Telephone: (046) 6248483 PO Box 2407 (083) 6751520 6170 15 August 2012

Our Reference: NRF/NMBWSP -1 Appendix A: Letter by Mr de Wet dated 16 June 2012. B: Ndlambe Bulk Water Supply: Kleinemonde Submission dated 18 January 2012 Dr Cherrie-Lynn Mack Coastal & Environmental Services P.O. Box 8145 EAST LONDON 5210 COMMENT: PROPOSED NDLAMBE MUNICIPAL BULK WATER SCEME PROJECT

INTRODUCTION

1. Notice of an Environmental Assessment dated 30 September 2011 the revised Basis Information Document, project progress report no 5 and the draft Basic Assessment Report dated June 2012 has reference. 2. Members of the project team met with committee members of and Ratepayers Associations on 19 July 2012. During this meeting it was agreed that the members of the project team and the Ndlambe Ratepayers Forum (NRF) will meet on 8 August 2012. The purpose of these meetings was to clarify uncertainties and discuss concerns identified by the members of the NRF. Various questions as well as studies required, were also raised during these meetings. 3. A letter by Mr Johan de Wet, Appendix A, was also drafted to address concerns regarding the project. 4. Attached, for ease of reference, the submission from Kleinemonde Ratepayers Association, Appendix B, dated January 2012. To a large extend none of the issues raised in the submission have been addressed in progress report no5. However, some specific issues are included under Ndlambe East Project Design below. 5. Concerns and questions addressed in both appendices must also be addressed. 6. The following design standards are used in the document. 6.1. Water availability: 750L to 1000L/household/day or 130L/person/day. 6.2. Fire Fighting requirements: Delivery rate >900L/minute. In addition ± 30% of total reservoir capacity to be retained for fire fighting. REPORTS 7. Draft Basic Assessment Report. The Draft Basic Assessment Report dated June 2012 paragraph 4.2 (page 13 and 14).

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7.1. The bulk water capacity (Ndlambe West) does not make provision for 30% of the storage capacity for emergency (fire) which is an immediate to short term concern that needs urgent attention. 7.2. Secondly, the absence of scheduled preventative maintenance on the bulk water system during the last 20 years is by far a bigger contribution towards the degeneration of the existing water infrastructure than the ageing process. 7.3. Figure A.1.6 (page 14) indicates a prediction growth of water demand of 10ML/day (4ML + 6 ML) currently to 23ML/day (9ML + 14 ML) in 2035.The same figure also indicates. Note 1: 14.5ML increased to 18ML in terms of the Revised BID 2: What is correct estimate water demand for Ndlambe West – 6 or 9 ML/day? 7.3.1. Questions. On which statistics is the predicted growth in water demand from 10ML/day (2010) to 23 ML/day (2035) based? 8. Report no 5. Ndlambe Bulk Water Supply Progress report no 5 paragraph 3.6 (page 7) indicates centralized desalination at a cost of R179m. 8.1. Question. Which desalination plant(s) is referred to in the Progress Report no5 paragraph 3.6 (page 7)? PROJECT DESIGN 9. Evaluation. The criterion that was used for the evaluation of the various project options is not visible which gives rise to the following questions. 9.1. Questions. 9.1.1. What are the factors accounting for the acceptance or the preferred alternative, is the preferred alternative based on environmental impact factors? 9.1.2. What criteria were used to decide in closing down existing water treatment works (including re-use). Also refer to Appendix A dated 16 June 2012 paragraph A.b (page 2). 9.1.3. Were the eight alternative options considered by the Department of Environmental Affairs and Tourism? 10. Water Demand. The existing water consumption indicates a usage of 10.2 ML/day (9.5ML/day plus estimated shortages of 0.7KL/day) for the Ndlambe Municipality. Whereas the project suggest a water demand of 20.8ML/day (Ndlambe east 14.5ML +Ndlambe west 6ML per day). See also Appendix A page 1, 2 and 3 under the heading “PROJECT”. 10.1. Question. With reference to the question in paragraph 7.3.1 above, what is reason for the inflated bulk water supply? 11. Project Time Frame. The total time frame of the project is not clear. If the demand of water is projected for 2035 what are the requirements for the short term 2012 to 2015 or medium term to 2025? In the event of a phased implementation approach, the time frame is essential to allow for milestones and the allocation of capital funds to each milestone as well as the visibility regarding funds required for operation. Funds required for operation will include normal corrective and preventative maintenance that will include amongst other the replacement of components such as filters etc. It is believed that the lifespan of a desalination plant varies between 13 to 15 years. At the end of its lifespan, the plant needs to be replaced/refurbished with the possible exception of minor components such as

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electric motors. Considering the expected life of a desalination plant of 13 to 15 years and the projection of the project until 2035, all desalination plants will have to replaced almost twice during the above mentioned period. 12. Storage Capacity. It is uncertain if the existing bulk water storage capacity of the Ndlambe Municipality conforms to outlet control requirements at its reservoirs to accommodate water reserves for fire fighting in accordance with design guidelines/legislation (see paragraph 6 above). 13. Question. Do any of the bulk water reservoirs in the Ndlambe Municipal area make provision for a 30% storage capacity for firefighting? 14. Studies. 14.1. A study to be conducted to determine whether the existing water reservoirs in the Ndlambe Municipal Area conform to storage reserves to satisfy legislation requirements or not. If not, the study must provide design guidelines of future reservoirs. 15. Project Costs. 15.1. Cost Escalation. In terms of the progress report no 5 (page 6) the cost of the project escalated from R484m to R780m, which is an increase of 87% in comparison to the increase of 38% as indicated in the report. 15.2. Question. What is the real project escalation? 15.3. Cost Distribution. Uncertainty exists regarding the distribution of project cost in terms of the various sources and their percentage liability, including the Nngqushwa Local Municipality. The progress report no 5 (executive summary page ii) indicates the co- funding of approximately 40% (± R348m) of the project cost, by Amatola Water and Ndlambe Municipality and do not refer to any cost sharing by the Nngqushwa Local Municipality. 15.4. The running costs of desalination plants are expensive. It is of concern to what extend the project cost has escalated from the original to the present. If this cost escalation is to continue it will eventually become too expensive to end-users to foot the bill - as was the case with the Bigon Africa proposal. What will the envisaged future water cost per liter be? Will consumers be billed for water usage only or will there be a water availability fee irrespective if water was consumed or not? If so, what will the estimated water availability fee be? Refer to question 15.5 below. 15.5. Question. What percentage of the project cost will the Ndlambe Municipality be liable for? 15.6. Electricity. Uncertainty exists regarding the availability of electricity to satisfy the demand i.e Cannon Rocks ± 24Mw, plus Port Alfred/ Nngqushwa Local Municipality ± 58Mw per day. 15.7. Question. Will there be any cost sharing between ESKOM and the municipality regarding additional electricity supply? NLAMBE EAST PROJECT DESIGN 16. Desalination Plant. The option to install a desalination plant at the Dabi Dam which will supply water to Ndlambe, is not only more expensive but also contrary to a basic principle namely the source or supply should be as close as possible to the user. If the Dabi Dam RO plant is built so far from Port Alfred, who will maintain and run it? To operate and control it from Port Alfred will be difficult and costs will be high. If the desalination plant is constructed at or near Port Alfred would it not be more cost effective to control and

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operate? Why pump water away from Port Alfred to be treated and then back to the point of consumption? Also refer to Appendix A paragraph B.a and b (page 3). 17. Water Losses. The loss of water experienced in the Port Alfred and Bathurst water infrastructure is of great concern. Should this problem not be addressed first, it would result in an increased loss of potable water. 18. Water reticulation/storage: Kleinemonde. The following issues have not been addressed in the report. 18.1 Water reticulation - Appendix B paragraph 2.1, 4.3 and 4.4. 18.2 Water storage - Appendix B paragraph 2.2 and 4.6. 19. Sources. 19.1. It is uncertain if water from the Sarel Hayward dam will also be subjected to a desalination process. Also refer to Appendix A paragraph B.c.d (page 4 and 5). 19.2. Appendix B paragraph 3 (3.1 and 3.2) addresses augmentation options to the existing water supply to Kleinemonde. 19.2 Apart from the above sources it has been brought to our attention that in the Fish River Light house area, a high yielding borehole was drilled for the proposed Carpe Diem development. This development was not approved but the possible use of this borehole should be investigated.

19.3 The progress report no 5 proposes the closure of the Kleinemonde water treatment works and the use of the pipeline from Wellington dam to supply potable water. It is unclear what the source of this potable water is. It must also be born in mind the diameter of the existing pipeline from Wellington dam is only 70mm. It is also not clear from the report how will Kleinemonde ultimately be fed, from the BWRO plant in Port Alfred? If so, what will the cost of such a pipeline be compared to supplementing existing supply with boreholes and beach extraction? 20 Questions. The following questions arose from the above 20.2.1 Why build the desalination plant at the Dabi Dam and not close to Port Alfred within the Ndlambe Municipal area? 20.2.2 If the desalination plant is to be used to supply consumers outside of Ndlambe will the other Municipalities contribute to the initial costs, running and maintenance costs thereof? 20.2.3 Have the options as suggested in Appendix B paragraph 3.1 and 3.2 been investigated? 20.3 Studies. 20.3.1 A study to determine the magnitude of water loss in the Port Alfred and Bathurst water infrastructure is required. 20.3.2 A study to investigate the Shaw Park area as possible source for underground water is required. 20.3.3 Will water from the Sarel Hayward dam also be subjected to a desalination process? 21 Project Operations. The responsibility and inventory holding of the desalination plant at the Dabi Dam needs clarification.

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NDLAMBE WEST PROJECT DESIGN 22 Desalination Plant at Cannon Rocks. 22.2 The existing desalination plant at Cannon Rocks is a sea water reverse osmoses plant and therefore any future upgrades or modular extensions will also require a sea water plant instead of a brakwater plant. The previous brakwater plant that was installed during 2007/8 failed after 90 days of operation, resulting in a loss of R3.7m. The design of a brakwater desalination plant indicated to be amongst other, the primary reason for the failure. Therefore to deliver 6ML/day will require a seawater plant with a design delivery capacity of ± 12ML which will dispose ± 6ML brine per day. Such a plant will require ± 48Mw electrical supply for operation. The availability of a sufficient electricity supply, is seriously questioned. 22.3 A brakwater plant must be able to deliver 8ML/day to deliver 6ML potable water and will dispose 2ML brine per day and will require ± 32Mw for operation. 22.4 The effect of brine will pose a threat to the current sea life at the coast opposite Cannon Rocks that is not acceptable by the residents of Cannon Rocks. Note 1: Above figures are based on the deliver capacity of a seawater plant of ±50% potable water and ±50% brine disposal, and a brakwater plant of ±70% potable water and ±30% disposal of brine respectively. Note 2: Electricity demands are based on the requirement that a desalination plant with a delivery capacity of 1ML/day will require ± 4Mw electricity. 23 Underground Water. The existing as well future desalination plant will abstract water from underground sources. The production boreholes in Cannon Rocks and Boknesstrand must be able to deliver a minimum of 12ML water per day (seawater plant) per day. The above average rainfall experienced over the last 24 months in the water catchment areas will have a direct impact on the quality of the underground water sources. The temporary ‘improved” water quality may indicate acceptable water quality to justify a brakwater plant. Incorrect water quality statistics also gave rise to the failure of the previous brakwater plant. The availability of this magnitude of water is questioned. 23.2 Question. Does the Boesmansriver area and the Boknesstrand/Cannon Rocks area share the same underwater source? 23.3 Study. If previous studies are not available, a new study is requested to determine if the area between Cannon Rocks and Boesmanriver share the same underground source. 24 Water Treatment Works. The existing Water Treatment Works – re-use (WTW) at Alexandria is not visible in the progress report. Notwithstanding that, the reason for the decommissioning of the water works is unknown, why is this water works excluded from the project (quick win). 25 Desalination Plant at Boemansriver. Progress report no 5 refers to the desalination plant at Boesmansriver as a brakwater plant. To the best of our knowledge the plant is a seawater plant. Clarification is necessary regarding the type of desalination plants at both Cannon Rocks and Boesmansriver due to the difference in delivery capacity and brine disposal as well as the demand for electricity. 26 Question. What type of desalination plants (seawater or brakwater) will be used at Boesmansriver and Cannon Rocks respectively? 27 Quick Win. 27.2 According to water usage figures there is not a vast difference between the water consumption of Alexandria (1.7ML/day) and the collective use of Kenton-on-Sea,

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Boesmansriver and Marselle (1.8ML/day). This phenomenon indicates serious water leakage of the Alexandria municipal water supply system, estimated to be in excess of 30%, compared to an acceptable loss rate of 10%. The quick win will therefore not relieve the water shortage, but rather result in an increased loss of potable water. 27.3 It must be noted that the desalination plant at Cannon Rocks can only supply a maximum of 300KL/day to Alexandria, providing the plant operates for 24 hours per day continuously. Planning at the maximum capacity, without any safety factors, may be regarded as short-sighted planning. 27.4 The proposed quick win for water to Alexandria will create expectations which will lead to confrontation. What will prevail, shutting down of water supply to Alexandria or “sharing” of water for longer periods than experienced in the past, especially during high demand periods? The identification and evaluation of the possible effects of the quick win is questioned. 28 Grants Valley. The source of the water supply to the Grants Valley development (next to the Eco Estate development) was raised as a concern. It is uncertain where the water to Grants valley will be piped from, as the design for Eco Estate development only made provision to satisfy the demand for water to the Eco Estate. Clarification is therefore required regarding the water supply to the proposed Grants Valley development. 29 Other Demands. Progress report no 5 does not address the water demands of nor that of the ± 500 new houses in Ekuphumleni. 30 Water Losses. The loss of water experienced in the Alexandria, Marselle, Klipfontein and Harmony Park is of great concern. Should this problem not be addressed first, it would result in an increased loss of potable water. The main outlet valves at the reservoirs at Alexandria are currently being closed on a nightly basis in order to enable the reservoirs to fill to an acceptable level. This is required to ensure an acceptable water supply for the following day. 31 Question. The following questions arose from the above. 32.1 What is the yield of production boreholes at Cannon Rocks and Boknesstrand? 31.2 What is the sustainable yield of the production borehole at Cannon Rocks and Boknesstrand? 31.3 What is the available electricity supply, for consumption by the desalination plant? Proof is required whether ESKOM can provide the increased demand for electricity? 31.4 What are the water quality levels that will be used for design parameters of the desalination plant? 31.5 Does Alexandria really experience a water supply shortage at present? 31.6 Should the “quick win” not rather investigate and restrict the water losses of the water infrastructure system of Alexandria with special reference to the water supply line from the “fishkraals,” instead of a short term supply from the existing desalination plant at Cannon Rocks? 31.7 From which water supply source will Grants Valley’s water demand be satisfied? 31.8 Are Kasouga and Ekupumleni included in the project?

31.9 Studies. The under mentioned independent specialised studies are requested. Generalised statement/answers or deductions from related studies or modelling, to address the above concerns will not be acceptable to the community. Real time studies must focus on the specific geographical, climatic and marine conditions at the proposed

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brine disposal area, The studies must determine the limit of the brine that may be safely released into the sea. This limitation will restrict the quantity of water that can be provided. 31.9.1 Determine the long term effect of 8ML of brine per day on the marine life at the disposal point at Cannon Rocks and other effected areas. 31.9.2 Determine the effect of the prevailing westerly and often gale force winds at the disposal point at cannon Rocks and the surrounding area. 31.9.3 Determine the real water loss between the "fishkraals" and the Alexandria reservoirs and update/amend the quick win accordingly. 32 A study to determine the magnitude of water loss (water wastage) in the Alexandria, Marselle, Klipfontein and Harmony Park is required. SUMMARY 33 Ratepayers Associations in the Ndlambe Municipal Area are concerned about the apparent growth in water demand and the associated costs as projected by the project. It seems that the project fails to determine the real magnitude of existing water losses and wastage currently experienced and therefore focusing on the treatment of the symptoms rather than the actual demand for water. The Associations are also concerned that decisions may not always be based on realistic water demands and futuristic projections, sound and logic environmental and engineering principles to ensure that the money of the ratepayers is well spend. Poor decisions will have a detrimental financial impact on the ratepayers in the Ndlambe Municipal area.

T Y·COCKBAlN CHAIRMAN: NDLAMBE RATEPAYERS FORUM

Alexandria Agricultural Association; Alexandria Ratepayers and Residents Association; Bathurst Ratepayers Association; Boknes Ratepayers Association; Bushman's River Mouth Ratepayers Organisation; Cannon Rocks Ratepayers Association; Kasouga Residents Association; Kenton- on-Sea Ratepayers Association; Kleinemonde Ratepayers Association; Port Alfred Ratepayers and Residents Association

- JJoohhaaann ddee WWeettt Page 1 8/13/2012 [email protected]

Johan de Wet P.O. Box 68 Cannon Rocks 6186

16 June 2012 APPENDIX A TO COMMENT BULK WATER PROJECT: DD. 15 AUGUST 2012

Members of the PSC – Ndlambe Bulk Water Supply.

Ndlambe Dir. Infrastructure, Amatola, Members of RBIG committee, DWA.

Gentlemen

NDLAMBE BULK WATER SUPPLY:- Fish to Port Alfred.

I followed the project with great interest, not only as a ratepayer, but also as engineer who contributed to Infrastructure projects in Ndlambe.

Not being privileged to participate in the project PSC, I decided to write this report as an attempt to make a written contribution to the project.

I wish to deal in this document with the project under five headings being:-

A. The Project B. Ndlambe East C. Ndlambe West D. Project Summary E. Conclusions and suggestions

A. THE PROJECT

This project is one of the biggest projects to be implemented in Ndlambe. The funding model of the project suggests that apart from RBIG DWA funding, a substantial contribution will come from the Ndlambe tax base of which the detail is still unclear. Implementation decisions are therefore of outmost importance as it will financially affect all people in Ndlambe.

a. Price Variance The indicated 38% increase between the initial budget of R464million (last year) and the present estimate of R869million is a misrepresentation of the escalated amount. The correct price escalation amounts to 87,2%. Project estimate differentials of such magnitudes indicate towards complete incorrect initial project definitions or alternatively towards un- informed cost estimates.

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 2 8/13/2012 [email protected]

Needless to say that such order cost variations in a timespan of one year does not confide confidence in the project understanding and implementation process of the implementing agent.

I accept the fact that water purification utilising Membrane technology has a definite function in the South African water supply systems, but do not accept the fact that conventional and surface water resources should be discarded giving preference to Membrane technology purification processes.

b. Perseverance of existing water sources: It is my experience (and I believe DWA is of the same opinion) that increasing the present water supply infrastructure of an institution, preference should be given to the re-use of existing infrastructure as far as possible. This project aims to decommission all existing WTW’s, and to replace purification processes with Reverse osmosis technology. This decission to my mind an incorrect decision.

I wish to offer the following reasons for the statement above: i. A RO processes is a high technology process that requires full-time well trained personnel.

ii. High energy power is required by the RO which in this particular proposal is not in line with national green energy objectives.

iii. All core components that are essential for the Reverse Osmosis process are imported rom overseas. (High pressure motor and pump, Membranes, Membrane vessels and other equipment.)

iv. The dependence on imported spares and replacement parts pose a sure risk on sustainable water supply.

v. Apart from natural drought conditions that Ndlambe suffered during 2010/11 where resources were tested to its limits, no critical shortages of a permanent nature ever threatened the Municipality. The 2010/11 drought was a pointer for Ndlambe that preferential focus is required on the water supply system. This 2010/11 pointer triggered projects such as the initial Glen Melville (Bigen) scheme and the Amatola Sandile Dam scheme.

c. Ndlambe present water demand: The following daily volumes are supplied from mainly surface and borehole resources (except

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 3 8/13/2012 [email protected]

Cannon Rocks and Bushmans/Kenton which are supplied by RO)

i. The present consumption of Port Alfred is in the order of 4,8ml/day (Including the dune extraction), Kleinemonde approx. 0,3ML/day, Bathurst 0.45Ml/day, Alexandria 1,7Ml/day, Cannon Rocks/Boknes 0,45Ml/day, Kenton/Bushmans 1,8ML/day which totals to 9,5ML/day

ii. Known water supply shortages existing in:- Alexandria approx. 0,3Ml/day, Bathurst approx. 0,25Ml/day and in Kleinemonde approx. 0,15ml/day, which totals to 0,7ML/day

iii. Thus, Ndlambe’s present total demand is 10.2ML/day

B. NDLAMBE EAST

Ndlambe East is considered to include Kleinemonde, Port Alfred and Bathurst with a present total supply capacity of purified water of 5,55ML/day and a known estimated supply shortage of approx. 0.4ML/day. The required demand is therefore approx 5,95ML/day at present.

The proposed Ndlambe Bulk water scheme suggest to Decommission all three(3) of the present surface water purification plants and to replace these plants with BWRO plants able to produce 14,5ML/day from two(2) BWRO plants. These plants appear to be erected at Port Alfred and Dabi dam, situated EAST of the fish river.

At this point of the report it needs to be noted that all water produced with Membrane technology needs to be stabilized – so Calcium and other minerals needs to be commercially procured and added. This action can be viewed in a sense that the product water produced by Reverse Osmosis is TOO pure and needs to be “contaminated” with other minerals.

The following controversial questions come to mind:-

a. Why is it necessary to pump Fish River semi sea-water first 13km away from Port Alfred to Dabi dam and then gravitate 57km back to Port Alfred?

b. Why is the 1st BWRO plant that will produce 50% of the planned future Port Alfred water purification situated OUTSIDE the Ndlambe Municipal demarcated area and positioned in the not WSP Ngqushwa district?

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 4 8/13/2012 [email protected]

i. Will there be maintenance agreements between Ndlambe and Ngqushwa? ii. Which Municipality will carry the plant on their asset register? iii. Will Ngqushwa benefit from the RO water? iv. If so, will Ngqushwa provide co-funding? v. Control from Port Alred will be difficult

It is known that energy consumption of a BWRO plant is less than a SWRO plant. The price difference per kilo litter of water produced should discount against water transport pipelines, ease of maintenance (supervision) transport of chemicals. Engineering support services is an important factor and I doubt if such services are available in the Pruddoe area.

c. Although RO Purified water is gravitated 57km far from the Dabi dam to Port Alfred, it can be argued:- a. Why convey “treated-sea water” (13+57) = 70km far (Fish-Dabi-Port Alfred) while “treatable-seawater” is available in Port Alfred? b. If water was extracted from the upper Kowie River, purified via the RO process, the pump line would be Minimal – not even 1km. (I did this calculation previously) (The Bushmans River is also a possible source)

c. Why not extracting semi-sea water from the Kowie River and purify such water via an RO process? RO water can be Blended with the present water supply to obtain optimum mineralisation instead of expensive commercial remineralisation of the RO water? RO purified water from the Kowie River can be mixed with the present conventionally purified Sarel Hayward water, which has a higher content of mineralised water from the Sarel Hayward dam or upper Kowie. This is a feasible approach because it eliminates the additional cost of running expenses or remineralisation of RO water. (I did this exercise also in the past)

I believe the project methodology and economic viability has not been thought through properly.

Such an approach will eliminate the construction of ONE of the RO plants, will utilize 100% of available Port Alfred surface water and will save on electric power and chemicals required for RO treatment. It will also save on ONE brine disposal structure to be constructed in the sea.

d. I fail to understand why the existing water supply needs to be treated via a 7ML BWRO plant as suggested for Port Alfred. If it is essential, for whatever unknown reason, to treat all the present surface water supply to Port Alfred with a RO process, the following

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 5 8/13/2012 [email protected]

must be observed:-

i. The RO treatment will waste between 25% and 30% of the present surface water supply from Sarel Hayward and dune extraction as brine waste. The input volume of raw water MUST therefore be not less than 8,4ML/day. Continuous extraction rate of this volume of water is simply NOT available from the present resources and if it can be “pushed” via the existing infrastructure it will mean that the present surface water available for Port Alfred will be REDUCED with 25% to 30% due to RO waste. - Please bear in mind that, after the RO processing, the water must be re- mineralised again.

ii. The above implies that Sarel Hayward’s effective usable raw water capacity will reduce by 25%-30%.

iii. WHILE:-

iv. 100% of available surface and borehole water can be blended with RO water eliminating costs of remineralisation and eliminating the reduction of the Sarel Hayward capacity by RO waste. (I have done these calculations previously)

I am of the opinion that the Ndlambe East proposal lack a clear understanding of the present status and that the proposal has not been thought through to optimise water resources as well as project costs.

I have a serious concern to construct a BWRO for Fish River water treatment (unless the extraction point is much higher upstream than I anticipate). A BWRO will be able to function successfully under the proposed conditions where fish river water meet certain salinity standards, but will still waste approx. 25% of the available water, which I note must be piped another 14km to the sea.

Should the 70km pipeline be disbanded, a small SWRO can be installed for supply to Kleinemonde.

C. NDLAMBE WEST

As today, the total water USAGE in Ndlambe West area is as follows:-

• Alexandria 1,7ML/day (From Fish kraals) • Cannon Rocks/Boknes 0,450ML/day and in season 1,1ML/day (RO) • Bushmans/ Kenton 1,8ML/day and in season 2,2ML/day

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 6 8/13/2012 [email protected]

Total 3,85ML/day

In season Ndlambe West demand 5ML/day for a relative short period.

With the exception of Alexandria, the west has enough water out of season. In season, Cannon Rocks needs to check demand carefully.

The proposed construction of a 6ML BWRO plant in Cannon Rocks does not make sense. Kenton/Bushmans is self-sufficient and do not need any water from CR. (their plant is 1,8ML plus 1ML from the Diaz dune fields in times of shortages) The plant at Bushmans offers potential for future extension.

Even if ALL the water requirements of Alexandria (1,7ML/day) and ALL the water to CR/Boknes (0,45ML/day) are to be supplied from the proposed new CR RO plant, the plant will still be oversized by 3,85ML/day.

Despite the proposed 6ML reservoir to be constructed in Cannon rocks, it will mean that the plant will be switched off for an average of 2/3rd of the time, which is the worst condition a RO should work under.

Again, just to put these numbers in perspective: Port Alfred and all the surrounding residential areas’ daily water consumption at the moment is in the order of 5,55ML per day.

It needs to be noted that if pure RO water is supplied to Alexandria as proposed, the water supplied to Alexandria needs to be mineralised. Decommissioning of the 1,7Ml/day from the fountains, Fish Kraal and dune field supply will be a wrong decision because this supply again offers an ideal opportunity for mineral stabilisation of RO supply from Cannon Rocks.

Statement 1: The Cannon Rocks RO is completely oversized which will be detrimental to the operation.

THE TECHNOLOGY PROPOSED TO BE USED

I do not have access to the intended detailed technology to be used, but the term BWRO indicates internationally a Brackish Water Reverse Osmosis

If the design is around the Brackish RO membrane technology, the plant will fail.

The only membrane technology that will work successfully in the Cannon Rocks area is SWRO technology where the term SWRO refers to Sea Water Reverse Osmosis.

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 7 8/13/2012 [email protected]

Statement 2: If the plant is designed on the lower pressure BWRO technology the plant operation will fail.

It will be a big mistake if a theoretical blending conductivity was calculated based on information from newly drilled borehole yields. I recall a DWA report done some 20 years ago investigating the Cannon Rocks fresh water aquifer. I trust this report or such documents have been consulted.

ELECTRICITY SUPPLY

It appears that no one gave this a thought as power line upgrade is not provided for in the project cost. CR is at “the end of a grid” and prior to the upgrade of the Eskom Dekselfontein leader, Cannon Rocks will always suffer with low voltage and unplanned power breaks.

Just to put the issue in context: The community of Cannon Rocks and Boknes use approx. 2,8Mega watt.

The proposed plant will use 24mega watt.

Statement 3: Implementation of the plant will not be possible without major upgrade of the Eskom infrastructure. (Dekselfontein upgrade)

Statement 4: There is NO possibility that the plant can be implemented by the end of 2012.

BRINE DISPOSAL

Depending of the membrane technology Amatola is going to use, the brine effluent can vary from 2 million litres per day to 6 million litres per day.

This will trigger a full EIA related around marine issues in a marine demarcated area.

The Cannon Rocks residents must be very aware of this environmental impact. I do not believe SANPARKS will allow such disposals in the protected marine park area.

Statement 5: The promised timescales is unachievable and the community will be led into further project price increases due to DEDEA time delays.

THE PRESENT SITE

The present site will be too small to accommodate a 6ML plant and the required reservoir capacity.

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 8 8/13/2012 [email protected]

Noise pollution should be considered very carefully.

PRICE OF WATER

At present Alexandria extracts from the Fish Kraals at a relatively cheap cost of operation. If Alexandria will be supplied from Cannon Rocks in full, it will mean an additional cost to water production of approx. R3.00/m3 or R5 100.00 per day (present cost)

Alexandria has a lot of indigent consumers who’s water is subsidised and I believe any actions to increase the cost of already subsidised water is an incorrect decision. I support the quality upgrade of the present water quality to Aleandrea to meet DWA standards by a blending process with RO water, but to deliver “new” RO water with drastically increased production costs is an incorrect decision.

The cost of water for Cannon Rocks will ESCALATE simply because the present plant is built to provide for optimum cost of production (Figures available from me).

The new 6ML plant will be an over designed plant and the present residents will need to pay for the benefit of the future users.

The calculation is simple: if 6ML can be sold per day, the cost will be optimum.

If only Alexandria and CR/Boknes consumption can be sold, users need to pay for the access capacity.

The existing plant is designed to be doubled-up as the population grows and I strongly believe that a 6ML plant will add additional costs to the cost of living of the present Cannon Rocks residents.

D. PROJECT SUMMARY

As a summary, the following should be noted:-

a. The salinity range for successful operation of brackish water reverse Osmosis plants is not clearly defined. I am of the opinion that even if saline water is extracted from the Fish River, the desalination design will require the usage of Sea water desalination technology.

My reasoning is based on the following:- i. Unless the implementing agent studied the salinity variance spectrum of the extraction point in the Fish River and can

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 9 8/13/2012 [email protected]

guarantee that the variance of the salinity spectrum will fall within a 95% statistical probability of brackish membrane operational limitations, the plant will fail.

I doubt if such an analysis was done as it will involve the full 365 day cyclic behaviour of sea tidal action, which is the determining factor of salinity levels in rivers where salinity increase due to sea water influx and tidal actions.

b. 6km upstream from the Fish River Mouth there is an elevation differential of 5 meters from sea level. At this point, tidal action will undoubtedly have an influence. As I am not privileged to the design information, I cannot make sensible comments on water quality, but if the extraction point is in this vicinity, you can expect reduced live expectancy of membranes in the BWRO plant. In Cannon Rocks we had the experience that a BWRO plant failed completely after 90 days of operation to such an extent that it was rebuilt completely.

c. The absolute maximum lifespan of a Reverse osmosis plant is 15 years. A realistic lifespan is 10 to 12 years. The financial model must provide for complete replacement of the RO plant after 15 years.

d. I do not believe that a BWRO will be the solution to treat Fish River water and it will proof not to be the ultimate solution to the scheme. I believe it will proof that SWRO is the desired approach should this RO production plant be thoroughly investigated. In such a case, the construction of a SWRO plant at the Fish River makes no sense at all and will be a waste of taxpayers’ money. It should be noted that a BWRO plant is technically NOT UPGRADABLE to a SWRO plant as all pumps, all pipes and pipe qualities, filters and even the complete electrical control will require replacement.

e. Some time ago, Ndlambe Municipality asked me to investigate a 2,5ML SWRO plant to be constructed on the Kowie River to augment the present water supply threads in Port Alfred. I assisted in preparing full documentation and tenders were obtained for well under R100million. I still believe that was the correct decision taken by the Municipality as it optimises water consumption on the medium term in Port Alfred.

The project was based on a 15 year Build, Operate Own and Transfer basis and the Municipality would be the supplier of Electricity ONLY with a guaranteed water volume procurement of the processed water. All operational costs were borne by the

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 10 8/13/2012 [email protected]

operator. Prices of as low as R6.25/kl was offered by operators.

E. CONCLUSIONS AND SUGGESTIONS

I wish to propose the following project approach.

a. Discard the 70km pipeline altogether.

Ndlambe East

b. Install a 0,5ML/day SWRO plant in Kleinemonde as a modular unit that can be increased if and when required.

c. Install a 5ML/day SWRO plant extracting from the Kowie River and blend the present supply from Sarel Hayward with RO production to produce good quality palatable water.

i. This will reduce the present extraction from Sarel Hayward and will restore the ecosystems in and around the Sarel Hayward Dam, ideally situated for eco-tourism development. ii. It will ensure a sustainable water source where both Sarel Hayward and the SWRO can be relied upon as a source.

d. Connect Bathurst as proposed in the Amatola document via the newly installed pump line.

Ndlambe West

e. Build a 5ML reservoir at Cannon rocks.

f. Connect a pump line from Bushmans RO to Cannon Rocks RO and then to Alexandria

g. This action will make available all excess RO water production that is “produced out of season” by both RO plants and can be used to augment the Alexandria shortfall. (I did such a study in 2010).

h. RO water to be blended with Alexandria water presently extracted from the Fish kraals, dune fields and fountains.

NOTE: The capacity of Cannon Rocks as well as the Bushmans plants can be extended should demand rises in either 3 of the towns.

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) JJoohhaaann ddee WWeettt Page 11 8/13/2012 [email protected]

As a concluding remark: I am concerned that the proposed scheme will have the impact that it will effectively reduce the yield of the present surface sources in East Ndlambe. The project carries a high risk to sustainable water supply and will doubtless contribute to escalation of water costs due to its 100% dependence on electric power. The BWRO in Cannon Rocks is oversized and will fail in operation.

I suggest that a value engineering exercise be done on the project to ensure that the Ndlambe taxpayer receives value for money.

This report is submitted to you as a taxpayer, but also in my capacity as professional engineer who has the ethical duty to report on issues which to his mind can have negative or detrimental effects on communities already suffering from lowering levels of service delivery.

Regards

Johan de Wet Pr Eng. BSc.,B.Eng.(Civil) DBSA(DF): Project Manager/Technical Expert Cell:082 578 3111

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch)

J.A. de Wet PrEng.B.Sc.,B.Eng Civil (Stellenbosch) Appendix B to Comment Bulk Water Project Dated 15 August 2012

NDLAMBE BULK WATER SUPPLY: KLEINEMONDE SUBMISSION

1. Present supply (See attached drawing) 1.1. Mount Wellington dam The main source feeding the water treatment works (WTW) situated in Island Beach North via a 75 mm diameter pipeline. The design capacity from this source (Wellington dam, water treatment works) is 360 kl/day. 1.2 Boreholes Four boreholes are utilized. The new borehole, connected up in 2011 is high yielding. The older three boreholes are low yielding. 2. Problems with existing supply 2.1 Wellington dam supply Although the design supply from this source is 350 kl/day, this can only be achieved with the booster pumps switched on at Wepner’s farm. In practice it was found that that under these circumstances (using the booster pumps), the WTW could not handle the flow for the floc process to be successful. Therefore, water from the dam is gravity fed to the WTW to reduce the inflow. It has also been found necessary to further reduce the inflow to the WTW by partially closing the inflow valve at the WTW in order for the floc process to be more successful. It is estimated that the supply capacity is approx. 250 kl/day from this source. 2.2 Water quality The water quality from Wellington dam, presently our main source, is poor with a high total dissolved solid count which places it into the high end of SANS241 classification for class 2 water, which is unacceptable. 2.3 Water reticulation Presently the Island is fed directly from the WTW when water is being pumped to the reservoir. Outside this period, water reverse flows from the reservoir along the same pipeline to supply the Island. 2

In the event of the amount of floc injected is not monitored meticulously, or in the event of a breakdown of the floc pump (what has happened), dirty water could be circulated directly to the Island residents. Kleinemonde East residents are connected directly to the reservoir, and are, therefore, to a large extend buffered from this as the reservoir is also fed from boreholes. Similarly, any over/under dosing of chlorine injected at the WTW will also impact on Island residents before it is experienced by Kleinemonde East residents. It should also be mentioned that water reticulation on the Island are by means of asbestos/cement pipes which have been in use for approximately twenty years. 2.4 Reservoir The present usable capacity is 900 kl, which with the growth of Kleinemonde, is not sufficient. A further problem is that the height of the reservoir compared to the high lying areas of Island Beach North is not sufficient to give adequate pressure. This worsens when the level of the reservoir is not maintained at full level. It should be noted that according to the 2006 Spatial Development Framework, future expansion for Kleinemonde will be to the north of the existing Island Beach North, which will make the present reservoir not inadequate due to insufficient capacity and water pressure.

3. Augmenting the existing supply

3.1 Ground water ( Boreholes) It is not clear if exploration for this source has been completed in our area. However, we would like to point out that in the Shaw Park area (approx. 15 km from Kleinemonde), there are indications of high yielding ground water. If further information is required, it is suggested that Johnathan Bradfield, a farmer in that area who knows the area very well, be contacted on 082 772 0398.

3.2 Beach extraction It is well known amongst Kleinemonde residents that at Clayton Rocks (approx. 2 km east along the beach from Kleinemonde), fresh water leaks continuously into the sand/sea. 3

See attached report by Rhodes University done in 1985. This area has not been visited recently to verify the amount of leakage taking place. 4. Submitted for consideration: 4.1 Present water treatment works be upgraded to handle the design flow of 350 kl/day; 4.2 The water supply (present and future additional sources) must be to SANS241 standards; 4.3 Water reticulation to the Island be changed to feed only and directly from the reservoir; 4.4 The cement/asbestos pipes used on the Island be replaced; 4.5 Possible water sources in the Shaw Park and Clayton Rocks area be investigated; 4.6 Increase in water storage capacity (reservoir), taking into to consideration the problems with water pressure.

Prepared by the Kleinemonde Ratepayers & Residents Association

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APPENDIX IV

Geography Department • RHODES UNIVERSITY - GRAHAMSTOWN

P.O. B0x 94 Grahamstown 6140

Mr. Steyn Rivett Carnac Sun Trail Resorts Limited P.O. Box 1007 CAPE TOWN 2 August 1985

Dear Steyn

AUGMENTATION OF WATER SUPPLIES TO KLEINEMONDE

With reference to our meeting at Kleinemonde last week I submit the following recommendations for obtaining additional groundwater supplies.

1. The extent of groundwater development of Seafieid cannot reasonably be increased because the boreholes and beach sources are yielding at close to maximum potential. Further drilling or excavation would result in "robbing Peter to pay Paul" in terms of the likely, storage potential,

2. Extension of the beach sources eastward would appear to be the most obvious solution to supply augmentation but the owner of the land is not prepared to allow any engineering works or servitudes across his property.

3. From a geological perspective the quartzite ridge at Clayton's Rocks represents the most probable source of reliable and permanent supply close to Kleinemonde. Groundwater associated with fractured quartzite is typically of good quality and when large fracture systems can be intersected, boreholes in quartzites may produce high yielding supplies.

There is a- continuous seepage of freshwater into the sea at Claytons Rocks with an observed surface flow of at least 2l/sec ;and probably a greater volume unobserved flowing into the sea. Much of the water is probably derived from the dunes but a proportion is likely to be related to the ridge of quartzite which extends inland for many kilometers.

It is recommended that exploration drilling be undertaken in the rock formations of the Witteberg quartzite ridge. In order to assess the potential of the quartzite aquifer it is suggested that exploration borehole(s) be drilled at the position(s) marked on the attached map. Drilling should be continued to 100 m and if yields'on drilling appear adequate 72 hour pumpng tests are suggested to establish yield reliability.

4. The establishment of borehole(s) close to the coast road would not only be an advantage from a supply reticulation point of view but also from the point of maintenance. /2

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I have spoken to a local drilling contractor who is available to undertake exploration drilling at a rate of R30 per m. The contractor is available almost immediately.

Yours sincerely

ANDREW STONE

Cherie-Lynn Mack

From: Steve Landolt Sent: 02 August 2012 01:43 PM To: [email protected] Cc: CasperBrink ([email protected]); Muller, Nikite ([email protected]); Jacobus Kriegler; Louis Koen; Werner Gous; Schalk van der Merwe (IS); Stephan Kleynhans; Alan Carter ([email protected]); Cherie- Lynn Mack ([email protected]); Louis Fourie; Goossens, Eunice ([email protected]) Subject: FW: Scan from a Xerox WorkCentre Attachments: img-802110224-0001.pdf

Dear Mr Venter,

Please find attached for your forum's consideration a letter drawn up by ourselves on behalf of Amatola Water and the professional team in response to the comments submitted by yourselves on the proposed Ndlambe Bulk Water Supply Project.

Please feel free to contact me should you require any further information or detail.

Regards

Steve Landolt I PrEng, BSc Hons Technical Director I Professional Engineer (Civil) I Aurecon T +27 43 721 0900 I M +27 82 567 7687 E [email protected] No 1 Pearce Street, Berea, East London I South Africa aurecongroup.com

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J28.5.6‐NBWS‐Existing Reservoir Parameters

Summary Potable Storage

Current Future 2025 2035 Current Future Current Shortfall Future Shortfall Future Current Current Future Future Future Future Phase 1a Phase 1b Phase 2 Current Current Shortfall Current (including Future Theoretical (including Actual Town Required Shortfall Required Theoretical Actual Actual (current (2025 Phase 1 (2035 Demand Capacity [pos‐ Shortfall Fire Demand Shortfall Fire Shortfall Capacity (rounded) Capacity Shortfall Shortfall Shortfall shortfall) shortfall) shortfall) shortfall] Requirem (rounded) Requirem (rounded) ent) ent) Kleinemonde 0.22 M/day 1.05 Ml 0.44 Ml ‐0.61 Ml 0 0.83 Ml 1.00 Ml 0.51 M/day 1.02 Ml 0.58 Ml 1.00 Ml ‐0.03 Ml 0 1.41 Ml 1.50 Ml 1.00 Ml 0.50 Ml 1.50 Ml 0.00 Ml Port Alfred 5.92 M/day 6.08 Ml 11.84 Ml 5.76 Ml 5.76 Ml 7.20 Ml 7.50 Ml 12.40 M/day 24.80 Ml 12.96 Ml 13.00 Ml 18.72 Ml 18.72 Ml 20.16 Ml 20.50 Ml 7.50 Ml 6.50 Ml 14.00 Ml 6.50 Ml Bathurst 0.93 M/day 0.00 Ml 1.86 Ml 1.86 Ml 1.86 Ml 3.30 Ml 3.50 Ml 1.30 M/day 2.61 Ml 0.74 Ml 1.00 Ml 2.61 Ml 2.61 Ml 4.05 Ml 4.50 Ml 3.50 Ml 0.50 Ml 4.00 Ml 0.50 Ml Kenton‐on‐Sea/ 2.49 M/day 9.60 Ml 4.99 Ml ‐4.61 Ml 0 0.00 Ml 0.00 Ml 4.74 M/day 9.48 Ml 4.49 Ml 4.00 Ml ‐0.12 Ml 0 1.32 Ml 1.50 Ml 0.00 Ml 1.00 Ml 1.00 Ml 0.50 Ml Bushman's River Cannon Rocks/ 0.68 M/day 0.93 Ml 1.37 Ml 0.44 Ml 0.44 Ml 1.88 Ml 2.00 Ml 1.69 M/day 3.37 Ml 2.00 Ml 2.00 Ml 2.44 Ml 2.44 Ml 3.88 Ml 4.00 Ml 2.00 Ml 1.00 Ml 3.00 Ml 1.00 Ml Boknesstrand Alexandria 1.70 M/day 3.40 Ml 3.40 Ml 0.00 Ml 0 1.44 Ml 1.50 Ml 2.42 M/day 4.83 Ml 1.44 Ml 1.00 Ml 1.43 Ml 1.43 Ml 2.87 Ml 3.00 Ml 1.50 Ml 1.00 Ml 2.50 Ml 0.50 Ml Check Total 21.06 Ml 23.89 Ml 8.06 Ml 14.64 Ml 15.50 Ml 23.05 Ml 46.10 Ml 22.00 Ml 25.20 Ml 33.68 Ml 35.00 Ml 15.50 Ml 10.50 Ml 26.00 Ml 9.00 Ml 35.00

Total East 7.07 Ml 7.13 Ml 14.14 Ml 7.62 Ml 11.33 Ml 12.00 Ml 14.21 Ml 28.43 Ml 15.00 Ml 21.33 Ml 25.62 Ml 26.50 Ml 12.00 Ml 7.50 Ml 19.50 Ml 7.00 Ml Total West 4.88 Ml 13.93 Ml 9.75 Ml 0.44 Ml 3.32 Ml 3.50 Ml 8.84 Ml 17.68 Ml 7.00 Ml 3.87 Ml 8.07 Ml 8.50 Ml 3.50 Ml 3.00 Ml 6.50 Ml 2.00 Ml Total 11.95 Ml 21.06 Ml 23.89 Ml 8.06 Ml 14.64 Ml 15.50 Ml 23.05 Ml 46.10 Ml 22.00 Ml 25.20 Ml 33.68 Ml 35.00 Ml 15.50 Ml 10.50 Ml 26.00 Ml 9.00 Ml

Note 1) Positive numbers reflect shortfall 2) Project implementation 2011 to 2014, thus reservoir phased in 10 yr increments for 2025 & 2035 3) Rounded to nearest 1 Ml 4) Storage capaicty based on storage of AADD @ 48 hours 5) Fire Volume Storage for Medium Risk = 4 hrs of 6000 l/min 1.44 Ml