SAPPI SOUTHERN AFRICA LTD SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, KWAZULU-NATAL FINAL BASIC ASSESSMENT REPORT (DM/0009/2020)
21 OCTOBER 2020
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, KWAZULU-NATAL FINAL BASIC ASSESSMENT REPORT (DM/0009/2020)
SAPPI SOUTHERN AFRICA LTD
TYPE OF DOCUMENT (VERSION)
PROJECT NO.: 41102161 DATE: OCTOBER 2020
WSP 1ST FLOOR, PHAROS HOUSE 70 BUCKINGHAM TERRACE, WESTVILLE DURBAN, 3629 SOUTH AFRICA
T: +27 31 240 8804 F: +27 31 240 8801 WSP.COM
QUALITY MANAGEMENT
ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3
Remarks Draft Final
Date August 2020 October 2020
Prepared by Babalwa Mqokeli Babalwa Mqokeli
Signature
Checked by Carla Elliott Carla Elliott
Signature
Authorised by Carla Elliott Carla Elliott
Signature
Project number 41102161 41102161
Report number 01 02
File reference G:\000 NEW Projects\41102161 - Sappi Saiccor Water Intake Upgrade
WSP is an ISO9001:2015, ISO14001:2015 and OHSAS18001:2007 certified company
SIGNATURES
PREPARED BY
Babalwa Mqokeli Environmental Consultant
REVIEWED BY
Carla Elliott Associate
This report was prepared by WSP Environmental (Pty) Ltd for the account of SAPPI SOUTHERN AFRICA LTD, in accordance with the professional services agreement. The disclosure of any information contained in this report is the sole responsibility of the intended recipient. The material in it reflects WSP Environmental (Pty) Ltd’s best judgement in light of the information available to it at the time of preparation. Any use which a third party makes of this report, or any reliance on or decisions to be made based on it, are the responsibility of such third parties. WSP Environmental (Pty) Ltd accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this report. This limitations statement is considered part of this report. The original of the technology-based document sent herewith has been authenticated and will be retained by WSP for a minimum of ten years. Since the file transmitted is now out of WSP’s control and its integrity can no longer be ensured, no guarantee may be given to by any modifications to be made to this document.
P R ODUCTION TEAM
CLIENT
Environmentalist Samuel Mokoena
SHEQ Manager Craig Daniel
WSP
Environmental Consultant Babalwa Mqokeli
Associate Carla Elliott
SUBCONSULTANTS
Wetland Specialist Andrew Husted – The Biodiversity Company
Estuarine Specialist Nicolette Forbes – Marine & Estuarine Research
TABLE OF 1 INTRODUCTION ...... 1 CONTENTS 1.1 Background ...... 1 1.2 The Purpose of the BA Process ...... 1 1.3 Basic Assessment Report Structure ...... 1 1.4 Assumptions and Limitations ...... 4
2 DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER ...... 5
3 LOCATION OF THE ACTIVITY ...... 6
4 ACTIVITY DESCRIPTION ...... 1 4.1 Project Overview ...... 1 4.2 Proposed Construction Activities ...... 1 4.3 Description of the Listed Activities Associated with the proposed project ...... 1
5 POLICY AND LEGISLATIVE CONTEXT .... 2
6 NEED AND DESIRABILITY...... 5
7 PROJECT ALTERNATIVES ...... 6 7.1 Site Alternatives ...... 6 7.2 Activity Alternative ...... 6 7.3 Layout Alternative ...... 6 7.4 Technology Alternative ...... 6 7.5 No-Go Alternative ...... 6
8 STAKEHOLDER ENGAGEMENT ...... 8
9 DESCRIPTION OF THE BASELINE ENVIRONMENT ...... 1 9.1 Climate ...... 1 9.2 Geology ...... 2 9.3 Aquatic Environment ...... 3
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
9.4 Terrestrial Environment ...... 4 9.5 Socio-Economic Environment ...... 6
10 IMPACT ASSESSMENT ...... 9
11 ENVIRONMENTAL ISSUES AND POTENTIAL IMPACTS ...... 13 11.1 Phases of Development ...... 13 11.2 Construction Phase ...... 13 11.3 Operational Phase ...... 19 11.4 Decommissioning Phase ...... 20 11.5 No-Go Alternative ...... 20 11.6 Cumulative Impacts ...... 20
12 ENVIROMENTAL IMPACT ASSESSMENT RESULTS ...... 1
13 ENVIRONMENTAL IMPACT ASSESSMENT STATEMENT ...... 1
BIBLIOGRAPHY ...... 2
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
TABLES TABLE 1: LEGISLATION REQUIREMENTS AS DETAILED IN APPENDIX 1 OF GNR 326 ...... 1 TABLE 2: DETAILS AND EXPERTISE OF THE EAP ...... 5 TABLE 3: LOCATION OF THE PROPOSED DEVELOPMENT SITE ...... 6 TABLE 4: DESCRIPTION OF THE APPLICABLE LISTED ACTIVITIES ...... 1 TABLE 5: SUMMARY OF APPLICABLE LEGISLATION ...... 2 TABLE 6: WATER USE PER SECTOR IN TERTIARY U10 ...... 8 TABLE 7 NATURE OR TYPE OF IMPACT ...... 10 TABLE 8 PHYSICAL EXTENT (E) RATING OF IMPACT ...... 10 TABLE 9 DURATION (D) RATING OF IMPACT .... 10 TABLE 10 REVERSIBILITY (R) RATING OF IMPACT ...... 11 TABLE 11 MAGNITUDE (MAGNITUDE) RATING OF IMPACT ...... 11 TABLE 12 PROBABILITY (P) RATING OF IMPACT ...... 11 TABLE 13 SIGNIFICANCE (S) WEIGHTINGS AS DECISION MAKING GUIDE ...... 12
FIGURES FIGURE 1: LOCALITY MAP FOR THE PROPOSED SAPPI WATER INTAKE PUMP HOUSE UPGRADE (WSP, 2020) . 1 FIGURE 2: THE FIRST FLOOR OVERVIEW OF THE PROPOSED PROJECT IN RELATION TO THE EXISTING STRUCTURE (ANDREW FRASER, 2019) ...... 2 FIGURE 3: IMAGE OF EXISTING PUMP HOUSE INDICATING ABSTRACT ADDITION IN YELLOW OUTLINE 1 FIGURE 4: ARCHITECTURAL ILLUSTRATIONS FOR THE PROPOSED MCC ROOM ...... 3 FIGURE 5: AVERAGE RAINFALL IN UMKHOMAZI, KWAZULU-NATAL (SOURCE: EN.CLIMATE-DATA.ORG) ...... 1 FIGURE 6: AVERAGE TEMPERATURE IN UMKHOMAZI, KWAZULU-NATAL
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
(SOURCE: EN.CLIMATE- DATA.ORG) ...... 2 FIGURE 7: GEOLOGICAL GROUP FORMATION ASSOCIATED WITH THE PROPOSED PROJECT AREA (WSP, 2020) ...... 3 FIGURE 8: AQUATIC ENVIRONMENT ASSOCIATED WITH THE PROPOSED PROJECT AREA (WSP, 2020) ...... 4 FIGURE 9: SAPPI SAICCOR PUMP HOUSE SITE LOCATED WITHIN THE KWAZULU-NATAL COASTAL BELT THORNVELD ...... 5 FIGURE 10: SAPPI SAICCOR PUMP HOUSE SITE IN RELATION TO THE IRREPLACEABLE CBA AND ESA (WSP, 2020) ...... 6
APPENDICES A EAP CV AND DECLARATION B STAKEHOLDER ENGAGEMENT REPORT C WETLAND RISK ASSESSMENT D ESTUARY SPECIALIST IMPACT ASSESSMENT E GEOTECHNICAL STUDY F ENVIRONMENTAL MANAGEMENT PROGRAMME
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
1 INTRODUCTION
1.1 BACKGROUND
Sappi Saiccor (Sappi) Mill, located in Umkhomazi, manufactures dissolving wood pulp to create a wide range of consumer products, particularly viscose fibre for clothing and textiles. The mill’s water intake pump house, supplying raw water to the Mill’s processes, was installed and commissioned approximately 60 years ago. As a result, the current electrical equipment within the pump house is now obsolete and prone to regular breakdowns. As a means to ensure continued water supply for the Mill’s processes, Sappi is proposing the upgrade of the water intake pump house by constructing a Motor Control Center (MCC) room adjacent to the existing pump house building. In terms of the National Environmental Management Act (Act 107 of 1998, as amended) (NEMA) and the Environmental Impact Assessment (EIA) Regulations promulgated in Government Notice (GNR) 326 of 7 April 2017, a Basic Assessment (BA) process is required for the proposed water intake pump house upgrade. In order for the proposed project to proceed, it will require an Environmental Authorisation (EA) from the Competent Authority (i.e. the KwaZulu-Natal Department of Economic development, Tourism & Environmental Affairs (EDTEA)), as well as approval in terms of the National Water Act.
1.2 THE PURPOSE OF THE BA PROCESS
The purpose of the BA is to identify, assess and report on any potential impacts that the proposed project may have on the environment. It applies to Listed Activities contained in GNR 327 and 324 of the EIA Regulations. The objective of the BA process is to, through a consultative process with stakeholders, identify the potential positive and negative environmental and social impacts associated with the proposed project. The process considers project alternatives and the possible measures to either mitigate the negative impacts or to enhance the positive impacts on the receiving environment. A significant aspect of the BA process is public participation, aimed at notifying the public and / or interested and affected parties (I&APs) regarding the proposed project. Effective public participation improves the ability to make informed decisions as the views of all I&APs are considered in decision-making.
1.3 BASIC ASSESSMENT REPORT STRUCTURE
For the purposes of demonstrating legal compliance, Table 1 cross-references the sections within the BA Report with the requirements as per Appendix 1 of GNR 326 of 2017. Table 1: Legislation Requirements as detailed in Appendix 1 of GNR 326
LEGISLATED REQUIREMENTS AS PER APPENDIX 1 SECTION IN BA REPORT 3. (1) A basic assessment report must contain the information that is Section 2 necessary for the competent authority to consider and come to a decision on the application, and must include:
(a) details of: (i) the EAP who prepared the report; and (ii) the expertise of the EAP, including a curriculum vitae; (b) the location of the activity, including: Section 3 (i) the 21digit Surveyor General code of each cadastral land parcel; (ii) where available, the physical address and farm name;
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 1 SAPPI SOUTHERN AFRICA LTD
(iii) where the required information in items (i) and (ii) is not available, the coordinates of the boundary of the property or properties; (c) a plan which locates the proposed activity or activities applied for Section 4 as well as associated structures and infrastructure at an appropriate scale; or, if it is- (i) a linear activity, a description and coordinates of the corridor in which the proposed activity or activities is to be undertaken; or (ii) on land where the property has not been defined, the coordinates within which the activity is to be undertaken; (d) a description of the scope of the proposed activity, including all Section 4 listed and specified activities triggered and being applied for; and a description of the activities to be undertaken including associated structures and infrastructure; (e) a description of the policy and legislative context within which the Section 5 development is proposed including- (i) an identification of all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks, and instruments that are applicable to this activity and have been considered in the preparation of the report; and (ii) how the proposed activity complies with and responds to the legislation and policy context, plans, guidelines, tools frameworks, and instruments; f) a motivation for the need and desirability for the proposed Section 6 development including the need and desirability of the activity in the context of the preferred location; (g) a motivation for the preferred site, activity and technology Section 7 alternative; (h) A full description of the process followed to reach the proposed Section 7 preferred alternative within the site, including - (i) details of all the alternatives considered; (ii) details of the public participation process undertaken in terms Section 8 of regulation 41 of the Regulations, including copies of the supporting documents and inputs; (iii) a summary of the issues raised by interested and affected Section 8 parties, and an indication of the manner in which the issues were incorporated, or the reasons for not including them; (iv) the environmental attributes associated with the alternatives Section 9 focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects;
(v) the impacts and risks identified for each alternative, including Section 11 the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be avoided, managed or mitigated; (vi) the methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of potential environmental impacts and risks associated with the alternatives; (vii) positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community that may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects; (viii) the possible mitigation measures that could be applied and level of residual risk;
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 2 SAPPI SOUTHERN AFRICA LTD
(ix) the outcome of the site selection matrix; (x) if no alternatives, including alternative locations for the activity were investigated, the motivation for not considering such; and (xi) a concluding statement indicating the preferred alternatives, including preferred location of the activity. (i) a full description of the process undertaken to identify, assess and Section 10 and Section 11 rank the impacts the activity will impose on the preferred location through the life of the activity, including- (i) a description of all environmental issues and risks that were identified during the environmental impact assessment process; and (ii) an assessment of the significance of each issue and risk and an indication of the extent to which the issue and risk could be avoided or addressed by the adoption of mitigation measures; (j) an assessment of each identified potentially significant impact and Section 11 and Section 12 risk, including- (i) cumulative impacts; (ii) the nature, significance and consequences of the impact and risk; (iii) the extent and duration of the impact and risk; (iv) the probability of the impact and risk occurring; (v) the degree to which the impact and risk can be reversed; (vi) the degree to which the impact and risk may cause irreplaceable loss of resources; and (vii) the degree to which the impact and risk can be avoided, managed or mitigated; (k) where applicable, a summary of the findings and impact Section 11 management measures identified in any specialist report complying with Appendix 6 to these Regulations and an indication as to how these findings and recommendations have been included in the final report; (l) an environmental impact statement which contains- Section 13 (i) a summary of the key findings of the environmental impact assessment; (ii) a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the environmental sensitivities of the preferred site indicating any areas that should be avoided, including buffers; and (iii) a summary of the positive and negative impacts and risks of the proposed activity and identified alternatives; (m) based on the assessment, and where applicable, impact Section 11 management measures from specialist reports, the recording of the proposed impact management outcomes for the development for Appendix E inclusion in the EMPr; (n) any aspects which were conditional to the findings of the N/A assessment either by the EAP or specialist which are to be included as conditions of authorisation; (o) a description of any assumptions, uncertainties, and gaps in Section 1.4 knowledge which relate to the assessment and mitigation measures proposed; (p) a reasoned opinion as to whether the proposed activity should or Section 13 should not be authorised, and if the opinion is that it should be authorised, any conditions that should be made in respect of that authorisation; (q) where the proposed activity does not include operational aspects, N/A the period for which the environmental authorisation is required, the
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 3 SAPPI SOUTHERN AFRICA LTD
date on which the activity will be concluded, and the post construction monitoring requirements finalised; (r) an undertaking under oath or affirmation by the EAP in relation to Appendix A - (i) the correctness of the information provided in the reports; (ii) the inclusion of comments and inputs from stakeholders and l&APs; (iii) the inclusion of inputs and recommendations from the specialist reports where relevant; and (iv) any information provided by the EAP to interested and affected parties and any responses by the EAP to comments or inputs made by interested and affected parties; and (s) where applicable, details of any financial provisions for the N/A rehabilitation, closure, and ongoing post decommissioning management of negative environmental impacts; (t) any specific information that may be required by the competent N/A authority; and (u) any other matters required in terms of section 24(4)(a) and (b) of N/A the Act. 2) Where a government notice gazetted by the Minister provides for the N/A basic assessment process to be followed, the requirements as indicated in such a notice will apply.
1.4 ASSUMPTIONS AND LIMITATIONS
General assumptions and limitations relating to the BA process are listed below: — The Environmental Assessment Practitioner (EAP) hereby confirms that they have undertaken to obtain project information from the client that is deemed to be accurate and representative of the project; — Site visits, by the EAP and Specialist, have been undertaken by the EAP to better understand the project and ensure that the information provided by the client is correct, based on site conditions observed; — The EAP hereby confirms their independence and understands the responsibility they hold in ensuring any comments received for the project will be accurately replicated and responded to within the EIA documentation; and — The comments received in response to the public participation process, will be representative of comments from the broader community; and — Based on the pre-application meeting and subsequent agreed upon minutes, the competent authority would not require additional specialist input, in order to make a decision regarding the application. Notwithstanding these assumptions, it is the view of WSP that this BA report provides a good description of the issues associated with the project and the resultant impacts.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 4 SAPPI SOUTHERN AFRICA LTD
2 DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER
In accordance with Regulation 12 (1) of the EIA Regulations, Sappi has appointed WSP Environmental (Pty) Ltd (WSP) to undertake the BA process in order to determine the biophysical, social and economic impacts associated with the proposed project. Table 2 below outlines the details of the EAP and their expertise. The Curriculum Vitae (CV) of the EAP is included in Appendix A of this report. Table 2: Details and Expertise of the EAP
EAP DETAILS
Name of Consultant WSP Environmental (Pty) Ltd
Contact Person / EAP Babalwa Mqokeli
Postal Address 1st Floor, Pharos House 70 Buckingham Terrace Westville, Durban 3629
Telephone 031 240 8804
Fax 031 240 8801
Email [email protected]
EAP Expertise Babalwa holds a Master’s degree in Ecological Science from the University of KwaZulu-Natal. She has more than 4 years of experience in environmental assessment and management, and 2 years of experience as an ecological scientist intern. She is a Registered Professional Natural Scientist (Registration Number: 009863) with the South African Council for Natural Scientific Professions (SACNASP). Babalwa has experience in the management and integration of various types of environmental assessments within the mining, agricultural and renewable energy sector. She has capabilities in undertaking environmental screening mapping using ArcGIS and as part of teams undertaking Strategic Environmental Assessment (SEA) work. Babalwa’s recent experience includes auditing for companies within the petroleum sector, a desalination demonstration plant, and manufacturing plants.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 5 SAPPI SOUTHERN AFRICA LTD
3 LOCATION OF THE ACTIVITY
Sappi Saiccor Mill is situated in Umkhomazi Drift, approximately 50km south of Durban in KwaZulu-Natal. The proposed MCC room will be located directly adjacent to the existing pump house building which is situated on the right-hand bank of the Umkhomazi River. The site is located within Ward 99 of the eThekwini Municipality. The property details, including the 21-digit Surveyor General (SG) code for the cadastral land parcel and coordinates is outlined in Table 3 below. A locality map of the site is included in Figure 1 and an overview of the location of the MCC room (and accompanying structures) in relation to the existing building is presented in Figure 2.
Table 3: Location of the Proposed Development Site
PROPERTY DETAILS
Farm Name Portion 1 of Farm Woodland Lodge 2363 ET, Umkhomazi
Surveyor General 21 Digit Code NOET00000000236400001
Central Coordinates 30°11'0.30"S, 30°45'40.34"E
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 6 SAPPI SOUTHERN AFRICA LTD
Figure 1: Locality Map for the Proposed Sappi Water Intake Pump House Upgrade (WSP, 2020)
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 1 SAPPI SOUTHERN AFRICA LTD
Figure 2: The first floor overview of the proposed project in relation to the existing structure (Andrew Fraser, 2019)
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 2 SAPPI SOUTHERN AFRICA LTD
4 ACTIVITY DESCRIPTION
4.1 PROJECT OVERVIEW
The existing pump house is approximately 154m2 and consists of motors and resistor bank. Sappi is proposing to replace this electrical equipment with 6,6 kV induction motors and 6.6 kV variable frequency drives (VFD) to control the pumps. The proposed VFD technology will be controlled from a stand-alone human machine interface (HMI), equipped with a programmable logic controller (PLC), to allow feed-back to the distributed control system (DCS) via a newly installed fibre optic link. This will allow for automated speed control of the pumps, based on the mill’s water demand. The VFD’s will be housed within the MCC room that is proposed to be constructed adjacent to the existing pump house. This would ensure the longevity of the VFD’s, as they will be housed in an air conditioned, clean and dust free environment. The project will comprise of four columns, encompassing an actual physical ground footprint of 16m2 on the upper banks of the estuary for the suspension of the 62 m2 size MCC structure. The overall upgrade of the water intake pump house consists of the following project components: — MCC room, and associated walkway (footprint area of 62m2) — 6.6kV induction motors (to be housed within the existing pump house) — 6.6kV VFD — Stand-alone HMI (to be housed within the existing pump house) — Air-conditioning — Associated cables
4.2 PROPOSED CONSTRUCTION ACTIVITIES
The new MCC room will be elevated to the floor level of the existing building by constructing a suspended slab supported by four structural concrete footings and columns. An abstract overview of the proposed addition at the floor level of the existing building is indicated by the yellow outline in Figure 3. Architectural illustrations of the proposed MCC room in in relation to the existing building are presented in Figure 4 and Figure 5. Below is a summary of the proposed construction methodology.
4.2.1 DEMOLITION
The existing steel staircase structure will be removed, and material will be cut into manageable pieces to be temporarily stored at the Sappi Saiccor refuse yard until it is sold/repurposed/taken to a licenced landfill. The concrete walkway will be demolished, and all building rubble will be stockpiled in the establishment/laydown area on site, for temporary storage at the Sappi Saiccor refuse yard. All demolition will be agreed with the competent design engineer before work starts. Precaution needs to be taken to ensure that no rubble falls into the river. The temporary stockpile area will be barricaded.
4.2.2 ROCK DRILLING
A rock drill will be established on site to drill 2m by 50mm diameter holes as per the engineer drawing into the south rock face. Access to the drilling of the holes will be within the establishment area. The hole locations will be marked out and agreed in advance with the design engineer.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 1 SAPPI SOUTHERN AFRICA LTD
4.2.3 EARTHWORKS
Tractor Loader Backhoe (TLB) and hand excavation will be used to expose insitu concrete structure. The footings will be excavated by means of a tracked 30-ton excavator and / or labour if required. Trench slopes will be battered where necessary and where trenches are more than 2m deep. While excavating the level will be checked continuously to ensure the correct level is achieved according to the design. This will be done with a fish line and a levelling staph. Excavated material will be stockpiled safely for re-use. All excavations will be inspected by a competent person appointed in writing, on a daily basis and after rain.
4.2.4 CONCRETE WORKS
Concrete shall be ordered from the approved supplier of ready mix concrete and will be delivered directly to the site. Backfilling of column foundations will be done in 150mm layer thicknesses and tested with each layer. After the blinding is casted and waterproofing placed where applicable, preparation for reinforcing steel will follow.
4.2.5 CONSTRUCTION CAMP / LAYDOWN AREA ESTABLISHMENT
The area of construction will be barricaded off and fencing around the water intake will be used as the construction site limits. The general office and store arrangement will be allocated inside the main Sappi Saiccor premises. The site will be maintained in a safe and tidy manner with the implementation of good housekeeping procedures. Temporary power, water and drainage will be tied into from the existing building. Existing ablutions will be used by contractors.
4.2.6 SENSITIVE AREA DEMARCATION
The edge of the watercourse will be treated as environmental sensitive area. All construction work will be done without interfering with the sensitive area, as follows: — Laydown areas will be located at the site and will be barricaded with fence and shade netting; — Construction rubble will be kept at minimal and stockpiled inside waste skips; and — Appropriate signage will be set in and around the laydown area.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 2 SAPPI SOUTHERN AFRICA LTD
Figure 3: Image of existing pump house indicating abstract addition in yellow outline
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 1 SAPPI SOUTHERN AFRICA LTD
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 2 SAPPI SOUTHERN AFRICA LTD
Figure 4: Architectural illustrations for the proposed MCC room
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 3 SAPPI SOUTHERN AFRICA LTD
4.3 DESCRIPTION OF THE LISTED ACTIVITIES ASSOCIATED WITH THE PROPOSED PROJECT
Table 4 provides a list of applicable listed activities associated with the proposed project in terms of Listing Notice 1 (GNR 327) and Listing Notice 3 (GNR 324) of the EIA Regulations (as amended). Table 4: Description of the Applicable Listed Activities
LISTED ACTIVITY DESCRIPTION OF PROJECT ACTIVITY
GNR 327
Activity 19 The infilling or depositing of any material of more The proposed upgrade and/or expansion of the Sappi than 5 cubic metres into, or the dredging, excavation, water intake pump house will result in removal of removal or moving of soil, sand, shells, shell grit, approximately 16 cubic metres of material within a pebbles or rock of more than 5 cubic metres from distance of 100 metres inland of the high-water mark of an estuary. (ii) The littoral active zone, an estuary or a distance of 100 metres inland of the high water mark of the sea or an estuary, whichever distance is the greater.
GNR 324
Activity 23 The expansion of – The proposed upgrade and/or expansion of the Sappi water intake pump house involves a development (ii) infrastructure or structures where the physical footprint of approximately 62m2 within an identified footprint is expanded by 10 square metres or more; estuarine functional zone (EFZ). where such expansion occurs-
(c) within 32 metres of a watercourse, measured from the edge of a watercourse d. KwaZulu-Natal iii. In an estuarine functional zone
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 1 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
5 POLICY AND LEGISLATIVE CONTEXT
Table 5 provides a summary of the applicable legislation, policy and/or guidelines considered relevant to the proposed project. Table 5: Summary of Applicable Legislation
TITLE OF LEGISLATION, POLICY OR GUIDELINE APPLICABILITY TO THE PROPOSED PROJECT
NEMA (Act 107 of 1998, as amended) The proposed development will require the consideration and implementation of environmental management practices in all stages of the project. An application for EA for the proposed project is submitted in terms of GNR 326 of the NEMA EIA Regulations, promulgated under NEMA.
NEMA EIA Regulations GNR 326 The EIA Regulations provide the process that needs to be followed for the BA ensuring the promotion of integrated environmental management. Contents of this BA Report are in line with the requirements of the EIA Regulations.
National Environmental Management: Any waste generated during the construction phase of the project Waste Act (Act 59 of 2008) will require proper management. The contents of this BA Report will include reasonable measures for the prevention or mitigation of environmental pollution.
National Environmental Management The purpose of the Biodiversity Act is to provide for the management and conservation of species and ecosystems that Biodiversity Act (Act 10 of 2004) warrant national protection. The proposed development is located on the bank of a watercourse within an EFZ. The protection of biodiversity needs to be considered in undertaking the proposed development. Specific management measures relative to biodiversity protection have been included in the Environmental Management programme (EMPr).
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 2 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
National Water Act (Act 36 of 1998) This Act aims to control the use of water which may impact on water resources through the licencing of specific water uses in terms of Section 21 of the Act. The construction of MCC room, adjacent to the existing pump house building, requires works to be done on the banks the Umkhomazi River (within 5m) within the delineated floodplain system. In order to determine the authorisation requirements for the MCC, a risk assessment has been undertaken (as attached) in line with the requirements as outlined in Government Notice 5091(August 2016). The risk assessment (The Biodiversity Company, 2019) factored in the construction and operational phases of the MCC. The operation of the development area poses “Low” risks to the identified wetland, pre-mitigation. The significance of the risks is expected to be reduced during the operational phase of the project, due to the four columns being the only disturbance to the ground level, and to an area already developed. A pre-application meeting needs to be undertaken with DWS to determine water use requirements.
National Heritage Resources Act (Act 25 of The existing building was installed approximately 60 years ago, and 1999) the proposed upgrade will encompass minor alteration to this structure to connect to the MCC room. According to the National Heritage Resources Act (NHRA) historical objects, structures and sites older than 60 years are protected as cultural heritage resources. Section 34 (1) of the mentioned act states that no person may demolish any structure or part thereof which is older than 60 years without a permit issued by the relevant provincial heritage resources authority. An application for Heritage Resources review was submitted to the South African Heritage Resources Agency (SAHRA) (Case ID: 14998) in terms of the NHRA, as amended.
National Environmental Management, Air The proposed construction activities, including earthworks, may Quality Act (Act 39 of 2004) result in temporary exposure to dust. Appropriate dust control measures will need to be applied.
National environmental Management: This Act provides for the holistic management of the coast and Integrated Coastal Management Act (Act estuarine areas as an integrated system. In terms of this Act, the 24 of 2008) Umkhomazi Estuary has been identified as a conservation priority system; an EFZ. Specific management measures to minimise any significant risks/impacts on the system have been considered in undertaking this BA process and included in the EMPr.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 3 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
Provincial Spatial Development Framework A key goal for the Provincial Spatial Development Framework (PSDF) is sustainable development which encompasses the integration of social, economic and ecological factors into planning and decision-making. It aims to promote economic growth and a better quality of life by delivering improved infrastructure. The proposed upgrade to the water intake pump house will align with the PSDF as it will ensure water supply with the use of improved infrastructure. The Provincial Growth and Development Strategy seeks to find means and ways to better utilise the natural resource base available whilst ensuring that sustainable environmental planning principles are applied. eThekwini Metropolitan Municipality Plans The following municipal plans were considered in undertaking this BA: — Municipal Spatial Development Framework (SDF) — Municipal Integrated Development Plan (IDP) — Durban Metropolitan Open Space System — KwaZulu-Natal Biodiversity Sector Plan These policies and guidelines have been considered as the legislated components of the municipality’s integrated development plans and framework to determine and guide sustainable land use.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 4 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
6 NEED AND DESIRABILITY
The provision and continued supply of water for the mill’s processes has been identified as a priority for meeting water demand and sustaining the Mill’s operations and water balance. The existing water intake pump house was installed approximately 60 years ago and is the only source of water supply for the mill’s processes. The existing electrical equipment is now obsolete and prone to regular breakdowns, therefore necessitating the upgrade to current technology that requires minimal maintenance and enables automation. The proposed project is based on maintaining capacity by the replacement of obsolete technology. This will reduce the risk of increase frequency of failures. The proposed project is for the expansion of an existing building and will be built within an existing developed area/cleared gravel surface. The development will entail the excavation of foundations for placement of four columns to suspend the MCC room. The physical disturbance to the area will be therefore be minimal (not exceeding 16m2). The only physical (or direct) disturbance to the ground will be associated with the four support columns. A key consideration for the proposed project is that abstraction rates will not change from the current operational abstraction rates. The current capacity of the pumps will not change, as the proposed motors are rated for the same speed and power as the existing motors; the proposed motors are to ensure efficiency. Therefore, no anticipated impacts on water flow or hydrology are associated with the proposed upgrade.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 5 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
7 PROJECT ALTERNATIVES
As per the GNR 326 Appendix 1(2)(b), alternatives for the proposed development are to be identified and considered. The identification of alternatives provides a basis for choice among options available to the decision making authority. The alternatives considered and evaluated in the BA process are outlined below.
7.1 SITE ALTERNATIVES
The proposed site was considered based on the fact that the development is for the expansion and/or upgrade of an existing facility within an existing developed area. The proposed upgrade aims to support operations of an existing Mill located within the same property; it is not operationally feasible for the improved technology to be located in a different property or site – away from the pump house. Furthermore, environmental impacts would be increased if a new facility was established at a new location compared to expanding an existing facility. Therefore, no alternate sites have been identified and assessed.
7.2 ACTIVITY ALTERNATIVE
The pump house is an existing operation at the site and is the source of water supply for the Mill; no other activity alternative exists that would meet the need in terms of the receiving Mill requirements. Therefore, an alternate activity has not been identified and assessed.
7.3 LAYOUT ALTERNATIVE
The design alternatives considered were either vertical (upward) extension of the existing building or the preferred lateral extension. However, the existing structure does not have the required load bearing capacity to be extended vertically, therefore the vertical alternative was considered not suitable and is excluded from the assessment. The preferred MCC room addition will be constructed on / tied into the east side of the existing pump house building, it will include an extension of the existing concrete sub-structure as well as extension of the first floor. The preferred lateral extension is in line with the surrounding/existing structure (i.e. developed area/cleared gravel surface) and is considered suitable for the proposed technology equipment.
7.4 TECHNOLOGY ALTERNATIVE
The preferred technology alternative is to replace the obsolete technology of the wound rotor motor and resistor bank with 6.6 kV induction motors and a 6.6 kV VFD respectively. Based on an enquiry sent to leading Motor Automation and Control companies, this technology is considered the most suitable and widely used technology currently available for speed control. The VFD will be controlled from a stand-alone HMI that is to be installed within the pump station. This stand-alone HMI will be equipped with a PLC, to allow for communication (feed- back) to the DCS via a newly installed fibre optic link; this will allow for automated control of the pumps based on the mill demand. Based on the above, no other technology alternatives have been considered and assessed for the project.
7.5 NO-GO ALTERNATIVE
The no-go alternative refers to the option of not undertaking the upgrade, and continue as per current status quo. In the event that the proposed upgrade does not go ahead, the frequency of failures at the pump house will continue to increase posing increased risk to Mill operations. The Mill will be forced to cut back on production as its main water supply will be reduced. Maintenance and labour costs will continue to increase, as the current
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 6 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
installation is regarded as approaching end of life. The no-go alternative is therefore not considered viable and has not been assessed further.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 7 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
8 STAKEHOLDER ENGAGEMENT
The stakeholder engagement process is being undertaken in accordance with GNR 326 of the EIA Regulations GNR 326, promulgated under the NEMA. The process aims to ensure that potential stakeholders are identified and provided with an opportunity to review the details of the proposed project and to submit any issues and concerns. In order to ensure compliance with the applicable national legislation, WSP undertook the stakeholder engagement process in a diligent manner at the outset of the BA Process. The NEMA requires an inclusive, transparent process of stakeholder engagement. The objectives of the stakeholder engagement process are as follows: — To ensure an open and transparent BA and consultation process, — To identify and inform stakeholders of the proposed project and associated environmental authorisation process, — Provide an opportunity for stakeholders to raise all issues, concerns and questions and ensure that these are considered in the environmental authorisation process for the project, — Ensure that stakeholders have an opportunity to make a meaningful contribution towards decision making by the competent authority, and — Compile an issues trail of all issues, concerns and questions raised during the stakeholder engagement process. A process followed to date is detailed in the Stakeholder Engagement Report (Appendix B)
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 8 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
9 DESCRIPTION OF THE BASELINE ENVIRONMENT
This section of the BA Report provides an overview of the biophysical and socio-economic receiving environment of the proposed project site and surrounding region.
9.1 CLIMATE
The Umkhomazi climate is classified as warm-temperate, characterised by warm and rainy summers, and cool and windy winters. Average rainfall is approximately 1024 mm per year, with most rainfall occurring in March (134 mm) and the lowest average rainfall in June (30 mm). (Figure 5). The temperature in Umkhomazi averages 20.5 °C per annum, with February being the warmest month with an average of 23.9 °C. The lowest average temperature is in July at around 17.0 °C. (Figure 6). The highest average temperatures ocuur in the summer months, between December and March, and the coldest months are between June and August.
Months Figure 5: Average rainfall in Umkhomazi, KwaZulu-Natal (Source: en.climate-data.org)
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 1 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
Months Figure 6: Average temperature in Umkhomazi, KwaZulu-Natal (Source: en.climate-data.org)
9.2 GEOLOGY
The geology of the area is underlain by weathered tillite of the Dwyka Group Formation (C-Pd) (Figure 7). The Dwyka Group forms the lowest and oldest deposit of the Karoo Supergroup, at a depth of between 3m and 26m below existing ground level. This is overlain by alluvial/estuarine clays, silts and silty clays capped by fill material generally comprising gravelly, silty clays and occasional wood chips and pulp. Dwyka tillite is regarded as the most abundant parent material in the Umkhomazi area. Tillite is a sedimentary rock that consists of consolidated masses of unweathered blocks (detached rock bodies) and glacial till in a rock flour (matrix or paste of unweathered rock). The matrix, which comprises a large percentage of the rock, usually is dark grey to greenish black in colour and consists of rock fragments in a very fine-grained paste. The unconsolidated alluvial/estuarine clayey and silty sediments vary in consistency from soft to very stiff. A Geotechnical study was undertaken for the proposed project to form the engineering basis of the building. The study evaluated the rock slope and founding conditions for the water intake building extension. This study was undertaken by Gondwana Geo Solutions (dated 29 May 2019) and is included as Appendix E of the BAR.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 2 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
Figure 7: Geological Group Formation associated with the proposed project area (WSP, 2020)
9.3 AQUATIC ENVIRONMENT
In terms of primary drainage, the site falls within the Mvoti to Umzimkhulu Water Management Area (WMA) (coded: 11), and is located in quartenary catchment U10M in the uMkhomazi River Catchment (Figure 8). The main rivers in WMA 11 are the uMvoti, uMngeni, uMkhomazi and the uMzimkhulu, which all drain directly into the Indian Ocean. The pump house site is situated adjacent to the Mkhomazi River, at the artificial head of the estuary. The uMkhomazi estuary is classified as a Permanently Open estuary (Whitfield 2000), however it should be noted that this classification does allow occasional periods of closure during extreme flows recorded for this estuary (Marine & Estuarine Research (MER), 2017). The lateral boundaries of the estuary are described, in terms of the EIA Regulations and the standardised published protocol, as the Estuarine Functional Zone (EFZ) at 5 m above mean sea level (aMSL). In terms of the KwaZulu-Natal Biodiversity Sector Plan the Mkhomazi River is classified as a National Freshwater Ecosystem Priority Area (NFEPA). The Present Ecological Status (PES) of this river system is moderately modified. The system is however considered of strategic conservation and service delivery importance at a provincial and national level. According the Estuarine Specialist Assessment carried out by MER for the proposed project (Appendix D), the uMkhomazi estuary is an identified critical provider of ecosystem services that cannot be provided at the same scale by other estuaries in the region. Among its most fundamental functional values is the periodic mass delivery of sediment and nutrients accumulated in the estuary to the marine environment during high flow and flood conditions. It is one of only four key systems supplying sediment, nutrients and detritus to the KZN coast (uMvoti, uMngeni, and uMzimkhulu estuaries). The uMkhomazi was found to be especially important to near- shore habitat formation and maintaining beaches in the region.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 3 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
Figure 8: Aquatic environment associated with the proposed project area (WSP, 2020)
9.4 TERRESTRIAL ENVIRONMENT
The proposed project site is located within the Indian Ocean Coastal Belt Biome of South Africa and falls within the KwaZulu Natal Coastal Belt Thornveld (CB 6) vegetation type (Mucina and Rutherford 2006) (Figure 9). This vegetation type is known to be located on steep valley sides and hilly landscapes mainly associated with drier larger river valleys in the rain shadow of the rain bearing frontal weather systems from the east coast (Scott-Shaw and Escott 2011). It is characterised by bushed grassland, bushland and bushland thicket and open woodland. According to the KZN Biodiversity Sector Plan the site is part of an Irreplaceable Critical Biodiversity Area (CBA): Critical Linkage in terms of Landscape Corridors. Additionally, the site lies within an Ecological Support Area (ESA); areas that play an important role in supporting the functioning of CBAs and/or delivering ecosystem services. (Figure 10).
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 4 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
Figure 9: Sappi Saiccor Pump House Site located within the KwaZulu-Natal Coastal Belt Thornveld
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 5 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
Figure 10: Sappi Saiccor Pump House Site in relation to the Irreplaceable CBA and ESA (WSP, 2020)
9.5 SOCIO-ECONOMIC ENVIRONMENT
9.5.1 REGIONAL CONTEXT
The proposed project site is located within the jurisdiction of the eThekwini Municipality, situated on the east coast of South Africa, within the Province of KwaZulu-Natal. The Municipality spans an area of approximately 2555 km2; extending from Tongaat in the North to Umkhomazi in the South, and from the coastline in the East to Cato Ridge in the West. The coastal area is considered to be the economic hub of KwaZulu-Natal and contributes significantly to the provincial Gross Domestic Product (GDP). The Municipal GDP was recorded at R304.4 billion in 2017, with the local economy dominated by tertiary industries that included finance (20%), manufacturing (19%), trade (18%), transport (14%) and construction (6%). The Municipality’s population was recorded at approximately 3.8 million in 2018, and comprises of approximately 35% of the provincial population and 7% of South Africa’s total population. According to the 2016 Stats SA Forecast the eThekwini Municipality population is largely young, with 63% of the population younger than 35 years old. According to Global Insight of 2018, the unemployment rate in eThekwini during 2016 was 18.2%. The economically active age group is between 15 to 59 years and comprises of 62% of the population. The forestry, timber, pulp and paper industry have the following South African economic impacts: — The forestry industry was a nett exporter of over R2.2 billion worth of goods in 2012, of which more than 99% took the form of converted value-added products.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 6 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
— In 2012, pulp products were the most important exports (R5 890 billion), followed by paper, solid wood products and other products. — The forestry sector employs around 165 900 workers and provides about 62 700 direct jobs and 30 000 indirect jobs. Forestry provides livelihood support to 652 000 people of the country's rural population. The pulp and paper industry provides about 13 200 direct and 11 000 indirect employment opportunities. — Approximately 20 000 workers are employed in sawmilling, and 6 000 in the timber board and 2 200 in the mining timber industries, while a further 11 000 workers are employed in miscellaneous jobs in forestry. — The forestry sector contributes about 1% to the country’s Gross Domestic Product (GDP). In terms of regional GDP, forestry in KwaZulu-Natal contributes 4,4%; in Mpumalanga 3,7%; in the Eastern Cape 0,6%; and in Limpopo about 0,6%.
9.5.2 LOCAL CONTEXT
The site falls within the Southern Municipal Planning Region (SMPR) of the eThekwini Municipality. The SMPR’s land area is approximately 510 km2; extending from the northern boundary consisting of the Umlazi River and the Umlaas Canal to the UFudu Escarpment and the EziMbokodweni River in the north-West to the western and southern boundaries of the eThekwini Municipality. This Region is regarded as having a large residential population, as well as some of the provinces leading economic sectors. The proposed intake site is located within Ward 99, comprising a land area of 90.5 km2.Due to a lack of available local data, Statistics SA 2011 and 2016 was used as the primary data source. The ward is comprised of a predominantly African population (68%), with a total population of 27 424 people. While the majority of economically active individuals are employed, the area has a characteristically low annual income per household. The population in the ward area has increased over time with majority of the population (34%) falling under the 20-39 year age group and 31% under the age of 18. Education levels are fairly average with 42.8% having completed their matric, which is about 10% higher than the provincial rate (Statistics SA, 2011). Unemployment in the ward is 41.6% which is significantly higher than the national rate of 29.8% (Statistics SA, 2011). In 2011, the average annual household income was recorded to be R29 400 and 14% of households had no household income. The number of employed individuals in the ward area is 40% with 76% employed in the formal sector. The Sappi Saiccor Mill is the largest industrial zone within the Umkhomazi area. The mill is considered a major contributor to the regional, as well as the local economies. Sappi Saiccor provides approximately 1250 direct employment opportunities and supports approximately 15 000 workers through secondary employment.
9.5.3 SURFACE WATER USERS
The water resources of the Mvoti to Umzimkulu WMA are of significant strategic importance, both for supply of demand, and from an environmental aspect. Each main river independently flows into the Indian Ocean, and therefore each estuary is of environmental significance in order to ensure the ecological integrity of the estuary remains strong. There are substantial areas of commercial afforestation and irrigation within the uMkhomazi catchment, supplied by both dams and rivers. The dominant crops under irrigation are Rye Grass and pastures, although a variety of crops are grown over the area. Based on the DWS WARMS Database (2016), five water use sectors were identified within the quaternary catchments associated with the uMkhomazi River, these included: — Industry (non-urban and urban); — Domestic and Industrial (urban); — Commercial afforestation; — Agriculture (irrigation and livestock watering); and — Water Supply Service.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 7 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
It must be noted that since the Mill is the last water user within the uMkhomazi River Catchment (UTM10), that water use associated with the Mill will not result in any effects on downstream water use barring potential ecological functioning and recreational use (e.g. fishing) between the estuary and the sea. Table 6 provides the water users per sector within the tertiary catchment U10. The total water use in the tertiary catchment is 166 million m3/a. Table 6: Water Use per Sector in Tertiary U10
WATER USE VOLUME SECTOR (M3/A) % OF TOTAL
Industry: Non-urban 60 024 317 36%
Clean Water Dam 34 309 120 21%
Commercial Afforestation 32 466 142 20%
Irrigation: Agriculture 30 073 016 18%
Water Supply Services 9 161 793 6% (Domestic & Industrial)
Industry: Urban 150 535 <0%
Schedule 1 68 532 <0%
Agriculture: Livestock Watering 55 070 <0%
Urban: Domestic and Industrial 5 280 <0%
Recreation 183 <0%
Total 166 313 988 100%
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 8 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
10 IMPACT ASSESSMENT
10.1 IMPACT ASSESSMENT METHODOLOGY
The impact assessment stage comprises a number of steps that assess the manner in which the proposed Project will interact with elements of the biophysical, cultural or socio-economic environment to produce impacts to resources/receptors, and identifies the mitigation measures to avoid, minimize or manage adverse impacts. The assessment of impacts is based on the condition of the baseline environment at the time of the assessment and considers the impacts from all perceivable planned and non-planned activities during all phases of a project. The process of predicting and evaluating impacts and development of mitigation measures is iterative, and should inform and run in parallel with the final design of the Project. The process also links with consultation and stakeholder input regarding the significance of impacts and the suitability of proposed mitigation measures. Impacts to the various social and environmental resources / receptors should be assessed in three stages: — Identify the potential impact, describe and assess a pre-mitigation significance rating to be assigned to the impact; — Propose the mitigation required; and — Present the residual impact (that remaining after mitigation) with an assigned post-mitigation significance level. The steps involved in the prediction, evaluation and mitigation of impacts are described in detail below.
10.1.1 IMPACT PREDICTION AND EVALUATION
The BA uses a methodological framework developed by WSP to meet the combined requirements of international best practice and national legislation. The determination and assessment of impacts will be based on the following criteria: — Nature of the Impact; — Significance of the Impact; — Consequence of the Impact; — Extent of the impact; — Duration of the Impact; — Probability of the impact; — Degree to which the impact: — Can be reversed; — May cause irreplaceable loss of resources; and — Can be avoided, managed or mitigated. — Magnitude: to what extent environmental resources are going to be affected based on sensitivity of the resource or receptor (rated as high, medium and low) by considering the importance of the receiving environment (international, national, regional, district and local), rarity of the receiving environment, benefits or services provided by the environmental resources and perception of the resource or receptor). It should be noted that the definitions given are for guidance only, and not all the definitions will apply to all of the environmental receptors and resources being assessed. Impact significance is assessed with and without mitigation measures in place, allowing residual impacts to be identified.
IMPACT ASSESSMENT METHODOLOGY Impacts are assessed in terms of the following criteria:
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 9 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
a) The nature; a description of what causes the effect, what will be affected and how it will be affected. Table 7 Nature or Type of Impact
NATURE OR TYPE OF IMPACT DEFINITION
Beneficial / Positive An impact that is considered to represent an improvement on the baseline or introduces a positive change.
Adverse / Negative An impact that is considered to represent an adverse change from the baseline, or introduces a new undesirable factor.
Direct Impacts that arise directly from activities that form an integral part of the Project (e.g. new infrastructure).
Indirect Impacts that arise indirectly from activities not explicitly forming part of the Project (e.g. noise changes due to changes in road or rail traffic resulting from the operation of Project).
Secondary Secondary or induced impacts caused by a change in the Project environment (e.g. employment opportunities created by the supply chain requirements).
Cumulative Impacts are those impacts arising from the combination of multiple impacts from existing projects, the Project and/or future projects. b) The physical extent: Table 8 Physical Extent (E) Rating of Impact
SCORE DESCRIPTION
1 Impact will be limited to the site;
2 Impact will be limited to the local area;
3 Impact will be limited to the region;
4 Impact will be national; or
5 Impact will be international. c) The duration, wherein it is indicated whether the lifetime of the impact will be: Table 9 Duration (D) Rating of Impact
SCORE DESCRIPTION
1 Very short duration (0 to 1 years);
2 Short duration (2 to 5 years);
3 Medium term (5–15 years);
4 Long term (> 15 years); or
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 10 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
5 Permanent. d) Reversibility: An impact is either reversible or irreversible. A scale of the level of reversibility if an impact is; or how long before impacts on receptors cease to be evident. Table 10 Reversibility (R) Rating of Impact
SCORE DESCRIPTION
1 Impact is immediately reversible;
3 Impact is reversible within 2 years after the cause or stress is removed; or
5 Activity will lead to an impact that is in all practical terms permanent. e) The magnitude of impact on existing processes, quantified on a scale from 0-5, where a score is assigned. Table 11 Magnitude (Magnitude) Rating of Impact
SCORE DESCRIPTION
1 Minor and will not result in an impact on processes.
2 Low and will cause a slight impact on processes.
3 Moderate and will result in processes continuing but in a modified way.
4 High (processes are altered to the extent that they temporarily cease).
5 Very high and results in complete destruction of patterns and permanent cessation of processes. f) The probability of occurrence, which describes the likelihood of the impact actually occurring. Probability is estimated on a scale where: Table 12 Probability (P) Rating of Impact
SCORE DESCRIPTION
1 Very improbable (probably will not happen);
2 Improbable (some possibility, but low likelihood);
3 Probable (distinct possibility);
4 Highly probable (most likely); or
5 Definite (impact will occur regardless of any prevention measures). g) The significance, which is determined through a synthesis of the criteria described above (refer formula below) and can be assessed as low, medium or high; h) The status, which is described as either positive, negative or neutral;
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 11 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
i) The degree to which the impact can be reversed; j) The degree to which the impact may cause irreplaceable loss of resources; and k) The degree to which the impact can be mitigated.
The significance is determined by combining the above criteria in the following formula: Significance = (Extent + Duration + Reversibility + Magnitude) x Probability [푆 = (퐸 + 퐷 + 푅 + 푀) × 푃] Where the symbols are as follows: The significance weightings for each potential impact are as follows: Table 13 Significance (S) Weightings as Decision Making Guide SIGNIFICANCE SIGNIFICANCE OVERALL RATING RATING DESCRIPTION SCORE (NEGATIVE) (POSITIVE)
4 – 15 points Very Low Very Low Impact would not have a direct influence on the decision to develop in the area. 16 - 30 points Low Low
Impact could influence the decision to develop in the area 31 - 60 points Moderate Moderate unless it is effectively mitigated.
61 - 80 points High High Impact must have an influence on the decision process to develop in the area. 81 – 100 Very High Very High points
The impact significance without mitigation measures will be assessed with the design controls in place. Impacts without mitigation measures in place are not representative of the proposed development’s actual extent of impact, and are included to facilitate understanding of how and why mitigation measures were identified. The residual impact is what remains following the application of mitigation and management measures, and is thus the final level of impact associated with the Project. Residual impacts also serve as the focus of management and monitoring activities during Project implementation and to verify that actual impacts are the same as those predicted in this BA.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 12 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
11 ENVIRONMENTAL ISSUES AND POTENTIAL IMPACTS
This section describes the environmental issues associated with the proposed upgrade works, in accordance with the 2014 NEMA EIA Regulations (amended 2017). The social, physical and biophysical aspects associated with the construction, operational and decommissioning phase of the proposed activity have been considered. Whilst not all will result in “likely environmental impacts”, they have been documented for purposes of completeness. An EMPr (Appendix E) has been compiled for the project to ensure that any likely negative biophysical and socio-economic impacts are mitigated; and benefits enhanced.
11.1 PHASES OF DEVELOPMENT
Potential impacts have been identified and assessed according to the phases of the project’s development. For purposes of this report, these have been defined in general below.
11.1.1 CONSTRUCTION PHASE:
The construction phase includes the preparatory works/activities typically associated with the proposed pump house upgrade. The activities most relevant to this phase include: — Demolition of the existing steel staircase structure; — Rock drilling of 2m x 50mm diameter holes into the south rock face; — Earthworks associated with excavations and levelling of the site; — Construction of the surface infrastructure including the columns, MCC structure, plumbing etc
11.1.2 OPERATIONAL PHASE
The operational phase includes the maintenance activities associated with the pump house.
11.1.3 DECOMMISSIONING PHASE
The decommissioning phase includes the activities associated with the removal/dismantling of the pump house and associated infrastructure when no longer necessary.
11.2 CONSTRUCTION PHASE
11.2.1 AIR EMISSIONS
Excavation activities and construction work may result in the generation of exhaust fumes, dust and other particulate matter which has the potential to impact the local air quality. Vehicles transporting material to the site along the gravel road may potentially increase the dust generated and cause a nuisance to the surrounding environment and residents. IMPACT ASSESSMENT
Impact Decrease in ambient air quality as a result of dust and other vehicular/machinery emissions generated resulting in a potential nuisance factor to nearby receptors..
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 13 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
Mitigation — Limit vehicle speeds on un-surfaced areas. — Implement effective and environmentally-friendly dust control measures, such as mulching or periodic wetting of the gravel access road. — Avoid dust-generating activities (i.e. grading and moving of soil) during windy periods. — Cover and/or maintain appropriate freeboard on trucks hauling any loose material that could produce dust when travelling. — Exposed areas should be re-vegetated or hard surfaced as soon as possible. — A complaints register should be kept on site, with records of complaints received and manner in which the complaint was addressed.
Significance Rating Without Mitigation Low With Mitigation Very Low
11.2.2 NOISE EMISSIONS
Elevated noise levels are likely to be generated from the excavator and heavy vehicles during the construction period, and could potentially become a nuisance to surrounding residents. Given the current noise levels of the site and the industrial nature of the area, that is the existing context of the pump house and mill, this impact is considered to be of low significance. IMPACT ASSESSMENT
Impact Increase in ambient noise resulting in a potential nuisance factor to nearby receptors.
Mitigation — Undertake noisy construction activities during daylight hours to minimise disturbance to the surrounding residents. — No sound amplification equipment to be used on site, except in the case of an emergency. — Maintain vehicles and machinery in good working order. — Instances of excessive noise and complaints must be investigated and possibilities for mitigation assessed. — Limit vehicles travelling to and from the site to minimise traffic noise to the surrounding environment.
Significance Rating Without Mitigation Low With Mitigation Very Low
11.2.3 SOIL EROSION AND SEDIMENTATION
Earth moving activities (excavations) will increase the potential for localised soil erosion to occur. The excavation of trenches and soil stockpiles can lead to the sedimentation of surface water and increased turbidity resulting in secondary impacts to the aquatic ecosystems functioning. High rainfall events could increase the probability and extent of the impact. IMPACT ASSESSMENT
Impact Soil erosion and sedimentation of water resources
Mitigation — All excavated material needs to be adequately managed (stored, transported and disposed). — Implement suitable erosion and sediment control measures. — Stormwater runoff should be directed away from active earthworks.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 14 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
— Limit the extent of active work areas — Excavated areas to be rehabilitated as much as possible.
Significance Rating Without Mitigation Moderate With Mitigation Low
11.2.4 WASTE GENERATION
The construction phase has the potential to generate both general waste and hazardous waste if construction activities are not properly managed. Waste generation includes litter from personnel on-site, construction solid waste (plastics, metal concrete, metal etc), oil spills etc. Improper segregation of waste will result in lost opportunity for reuse and recycling resulting in increased pressure on local landfills.
Impact Pollution and contamination of soil and groundwater leading to potential secondary impact to human and ecosystem (estuary) health.
Mitigation — There must be adequate waste bins on site for general and hazardous waste. — Waste should be stored in separate, labelled and secure skips / containers depending on management options – opportunities should be determined, in consultation with waste service providers, for re-use, recycle, or disposal options. — Construction workers must be instructed not to litter and to place all waste in the appropriate waste bins provided on site. — Working areas are to be cleared of litter on a daily basis. No litter / waste is to be burnt on-site. — Bins must be emptied regularly and collected by a licensed contractor for disposal at an appropriate, licensed facility. — Proof of disposal is to be received and filed. — Bins must not be allowed to overflow. — Storage of hazardous waste should be undertaken within impermeable, bunded and covered storage areas, with a capacity to contain 110% of total volume. — Personnel involved in the handling of hazardous waste must be provided with the necessary PPE as stipulated in the MSDS or SDS.
Significance Rating Without Mitigation Moderate With Mitigation Low
11.2.5 HAZARDOUS SUBSTANCES AND CONTAMINATION
The construction of the proposed pump house will involve the handling and storage of a small volume of hazardous substances, as well as hazardous waste such as oils, greases etc. These substances may result in soil, surface and groundwater contamination in the event of accidental spillage and loss of containment on site leading to potential secondary impact to human and ecosystem (estuary) health. Given that the site is located on the bank of the Umkhomazi estuary there is high potential of these substances entering sensitive environments through surface runoff and consequently impacting water quality. This would remain a risk until the construction phase is completed, and the implementation of mitigation measures can effectively lower the significance. It is noted that the proposed project will occur within existing retaining walls thus minimising the risk to the aquatic system. IMPACT ASSESSMENT
Impact Pollution and contamination of soil and groundwater leading to potential secondary impact to human and ecosystem (estuary) health.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 15 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
Mitigation — Construction footprint must be well demarcated and fenced off from sensitive environmental features, to contain site activities and staff within the development footprint areas and prevent disturbance or risk to the aquatic system. — Construction vehicles and machinery must make use of existing access routes. — As much as possible, on-site fabrication must be avoided. It is preferred that balustrades, concrete slaps and concrete columns be fabricated off-site. — Stormwater runoff should be directed away from active earthworks. Prevent stormwater runoff from coming into contact with wastes or contaminants on site. — Contaminated water must be collected in sealed tanks and transported to an appropriate site for disposal. — Storage of hazardous materials should be undertaken within impermeable, bunded and covered storage areas, with a capacity to contain 110% of total volume. — All storage containers are to be labelled, sealed and stored in accordance with Material Safety Data Sheets (MSDS) requirements. — All machinery to be re-fuelled and serviced in a designated area, no vehicles may be serviced or repaired on-site. In the event of emergency repairs, adequate spillage containment must be implemented. — Drip trays must be used on vehicles and machinery that are prone to oil leaks. — An appropriate spill management procedure must be implemented and spill kiits available on site. — Prevent spillage of construction material and other pollutants, and strictly prohibit any pollution or littering. — Establish appropriate emergency procedures for accidental contamination of the surroundings.
Significance Rating Without Mitigation Moderate With Mitigation Low
11.2.6 DISTURBANCE TO ESTUARINE FUNCTIONAL ZONE AND WETLAND
The proposed development occurs within the delineated EFZ of the uMkhomazi estuary. The estuary is also mapped as a National Freshwater Ecosystem Priority Areas (NFEPA) wetland (channelled valley bottom). It is noted that the development will be within an existing developed area and cleared gravel surface. Additionally, the physical disturbance to the area in terms of vegetation is reduced due to planned small footprint (MCC suspended on columns) According to the Estuarine Specialist Study (MER,2020) (Appendix D), the impact in terms of loss of EFZ habitat and especially loss of functionality is considered extremely low. This is due to the fact that the project is an expansion of an existing structure at this location, with minimal physical disturbance. It is however recommended that care should be taken to limit the footprint of the construction camp and materials to the already disturbed areas at the site. According to the Wetland Risk Assessment (The Biodiversity Company, 2019) (Appendix C), the proposed water intake pump house will not pose any direct risk to the wetland system. This is due to the fact that the project is an expansion of an existing building, with existing retaining walls. The structure will constitute four columns being the only physical disturbance to the ground IMPACT ASSESSMENT
Impact Habitat disturbance and loss of EFZ functionality
Mitigation — Development planning must ensure disturbance is restricted to the expansion layout footprint. — Development must be planned for areas that are already transformed.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 16 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
— Identify sensitive fauna and flora prior to construction works and cordon off to avoid disturbance. — Remove only the vegetation where essential for construction and limit any disturbance to the adjoining natural vegetation cover.
Significance Rating Without Mitigation Low With Mitigation Very Low
11.2.7 VISUAL
The visual aesthetic of the site will most likely be negatively impacted by the presence of construction vehicles, equipment, construction camp, excavations and stockpiles. If materials and equipment are kept neatly and in stores where practical, the severity of this impact can be easily reduced. IMPACT ASSESSMENT
Impact Visual disturbances during construction phase resulting in a potential nuisance factor to nearby receptors..
Mitigation — The storage areas of construction materials, equipment and waste facilities should be clearly demarcated and maintained in a neat and orderly fashion at all times. — Construction camp must be positioned in a manner to reduce visual impacts. — Mitigation measures for dust control must be implemented during construction. — Construction rubble, construction material, refuse, litter or any other material not found naturally in the surroundings should not be left lying around at the construction site
Significance Rating Without Mitigation Low With Mitigation Very Low
11.2.8 HERITAGE
The Mill’s current water intake pump house was constructed approximately 60 years ago, consequently regarded as a historical building of heritage significance. The proposed development will include the alteration of the current structure to connect the proposed MCC room, therefore resulting in a change to a structure of heritage significance. It is however important to note that the current structure will not be demolished, and that as per the architectural design, the proposed extension will match the existing building; with Corobrick firelight satin facebrick walls, concrete substructure and concrete roof. IMPACT ASSESSMENT
Impact Alteration of heritage building and disturbance of features of heritage importance.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 17 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
Mitigation — Due to the fact that the building is older than 60 years and consequently attributed heritage significance, it is important that is preserved to some extent to maintain its historic value. It is recommended that the building style is preserved. — A selection of outdated equipment, machinery and operations manuals be donated to a Museum for specialised curation, if applicable. — Architectural design of the proposed MCC room to match the existing building, to reduce the impact on aesthetic value/characteristics and/or representivity. — Should any archaeological features be discovered on site during construction, it should be reported to SAHRA (AMAFA) and a qualified Heritage specialist should be notified. — Contractors should be made aware of the moderate paleontological significance within the proposed development site. A qualified professional paleontologist should be contacted immediately if fossils are unearthed in the construction phase.
Significance Rating Without Mitigation Moderate With Mitigation Low
11.2.9 TRAFFIC
During the construction phase there is likely to be an increase in vehicular movement associated with the transportation of construction equipment, supplies and removal of waste for disposal. These movements may lead to an increase of road traffic in the vicinity of the Mill, as well as increased use of the internal gravel access road to the pump house site by heavy vehicles. This has the potential to result in short term congestion. These traffic movements will however be temporary and intermittent, and therefore unlikely to be of significant impact. IMPACT ASSESSMENT
Impact Increased traffic leading to potential road congestion.
Mitigation — Effective signage and traffic control measures must be implemented along the route. — Traffic should be restricted to the designated access roads and haul roads. — Limit vehicles travelling to the site. — Maintain and/or upgrade the gravel access road if degradation observed to ensure safe conditions.
Significance Rating Without Mitigation Low With Mitigation Very Low
11.2.10 HEALTH AND SAFETY
Construction of the pump house has the potential to impact on the general health and safety of the construction workers. These risks include, inhalation of dust and fumes, noise causing hearing problems, slips, trips and falls, risks associated with working at heights, as well as the risk of worker exposure to hazardous chemicals. The use of appropriate personal protective equipment (PPE) and implementation of health and safety measures is required for the construction phase. IMPACT ASSESSMENT
Impact Health and safety risks to workers.
Mitigation — The management of worker health and safety falls outside of the remit of the EIA Regulations and this BA Report, and the associated EMPr thus excludes mitigation measures. Sappi and its appointed contractors are required to manage
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 18 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
worker health and safety in accordance with the Occupational Health and Safety Act, 1993 (Act No. 85 of 1993). This must include: — Detailed project / activity specific hazard identification and risk assessment (HIRA) process; and; — Implementation of appropriate mitigation measures e.g. safe work procedures, use of PPE; design safety, occupational monitoring, training and awareness programmes, and performance assessment and reporting.
Significance Rating Without Mitigation Moderate With Mitigation Low
11.3 OPERATIONAL PHASE
11.3.1 NOISE EMISSIONS
The pump house is inherently a noisy environment due to the running engines and other pump equipment, in particular the pump. Pump drives, including motors, by their nature generate noise which may significantly impact personnel working on the site as well as surrounding sensitive receptors. The upgrade is not anticipated to result in significant changes to the noise profile of the water intake pump house. The noise levels are expected to remain the same as the main source is from the existing pumps, which will not be changed. IMPACT ASSESSMENT
Impact Changes in noise levels
Mitigation — Workplace noise and vibration issues must be managed as part of the Occupational Health and Safety Management System, and must include specific measures to prevent hearing loss and other health impacts as a result of workplace noise and vibration. — Sappi to record any noise complaints and responses / corrective actions
Significance Rating Without Mitigation Moderate With Mitigation Low
11.3.2 VISUAL
Visual impacts of the site are anticipated to be minimal due to the fact that the proposed project is for the expansion of an existing building and the footprint size is relatively small, thus not resulting in significant changes to the landscape character. The MCC room is similar in design; with Corobrick firelight satin facebrick walls, concrete substructure and concrete roof. The proposed structure will have a minimal cumulative negative effect to the surrounding visual resources. Consequently, landscape sensitivity is considered low from a visual perspective. IMPACT ASSESSMENT
Impact Potential visual impacts.
Mitigation — Ensure the architectural design of the proposed MCC room is similar to the existing building, to reduce the impact on visual and landscape character.
Significance Rating Without Mitigation Low With Mitigation Very Low
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 19 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
11.4 DECOMMISSIONING PHASE
The decommissioning of the site is not foreseen to take place. However, should the site be decommissioned at some point, environmental impacts are anticipated to be similar to those identified for the construction phase, specifically in terms of soil and sedimentation, surface water contamination and waste management.
11.5 NO-GO ALTERNATIVE
The no-go alternative is the option of not constructing the proposed water intake pump house upgrade. In the event that the pump house is not constructed, all anticipated impacts mentioned above will not occur. The site would remain with the existing building structure and obsolete equipment that is prone to regular breakdown. More failures of the equipment, at an increased frequency, should be expected as the motors and resistor banks at the intake pump station are approaching end of life. This would result in a continued increase in maintenance and labour costs. Maintaining the status quo at the pump house is considered a risk to the Mill’s production, as the water intake pump house is one of the main sources of water supply to the Mill. The Mill would consequently be forced to cut back on production as water supply will be reduced resulting in potential job losses The no-go alternative presents a lost opportunity to contribute to sustained operations.
11.6 CUMULATIVE IMPACTS
Cumulative impacts associated with this type of development include impacts on traffic, air quality and water resources as discussed above. Impacts may not be direct and or quantifiable, however incremental occurrences over a longer term may have amplified effects to the biophysical and social attributes on a local and regional scale. Cumulative impacts are most prevalent in the event that continuous and long-term impacts are occurring. However, the nature of the proposed development is such that these impacts are only anticipated during the construction phase and of a temporary nature, and are thus considered negligible on a local or regional scale.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 20 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
12 ENVIROMENTAL IMPACT ASSESSMENT RESULTS
CONSTRUCTION Ease of Pre-Mitigation Post-Mitigation Impact number Aspect Description Stage Character Mitigation (M+ E+ R+ D)x P= S Rating (M+ E+ R+ D)x P= S Rating Impact 1: Air Emissions Decrease in ambient air quality Construction Negative Moderate 2 2 1 1 4 24 N2 2 2 1 1 1 6 N1 Significance N2 - Low N1 - Very Low Noise Impact 2: The increase in ambient noise Construction Negative Moderate 2 2 1 1 4 24 N2 2 1 1 1 3 15 N1 Emissions Significance N2 - Low N1 - Very Low Soil Erosion Soil erosion and sedimentation of Impact 3: and Construction Negative Moderate 4 2 3 2 3 33 N3 3 2 2 2 2 18 N2 water resources Sedimentation Significance N3 - Moderate N2 - Low Waste Potential secondary environmental Impact 4: Construction Negative Moderate 4 2 3 2 3 33 N3 3 2 2 2 2 18 N2 Generation and social impacts Significance N3 - Moderate N2 - Low Hazardous Potential pollution and Substances Impact 5: contamination of soil, surface and Construction Negative Moderate 4 2 3 2 3 33 N3 3 2 2 2 2 18 N2 and groundwater. Contamination Significance N3 - Moderate N2 - Low Disturbance to Habitat disturbance and loss of Impact 6: EFZ and Construction Negative High 2 3 3 5 2 26 N2 1 3 2 5 1 11 N1 EFZ functionality Wetland Significance N2 - Low N1 - Very Low Visual disturbances during Impact 7: Visual Construction Negative Moderate 4 2 1 1 3 24 N2 3 2 1 1 2 14 N1 construction phase Significance N2 - Low N1 - Very Low
Impact 8: Heritage Alteration of Heritage building Construction Negative Moderate 3 2 3 5 4 52 N3 2 1 2 5 3 30 N2
Significance N3 - Moderate N2 - Low
Impact 9: Traffic Increased road traffic Construction Negative High 2 2 1 1 3 18 N2 1 2 1 1 2 10 N1
Significance N2 - Low N1 - Very Low
Health and Impact 10 Health and safety risks on workers Construction Negative High 5 1 5 1 3 36 N3 5 1 5 1 2 24 N2 Safety
Significance N3 - Moderate N2 - Low
OPERATIONAL
Ease of Pre-Mitigation Post-Mitigation Impact number Receptor Description Stage Character Mitigation (M+ E+ R+ D)x P= S (M+ E+ R+ D)x P= S Noise Impact 1: Changes in noise levels Operational Negative Moderate 3 2 3 5 3 39 N3 2 1 2 5 2 20 N2 Emissions Significance N3 - Moderate N2 - Low
Visual impacts during the Impact 2: Visual Operational negative Low 2 2 1 5 3 30 N2 1 1 1 4 2 14 N1 operational phase
Significance N2 - Low N1 - Very Low
WSP Project No. 41102161 SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 SAPPI SOUTHERN AFRICA LTD KWAZULU-NATAL Page 1
13 ENVIRONMENTAL IMPACT ASSESSMENT STATEMENT
The overall objective of the BA process is to provide sufficient information to enable informed decision-making by the authorities. This was undertaken through consideration of the proposed project components, identification of the aspects and sources of potential impacts and subsequent provision of mitigation measures. The proposed project is for the expansion of an existing building within an existing transformed area and cleared gravel surface. The development will entail the excavation of foundations for four columns for the suspension of the MCC room (the only direct disturbance to the ground will be associated with the four support columns). Potential impacts associated with the proposed Sappi Saiccor pump house upgrade project have been considered and the significance of these evaluated in light of the proposed mitigation measures. Overall, majority of the potential negative pre-mitigation impacts were considered to be of moderate to low significance. The low to very low significance of residual impacts was substantiated on the premise that mitigation measures stipulated in the EMPr (Appendix E) would be implemented and legally enforced. This is imperative considering the proximity of the project to a watercourse (Umkhomazi River and Estuary). This BA process also highlights the no-go option which would result in a lost opportunity to upgrade the pump house to ensure continued water supply for the Mill’s processes. Taking into consideration the findings of this BA process and the overall need and desirability of the project to ensure continued water supply for the Mill, it is the opinion of the EAP that there are no fatal flaws associated with the project, and that the project will make a beneficial contribution to the Mill. Provided that the suggested mitigation measures are applied effectively, it is recommended that the project receives authorisation in terms of the EIA Regulations (as amended) promulgated under the NEMA.
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 1 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
BIBLIOGRAPHY
— https://en.climate-data.org/africa/south-africa/kwazulu-natal/umkomaas-27387/ — Marine & Estuarine Research (2017) Estuary Specialist Impact Assessment: Proposed Flood Protection Berm, Sappi Saiccor — Scott-Shaw, C.R and Escott, B.J. (Eds) (2011) KwaZulu-Natal Provincial Pre-Transformation Vegetation Type Map – 2011. Unpublished GIS Coverage [kznveg05v2_1_11_wll.zip], Biodiversity Conservation Planning Division, Ezemvelo KZN Wildlife, P. O. Box 13053, Cascades, Pietermaritzburg, 3202. — Whitfield A.K. (2000) Available scientific information on individual South African estuarine systems WRC Report No.577/3/00
WSP SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, October 2020 KWAZULU-NATAL Page 2 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD APPENDIX
A EAP CV AND DECLARATION
BABALWA MQOKELI, Pr.Sci.Nat, MSc Ecological Environmental Consultant, Environment & Energy
CAREER SUMMA RY Babalwa holds a Masters degree in Ecological Science from the University of KwaZulu-Natal. She has more than 5 years of experience in environmental assessment and management, and 2 years of experience as an ecological scientist intern. She is a registered Professional Natural Scientist (Pr. Sci. Nat.) in Environmental Science (Reg. No: 009863) with the South African Council of Natural Scientific Professions. Babalwa has experience in the management and integration of various types of environmental assessments, including the mining, agricultural and renewable energy sector. Her experience includes environmental screening mapping using ArcGIS. She
has also been part of teams undertaking Strategic Environmental Assessment work. Years with the firm Babalwa’ recent experience includes auditing for companies within the petroleum 1 year 4-months sector, a desalination demonstration plant and manufacturing plants. Babalwa is passionate about incorporating environmental planning and legislation, and Years of experience socio-economic development to effectively contribute to the growth of South Africa. 6
Areas of expertise EDUCATION Environmental Impact Master of Ecological Science (MSc), University of KwaZulu-Natal, 2012 Assessments Pietermaritzburg, South Africa Basic Assessments Bachelor of Ecological Science, Honours (BSc Hons.), University of 2010 Ecological Monitoring KwaZulu-Natal, Pietermaritzburg, South Africa Strategic Environmental Planning Bachelor Biological Science, Honours (BSc), University of 2009 Zululand, Empangeni, South Africa Environmental Audits
Languages ADDITIONAL TRAINING
English Training in Health and Safety Representation, Medical Education 2017 IsiXhosa Centre isiZulu Understanding Watercourses and Managing impacts to their 2017
characteristics, IAIAsa Technical Workshop on the Roles and Responsibilities of 2016 Environmental Control Officer, IAIAsa CILLA Presentation Skills Course, CSIR 2016 CILLA Project Management 1 Course, CSIR 2015 Environmental Law Course, Shepstone & Wylie Attorneys 2015 Media Training Course, B Style Media 2015 Practical Adaption for Vulnerable Communities Training 2015 Workshop, South African Adaption Network African Marine Debris Summit, South African Network 2013
PROFESSIONAL MEMBERSHIPS
South African Affiliate of the International Association for Impact IAIA Assessment (5321) South African Council for Natural Scientific Professions, SACNASP Professional Natural Scientist (Reg: 009863) BABALWA MQOKELI, MES, Pr.Sci.Nat Environmental Consultant, Environment & Energy
PROFESSIONAL EXPERIENCE
Strategic Environmental Assessment — Strategic Environmental Assessment (SEA), South Africa (2018 - 2019): Project member. Strategic Environmental Assessment (SEA) for the Phased Gas Pipeline and Expansion of Electricity Grid Infrastructure Corridors. Client: National Department of Environmental Affairs. — Strategic Environmental Assessment (SEA) for Renewable Energy Development Zones, South Africa (2019): Project member, report writing and mapping. Stakeholder engagement and project support for SEA. Client: National Department of Environmental Affairs. Environmental Authorisation Process — Basic Assessment for the proposed Sappi Water Intake Pump House Upgrade in uMkhomazi, KwaZulu-Natal, South Africa (2020): Project Manager. Client: Sappi Southern Africa Ltd. — Basic Assessment for the proposed Flood Protection Berm at the Sappi Saiccor Mill in uMkhomazi, KwaZulu-Natal, South Africa (2020): Project Manager. Client: Sappi Southern Africa Ltd. — Basic Assessment for the proposed Transnet Pipeline Protection Structure in Elardus Park, Pretoria (2019): Project Manager. Client: Transnet Pipelines. — Basic Assessment for the proposed Transnet Pipeline Protection Structure in Kroonstad, Free State (2019): Project Manager. Client: Transnet Pipelines. — Basic Assessment for the proposed development of a Pig Production enterprise, Gauteng, South Africa (2019): Project Manager and GIS. Basic Assessment for the proposed development of a Pig Production enterprise on Plot 78 Jakkasldans, near Cullinan. Client: Zafoho assisted pro bono under the DEA-CSIR SNSD programme. — Basic Assessment for the proposed development of a Solar PV Facility (Vryburg Solar 1) and associated electrical infrastructure. Vryburg, North West, South Africa (2018): Project member and GIS. Client: Private energy company. — Basic Assessment for the proposed development of a Solar PV Facility (Vryburg Solar 2) and associated electrical infrastructure. Vryburg, North West, South Africa (2018): Project member and GIS. Client: Private energy company. — Basic Assessment for the proposed development of a Solar PV Facility (Vryburg Solar 3) and associated electrical infrastructure. Vryburg, North West, South Africa (2018): Project member and GIS. Client: Private energy company. — Basic Assessment for the proposed construction of electrical grid infrastructure to support the juwi Skeerhok PV1, 2 and 3 Solar Energy Facilities (SEF). Kenhardt, Northern Cape, South Africa (2018): Project member and GIS. Client: Private energy company. — Scoping and Environmental Impact Assessment (EIA) for the proposed development of a Solar PV Facility (Skeerhok PV 1). Kenhardt, Northern Cape, South Africa (2018): Project member and GIS. Client: Private energy company. — Scoping and Environmental Impact Assessment (EIA) for the proposed development of a Solar PV Facility (Skeerhok PV 2). Kenhardt, Northern Cape, South Africa (2018): Project member and GIS. Client: Private energy company. — Scoping and Environmental Impact Assessment (EIA) for the proposed development of a Solar PV Facility (Skeerhok PV 3). Kenhardt, Northern Cape, South Africa (2018): Project member and GIS. Client: Private energy company.
Page 2 of 4
BABALWA MQOKELI, MES, Pr.Sci.Nat Environmental Consultant, Environment & Energy
— Basic Assessment for the proposed expansion of a chicken layer facility, Springs, Gauteng, South Africa (2018): Client: New Age Chicken Supply assisted pro bono under the DEA-CSIR SNSD programme. — Basic Assessment for the proposed expansion of a chicken layer facility, Kameeldrift West, Pretoria, Gauteng, South Africa (2018): Project Manager and GIS. Client: IDCNKE assisted pro bono under the DEA-CSIR SNSD programme. — Basic Assessment for the proposed Sand Mining Project, Umzimkhulu River, Port Shepstone, KwaZulu-Natal, South Africa (2017). Project Manager and GIS. Client: Ms Singh assisted pro bono under the DEA-CSIR SNSD programme. — Basic Assessment for the proposed cultivation of 18.4 ha of fallow land for sugarcane production on sub 2 & 3 of Farm No. 850 Maybole in Baynesfield near Richmond, KwaZulu-Natal, South Africa (2017). Client: The She Creative House cc assisted pro bono under the SEA-CSIR SNSD programme. — Basic Assessment and Waste Management Licence Application, for Legae La Tlhago’s proposed expansion of a Pig production enterprise on Plot 684 Winterveldt Agricultural Holding Winterveldt, Pretoria, Gauteng, South Africa (2017): Project Manager and GIS. Client: Legae La Tlhago (Pty) Ltd assisted pro bono under the DEA-CSIR SNSD programme. Environmental Compliance Audit — Environmental Compliance Audits of the construction of the Sappi Project Vulindlela in uMkhomazi, KwaZulu-Natal (2020). Client: Sappi Southern Africa Ltd. — Regulation 34 Environmental Compliance Audit of the Bidvest Tank Terminals in Richards Bay, KwaZulu-Natal (2020). Client: Bidvest Tank Terminals. — Environmental Compliance Audits of the Desalination Plant in Bluff, Durban (2019). Client: Hitachi Limited — Regulation 34 Environmental Compliance Audits of Petrol Filling Stations in Avoca, Mandeni, Melmoth, Pietermaritzburg, Howick, Newcastle, Isipingo and Durban, KwaZulu-Natal (2019). Client: Sasol. — Regulation 34 Environmental Compliance Audit of the Sappi Amakhulu Expansion Project in uMkhomazi, KwaZulu-Natal (2019). Client: Sappi Southern Africa Ltd. — Regulation 34 Environmental Compliance Audits of the SAPREF Effluent Treatment Plant in Bluff, Durban, KwaZulu-Natal (2019). Client: SAPREF — Environmental Audits of oil reprocessing sites (Motolube, Universal Oil and FFS Refinery) (2019). Client: Rose Foundation. Research Projects — Groot River Macroinvertebrates monitoring research project, Plettenberg Bay, Western Cape, South Africa (2014): Project Coordinator. — Invasive Alien Mosquito fish research project, Plettenberg Bay, Western Cape, South Africa (2014): Project Coordinator. — Groot Estuary fish monitoring research project, Plettenberg Bay, Western Cape, South Africa (2014): Project Coordinator. — MSc Thesis: Aspects of digestion and physiology in Wahlberg's epauletted fruit bat (Epomophorus wahlbergi), Pietermaritzburg, KwaZulu-Natal (2012): Project Coordinator.
Page 3 of 4
BABALWA MQOKELI, MES, Pr.Sci.Nat Environmental Consultant, Environment & Energy
PUBLICATIONS AND PRESENTATIONS Publications — Downs, C.T., Mqokeli, B.R. & Singh, P. 2012. Sugar assimilation and digestive efficiency in Wahlberg’s epauletted fruit bat (Epomorphorus Wahlberg). Comparitive Biochmistry and Physiology A 161: 344-348. — Mqokeli, B.R. & Downs, C.T. 2013. Blood plasma glucose regulation in Wahlberg’s epauletted fruit bat. African Zoology 47:348-352. — Mqokeli, B.R. & Downs, C.T.2013. Palatal and lingual adaptions for frugivory and nectarivory in the Wahlberg’s epauletted fruit bat (Epomophorus Walhberg). Zoomorphology 132:111-119. — Mqokeli, B.R. & Downs, C.T. 2014. Is protein conent in the diet of Wahlberg’s epauletted fruit bats, Epomophours Wahlberg. African Zoology 49: 161-166. Presentations — Presented on the Overlap between biodiversity conservation & economic development: a case study of a proposed piggery, a project under the DEA-CSIR “Special Needs and Skills Development Programme” Annual IAIAsa Conference, Port Elizabeth, South Africa. 2016 — Presented on the Palatal and lingual adaptions for frugivory and nectarivory in the Wahlberg’s epauletted fruit bat, Microscopy Society of Southern African Annual Conference. Pretoria, South Africa. (2011).
Page 4 of 4
DECLARATION OF THE EAP
I, _____Babalwa Mqokeli______, declare that –
I act as the independent environmental assessment practitioner in this application; I have expertise in conducting environmental impact assessments, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity; I will comply with the Act, Regulations and all other applicable legislation; I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant; I will take into account, to the extent possible, the matters listed in Regulation 13 of the Regulations when preparing the application and any report relating to the application; I undertake to disclose to the applicant and the Competent Authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the Competent Authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the Competent Authority, unless access to that information is protected by law, in which case it will be indicated that such information exists and will be provided to the Competent Authority; I will perform all obligations as expected from an environmental assessment practitioner in terms of the Regulations; and I am aware of what constitutes an offence in terms of Regulation 48 and that a person convicted of an offence in terms of Regulation 48(1) is liable to the penalties as contemplated in Section 49B of the Act.
Disclosure of Vested Interest (delete whichever is not applicable) I do not have and will not have any vested interest (either business, financial, personal or other) in the proposed activity proceeding other than remuneration for work performed in terms of the Regulations; I have a vested interest in the proposed activity proceeding, such vested interest being: ______
______
______
______
Signature of the environmental assessment practitioner
WSP Environmental (Pty) Ltd Name of company: 21 October 2020 Date
www.wsp.com
APPENDIX
B STAKEHOLDER ENGAGEMENT REPORT
SAPPI SOUTHERN AFRICA LTD SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, KWAZULU-NATAL STAKEHOLDER ENGAGEMENT REPORT
21 OCTOBER 2020 PUBLIC
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, KWAZULU-NATAL STAKEHOLDER ENGAGEMENT REPORT
SAPPI SOUTHERN AFRICA LTD
TYPE OF DOCUMENT (VERSION) PUBLIC
PROJECT NO.: 41102161 DATE: OCTOBER 2020
WSP 1ST FLOOR, PHAROS HOUSE 70 BUCKINGHAM TERRACE, WESTVILLE DURBAN, 3629 SOUTH AFRICA
T: +27 31 240 8804 F: +27 31 240 8801 WSP.COM
QUALITY MANAGEMENT
ISSUE/REVISION FIRST ISSUE REVISION 1 REVISION 2 REVISION 3
Remarks Included in Draft Included in Final BAR BAR
Date August 2020 October 2020
Prepared by Babalwa Mqokeli Babalwa Mqokeli
Signature
Checked by Carla Elliott Carla Elliott
Signature
Authorised by Carla Elliott Carla Elliott
Signature
Project number 41102161 41102161
Report number 01 01
File reference G:\000 NEW Projects\41102161 - Sappi Saiccor Water Intake Upgrade
WSP is an ISO9001:2015, ISO14001:2015 and OHSAS18001:2007 certified company
SIGNATURES
PREPARED BY
Babalwa Mqokeli Environmental Consultant
REVIEWED BY
Carla Elliott Associate
This report was prepared by WSP Environmental (Pty) Ltd for the account of SAPPI SOUTHERN AFRICA LTD, in accordance with the professional services agreement. The disclosure of any information contained in this report is the sole responsibility of the intended recipient. The material in it reflects WSP Environmental (Pty) Ltd’s best judgement in light of the information available to it at the time of preparation. Any use which a third party makes of this report, or any reliance on or decisions to be made based on it, are the responsibility of such third parties. WSP Environmental (Pty) Ltd accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this report. This limitations statement is considered part of this report. The original of the technology-based document sent herewith has been authenticated and will be retained by WSP for a minimum of ten years. Since the file transmitted is now out of WSP’s control and its integrity can no longer be ensured, no guarantee may be given to by any modifications to be made to this document.
PRODUCTION TEAM
CLIENT
Environmentalist Samuel Mokoena
SHEQ Manager Craig Daniel
WSP
Environmental Consultant Babalwa Mqokeli
Associate Carla Elliott
TABLE OF 1 INTRODUCTION ...... 1 CONTENTS 1.1 Purpose of this Report ...... 1 1.2 Objective of the Stakeholder Engagement Process ...... 1
2 STAKEHOLDER NOTIFICATION ...... 2 2.1 Authority Consultation ...... 2 2.2 Advertisement...... 2 2.3 Public Notices ...... 2 2.4 Written Notification ...... 2 2.5 Stakeholder Database ...... 10 2.6 Comment and Response Report...... 16
3 DRAFT BASIC ASSESSMENT REPORT .. 1 3.1 Availability of the Draft Basic Assessment Report ...... 1 3.2 Comment and Response Report...... 1
4 FINAL BASIC ASSESSMENT REPORT .... 1
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
TABLES TABLE 1: INTERESTED AND AFFECTED PARTIES ...... 2 TABLE 2: STAKEHOLDER DATABASE ...... 10 TABLE 3: COMMENT AND RESPONSE TO NOTIFICATIONS ...... 1 TABLE 4: COMMENT AND RESPONSE REPORT ON DRAFT BAR ...... 1
FIGURES FIGURE 1: PROOF OF NEWSPAPER ADVERTISEMENT – MID SOUTH COAST RISING SUN ...... 4 FIGURE 2: ENGLISH AND ISIZULU SITE NOTICE AT THE ROADSIDE LEADING TO THE SAPPI SAICCOR MILL OFF THE N2 ...... 6 FIGURE 3: ENGLISH AND ISIZULU SITE NOTICE AT THE SAPPI SAICCOR ENTRANCE ...... 6 FIGURE 4: ENGLISH AND ISIZULU SITE NOTICE AT THE MAIN ACCESS GRAVEL ROADWAY TO THE PUMP HOUSE ...... 6 FIGURE 5: ENGLISH AND ISIZULU SITE NOTICE AT THE CRAIGIEBURN SPAR SUPERMARKET ENTRANCE ...... 6 FIGURE 6: WRITTEN NOTICE DISTRIBUTED TO VARIOUS STAKEHOLDERS...... 7 FIGURE 7: PROOF OF WRITTEN NOTICE DISTRIBUTED TO VARIOUS STAKEHOLDERS VIA EMAIL ON 21 JULY 2020 (PAGE 1)...... 8 FIGURE 8: PROOF OF WRITTEN NOTICE DISTRIBUTED TO VARIOUS STAKEHOLDERS VIA EMAIL ON 21 JULY 2020 (PAGE 2)...... 9 FIGURE 9: STAKEHOLDER NOTIFICATION LETTER ON AVAILABILITY OF THE DRAFT BAR FOR REVIEW .. 2
APPENDICES A EDTEA PRE-APPLICATION MEETING MINUTES B PROOF OF WRITTEN NOTIFICATION COMMENTS
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
C PROOF OF DRAFT BAR COMMENTS
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 SAPPI SOUTHERN AFRICA LTD
1 INTRODUCTION
1.1 PURPOSE OF THIS REPORT
Sappi Southern Africa Ltd (Saiccor Mill) is proposing the upgrade of the water intake pump house located in Umkhomazi. The mill’s existing water intake pump house, supplying raw water to the Mill’s processes, was installed and commissioned approximately 60 years ago. As a result, the current electrical equipment within the pump house is now obsolete and prone to regular breakdowns. The proposed water intake pump house upgrade requires environmental authorisation (EA) in terms of the National Environmental Management Act (Act 107 of 1998, as amended) (NEMA) and the 2014 Environmental Impact Assessment (EIA) Regulations (as amended). WSP Environment (Pty) Ltd has been appointed by Sappi to undertake the function of independent Environmental Assessment Practitioner (EAP) to facilitate the Basic Assessment (BA) process in accordance with the EIA Regulations. The stakeholder engagement process is being undertaken in accordance with the EIA Regulations. The process aims to ensure that potential stakeholders are identified and provided with an opportunity to review the details of the proposed project and to submit any issues and concerns.
1.2 OBJECTIVE OF THE STAKEHOLDER ENGAGEMENT PROCESS
In order to ensure compliance with the applicable national legislation, WSP undertook the stakeholder engagement process in a diligent manner at the outset of the BA Process. The NEMA requires an inclusive, transparent process of stakeholder engagement. The objectives of the stakeholder engagement process are as follows: — To ensure an open and transparent BA and consultation process, — To identify and inform stakeholders of the proposed project and associated environmental authorisation process, — Provide an opportunity for stakeholders to raise all issues, concerns and questions and ensure that these are considered in the environmental authorisation process for the project, — Ensure that stakeholders have an opportunity to make a meaningful contribution towards decision making by the competent authority, and — Compile a Comment and Response Report (CRR) of all issues, concerns and questions raised during the stakeholder engagement process.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 1 SAPPI SOUTHERN AFRICA LTD
2 STAKEHOLDER NOTIFICATION
2.1 AUTHORITY CONSULTATION
A pre-application meeting was held on 09 March 2020 with the KwaZulu-Natal Department of Economic Development, Tourism and Environmental Affairs (EDTEA) in order to discuss the proposed project. The minutes of this meeting are included in Appendix A. An application for EA was submitted to EDTEA on 22 July 2020 and acknowledged by EDTEA on 04 August 2020 with reference number: DM/0009/2020. The organs of state that have jurisdiction over the activity are EDTEA and the eThekwini Municipality (Development Planning, Environment and Management Unit). These two organs of state were provided written notification of the project via email. Other authorities provided with written notification included: — EDTEA: Coastal Unit; — Department of Water and Sanitation (DWS); — Ezemvelo KZN Wildlife; and — Amafa
2.2 ADVERTISEMENT
The EIA Regulations require that an advertisement be placed in a local newspaper or official gazette for a project of this nature. An advert was published in the Mid South Coast Rising Sun local newspaper on 24 March 2020 (Figure 1). The advertisement formally announced the commencement of the EA application process and requested that stakeholders register their interest with the EAP.
2.3 PUBLIC NOTICES
The EIA Regulations require that site notices be fixed at places that are conspicuous to and accessible by the public at the boundary or on the fence or along the corridor of the site where the application will be undertaken or any alternative site. English and IsiZulu site notices were placed at the following locations on 07 July 2020. — Roadside leading to the Sappi Saiccor Mill off the N2 (Figure 2); — Sappi Saiccor entrance (Figure 3); — Main access gravel roadway to the pump house (Figure 4); and — Craigieburn Spar Supermarket entrance (Figure 5).
2.4 WRITTEN NOTIFICATION
Section 41 of the EIA Regulations states that written notices must be given to the stakeholders outlined in Table 1. Written notice (Figure 6) notifying stakeholders of the proposed development was distributed via email on 21 July 2020 (Figure 7 – 8). Table 1: Interested and Affected Parties
STAKEHOLDER EAP COMMENT
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 2 SAPPI SOUTHERN AFRICA LTD
(i) The occupiers of the site and, if the proponent or Sappi is the landowner of the site in which the water intake applicant is not the landowner or person in control of pump house upgrade is proposed. the site which the activity is to be undertaken, the owner or person in control of the site where the activity is or is to be undertaken and to any alternative site where the activity is to be undertaken;
(ii) Owners, persons in control of, and occupiers of land Sappi provided WSP with a list of occupiers of land adjacent adjacent to the site where the activity is or is to be to the site for inclusion in the stakeholder database. Written undertaken and to any alternative site where the activity notice was distributed via email and SMS on 21 July 2020. is to be undertaken;
(iii) The municipal councillor of the ward in which the site The Ward Councillor (Buyisiwe Gumede (Ward 99)) was and alternative site is situated and any organisation of notified via email on 21 July 2020. ratepayers that represent the community in the area;
(iv) The municipality which has jurisdiction in the area; eThekwini Municipality were notified via email on 21 July 2020. This was sent to Nhle Zuma for distribution to the relevant line departments.
(v) Any organ of state have jurisdiction in respect of any Written notice was distributed to authorities (as per Section aspect of the activity; and 2.1) via email on 21 July 2020.
(vi) Any other party as required by the competent authority Stakeholders will be added on request by EDTEA as the competent authority.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 3 SAPPI SOUTHERN AFRICA LTD
Figure 1: Proof of Newspaper Advertisement – Mid South Coast Rising Sun
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 4 SAPPI SOUTHERN AFRICA LTD
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 5 SAPPI SOUTHERN AFRICA LTD
Figure 2: English and IsiZulu Site Notice at the Figure 3: English and IsiZulu Site Notice at the roadside leading to the Sappi Saiccor Mill off the Sappi Saiccor entrance N2
Figure 4: English and IsiZulu Site Notice at the Figure 5: English and IsiZulu Site Notice at the main access gravel roadway to the pump house Craigieburn Spar Supermarket entrance
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 6 SAPPI SOUTHERN AFRICA LTD
Figure 6: Written notice distributed to various stakeholders.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 7 SAPPI SOUTHERN AFRICA LTD
Figure 7: Proof of written notice distributed to various stakeholders via email on 21 July 2020 (Page 1)
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 8 SAPPI SOUTHERN AFRICA LTD
Figure 8: Proof of written notice distributed to various stakeholders via email on 21 July 2020 (Page 2)
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 9 SAPPI SOUTHERN AFRICA LTD
2.5 STAKEHOLDER DATABASE
Stakeholders with a potential interest in the project were identified at the project outset, and continue to be identified throughout the BA process. This included all relevant authorities (government departments and the eThekwini Municipality), relevant conservation bodies and non-governmental organisations (NGO’s), as well as neighbouring landowners and the surrounding community. The stakeholder database (Table 2) has been maintained throughout the BA process, and those who registered with an interest in the project as a result of the notification process. Table 2: Stakeholder Database
ORGANISATION NAME SURNAME
National Authorities
Department of Forestry, Fisheries and the Environment Lona Nondaka
Department of Forestry, Fisheries and the Environment: Integrated Thilivhali Meregi Coastal Management
Department of Forestry, Fisheries and the Environment: Coastal Mulalo Tshikotshi Pollution Management
Department of Forestry, Fisheries and the Environment: Oceans and Tandiwe Njajula Coasts
Department of Forestry, Fisheries and the Environment: Oceans and Nitasha Baijnath-Pillay Coasts
Department of Forestry, Fisheries and the Environment: Oceans and Ramaru Tshililo Coasts
Department of Human Settlements, Water & Sanitation Rendani Ndou
Department of Human Settlements, Water & Sanitation: Water Use Busi Tshabalala Efficiency
Provincial Authorities
Department of Economic Development, Tourism & Environmental Yugeshni Govender Affairs: eThekwini District EIA Component
Department of Economic Development, Tourism & Environmental Natasha Brijlal Affairs: eThekwini District EIA Component
Department of Economic Development, Tourism & Environmental Christabell Tshonaphi Affairs
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 10 SAPPI SOUTHERN AFRICA LTD
Department of Economic Development, Tourism & Environmental Vanessa Maclou Affairs
Department of Economic Development, Tourism & Environmental Omar Parak Affairs: Coastal Unit
Department of Economic Development, Tourism & Environmental Nozuko Mhlongo Affairs
Department of Human Settlements, Water & Sanitation Shameela Ramburan
Department of Human Settlements, Water & Sanitation Siyabonga Buthelezi
Department of Human Settlements, Water & Sanitation Neo Leburu
Department of Human Settlements, Water & Sanitation Renelle Pillay
Department of Human Settlements, Water & Sanitation Colleen Moonsamy
Department of Human Settlements, Water & Sanitation Jabulile (Ntombi) Madibe
Department of Human Settlements, Water & Sanitation SC Sikhosana
Department of Agriculture & Rural Development Karen Moodley Rural Development
KZN Department of Transport Juddy Reddy
KZN Corporate Governance and Traditional Affairs Vishnu Govender
Local Authorities eThekwini Municipality: EIA Section Nhle Zuma
Environmental Health Services /Air Quality Officer (AQO) Health Bruce Dale Unit eThekwini Municipality
Environmental Health Services /AQO Health Unit eThekwini Lucky Mkhize Municipality
Environmental Health Services /AQO Health Unit eThekwini Ratasha Pillay Municipality
Environmental Health Services /AQO Health Unit eThekwini Sam Sewlall Municipality
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 11 SAPPI SOUTHERN AFRICA LTD
eThekwini Municipality South Bruce Blake
Umdoni Municipality Kavershen Subben eThekwini Transport Authority Dookhi Revash
Ezemvelo KwaZulu Natal Wildlife Sam Ndlovu
Ezemvelo KwaZulu Natal Wildlife: Coordinator IEM Dominic Wieners
Ezemvelo KwaZulu Natal Wildlife Nerissa Pillay
Ezemvelo KwaZulu Natal Wildlife Santosh Bachoo
Amafa aKwaZulu Natali Weziwe Tshabalala
Amafa aKwaZulu Natali Bernadet Pawandiwa
Umkomaas Police Station Mark West
Ward 99 Councillor Buyisiwe Gumede
NGOs and CBOs
Coast Watch Carolyn Schwegman
Coastwatch KZN Judy Bell
Empisini Nature Reserve Mike Bentley
Groundwork Admin
Groundwork Euripidou Rico
KZN Conservancies Rob Crankshaw
Anti-Pollution Watch Dog MA Naicker
Anti-Pollution Watch Dog S Mkhize
South Durban Community Environmental Alliance (SDCEA) Sanusha Samson
SDCEA Shanice Gomes
SDCEA Desmond D'Sa
TC Robertson Nature Reserve Gower Mike
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 12 SAPPI SOUTHERN AFRICA LTD
Ubuntu Community Chest Celeste Netto
Umkomaas Tourism Mike Bentley
Vernon Crookes Nature Reserve Angus Brenda
Traditional Authorities
Traditional Leader (Induna) Justice Mkhize
Traditional Leader (Inkosi) Roy Bele
Traditional Leader (Inkosi) Cele
Traditional Leader (Inkosi) Hlengwa
Traditional Leader (Inkosi) Hlengwa
Traditional Leader (Inkosi) Luthuli
Traditional Leader (Inkosi) Mbhele
Traditional Leader (Inkosi) Mkhize
Traditional Leader (Inkosi) Mqadi
Media
Isolezwe Collin Pillay
Mid-South Coast Mail Juan C
Mid-South Coast Mail Tiffany Avern Taplin
Mid-South Coast Rising Sun Prakash Sadhai
Mid-South Coast Rising Sun Slindile Mgozi
Rising Sun Newspapers Krish Moodley
Surrounding Schools
Danganya Primary School Bongiwe Magigaba
Esizibeni Comprehensive High School Sipho Gumbi
Magabeni Primary School LV Lushaba
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 13 SAPPI SOUTHERN AFRICA LTD
Naidoo Memorial Primary School Naidoo Sirishem
Naidooville Primary School Ramiah
Opapheni Primary School Msomi Alexandra
Sheshisa Primary School Nzama
Sidelile High School Clive Thomas
Umkomaas Primary School Govender Steve
Umkomaas Secondary School Jagdev Prem
Adjacent Landowners
Private Dumisani Mdletshe
Private Ashram Brumdaw
Sappi Tenants
Babcock Lucas Coetzer
Babcock Michael Hawkins
Cross Refractory Lauren Sutherland
Divas Electrical Vuyi Mncwabe
HM Engineering Melissa Jansen van Vuuren
HM Engineering Clyde Govender
IPSS South africa Jane Helberg van Emmenis
J & D Scaffolding Joseph Mkhize
Lanara Projects Alan Norris
LCPS Contsruction Luca Casale
Lignotech South Africa Henry Reddy
Machine Moving & Engineering Regan Cherry
Norwell Engineering Earl Barnwell
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 14 SAPPI SOUTHERN AFRICA LTD
Protek Engineering Prega Naidoo
Protek Engineering Vignesh Naidoo
Sanitech Derrick Mnguni
Sanitech Jacquiline Stander
SGB Cape Yusuf Wilfred
Titan Projects Vaughen Renaud
Umbogintwini Riggers L&M Inspectors Karmen Britz
Watac Engineering Wim Jansen
Watac Engineering Wim Jansen
Waybar Construction Don Holtzhausen
General
Consultant Lisa Guastella
Consultant Allan Connell
Council for Scientific and Industrial Research (CSIR) Aadila Omarjee
CSIR Brent Newman
CSIR Steven Weerts
Khanya Hospice Umkomaas Neil McDonald
Lignotech South Africa Henry Reddy
Marine & Estuarine Research Nicolette Forbes
Phelamanga Rosemary Owen
Phelamanga Projects Fiona Bulman
Phelamanga Projects Rod Bulman
PUGASA/Coastwatch Andy Cobb
Scottburgh Surf Lifesaving Club Roy Carty
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 15 SAPPI SOUTHERN AFRICA LTD
Technical Association of the Pulp and Paper Industry of Southern Jodie Watt Africa (TAPPSA)
Private Individual Divas Mncwabe
Private Individual Mannie Pillay
Umkhomazi Blockmakers Association (Deputy Secretary) Naren Judanarain
Umkhomazi Blockmakers Association (Secretary) Mandla Mngadi
Umkhomazi Blockmakers Association (Treasurer) Anand Moodley
Umkhomazi Blockmakers Association (Vice Chairman) B M Nxumalo
Umkomaas Bowling Club Marion Liebenburg
Umkomaas Italian Club Patty Mazzaro
Private Individual Mzamo Mbili
Eskom Nandi Mbili
2.6 COMMENT AND RESPONSE REPORT
The CRR associated with the notifications is included in Table 3. Copies of comments received are included in Appendix B.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 16 SAPPI SOUTHERN AFRICA LTD
Table 3: Comment and Response to Notifications
NO. COMMENT RESPONSE
1. Melissa, HM Engineering – 22 July 2020 (via email)
1.1 HM Engineering would be interested in the below project. Please contact us on (details Contact details have been added to the stakeholder database. omitted on public record).
2. Ms R J Madibe, DWS – 22 July 2020 (via email)
2.1 Please receive the attached as a form of registration of the Department’s interest in the project.
2.2 This Department would like these to be addressed in the Basic Assessment Report:
2.2.1 The management of solid waste and hazardous waste material generated during the The BAR and the EMPr (Appendix F of the BAR) for this project includes the necessary construction phase of the project. management actions for general and hazardous waste during the construction phase.
2.2.2 Stormwater Management Plan/System. A Stormwater Management Plan is in place for the existing operations at the Mill. The proposed area of construction work is located in an area with existing drainage infrastructure.
2.2.3 Wastewater and sewage treatment and/or management including the type of toilet Existing ablutions will be used by contractors. The EMPr (Appendix F of the BAR) facilities to be provided for workers. includes the necessary measures for the management of wastewater.
2.2.4 Erosion control measures to be implemented. All precautionary measures to prevent and/or manage erosion are addressed in this BAR and EMPr (Appendix F of the BAR).
2.2.5 Environmental Management Programme for the construction of the project. An EMPr (Appendix F of the BAR) has been compiled for the project to ensure that any likely negative biophysical and socio-economic impacts are mitigated.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 1 SAPPI SOUTHERN AFRICA LTD
2.2.6 Spill contingency plan for the construction and operational phase of the project. A Spill Management Plan is in place for the existing Mill operations. This plan will be updated to include spill control measures contained in the EMPr (Appendix F of the BAR) for this project.
2.2.7 Erosion control measures to be implemented. All precautionary measures to prevent and/or manage erosion are addressed in the BAR and EMPr.
2.2.8 This Department would like to reiterate that it is the responsibility of the Applicant to Noted. A pre-application meeting request has been submitted to the DWS via the e-Wulaas identify all water uses applicable to the activity in terms of Section 21 of the NWA and platform, in order to determine water use requirements for the proposed project. ensure that all applicable water uses are authorised as such. The Applicant must consult with this Department if clarity is required with regard to water uses and water use authorisations. These water uses are listed in Table 1: Water Uses as per Section 21 of the NWA.
2.2.9 The river, stream, and associated tributaries must be treated as sensitive environment The estuary and wetland system in the project area have been identified as sensitive areas. Caution must be exercised when developing near any watercourse. Please note environments (Estuarine Functional Zone and NFEPA Wetland). All construction work that the Applicant will require an authorisation from the Department for any activity will be managed to ensure that these areas are treated as no-go zones. Precautionary within the riparian habitat or 1: 100 year floodline, whichever is the greatest distance. measures to ensure protection of the aquatic and riparian systems are stipulated in the EMPr (Appendix F of the BAR). A pre-application meeting request has been submitted to the DWS via the e-Wulaas platform, in order to confirm authorisation process required.
2.2.10 A pre-water Use licence Application meeting is recommended, the Applicant may A pre-application meeting request has been submitted to the DWS via the e-Wulaas contact Ms Zama Hadebe of the Water Use Authorisation Unit on 031 336 2767/2700 platform, in order to determine water use requirements. for any water use authorisation queries and guidance.
2.2.11 The onus is on the Applicant to identify all the water uses activity to be undertaken in Noted. relation to the proposed project and ensure that authorisation is obtained prior to commencing with the activities.
3. Nhle Zuma, eThekwini Municipality – 22 July 2020 (via email)
3.1 eThekwini Municipality would like to comment on the proposed upgrade, please can The Draft BAR was submitted via Dropbox to the Municipality, in line with this request, you send us the documents via drop box to this email address. for comment.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 2 SAPPI SOUTHERN AFRICA LTD
4. Bobby Peek, Groundwork – 23 July 2020 (via email)
4.1 Please remove my details from this process. Contact details have been removed from the stakeholder database.
5. Thembi, Divas Electrical – 23 July 2020 (via email)
5.1 We confirm we are interested in this project. Our Detail (details omitted on public Contact details have been added to the stakeholder database. record).
6. Rose Owen, Phelamanga – 24 July 2020 (via email)
6.1 Please register Phelamanga and the Sappi Coastal Advisory Forum as an I&AP. Please Phelamanga and the Coastal Advisory Forum have been added on the project’s database. use my contact details.
6.2 I have sent the below out to our forum members. I have also placed the letter as a link Noted. within our website – see attached screengrab. “Dear Colleagues We received notice from WSP regarding the Basic Assessment for the Proposed Sappi Water Intake Pump House Upgrade at the Sappi Saiccor Mill. We would like to share this with you as a potential I&AP - See letter as received below. Please contact Babalwa the EAP and register as an I&AP. The letter is also available at the following link on the Sappi CAF page within our website: https://www.phelamanga.co.za/19-sappi-saiccor-coastal-advisory-forum”
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 3 SAPPI SOUTHERN AFRICA LTD
3 DRAFT BASIC ASSESSMENT REPORT
3.1 AVAILABILITY OF THE DRAFT BASIC ASSESSMENT REPORT
The Draft BAR was available for public review for a period of 30 days from 13 August 2020 to 13 September 2020 (Figure 9). The 30-day period was agreed upon by EDTEA during the pre-application meeting and subsequent minutes (Appendix A) provided during the National Lockdown Level 3. WSP has understood this to be confirmation that the public participation approach discussed and contained in these minutes is acceptable. Hard copies and/or electronic copies of the report were provided to the relevant regulatory and local authorities for comment, including: — EDTEA: Coastal Unit; — DWS; — Ezemvelo KZN Wildlife; and — Amafa In terms of Directions Regarding Measures to Address, Prevent and Combat the Spread of Covid -19 Relating to National Environmental Management Permits and Licences, published on 05 June 2020, reports may not be made available at any public places or premises closed to the public, as contemplated in the regulations. Stakeholders were notified of the availability of the report as follows: — Ward 99 Councillor offices (01 Calendula Avenue, Civic Centre, Craigieburn Umkomaas 4170); — WSP on request; and — Online on the WSP website: http://www.wspgroup.com/en/WSP-Africa/What-we-do/Services/All-Services- A-Z/Technical-Reports/
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 1 SAPPI SOUTHERN AFRICA LTD
Figure 9: Stakeholder Notification Letter on availability of the Draft BAR for review
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 2 SAPPI SOUTHERN AFRICA LTD
3.2 COMMENT AND RESPONSE REPORT
Comments received in response to the Draft BAR are included as Appendix C. The CRR is presented as Table 4. Table 4: Comment and Response Report on Draft BAR
COMMENT RESPONSE
Rose Owen, Phelamanga – 17 August 2020 (via email)
Thanks for the notice – I have sent it on to our forum, I have also loaded the letter to Noted. our forum page on the website.
See below communication as sent to forum members. Noted. “Dear Colleagues We received notice from WSP regarding the Basic Assessment Report availability for the Proposed Sappi Water Intake Pump House Upgrade at the Sappi Saiccor Mill. We would like to share this with you as a potential I&AP - See letter as received below. Please contact Babalwa the EAP and register as an I&AP. The letter is also available at the following link on the Sappi CAF page within our website: https://www.phelamanga.co.za/19-sappi-saiccor-coastal-advisory-forum”
eThekwini Municipality – 07 September (via email)
With reference to the abovementioned Draft Basic Assessment Report please be advised that various Municipal Departments have had sight of the proposal and the following comments are submitted for your attention:
Cleansing and Solid Waste (CSW) Noted. No comments or requirements for this proposed project.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 1 SAPPI SOUTHERN AFRICA LTD
Coastal Policy Noted. No comments.
Coastal Stormwater and Catchment Management (CSCM) Noted No objections to this proposal.
Disaster Management Noted. No comments to date.
Environmental Health — All construction work will be carried out in accordance with good building practice and in strict accordance with the current version of: The Basic Assessment report provides good summary of mitigation measures for the — The model preamble for trades as issued by the Association of South African environmental impacts identified in terms of noise, water pollution, air quality, Quantity Surveyors Occupational Health and Safety, waste management, risk management and transportation. Therefore, this department supports the upgrade of the Sappi water — South African National Standard (SANS) intake pump house. However, it is recommended that the development be conducted — eThekwini Municipality requirements within the following parameters as it is articulated in the BAR: — Relevant South African Bureau of Standards (SABS) — Construction to be accordance with the Occupational Health and Safety Act 85 of — National Home Builders Registration Council (NHBRC) Regulations 1993, National Building Regulations and any other applicable Regulations and The Occupational Health and Safety Act 85 of 1993: Construction Regulations eThekwini Bylaws. — Development plans for the proposed water intake building were submitted to the Monitor and ensure control measures for potential pollution and or contamination — eThekwini municipality for approval. Municipal approval, dated 17 March 2020, was sources e.g. noise pollution, air pollution, dust emissions, hazardous substances received for the proposed project. and waste management, effluent and storm water management to ensure that the project is done according to stipulated legislation and in terms of the bylaws. The EMPr Section 1.4: Proposed Construction Activities includes building design specifications that the proposed project will adhere to. — All waste and rubble generated during/and or after construction to be disposed off at an approved landfill site (records thereof to be kept). — The recommendations and requirements to minimise and/or prevent potential pollution and/or contamination have been included in Section 3 of the EMPr. — Water and ablution facilities for staff at the construction site to be available at the beginning and to the end of construction. Effluent to be disposed of at an approved — Measures for waste management are contained in Section 3.2.4 of the EMPr, these site (records to be kept). include the disposal of generated waste at a licensed disposal facility, as well as keeping records of proof of disposal. This department reserves the right to call for additional requirements should any health — There are adequate existing toilets available on site, which will be used by contractors nuisance arise. throughout the construction phase. The EMPr includes measures for the management of ablution facilities on site.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 2 SAPPI SOUTHERN AFRICA LTD
Environmental Planning and Climate Protection Department (EPCPD) Noted. The Environmental Planning and Climate Protection Department (EPCPD) has reviewed the Draft Basic Assessment Report for the proposed Sappi water intake pump house upgrade, Sappi Saiccor Mill In Umkhomazi, Kwazulu-Natal and it has been noted the site is located within the Durban Metropolitan Open Space System (D’MOSS), therefore the site is of biodiversity importance to this Department. Furthermore, the site is adjacent to uMkhomazi River which is classified as a National Freshwater Ecosystem Priority Area and considered of strategic conservation importance with the estuary being a critical provider of ecosystem services. The proposed upgrade has a potential to impact the aquatic and the terrestrial ecology. However, it has been noted that the specialist studies have been conducted thus providing more evidence that uMkhomazi is important to near-shore habitat formation thus maintaining beaches in the region and that the area supports the functioning of Critical Biodiversity Areas within the region. The mitigation measures provided in the report would render the impacts minimal should the applicant comply with them, thus reducing the impacts on the environment while ensuring that the development takes place. The applicant is advised not to commence with any development of the property prior to the issuance of the Environmental Authorisation in terms of the National Environmental Management Act, 1998.
eThekwini Electricity A copy of the Draft BA Report has been submitted to Eskom for comment and to confirm interest on the project based on this comment. It is also important to note that this proposed Please note that HV Planning and MV/LV Operations have no objections to this project will not entail any overhead lines and will not make use of Eskom’s power. This application. An approval from Eskom would also be required and they would be part of the Mill (water intake pump house) is fed from two electrical substations from the required to comment as their High voltage infrastructure is around the Sappi plant. This Mill, that is, using the Mill’s generated power supply. Additionally, the proposed project site is in Eskom’s area of supply. will not increase the current electricity demand, nor increase electricity demand from Eskom.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 3 SAPPI SOUTHERN AFRICA LTD
eThekwini Transport Authority (ETA) Noted. Documents considered in the review: The comment and/or recommendation on the inclusion of the condition in the Decision Notice is for the review of the Competent Authority (. i.e. EDTEA). Draft Basic Assessment Report (DM/0009/2020) prepared by WSP. Key factors considered: — Total Site Area = 62m² — The size of the Motor Control Centre (MCC) in the pump house is = 62m² — The pump house is existing and is being upgraded The application is APPROVED subject to the following Conditions to be included in the Decision Notice. — The development is to upgrade of the existing water pump house, restricted to a maximum of 62 m² of MCC of the water pump house, with only 16 m² minimal touch footprint. Further development is subject to a traffic impact assessment. — The water pump house is located adjacent to the Umkhomazi River.
EThekwini Water and Sanitation (EWS – Water Planning) Noted. No comments to date.
Fire Safety — Building plans were submitted to the eThekwini Municipality’s Fire and Emergency Services for approval. Approval dated 11/02/2020 was received. This department has no objection to the application subject the applicant adheres to the — Noted. Sappi plans to install additional sensors and fire suppressants to cover the following: additional building area, prior to the issuance of the Occupancy Certificate and — Building plans have been submitted to this department for scrutiny and approval. building use. — The site must comply with the Interim Code Relating to Fire Prevention. — Full compliance with other applicable Legislative requirements.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 4 SAPPI SOUTHERN AFRICA LTD
Land Use Management (LUM) Noted. This Branch has no objection at this stage to the proposed Sappi Water Intake Pump House Upgrade. The Land Use Management Branch reserves its right to provide further comment on the Final Basic Assessment Report as well as during the eThekwini Municipality: Planning and Land Use Management By-Law application process.
Parks, Leisure and Cemeteries Noted. No comments to date.
Pavement & Geotech The geology description in section 9.2 has been updated in the BAR. P&GE has no geotechnical objection to this development. A Geotechnical study was undertaken for the proposed project to form the engineering basis of the building. The study evaluated the rock slope and founding conditions for the The geological description in section 9.2 is a tad confused. We suggest that a founding water intake building extension. This study was undertaken by Gondwana Geo Solutions investigation is carried out by a suitably experienced, registered engineering geologist (dated 29 May 2019) and is included as Appendix E of the BAR. before finalising the foundation design.
Strategic Spatial Planning (SSP) Noted. The Strategic Spatial Planning Branch has no objections to the above draft basic assessment for the construction of a Motor Control Centre to maintain a continuous water supply for the Sappi’s mill processes. — This branch’s support is subject to the applicant meeting all sector requirements. — This support should not be deemed to be an approval of the eThekwini Municipality. — This branch reserves the right to comment further should the need arise.
Catalytic Projects Noted. N/A
Natasha Brijlal, KwaZulu-Natal Department of Economic Development, Tourism and Environmental Affairs – 17 September 2020 (via email)
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 5 SAPPI SOUTHERN AFRICA LTD
The Draft Basic Assessment Report (dBAR) with reference number DM/0009/2020, which was submitted to the Department of Economic Development, Tourism and Environmental Affairs (hereafter referred to as “the Department”) on 13 August 2020 has reference. Comments on the dBAR are as follows:
The recommendations to prevent uncontrolled access of vehicles through the buffer The locality map included in the EMPr (Appendix F of the BAR) has been updated to area that can cause an adverse impact on the integrity and functioning of the sensitive include and/or depict the existing access route to the site (Figure 2). areas states that construction vehicles must only make use of existing access routes. A depiction of this must be included in the final layout plan.
A preliminary Construction Methodology/Environmental Method statement must be A Method Statement relating to civil works for the construction of the proposed extension developed in consultation with the SAPPI project team and included in the final BAR to the water intake pump house was developed in consultation with the Sappi project team as an appendix to the EMPr and included in tendering documentation. The preliminary and is included in the final BAR, as Appendix A of the EMPr. The Method Statement is in construction phase methodology must detail how construction activities as listed on line with key mitigation measures as detailed in the EMPr for this project. It is important to page 5, section 2.7 of the EMPr will be in line with the recommended mitigation note that the Method Statement will be used in conjunction with the EMPr during project measures contained in the dBAR and associated specialist studies. This preliminary activities and included in Contractor tender documents, consequently construction methods Construction Methodology/Environmental method statement may be amended once a will be in line with the recommended measures contained in the EMPr. contractor is appointed should the need arise.
Refer to page 13 and figures 3-1 and 3-2 of the Estuary Specialist Impact Assessment: The EAP has reviewed this comment and relevant figures within the report, and no The figures seem not to have been captured correctly, with 3-1 only showing the blue discrepancies were noted in the figures indicated. The Estuarine Specialist has however dot indicating the location and extent of the uMkhomazi estuary and the yellow dot modified the maps for ease of reference. indicating the location of the proposed development area but without a base map of the estuary. Figure 3-2 does not have the existing Intake pump station and weir at the head of the estuary as stated.
Comments on the EMPr dated March 2020:
Page 6, section 2.8 of the EMPr states: “In the operational phase, to avoid complexity, Noted. it is proposed that the project aspects dealt with in this EMPR will be incorporated into the Standard Operating Procedures (SOP) forming part of Sappi’s ISO 14000 EMS, subject to the approval of this approach by the EDTEA; as such this EMPr will be superseded i.e. become redundant in the operational phase. The Department supports this proposal as the activity triggered by the proposed development does speak to operational aspects.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 6 SAPPI SOUTHERN AFRICA LTD
Furthermore, the incorporation of the operational phase aspects of the proposed Noted. development into SAPPI’s ISO 14000 EMS promotes the principles of duty of care and is in line with Section 28 of NEMA, 1998 (Act No. 107 of 1998).
The EMPr must specify clear timeframes for carrying out rehabilitation measures of Rubble and stockpiles not being used as backfilling will be removed from site on a regular areas disturbed by construction activities, removal of stock piles and removal of rubble. basis throughout construction. All remaining stockpiles will be removed within one week of completion of the construction phase. Rehabilitation, where necessary, will be undertaken within the last four weeks of construction. The recommendations regarding stockpiles, rubble and rehabilitation as well as the timeframes to carry out the recommended measures have been specified in the EMPr.
Omar Parak, KwaZulu-Natal Department of Economic Development, Tourism and Environmental Affairs (Coastal Unit) – 28 September 2020 (via email)
Is any infrastructure or equipment in the existing pumphouse to be The space that will be created by the removal (without demolition) of some of the current decommissioned? The related question is that if there is decommissioning or control technology that is being replaced will not be sufficient to accommodate the new additional space, can the proposed Motor Control Centre (MCC) room be housed in the technology. The additional space is therefore required to accommodate the new technology existing structure? in the proposed building
What are the load shedding contingencies applicable to the MCC? Will an additional An additional generator will not be required for the proposed project. This part of the Mill generator be required? (i.e. the water intake pump house) is fed from two separate electrical substations at the Mill. Therefore, there is capability to ensure uninterrupted power supply to the water intake pump house. It is also important to note that the proposed upgrade and installation will not increase the current electricity demand.
All recommendations and mitigation measures identified by the estuarine specialist for Noted. construction and operational phases are supported and must be implemented.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 7 SAPPI SOUTHERN AFRICA LTD
4 FINAL BASIC ASSESSMENT REPORT
The final BAR will be submitted to the EDTEA, and made available to all stakeholders for final review and comment. Stakeholders will be requested, in terms of the EIA Regulations, as amended, to submit any further comments directly to the EDTEA and provide a copy to the EAP.
SAPPI WATER INTAKE PUMP HOUSE UPGRADE, SAPPI SAICCOR MILL IN UMKHOMAZI, WSP KWAZULU-NATAL October 2020 Project No. 41102161 Page 1 SAPPI SOUTHERN AFRICA LTD
APPENDIX
A EDTEA PRE- APPLICATION MEETING MINUTES
APPENDIX
APPENDIX
APPENDIX
APPENDIX
B PROOF OF WRITTEN NOTIFICATION COMMENTS
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
C PROOF OF DRAFT BAR COMMENTS
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
APPENDIX
C WETLAND RISK ASSESSMENT
ADDENDUM: A WETLAND RISK ASSESSMENT FOR THE SAPPI WATER INTAKE BUILDING PROJECT
DATE 4 November 2019
CLIENT
Prepared by:
The Biodiversity Company Cell: +27 81 319 1225 Fax: +27 86 527 1965 [email protected] www.thebiodiversitycompany.com 1 www.thebiodiversitycompany.com
Wetland Risk Assessment
Sappi Water Intake Building
ADDENDUM: A WETLAND RISK ASSESSMENT FOR THE SAPPI WATER Report Name INTAKE BUILDING PROJECT Submitted to
Andrew Husted
Andrew Husted is Pr Sci Nat registered (400213/11) in the following fields of practice: Report Writer Ecological Science, Environmental Science and Aquatic Science. Andrew is an Aquatic, Wetland and Biodiversity Specialist with more than 12 years’ experience in the environmental consulting field. Andrew has completed numerous wetland training courses, and is an accredited wetland practitioner, recognised by the DWS, and also the Mondi Wetlands programme as a competent wetland consultant. The Biodiversity Company and its associates operate as independent consultants under the auspice of the South African Council for Natural Scientific Professions. We declare that we have no affiliation with or vested financial interests in the proponent, other than for work performed under the Environmental Impact Assessment Regulations, 2014 (as amended). We have no conflicting interests in the undertaking of this activity and have Declaration no interests in secondary developments resulting from the authorisation of this project. We have no vested interest in the project, other than to provide a professional service within the constraints of the project (timing, time and budget) based on the principles of science.
2 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building DECLARATION I, Andrew Husted, declare that:
I act as the independent specialist in this application;
I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;
I declare that there are no circumstances that may compromise my objectivity in performing such work;
I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, regulations and any guidelines that have relevance to the proposed activity;
I will comply with the Act, regulations and all other applicable legislation;
I have no, and will not engage in, conflicting interests in the undertaking of the activity;
I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing any decision to be taken with respect to the application by the competent authority; and the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority;
All the particulars furnished by me in this form are true and correct; and
I realise that a false declaration is an offence and is punishable in terms of Section 24F of the Act.
Aquatic & Wetland Ecologist
The Biodiversity Company
November 2019
3 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building 1 Introduction The Biodiversity Company has been commissioned to complete a wetland impact (risk) assessment for the Sappi Southern Africa Limited (Sappi) Saiccor water intake building project. The project is for the construction (and operation) of an electrical control room, which will be located adjacent to the existing pumphouse building. An overview of the location of the control room in relation to the existing building and the accompanying structures is presented in Figure 1.
Figure 1: The first floor overview of the project (Andrew Fraser, 2019)
The assessment has been completed in accordance with the requirements of the Water Use Authorisation in terms of Section 21(c) and (i) of the National Water Act (Act 36 of 1998) (NWA).
1.1 Background WSP Environmental (Pty) Ltd (WSP) completed a wetland delineation and functional assessment for the project in 2016 (WSP, 2016). All wetlands on or within 500m of the site were delineated and wetland functional assessments conducted. One floodplain wetland was located within 500m of the study site. The Present Ecological State (PES) of the system was determined to be largely modified (or class D). The Ecological Importance and Sensitivity of the system was determined to be high. It was recommended that a 30m buffer is set to protect wetland functionality.
4 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building
Figure 2: The wetland delineation and 30m buffer for the study site (WSP, 2016)
5 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building
2 Methodology The risk assessment was completed in accordance with the requirements of the Department of Water and Sanitation (DWS) General Authorisation (GA) in terms of Section 39 of the National Water Act (No. 36 of 1998) for water uses as defined in Section 21(c) or Section 21(i) (GN 509 of 2016).
2.1 Limitation This assessment has assumed all baseline information (WSP, 2016) provided is true and accurate, and remains valid for this risk assessment. Desktop data has been considered to supplement this component of the assessment (Figure 3).
Figure 3: The location of the control room in relation to the NFEPA wetlands and floodplain (WSP, 2016) 3 Risk Assessment Sappi Saiccor has proposed additions to the existing water intake building, with designs provided by Andrew Fraser (2019). Illustrations of the proposed electrical control room in relation to the existing water intake building are presented in Figure 4.
6 www.thebiodiversitycompany.com
Wetland Risk Assessment
Sappi Water Intake Building
Figure 4: Architectural illustrations for the proposed control room (Andrew Fraser, 2019)
7 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building
The risk assessment has considered the following:
The project is for the expansion of an existing building (Figure 5);
The placement of new support columns for the suspension of the control room. Four columns are proposed;
The dominant materials include steel balustrades, bricks and concretes;
The only physical (or direct) disturbance to the ground will be associated with the four support columns, which are behind an existing retaining wall;
Only construction and operational phases have been considered for the risk assessment, no decommissioning phases has been assessed; and
The structure is located directly adjacent to an existing building, on the right-hand bank of the uMkomaas River. This project is not considered to be a new development, but rather the expansion of an existing structure. Based on this, risks are expected to be low due to the level of onsite disturbance.
Figure 5: The approximate location of the control room in relation to the existing structure and the NFEPA wetland
The risk assessment undertaken for the control room has considered both direct risks and indirect risks posed by the construction and operational phases of the project. The proposed control room is located adjacent to the uMkomaas River (within 5m), on the right-hand embankment of the delineated floodplain system. According to Macfarlane and Bredin (2017)
8 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building a minimum buffer of 15m is recommended for “offices”, which is deemed applicable for the control room. Due to the project being for the expansion of an existing building, with existing retaining walls, tunnels and foundations, no direct risks to the wetland are expected for the project. Further to this, the physical disturbance to the area is also greatly reduced considering that only four (4) columns are planned for the suspension of the room. A key consideration for the risk assessment is the indirect risks posed, particularly for the construction phase of the project.
Pre-mitigation aspects during the construction phase have scored “Low” significance ratings, with the significance expected to be further reduced by means of implementation of relevant mitigation measures and recommendations outlined in Section 3.1: Mitigation Measures. As for the operational phase, some of the associated aspects involved have been scored “Moderate” significance ratings of which all are expected to be decreased to “Low” with application of prescribed mitigation measures (Table 1 to Table 3).
9 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building
Table 1: Impacts assessed for the proposed project
Andrew Husted Pr Sci Nat 400213/11 Activity Aspect Impacts to Wetlands Alteration to flow volumes Clearing of vegetation Alteration of patterns of flows (increased flood peaks) Increase in sediment inputs & turbidity Alteration to flow volumes Stripping of soil Alteration of patterns of flows (increased flood peaks) Increase in sediment inputs & turbidity Alteration to flow volumes Excavation of foundations Alteration of patterns of flows (increased flood peaks) Increase in sediment inputs & turbidity Alteration to flow volumes Delivery of building material (heavy vehicles) Alteration of patterns of flows (increased flood peaks) Increase in sediment inputs & turbidity Alteration to flow volumes Operation of machinery and vehicles in close proximity to the Alteration of patterns of flows (increased flood peaks) Construction of control room watercourse area Increase in sediment inputs & turbidity Alteration to flow volumes Operation of machinery and vehicles in adjacent areas Alteration of patterns of flows (increased flood peaks) Increase in sediment inputs & turbidity Waste and ablutions facilities Inputs of toxic organic contaminants Mixing and pouring concrete Inputs of toxic organic contaminants Storage of materials on site Inputs of toxic organic contaminants Increase in sediment inputs & turbidity Final landscaping and shaping Inputs of toxic heavy metal contaminants Alteration of acidity (pH) Post-construction rehabilitation Increase in sediment inputs & turbidity Alteration to flow volumes Alteration of in channel flows Alteration of patterns of flows (increased flood peaks) Increase in sediment inputs & turbidity Operation of control room Alteration to flow volumes Alteration of surface drainage and runoff Alteration of patterns of flows (increased flood peaks) Increase in sediment inputs & turbidity Stormwater management system Alteration to flow volumes
10 www.thebiodiversitycompany.com
Wetland Risk Assessment 2019
Sappi Saiccor Project
Alteration of patterns of flows (increased flood peaks) Increase in sediment inputs & turbidity Alteration of acidity (pH) Alteration to flow volumes Establishment of alien plants on disturbed areas Alteration of patterns of flows (increased flood peaks) Alteration to flow volumes Sedimentation of wetland areas (altered flows) Alteration of patterns of flows (increased flood peaks) Increase in sediment inputs & turbidity Alteration of patterns of flows (increased flood peaks) Human disturbance in wetland areas Increase in sediment inputs & turbidity
11 www.thebiodiversitycompany.com Wetland Risk Assessment 2019
Sappi Saiccor Project Table 2: DWS Risk Impact Matrix for the proposed project
Flow Water Spatial Aspect Habitat Biota Severity Duration Consequence Regime Quality scale Construction Phase Clearing of vegetation 1 1 0 1 0.75 1 1 2.75 Stripping of soil 0 1 0 0 0.25 1 1 2.25 Excavation of foundations 1 1 0 1 0.75 1 1 2.75 Delivery of building material (heavy vehicles) 0 1 0 1 0.5 1 1 2.5 Operation of machinery and vehicles in close proximity to the watercourse 0 1 0 1 0.5 1 1 2.5 area Operation of machinery and vehicles in adjacent areas 0 1 0 1 0.5 1 1 2.5 Waste and ablutions facilities 0 1 1 1 0.75 1 1 2.75 Mixing and pouring concrete 0 1 1 1 0.75 1 1 2.75 Storage of materials on site 0 1 0 0 0.25 1 1 2.25 Final landscaping and shaping 1 1 0 1 0.75 1 1 2.75 Post-construction rehabilitation 0 1 1 1 0.75 1 1 2.75
Operational Phase
Alteration of in channel flows 2 1 0 1 1 2 4 7 Alteration of surface drainage and runoff 2 1 0 1 1 2 4 7 Stormwater management system 1 1 1 1 1 2 4 7 Establishment of alien plants on disturbed areas 1 0 1 1 0.75 1 4 5.75 Sedimentation of wetland areas (altered flows) 1 1 1 1 1 2 4 7 Human disturbance in wetland areas 0 0 0 1 0.25 2 4 6.25
12 www.thebiodiversitycompany.com
Wetland Risk Assessment
Sappi Water Intake Building Table 3: DWS Risk Impact Matrix for the proposed project continued
Frequency Frequency Legal Without With Aspect Detection Likelihood Sig. of activity of impact Issues Mitigation Mitigation Construction Phase Clearing of vegetation 1 3 5 2 11 30.25 Low Low Stripping of soil 1 3 5 2 11 24.75 Low Low Excavation of foundations 1 3 5 2 11 30.25 Low Low Delivery of building material (heavy vehicles) 1 3 1 2 7 17.5 Low Low Operation of machinery and vehicles in close proximity to the 2 3 1 2 8 20 Low Low watercourse area Operation of machinery and vehicles in adjacent areas 2 3 1 3 9 22.5 Low Low Waste and ablutions facilities 2 3 1 2 8 22 Low Low Mixing and pouring concrete 2 3 1 2 8 22 Low Low Storage of materials on site 2 3 1 2 8 18 Low Low Final landscaping and shaping 2 2 1 2 7 19.25 Low Low Post-construction rehabilitation 2 2 1 2 7 19.25 Low Low Operational Phase Alteration of in channel flows 3 2 1 2 8 54 Low Low Alteration of surface drainage and runoff 3 1 1 2 7 49 Low Low Stormwater management system 3 1 1 2 7 49 Low Low Establishment of alien plants on disturbed areas 2 1 1 1 5 28.75 Low Low Sedimentation of wetland areas (altered flows) 3 1 1 1 6 42 Low Low Human disturbance in wetland areas 2 1 1 1 5 31.25 Low Low
13 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building The proposed development consists of a construction and operational phase, there has been no allowance for a decommissioning phase for the project. The project will entail the clearing of areas and excavation of foundations for four (4) columns, and the construction of a control room supported by the columns. Despite the proximity to the uMkomaas River, the significance of all pre-mitigation risks was determined to be “Low”. This is largely attributed to the project being for the expansion of an existing building, but also the small disturbance footprint area required for four columns. Despite these Low risks, supporting mitigation measures have been prescribed.
The operation of the development area poses “Low” risks to the identified wetland, pre-mitigation. The significance of the risks is expected to be reduced during the operational phase of the project, due to the four (4) columns being the only disturbance to the ground level, and to an area already developed. Similarly, mitigation measures have been prescribed to ensure best practice is achieved, and the identified risks are mitigated.
3.1 Construction Mitigation Measures The following general mitigation measures are provided:
The wetland buffer area must be visibly demarcated and avoided for the portion of the facility (and supporting activities) not required to encroach into the 15m buffer;
The construction vehicles and machinery must make use of existing access routes as much as possible, before adjacent areas are considered for access;
Laydown yards, camps and storage areas must be located beyond the wetland buffer area;
As much as possible, on-site fabrication must be avoided. It is preferred that balustrades, concrete slaps and concrete columns be fabricated off-site;
The contractors used for the project should have spill kits available to ensure that any fuel or oil spills are clean-up and discarded correctly;
Construction of the supporting columns must take place during the dry season (April- September);
The footprint area of the columns must be kept to a minimum. The footprint area must be clearly demarcated to avoid unnecessary disturbances to adjacent areas, specifically the micro-channel.;
Prevent uncontrolled access of vehicles through the buffer area that can cause an adverse impact on the integrity and functioning of the area. Only make use of existing access routes;
All chemicals, fuels, lubricants and toxicants to be used must be stored in a bunded area;
All machinery and equipment should be inspected regularly for faults and possible leaks, these should be serviced off-site;
14 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building All contractors and employees should undergo induction which is to include environmental awareness. The induction is to include aspects such as the need to avoid littering, the reporting and cleaning of spills and leaks, avoidance of sensitive areas and general good “housekeeping”;
Adequate sanitary facilities and ablutions on the servitude must be provided for all personnel throughout the project area. Use of these facilities must be enforced (these facilities must be kept clean so that they are a desired alternative to the surrounding vegetation);
Have action plans on site, and training for contactors and employees in the event of spills, leaks and other impacts to the aquatic systems;
Any exposed earth should be rehabilitated promptly by planting suitable vegetation (vigorous indigenous grasses) to protect the exposed soil;
No dumping of construction material on-site may take place; and
All waste generated on-site during construction must be adequately managed. Separation and recycling of different waste materials should be supported. 3.2 Operation Mitigation Measures The following mitigation measures are to be continued in this project phase:
Prevent uncontrolled access of vehicles through the 15m buffer area that can cause an adverse impact on the integrity and functioning of the area. Only make use of existing access routes;
Adequate sanitary facilities and ablutions on the servitude must be provided for all personnel. Use of these facilities must be enforced (these facilities must be kept clean so that they are a desired alternative to the surrounding vegetation);
Any rehabilitated area must be monitored for success. In the event that rehabilitation is not achieved (i.e. good vegetation cover), a vegetation specialist must be consulted for remedial actions;
Stormwater management measures must be continued for the operation of the facility; and
All waste generated on-site during must be adequately managed. Separation and recycling of different waste materials should be supported
15 www.thebiodiversitycompany.com Wetland Risk Assessment
Sappi Water Intake Building 4 Conclusion A wetland impact (risk) assessment was completed for the Saiccor water intake building project. The baseline information considered for this assessment was completed in 2016, and considered to be true and accurate (to date) for the requirements of the assessment.
The baseline assessment delineated one floodplain wetland. The health of the system was determined to be largely modified (or class D). The ecological significance of the system was determined to be high. It was recommended that a 30m buffer is set to protect wetland functionality.
The proposed development consists of a construction and operational phase, there has been no allowance for a decommissioning phase for the project. The project will entail the clearing of areas and excavation of foundations for four (4) columns, and the construction of a control room supported by the columns. Despite the proximity to the uMkomaas River, the significance of all pre-mitigation risks was determined to be “Low” for both phases of the project. This is largely attributed to the project being for the expansion of an existing building, but also the small disturbance footprint area required for four columns. Despite these Low risks, mitigation measures have been prescribed to ensure est practice is achieved, and the identified risks are further mitigated. 5 References Andrew Fraser Architecture (Layout and Site Plan). 2019. Proposed additionas to existing water intake building for Sappi Saiccor. Date 02/07/2019. Ref: 1903-4A-1-REVE Macfarlane DM and Bredin IP. 2017. Part 1: technical manual. Buffer zone guidelines for wetlands, rivers and estuaries
WSP Environmental (Pty) Ltd (WSP). 2016. Wetland assessment, Saiccor Mill. Project no: 47385
16 www.thebiodiversitycompany.com APPENDIX
D ESTUARY SPECIALIST IMPACT ASSESSMENT
Water Intake Pump House
Estuary Specialist Impact Assessment
May 2020 | DRAFT FINAL REPORT
VER1.2
Prepared by
For
WSP ENVIRONMENTAL (PTY) LTD
Copyright reserved
No part of this publication may be reproduced in any manner without full acknowledgement of the source.
Citation:
MER 2020: Sappi Saiccor Proposed Intake Pump House Upgrade: Estuary Specialist Impact Assessment. MER Report 09/2020 for WSP Parsons Brinckerhoff.
REPORT DETAILS
TITLE Sappi Saiccor Proposed Intake Pump House Upgrade: Estuary Specialist Impact Assessment.
DATE MAY 2020
COMPANY Marine & Estuarine Research
REPORT NO MER Report 09/2020
CLIENT WSP Environmental (PTY) LTD
FORMAT MSWord and PDF
WEB ADDRESS http://www.mer.co.za/Downloads/ (only with client password and permission)
Approved for Marine & Estuarine Research by:
______Director
Page | i
EXECUTIVE SUMMARY
Sappi Saiccor is proposing the upgrade of their water intake pump house on the uMkhomazi estuary with modern technology that requires minimal maintenance and enables automation. The proposal is to replace the electrical equipment with modern technology to be housed within the proposed Motor Control Centre (MCC) room to be constructed adjacent to the existing pump house. This will ensure continued water supply. The MCC room structure (area of 62m2) will be suspended on four columns, encompassing 16m2 minimal touch footprint. WSP is therefore undertaking the required Basic Assessment process in applying for Environmental Authorisation
The report assessed, using standard environmental impact assessment methods, the potential issues and impacts to the estuary which may result from this project both during the construction and operational phases. The pump station is situated in an elevated position within the delineated estuarine functional zone (EFZ). This places it in a sensitive area close to the riparian zone and aquatic resources. In total three potential impacts to the estuary environment during the construction phase were identified and two during the operational phase. However, the assessment of potential impacts did not indicate any fatal flaws for any individual impact and each impact was assessed with a high degree of confidence. No impacts were evaluated for a decommissioning phase as it is unlikely that this will occur within the long- term future of the project.
Summary of potential impacts and assessed status
1. Additional Development within the EFZ Construction and Operation Spatial extent Duration Probability Significance Status Regional Permanent Definite Low Negative Post-mitigation Spatial extent Duration Probability Significance Status Regional Permanent Definite Very Low Negative 2. Noise and Lights Construction and Operation Spatial extent Duration Probability Significance Status Local Permanent Possible Medium Negative Post-mitigation Spatial extent Duration Probability Significance Status Local Permanent Possible Very Low Negative
Page | ii
3. Pollution Construction Spatial extent Duration Probability Significance Status Regional Temporary Possible Medium-High Negative Post-mitigation Spatial extent Duration Probability Significance Status Local Permanent Possible Low Neutral
A range of mitigation measures are proposed to control disturbance, noise and light including:
• Install the minimum possible light fittings • Install lighting with shields to reduce light emitted to the surroundings; • All area lights should be installed with timers or photoelectric cells to ensure they are only operational during night hours. • Where possible install area lighting linked to movement sensors, thus the lights are only used when they are needed. • Limit vehicle speed in and around the construction site. • Control the footprint of the construction activities • Awareness training of all staff regarding fauna disturbance. • Prevent extractive exploitation of natural resources by construction workers. notably, fishing in the estuary should be prohibited.
Noise that emanates from construction activities should be addressed through targeted best practices for noise monitoring and management in the EMPr.
Measures for the prevention of pollution of both land and water resources during construction of the proposed project should ensure the control and appropriate disposal of:
• Waste generated from site preparations (e.g. plant material); • Domestic waste; • Surplus and used building material; • Hazardous waste (e.g. chemicals, oils, soil contaminated by spillages, diesel, oils); • Wastewater (sanitation facilities, washing of plant, operations at the batching plant, etc.); and • Disposal of excess spoil material (soil and rock) generated as part of the earthworks.
Page | iii
TABLE OF CONTENTS
REPORT DETAILS ...... i EXECUTIVE SUMMARY ...... ii TABLE OF CONTENTS ...... iv LIST OF FIGURES ...... v LIST OF TABLES ...... v GLOSSARY ...... vi ABBREVIATIONS ...... vii 1 INTRODUCTION ...... 11 1.1 Terms of Reference ...... 11 1.2 Approach ...... 12 2 Assumptions and limitations ...... 12 3 STATE OF THE RECEIVING ENVIRONMENT ...... 12 3.1 Background uMkhomazi estuary ...... 12 3.2 Estuary health ...... 14 3.3 Conservation status ...... 14 4 PROPOSED DEVELOPMENT ...... 15 5 IMPACT ASSESSMENT ...... 15 5.1 Method ...... 15 5.2 Identification of potential issues and impacts ...... 17
5.2.1 Construction phase ...... 18
5.2.1.1 Loss of EFZ ...... 18 5.2.1.2 Disturbance, Lights and noise ...... 18 5.2.1.3 Pollution ...... 19 5.2.2 Operational phase ...... 19
5.2.2.1 Loss of EFZ ...... 19 5.2.2.2 Lights and noise ...... 20 5.2.3 Summary Impact Table ...... 20 6 CONCLUSIONS AND RECOMMENDATIONS ...... 21 7 REFERENCES ...... 21
Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
LIST OF FIGURES
Figure 3-1 Location and extent (blue) of the uMkhomazi estuary with the location of the proposed development area indicated by the yellow dot...... 13 Figure 3-2 Existing Intake Pump station and weir at the head of the estuary ...... 13 Figure 4-1 Additions to pump station indicated in yellow...... 15
LIST OF TABLES
Table 4—1 Summary of impact rating scales ...... 17
Page | v Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
GLOSSARY
Anthropogenic Having to do with people, or caused by humans. Benthic macroinvertebrates Or benthos, refers to invertebrates attached to, living on (epifauna) or in (infauna) the substratum, that can be captured by a 500 µm net or sieve. Biodiversity The variability among living organisms from all sources including, inter alia, terrestrial, marine and other aquatic ecosystems and the ecological complexes of which they are part. This includes diversity within species, between species and of ecosystems. Catadromous Freshwater animal species that migrate downstream through estuaries to the sea to breed. Catchment In relation to a watercourse or watercourses or part of a watercourse, this term means the area from which any rainfall will drain into the watercourse or watercourses or part of a watercourse, through surface flow to a common point or common points. Community Assemblage of organisms characterised by a distinctive combination of species that occupy a common environment and interact with one another. Community composition All taxa, plants and animals, present in a community. cumecs Cubic metres of water per second Cumulative impact Impact on the environment which results from the incremental or combined effects of one or more developmental activities in a specified area over a particular time period, which may occur simultaneously, sequentially, or in an interactive manner. Estuarine Functional Zone Low lying land adjacent to the river or estuary periodically flooded and where river borne materials are deposited, including areas adjacent to the estuary banks and below the 5 m amsl for estuaries along the South African coastline, as described on BGIS. Environmental Flows The quantity and quality of water required to sustainably keep aquatic systems healthy and in the classified ecological management category
Page | vi Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
Environmental impact A discrete (definable) interaction between a project activity and one or more components of the environment (biophysical and social). Eutrophic Rich in mineral and organic nutrients that facilitate prolific plant growth. Habitat The natural home of an organism or community of organisms (this also includes the surrounding area). This includes biotic and abiotic features. Habitat loss or fragmentation is one of the primary causes of the loss of biodiversity and resilience. Invasive alien species A species that does not naturally occur in a specific area and whose introduction does or is likely to cause economic or environmental harm or harm to human health. Oligotrophic Conditions characterised by low mineral and organic nutrients resulting in limitations to plant growth / primary production. Present Ecological Status This is a measure of the health of a water resource Status based on a comparison between the original / reference condition and the present state according to the reserve determination method of the Department of Water Affairs and Sanitation (DWAF 2008. Water Resource Protection and Assessment Policy Implementation Process. Resource Directed Measures for protection of water resources: Methodology for the Determination of the Ecological Water Requirements for Estuaries. Version 2). This is generally denoted by a classification that can range from an “A” being unmodified to an “F” being critically modified.
ABBREVIATIONS aMSL above mean sea level BGIS Biodiversity Geographic Information System (GIS) developed and managed by the South African National Biodiversity Institute and accessed at http://www.bgis.sanbi.org/ DMOSS Durban Metropolitan Open Space System
Page | vii Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
DWA Department of Water Affairs DWAF Department of Water Affairs and Forestry DWS Department of Water and Sanitation (formerly Department of Water Affairs (DWA) and Department of Water Affairs & Forestry (DWAF)) EDTEA Department of Economic Development, Tourism and Environmental Affairs EFZ Estuarine Functional Zone EIA Environmental Impact Assessment in terms of the 2014 Regulations under the National Environmental Management Act No. 107 of 1998. EWR Environmental Water Requirements GIS Geographic Information System. GIS is a combination of computer software and hardware tools used for creating maps and analysing spatial data. GIS links the map and database information so that questions can be asked and answers given in map or visual form. IAP Invasive Alien Plant KZN KwaZulu-Natal MAR Mean Annual Runoff MER Marine & Estuarine Research NEMA National Environmental Management Act No. 107 of 1998 NFEPA National Freshwater Ecosystem Priority Areas PES Present Ecological Status SANBI South African National Biodiversity Institute
Page | viii Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
______(For official use only) Provincial Reference Number:
NEAS Reference Number: KZN / EIA / Waste Management Licence Number (if applicable): Date Received by Department:
DETAILS OF SPECIALIST AND DECLARATION OF INTEREST
Submitted in terms of section 24(2) of the National Environmental Management Act, 1998 (Act No. 107 of 1998) or for a waste management licence in terms of section 20(b) of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008).
KINDLY NOTE:
1. This form is current as of October 2019. It is the responsibility of the Applicant / Environmental Assessment Practitioner (“EAP”) to ascertain whether subsequent versions of the form have been released by the Department.
PROJECT TITLE Sappi Saiccor Proposed Intake Pump House Upgrade
DISTRICT MUNICIPALITY eThekwini Municipality
1. SPECIALIST INFORMATION
Specialist name: Nicolette Forbes Contact person: Nicolette Forbes Postal address: P.O. Box 417, Hyper by the Sea Postal code: 4053 Cell: 082 4518078 Telephone: 031 5722705 Fax: E-mail: [email protected] Professional affiliation(s) SACNASP (if any)
Project Consultant / EAP: Babalwa Mqokeli Contact person: Same as above
Page | ix Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
1ST FLOOR, PHAROS HOUSE Postal address: 70 BUCKINGHAM TERRACE WESTVILLE Postal code: 3629 Cell: +27 79 773 5560 Telephone: +27 31 240 8800 Fax: E-mail: [email protected]
2. DECLARATION BY THE SPECIALIST
I, ,, declare that --
General declaration:
• I act as the independent specialist in this application; • do not have and will not have any vested interest (either business, financial, personal or other) in the undertaking of the proposed activity, other than remuneration for work performed in terms of the Environmental Impact Assessment Regulations, 2014; • I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant; • I declare that there are no circumstances that may compromise my objectivity in performing such work; • I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, regulations and any guidelines that have relevance to the proposed activity; • I will comply with the Act, regulations and all other applicable legislation; • I have no, and will not engage in, conflicting interests in the undertaking of the activity; • I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; • all the particulars furnished by me in this form are true and correct; and • I am aware that a person is guilty of an offence in terms of Regulation 48 (1) of the EIA Regulations, 2014, if that person provides incorrect or misleading information. A person who is convicted of an offence in terms of sub-regulation 48(1) (a)-(e) is liable to the penalties as contemplated in section 49B(1) of the National Environmental Management Act, 1998 (Act 107 of 1998).
Signature of the specialist:
MARINE AND ESTUARINE RESEARCH Name of company:
Date:
Page | x Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
PROPOSED INTAKE PUMP STATION UPGRADE Estuary Specialist Impact Assessment
1 INTRODUCTION Sappi Saiccor is proposing the upgrade of their water intake pump house with modern technology that requires minimal maintenance and enables automation. The proposal is to replace the electrical equipment with modern technology to be housed within the proposed Motor Control Centre (MCC) room to be constructed adjacent to the existing pump house. This will ensure continued water supply. The MCC room structure (area of 62m2) will be suspended on four columns, encompassing 16m2 “touch-ground” footprint. WSP is therefore undertaking the required Basic Assessment process in applying for Environmental Authorisation
1.1 Terms of Reference
The objectives of the study were to:
v review available information and MER data on the uMkhomazi Estuary with emphasis on the area of the estuary to be influenced – namely the upper estuary
v identify and assess the direct, indirect and cumulative risks / impacts to the estuary as a result of the proposal;
Page | 11 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
v advise on any mitigation measures to minimise any significant risks / impacts identified, where possible and / or necessary; and
v identify the need for additional information to inform decision-makers on specific potential impacts on estuarine processes or biota.
1.2 Approach
This study was informed by technical information and designs detailed by Andrew Fraser Architects (drawing number/ 1903-4A-1-REVE) provided by WSP Environmental (Pt) Ltd.
2 ASSUMPTIONS AND LIMITATIONS It has been assumed that the existing data, published and unpublished, remain relevant to the estuary impact assessment. It was also determined that only a site visit to look at the nature of the footprint area and adjacent habitats was necessary and that a desktop level assessment was sufficient for the estuary specialist reporting.
3 STATE OF THE RECEIVING ENVIRONMENT
3.1 Background uMkhomazi estuary
The uMkhomazi estuary (Figure 3-1) is situated 50 km south-west of Durban (30°12’ S; 30°48’ E). and is one of only two estuarine systems within the eThekwini Municipal boundary classified as a Permanently Open estuary (Whitfield 2000; Forbes & Demetriades 2010, Whitfield 2013; DWS 2014), one of only five between uThukela and uMtamvuna. In practical terms the Sappi Saiccor weir above the old metal bridge ca. 6 km from the mouth sets an artificial and absolute limit on tidal and to some extent saline penetration (Figure 3-2). The lateral boundaries of the estuary are described in terms of the EIA Regulations and standardised, published protocol as the Estuarine Functional Zone (EFZ) at 5 m aMSL contour (Turpie, Taljaard, van Niekerk, Adams, Wooldridge, Cyrus, Clark, & Forbes 2012).
Page | 12 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
Figure 3-1 Location of the uMkomazi estuary on the Kwazulu-Natal coast (red dot on inset map). The estuary delineation or extent of the estuary is indicated on the satellite image by the blue transparent shading and the location of the proposed development area is indicated by the yellow dot.
Figure 3-2 The currently existing intake pump station and weir with water passing over it at the head of the estuary. Viewed from the north bank of the estuary.
Page | 13 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
3.2 Estuary health
The uMkhomazi estuary has been identified as a critical provider of ecosystem services that cannot be provided at the same scale by other estuaries in the region. Among its most fundamental functional values is the periodic mass delivery of sediment and nutrients accumulated in the estuary to the marine environment during high flow and flood conditions (DWA 2014). It is one of only four key systems supplying sediment, nutrients and detritus to the KZN coast (uMvoti, uMngeni, and uMzimkhulu estuaries). The uMkhomazi was found to be especially important to near-shore habitat formation and maintaining beaches in the region.
More recently and following the prescribed methods for estimating estuarine health (DWAF 2008; Turpie et al. 2012) the estuary health has been determined to have a Present Ecological Status (PES) of “C – Moderately Modified” (DWA 2014). Work conducted by MER for the last 18 years on the estuary suggests its health status is likely even higher than this score.
3.3 Conservation status
The uMkhomazi Estuary has been identified as a conservation priority and is part of the core set of priority estuaries in need of protections to meet national, regional and local biodiversity targets1. In terms of satisfying biodiversity conservation targets in 2002 the uMkhomazi was estimated to be 30th in South Africa out of 250, based on size, zonal type rarity, habitat and biodiversity importance (Turpie, Adams, Joubert, Harrison, Colloty, Maree, Whitfield, Wooldridge, Lamberth, Taljaard & van Niekerk 2002). Although it was ranked 53rd out of 256 estuaries in 2007 (Turpie & Clark 2007), this study developed a regional ranking of estuaries in the cool temperate bioregion, with significantly different estuarine function and biodiversity to the estuaries within the subtropical bioregion. The estuary specific assessment of conservation value and the delivery of important ecosystem services applied in the EWR (DWS 2014) should therefore prevail.
1 In terms of the National Environmental Management: Biodiversity Act No. 10 of 2004 and the National Environmental Management: Integrated Coastal Management Act No. 24 of 2008 (van Niekerk & Turpie 2012).
Page | 14 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
4 PROPOSED DEVELOPMENT The proposal involves the addition of built infrastructure to the existing pump station with a minimal increase in ground touch footprint. A new electrical control room forms the only addition at the second level of the structure at 11.5m ground level and is indicated by the yellow outline on Figure 4-1Error! Reference source not found.. Contact with the ground is only via support columns minimising the ground footprint of the new section.
Figure 4-1 Additions to pump station indicated in yellow.
5 IMPACT ASSESSMENT
5.1 Method
A key component of the EIA process is the identification and assessment of potential impacts of the proposed activity. The use of a logical approach, where uncertain elements are assessed in a clear and methodical process helps to ensure that the assessment is focused and provides a basis for making predictions and value judgments that will ultimately inform the decision of the competent authority. The process of assessing the impacts of this proposal has followed
Page | 15 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
the recommended format within the 2017 EIA Regulations with regards to the assessment of the nature, extent, duration, probability significance, and consequence of potential impacts.
Impacts are the changes in an identified parameter that result from undertaking an activity and may be characterised as positive or negative. The change is the difference predicted or observed where the activity is undertaken compared with unaffected areas and can be described as low, medium or high. In addition, impacts may occur over a specific period and within a defined area allowing these to be described in terms of short-, medium- or long-term and local, regional or international.
The impacts may be positive or negative and may be categorized as being direct (primary), indirect (secondary) or cumulative. Direct impacts are those caused directly by the activity and generally occur at the same time and at the place of the activity (e.g. habitat removal within the proposed footprint). These impacts are usually associated with the construction, operation or maintenance of an activity and are generally obvious and quantifiable.
Indirect impacts of an activity are indirect or induced changes that occur as a result of the activity (e.g. increased velocity of surfacewater flows to downstream aquatic habitats). These types of impacts include all the potential impacts that do not manifest immediately when the activity is undertaken or occur at a different place as a result of the activity.
Cumulative impacts are those that result from the incremental impact of the proposed activity on a common resource when added to the impacts of other past, present or reasonably foreseeable future activities (e.g. where the risk of the combined nutrient loads in stormwater runoff and effluent discharges to a water resource may accumulate to levels that cause algal blooms, and this effect is greater than the additive impacts of each pollutant when considered separately). Cumulative impacts can occur from the collective impacts of individual minor actions over a period of time and can include both direct and indirect impacts.
The range of factors that were taken into account in the impact assessment for this study included positive impacts (a benefit), negative (a cost) and neutral (no discernible benefit or detriment). The impact was also rated by extent or scale, duration and probability of occurrence and significance as summarised in Table 5—1.
Page | 16 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
Table 5—1 Summary of impact rating scales
- Site specific: impact limited to the immediate areas of development activity - Local: limited to within 5 km of the development Extent/Scale - Regional: would affect the region as a whole - National: occurs at a scale affecting National diversity ratings, processes or species populations - International: occurs at a scale affecting global processes or species populations - Short-term: 0 to 5 years - Medium-term: 5 to 15 years Duration: - Long-term: > 15 years - Permanent - Improbable: low likelihood Probability of - Probable: distinct possibility occurrence: - Definite: impact would occur regardless of prevention measures - Uncertain: insufficient data to determine probability - Insignificant: impact is insubstantial and does not require management - Low: impact is of little importance, but may require management - Medium: impact is important, management is required to reduce negative impacts to acceptable levels - High: impact is of great importance; negative impacts could render some development options fatally flawed if they cannot be reduced to acceptable levels and/or if they are not balanced by significant positive impacts. Management of negative impacts is essential
As an aid to impact table interpretation the significance of a potential impact has been indicated Significance: visually according to its status. Positive impacts are shaded in green, negative impacts in red and neutral impacts as orange. Increases in significance are indicated by increased intensity of the shading colour as follows:
Significance Status Insignificant Low Medium High Positive Negative Neutral
- Positive: beneficial to the receiving environment Status: - Neutral: no discernible benefit or detriment to the receiving environment - Negative: detrimental to the receiving environment
5.2 Identification of potential issues and impacts
The pump station is situated in an elevated position within the delineated estuarine functional zone (EFZ). This places it in a sensitive area close to the riparian zone and aquatic resources. In total three potential impacts to the estuary environment during the construction phase were identified and two during the operational phase. However, the assessment of potential impacts did not indicate any fatal flaws for any individual impact and each impact was assessed with a high degree of confidence. No impacts were evaluated for a decommissioning phase are it is unlikely that this will occur within the long-term future of the project.
Page | 17 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
5.2.1 Construction phase
5.2.1.1 Loss of EFZ
The proposed development occurs within the delineated EFZ of the uMkhomazi estuary. However, the existing intake pump station has already been at this location for decades and the proposal involves the simple addition of a room and slight modification to the existing structure (Figure 4-1). The ground-based footprint would be a total of 16m2 which supports an elevated structure of 62m2 above the existing access road. The impact in terms of loss of EFZ habitat and especially loss of functionality is therefore considered extremely low. Care should be taken to limit the footprint of the construction camp and materials to the existing disturbed areas.
5.2.1.2 Disturbance, Lights and noise
It is possible that noise from the use of powered mechanical equipment (PME) on site and the haulage of construction materials during the construction of the project could impact nearby noise sensitive receivers such as birds, reptiles and small mammals utilizing this area. This would be especially true if pile driving is required. This could impact on bird populations, as well as small reptiles and mammals currently inhabiting the surroundings. The mere presence of a work force in the area will be a source of disturbance. The impact should be temporary and animals that move away from the source are expected to return to the area on cessation of these activities. The intensity has therefore been assessed as medium-low and the overall significance is rated as low (without the implementation of key mitigation measures). This assumes exploitation of resources (e.g. fish in the estuary) by worker is prohibited, as is standard good practice.
The existing and operational pump station has already elevated the ambient noise and light levels in the area and therefore these impacts are predicted to be of low significance even before mitigation. Mitigation is however always the best action to take and while there can be little done to reduce expected noise levels during construction, mitigation of light and other disturbance on the site is possible. Mitigation measures proposed to control disturbance, noise and light:
• Install the minimum possible lights • Install area lighting with shields to reduce light emitted to the surroundings;
Page | 18 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
• All area lights should be installed with timers or photoelectric cells to ensure they are only operational during night hours. • Where possible install area lighting linked to movement sensors, thus the lights are only used when they are needed. • Limit vehicle speed in and around the construction site. • Control the footprint of the construction activities • Awareness training of all staff regarding fauna disturbance. • Prevent extractive exploitation of natural resources by construction workers. notably, fishing in the estuary should be prohibited.
Noise that emanates from construction activities should be addressed through targeted best practices for noise monitoring and management in the EMPr.
5.2.1.3 Pollution
The construction site could impact the local area and estuary by the introduction of solid waste and other contaminants from the construction crew, machinery and materials used. Measures for the prevention of pollution of both land and water resources during construction of the proposed project should ensure the control and appropriate disposal of:
• Waste generated from site preparations (e.g. plant material); • Domestic waste; • Surplus and used building material; • Hazardous waste (e.g. chemicals, oils, soil contaminated by spillages, diesel, oils); • Wastewater (sanitation facilities, washing of plant, operations at the batching plant, etc.); and • Disposal of excess spoil material (soil and rock) generated as part of the earthworks.
5.2.2 Operational phase
5.2.2.1 Loss of EFZ
There are no significant impacts anticipated to the estuary as a result of the operation of the building extension. The only risk is directly to the pump station and its access route during
Page | 19 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
very large flood events. Historically, the 1987 flood reached the floor level of the existing building and the access road was washed away. However, as stated there is no measurable impact to the estuary as a result of the small modification to the building. The indirect impacts of the pump station can be offset and mitigated by the management of alien vegetation in the surrounding habitat and good design of light and noise mitigation will reduce the impact of the loss to the EFZ.
5.2.2.2 Lights and noise
These areas are typically relatively quiet during the day and experience even lower levels of night time noise. In the operational stages it is assumed that the pump station will comply with best practices to limit any light and noise impacts for the life of the project.
5.2.3 Summary Impact Table
Additional Development within the EFZ Construction and Operation Spatial extent Duration Probability Significance Status Regional Permanent Definite Low Negative Post-mitigation Spatial extent Duration Probability Significance Status Regional Permanent Definite Very Low Negative Noise and Lights Construction and Operation Spatial extent Duration Probability Significance Status Local Permanent Possible Medium Negative Post-mitigation Spatial extent Duration Probability Significance Status Local Permanent Possible Very Low Negative Pollution Construction Spatial extent Duration Probability Significance Status Regional Temporary Possible Medium-High Negative Post-mitigation Spatial extent Duration Probability Significance Status Local Permanent Possible Low Neutral
Page | 20 Proposed Intake Pump Station Upgrade, Sappi Saiccor WSP Parsons Brinckerhoff
6 CONCLUSIONS AND RECOMMENDATIONS The pump station is situated in an elevated position just within the delineated estuarine functional zone (EFZ). This places it in a sensitive area close to the riparian zone and aquatic resources. In total three potential impacts to the estuary environment during the construction phase were identified and two during the operational phase. All the impacts assessed although negative were of low significance and even lower after mitigiation. Therefore, the assessment of potential impacts did not indicate any fatal flaws for any individual impact and each was assessed with a high degree of confidence. A range of mitigation measures have been proposed within each impact section of the report and the Executive Summary.
7 REFERENCES
Begg G.W. 1978. The estuaries of Natal. Natal Town and Regional Planning Report 41.
Department of Water and Sanitation (DWS). 2014. Classification of Water Resources and Determination of the Comprehensive Reserve and Resource Quality Objectives in the Mvoti to Umzimkulu WMA: Volume 2b: Mkomazi Estuary Ecological Consequences Prepared by: MER.
Forbes A.T. & Demetriades N.T. 2010. Estuaries of Durban, Kwazulu-Natal, South Africa. Report for the Environmental Management Department, eThekwini Municipality.
Turpie, J.K., Taljaard, S., van Niekerk, L., Adams, J., Wooldridge, T., Cyrus, D., Clark, B. & Forbes, N. 2012. The Estuary Health Index: A standardised metric for use in estuary management and the determination of ecological water requirements. Water Research Commission Report No. 1930/1/12.
Turpie J.K. & Clark B.M. 2007 The health status, conservation importance, and economic value of temperate South African estuaries and development of a regional conservation plan. Report to Cape Nature. Turpie JK, Adams JB, Joubert A, Harrison TD, Colloty BM, Maree RC, Whitfield AK, Woolridge TH, Lamberth SJ, Taljaard S & van Niekerk L. 2002. Assessment of the conservation priority status of South African estuaries for use in management and water allocation. Water SA 28(2): 191-206.
Whitfield A.K. 2000. Available scientific information on individual South African estuarine systems. WRC Report No.577/3/00.
Whitfield A.K. & Baliwe N.G. 2013. A century of science in South African estuaries: Bibliography and review of research trends. SANCOR Occasional Report No. 7.
Page | 21 APPENDIX
E GEOTECHNICAL STUDY
29th May 2019 Enquiries: Mark Richter Other Ref: SAPPI – Intake Extensions Ref: 19-137.L01MVR File: 19-137
Profcon
Att: Mr Lawrence Fraser Email: [email protected]
EVALUATION OF ROCK SLOPE STABILITY AND FOUNDING CONDITIONS: EXTENSION TO SAPPI RIVER WATER INTAKE BUILDING As requested, we have evaluated the rock slope and founding conditions for the new extensions to the Sappi river water intake building on the Mkomazi River near the Sappi plant. This report contains the results of this evaluation. Recommendations for rock slope stabilisation and foundations are provided. 1. INFORMATION SUPPLIED
The following information was supplied by Mr Fraser for this investigation:
• Drawing No 2019_07_Sappi_Saiccor_Rev_A_For_Information_Only; Column & foundation layout • Drawing No 190523-Submission prov: plan showing survey and new structure • Drawing titled: SAPPI PUMP HOUSE: topographical survey • Photos of the site obtained in RfQ email
2. FIELDWORK
The fieldwork for this investigation was carried out on the 16th April 2019. The proposed extensions to the Water Intake Building are situated on tillite bedrock. The rock outcrop to either side of the existing intake building, as well as under the tunnel area, were mapped structurally to determine the following:
• Strength of the rock • Joint characteristics, i.e: - joint patterns which may combine to form an unstable rockmass - smoothness and shape of joint planes, presence of clay gouge etc) - angle of excavation slopes • Presence of water in the joints and efficiency of drainage thereof • Taking of samples for uniaxial compressive strength (UCS) tests to determine rock hardness
The results of the mapping indicated that the tillite rock has the following dominant jointing patterns (dip of rock joint / direction of dip): Primary Joint, J1: 22 to 300 (average 270) / 330 to 3420, average 3340 (8 readings) - Joints are slightly smooth, wavy, no infill. Stained brown
Secondary Joint, J2: 60 to 780 (average 670) / 130 to 1900, average 1560 (7 readings) - Joints are rough, wavy, no infill Subordinate Joint, J3: 56 to 700 (average 700) / 350 to 0080, average 3580 (6 readings) - Joints are smooth, flat, no infill
Plate 1: West side of Tunnel: Note drill & blast holes Plate 2: East side of Tunnel: note J1 joints (stained brown) dipping N out of face; J2 joints dipping S into face, and J3 joints near vertical and diagonally cross-cutting N-S. Note groundwater seepage
3. LABORATORY TESTING
Two samples of the bedrock were broken off the rock cutting face on the south side of the tunnel area and submitted for UCS tests at SGS Matrolab in Durban. The results are summarised in Table 1 below: Table 1 : Results of Uniaxial Compressive Strength Tests
COLTO Rock Strength Rock Strength 1 Sample Description Classification (MPa) Classification1
No 2 Dark/ light mottled, medium Medium Hard 12.6 weathered Tillite rock Rock R3
No 4 Dark/ light mottled, medium 4.2 Soft Rock weathered Tillite rock R2
Note that Sample 4 contains hairline cracks
1 COLTO Standard Specifications for Road and Bridge Works for State Road Authorities (1998). Committee of Land Transport Officials. Series 6100: Table 6113/1 Rock Classification
Page 2 of 5
4. GEOTECHNICAL EVALUATION AND DEVELOPMENT RECOMMENDATIONS
4.1 Evaluation of Rock Structure and Hardness
The mapping of the rock face revealed the following:
• There are no signs of existing lateral support measures on the existing face of the rock cutting, i.e. there are no rock bolts and /or weep-holes evident etc. This implies that the existing cutting face has been stable without support; the general rockmass is intact and stable in spite of a near vertical face • Excavation of the rock required drill and blast excavation methods, indicating that it falls into the Hard Rock Excavation class (SABS1200D) • There are no signs of any rock wedge slippage or failures, i.e no loose blocks along the toe of the slope which may indicate small failures • The tillite is jointed with the major or dominant joint plane J1 dipping directly out of, or “daylighting” from the cutting face at an average dip angle of 270, in the range 22 to 300, to the horizontal. The joints are slightly smooth, wavy, no infill. It is considered that the potential for movement along this joint plane is low. Any movement on this joint plane will depend on the presence of J2 which dips into the face and creates a release plane. There may be potential for the sliding of rock slabs or wedges along the J1 plane if an unfavourable combination of J2 & J3 joints occurs in a near vertical rock face. Localised increased joint frequency could result in an unstable configuration. • As is evident continuous groundwater seepage can be anticipated down parts of the rock face, since the drainage potential of the catchment area behind the Intake Building is downslope towards the Umkomaas River. The tillite rock is considered reasonably permeable as a result of the well- defined and open joints which will duct the groundwater to the river • The hardness of the rock is surprisingly of a low strength magnitude, being 12MPa, i.e. medium hard rock in strength. The initial visual impression obtained of the rock is that it appears to be much higher in strength than this. • There are almost microscopic hairline cracks evident in the rock in some areas of the cutting – this reduces the strength of the rock significantly, with the UCS result yielding 4MPa or soft rock strength (see Sample 4 result). It is however, not possible to predict where these hairline cracks may proliferate within the rockmass as they are slightly larger than microscopic. They may have occurred as a function of blasting stresses and/or natural weathering processes, or a combination thereof
4.2 Recommendations for Slope Stability and Foundations
The drawings of the foundations for the new extension to the intake building indicate the following: • The southernmost footings will be positioned in the existing cutting area which means that either the cutting face will need to moved back further to widen it, or individual small box cuttings must be created in the face to accommodate each column and footing. • The northernmost footings are located very close to the existing retaining wall and the river
4.2.1 Slope Stability
The widening of the area to accommodate the existing creation of a near vertical face to accommodate some of the columns supporting the new building extension is not considered likely to result in an unstable face. However, as mentioned above, there could be potential for the sliding of rock slabs or wedges along the J1 plane if there is an unfavourable combination of J2 & J3 joints in a near vertical rock face, particularly where increased joint frequency could result in a localised unstable configuration.
Therefore, the following is recommended:
Page 3 of 5
• GGS inspect the excavation(s) as soon as it is opened to confirm whether any stabilisation is necessary. • To this end, it is recommended that allowance be made in the BOQ for rockbolts consisting of minimum Y20 dowels of minimum 2m length to be drilled at 600 to the horizontal and grouted in place with grout of minimum 30MPa strength. A minimum hole diameter of 75mm is advisable. • At this stage it is difficult to advise how many rockbolts should be allowed because the extent of the excavation(s) is unknown; therefore, minimum one rockbolt per 0.5m x 0.5m section of cutting face is advisable unless spacing further apart can be confirmed by inspection
4.2.2 Foundations
The new extension will be situated on the eastern side of the existing building and tunnel / underpass area. The footings on the south will encroach into the existing cutting while those on the north will be positioned very closely to the existing retaining wall and river. Using BS8004:19862 other physical criteria are applied for the assessment of bearing capacity:
• Jointing: the rock is closely to medium jointed • Degree of cementing (sedimentary rocks – tillite or diamictite): the rock is considered to be well cemented - Type 2/3 Rock. • Use lower UCS value for tillite rock of 4MPa, assume hairline cracks exist • Applying the rock joint pattern / rock strength relationship curve, a maximum allowable bearing pressure of 1.0 MPa for Type 2/3 rocks is obtained. However, it is recommended that a maximum bearing pressure of 500kPa be used for the design of the foundations as this should be more than adequate, subject to inspection of the open excavations by GGS • Settlement must be taken as 0.5% of the base width i.e. a 1000mm wide footing will settle 5mm.
The footings on the north are to be positioned very closely to the existing retaining wall at the edge of the river. No information of the backfill behind the retaining wall, or construction details of the retaining wall itself, is currently available. Given that the bedrock has the potential to slide along the J1 joint planes towards the river if there are suitable release planes to enable this, the added weight of the new building extension must be allowed for. Therefore, subject to inspections by GGS it may be necessary to install similar angled, and possibly vertical, rockbolts as discussed above to anchor the rock beneath the foundations supporting the columns as well as ensure that there is no foundation load acting as a horizontal surcharge behind the retaining wall.
2 BS 8004:1986 Section 2: pp16-19; Figure 1
Page 4 of 5
We trust that the information provided in this quotation meets with your requirements. Should you have any queries do not hesitate to contact us. Yours faithfully GONDWANA GEO SOLUTIONS (PTY) LTD
MV RICHTER Pr SciNat 0834616194
Page 5 of 5
APPENDIX
F ENVIRONMENTAL MANAGEMENT PROGRAMME