2086 the contaminants that are mobilized along the diabase intrusion are expected to impact the Witbank dam. However, the sulphate concentration of the groundwater that reaches the Witbank dam are predicted to be less than 500 mg/l, and the groundwater will be classified as water of good to marginal quality.

The encapsulation and rehabilitation of Ash Dam was simulated, simply by stopping the additional excess water on top of the ash dam. Lowering of the phreatic surface within the ash dam starts occurring within 10 years after decommissioning. The pollution will be encapsulated in the ash, once the water table has stabilized to natural elevations prior to the creation of the artificial elevated water table within the ash dam.

Conclusion:

The model shows that there is a slow movement of pollution plume from the source of pollution (Ash Dam Facility) to the Witbank dam, and by the time the ground water reaches the dam the water will be classified as good to marginal quality.

Appendix III: 8.1

Strict access procedures must be followed in order to gain access to the property. Access to the Ash Return Water Dam must be limited to authorised personnel employed by the mine contractors only.

Strict access procedures must be followed in order to gain access to the property. Access to the Ash Return Water Dam must be limited to authorised personnel employed by Eskom Duvha Power Station only.

The erroneous reference to “the mine contractors” must be replaced with “Eskom Duvha Power Station “.

Appendix III: 13.1

The information required in terms of the conditions of this license shall be submitted to:

The Regional Director Department of Water Affairs and Forestry Private Bag X11259

The information required in terms of the conditions of this license shall be submitted to:

The Regional Director Department of Water and Sanitation

Amendment required to update a change in the Department of Water and Sanitation’s postal address and contact details.

02 March 2018 7-11 15008


Clause no.


Required amendment

Motivation

Nelspruit 1200

Tel: (013) 932 2061 Fax: (013) 932 2071

Private Bag X 10580 Bronkhorstspruit 1020

Tel: 013 932 2061 Fax: 013 759 2071

02 March 2018 8-1 15008


8 REFERENCES

Airshed Planning Professionals, 2015. Coal mining at Middelburg Mine, Klipfontein

Section: Air Quality Impact Assessment. Report Ref: 13JAW04.

CSIR, 2003. National Landcover dataset attributes. Satellite Applications Centre, ICOMTEX,

Council for Scientific and Industrial Research, Pretoria.

DEA, 2011. National Waste Management Strategy.

DWS, 2011a. Classification of significant water resources in the olifants water management

area: (wma 4) ‐ wp 10383. Report On Socio‐Economic Evaluation Framework and the

Decision Analysis Framework Analysis Scoring System. Report no.:

RDM/WMA04/00/CON/CLA/0311.

DWS, 2011b. Evelopment of a reconciliation strategy for the Olifants River water supply

system. Water Requirements and Water Resources Report. Report Number: P WMA

04/B50/00/8310/6.

DWS, 2013. Classification of significant water resources in the olifants water management

area: (wma 4) - wp 10383. Management classes of the olifants water management area

report. Report no.: RDM/WMA04/00/CON/CLA/0213

DWS, 2016. GN 466. Classes and Resource Quality Objectives of water resources for the

Olifants Catchment.

EMalahleni Local Municipality. 2012. Integrated Development Plan (IDP) 2012/2013 report

Emalahleni Local Municipality.

eMalahleni Local Municipality. 2016. Integrated Development Plan (IDP) 2016/2016 report

Emalahleni Local Municipality.

EnviRoss, 2016. Eskom Generation: Duvha Power Station Wetland Surveys. Report Ref:

Duvha_Wet201606.

Eskom, 2016a. Routine Biomonitoring Network for Eskom 2015/16. Eskom Research,

Testing and Development. Esosystem Management, Sustainability Department. Ref:

RES/RR?15/1776865.

Eskom, 2016b. Integrated Report. 31 March 2016

GCS, 2009. Duvha Power Station Hydrocensus Repo RVN 552.1/958rt.

02 March 2018 8-2 15008


Golder, 2011. Classification of significant water resources in the Olifants Water

Management Area (WMA 4): WP 10383. IUA Delineation Report.

ISO-Q, 2016. Waste Classification and Landfill Assessment for Eskom.

LMC, 2016. Eskom Duvha Power Station: Surface and Groundwater Monitoring Report.

Report Ref: LMC/EDPS/001/16. October 2016.

Zitholele, 2017. Duvha Power Station Stormwater Management Plan. Duvha IWULA

amendment. Ref. No: 15008-45-Mem-001-Duvha PS Stw Management Plan Rev0.

ZITHOLELE CONSULTING (PTY) LTD

Virginia Ramakuwela Tania Oosthuizen

Project Manager Project Associate

Z:\PROJECTS\15008 - DUVHA WULA AMENDMENT\4 REPORTS\46 ENVIRONMENTAL\15008-46-REP-001-DUVHA WULA AMENDMENT-REV0 DRAFT12.DOCX

Integrated Water Use Licence Amendment Application (IWULA ... · Duvha Power Station is located on Portion 0 of the farm Duvha Kragstasie 337, approximately 12 km south east of Emalahleni

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