January 2010

METOLONG WATER TREATMENT WORKS

Environmental Management Plan

Submitted to: Metolong Dam and Water Supply Project - MPMU Red Cross Building, 29 Mabile Street Maseru 100

REPORT Report Number: 12280-9299-2 Distribution: 6 X Metolong Dam and Water Supply Project - MPMU

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List of Acronyms AFS - Additional Feasibility Study (Mott Macdonald) CEO - Chief Executive Officer C&RAP - Compensation and Resettlement Action Plan CLA Community Liaison Assistant CMC - Catchment Management Committee CMMS - Computer-aided Maintenance Management System COD - Chemical Oxygen Demand COW - Commissioner of Water C.t - Chlorine contact time (mg/L x minutes) DAF - Dissolved Air Floatation DB - Design Build DRIFT - Downstream Response to Imposed Flow Transformation

DRWS - Department of Rural Water Supply DWA - Department Water Affairs ECO - Environmental Compliance Officer

EPP - Environmental Protection Plan FSL - Full Supply Level GAC - Granular Activated Carbon

ICM - Integrated Catchment Management IDA - International Development Agency IFB - Invitation for Bid

IFC - International Finance Corporation IFR - Instream Flow Requirement LCN - Lesotho Congress of NGOs LEC - Lesotho Electricity Corporation LWJV Lowlands Waterworks Joint Venture LLWSFS - Lowlands Water Supply Feasibility Study MCA-L - Millennium Challenge Account - Lesotho MCC - Millennium Challenge Corporation MDWSP - Metolong Dam and Water Supply Project

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MNR - Ministry of Natural Resources MPIU - Metolong Project Implementation Unit MPMU - Metolong Project Management Unit NES - National Environmental Secretariat QAQC - Quality Assurance and Quality Control QAO - Quality Assurance Officer RoD - Record of Decision RP - Resettlement Plan SADC - Southern African Development Community SANS - South African National Standards SCADA - Supervisory Control and Data Acquisition SPI - Species Pollution Sensitivity Index SRP - Soluble Reactive Phosphate STIs - Sexually Transmitted Infections

TRC - Transformation Resource Centre UNFCCC - United Nations Framework Convention on Climate Change WASA - Water and Sanitation Authority

WATSAN - Water and Sanitation Project WTW - Water Treatment Works WWTW - Waste Water Treatment Works

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Executive Summary

The Metolong Dam and Water Supply Programme (MDWSP), comprising the Metolong Dam, the Water Treatment Works (WTW) and conveyance systems, is designed to augment water supplies to the lowland towns of Lesotho by an amount of 75 Mℓ/day over and above the existing 45 Mℓ/day supplied by the Maseru water supply system. Various studies have been undertaken since 2002 that confirmed Metolong as the preferred location for the dam and the WTW. The project is rated as high priority by the Government of Lesotho (GoL). The WTW and conveyance system will be constructed with funding from the US Millennium Challenge Corporation (MCC) administered through the Millennium Challenge Account – Lesotho (MCA-L). The MCA-L appointed the Lowlands Waterworks Joint Venture (LWJV) consortium to undertake a conceptual design of the WTW and prepare tender documents for a Design-Build contract, as well as compile an Environmental and Social Impact Assessment (ESIA) and Environmental Management Plan (EMP). The ESIA and this EMP has been prepared by an independent team of sub-consultants to the LWJV. This EMP has been derived in collaboration with the development of the Invitation for Bids (IFB# WS-A-016- 09) Design-Build of Metolong WTW bidding documents (Volume 1 to Volumes IX) December 2009.

This EMP provides a comprehensive overview of the mitigation and monitoring requirements for construction and operation of the proposed WTW. Adherence to these mitigation measures and management requirements will minimise the impacts of the WTW to the extent that no significant residual impact of construction or operation is likely to occur. Key tasks for implementation of the EMP during the planning and construction phases include (but are not limited to):  Layout planning and compilation of detailed layout plans to ensure environmental impacts are minimised (e.g. toilets more than 50m from water courses or springs; siting of “no go” or sensitive areas such as ruins of 19th Century village, location of bunded areas, chemical stores, effluent ponds and discharge monitoring points).  A stormwater layout plan designed to ensure adequate diversion and dissipation of stormwater to prevent erosion and sedimentation.  Encouragement of preferential labour recruitment from the local communities to minimise social impacts associated with influx of a large labour force such as increased HIV/AIDS, increased crime, social disruption, alcoholism etc.  Regular dialogue between the Contractor’s Community Relations Officer (CRO) and the Metolong Authority’s Community Relations Manager (CRM) and Community Liaison Assistants (CLAs) to keep the community abreast of work schedules and activities, and to hear and address concerns.  Awareness raising and training of the workforce to ensure they are familiar with all on-site rules and requirements relating to aspects such as solid and chemical waste disposal; use of toilets; prohibition on using the veld as a toilet; for littering; trampling and harvesting of fauna and flora, or the lighting of fires. Other aspects covered include workforce awareness of communication channels and key points of contact for specific workforce issues.  Implementation of the Contractor Standards for construction that are designed to mitigate erosion and sedimentation risks, pollution risks, and to manage social impacts (e.g. visual, dust/noise, blasting,

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traffic accidents etc) and other biophysical impacts (e.g. loss of flora and fauna, general habitat disturbance).  Rehabilitation of disturbed areas within and around the WTW, and appropriate landscaping of the site, will minimise the visual impacts of the construction activities and the development as a whole, while minimising the risk of erosion.  Auditing, monitoring, site inspections and reporting will be implemented in accordance to the EMP by the Environmental Compliance Officer (ECO), the site Engineer and the regulatory organisations such as NES, WASA, DWA etc. Key tasks for implementation of the EMP during the operational phase include:  Encouragement of preferential labour recruitment from the local communities to be trained and used in the WTW.  Ongoing dialogue between the CRO and the Metolong Authority’s Community Relations Manager (CRM) and CLAs to keep the community abreast of the operational issues associated with the WTW and to hear and address concerns.  Awareness raising and training of the WTW workforce to ensure they are familiar with all on-site rules and requirements relating to aspects such as solid and chemical waste disposal. Other aspects covered include workforce awareness of communication channels and key points of contact for specific workforce issues.  Testing of sludge produced to confirm that the preferred long-term sludge disposal solution, which is land application for soil augmentation, is environmentally acceptable. The results will be checked against guideline values specified.  Monitoring of supernatant (liquid draining from the sludge) to determine whether it complies with effluent standards for disposal back to the river. If non-compliant then the supernatant will require treatment and/or dilution to meet the standards for release back to the river below the dam wall.  The operator with their staff must further develop and implement a detailed Emergency Response Plan which addresses aspects such as hazardous material accidents, e.g. chlorine gas emission; compilation of an emergency contacts list; protocols for remedial action; and training of key staff to deal with incidents and accidents.  Auditing, monitoring, site inspections and reporting will be implemented in accordance to the EMP by the Environmental Compliance Officer (ECO), the site Engineer and the regulatory organisations such as NES, WASA, DWA etc.

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Table of Contents

1.0 INTRODUCTION ...... 1

1.1 Background to the Metolong Dam and Water Supply Project ...... 1

1.2 Project Team ...... 1

1.3 Objectives of this EMP ...... 2

1.4 Background to this EMP ...... 2

1.5 Layout of this document ...... 3

2.0 PROJECT DESCRIPTION, TECHNOLOGY AND PROCESSES ...... 8

2.1 Metolong Dam and Water Supply Programme Components ...... 8

2.2 Metolong WTW components ...... 10

2.3 Location and layout of the WTW site ...... 10

2.4 Water Treatment Standards for Water Quality ...... 13

2.5 Water Treatment Process ...... 13

2.6 WTW Chemicals and Storage Requirements ...... 21

2.7 The WTW DB Contract ...... 22

2.7.1 WTW implementation ...... 22

2.7.2 Scope of the Design-Build Contract ...... 22

2.7.3 Specific infrastructure and services ...... 23

2.7.3.1 Roads and access...... 23

2.7.3.2 Fencing ...... 24

2.7.3.3 Electricity ...... 24

2.7.3.4 Telecommunications ...... 24

2.7.3.5 Water ...... 24

2.7.3.6 Sewage and waste water disposal ...... 25

2.7.3.7 Solid waste disposal ...... 25

2.7.4 Stages of the Design-Build Contract ...... 25

2.7.5 Reporting Requirements of the DB Contract ...... 26

2.7.5.1 Pre-construction Phase ...... 26

2.7.5.2 Construction Phase ...... 26

2.7.5.3 Post-construction Phase ...... 26

3.0 LEGAL FRAMEWORK ...... 28

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3.1 Relevant legislation and policies of Lesotho ...... 28

3.2 Permit Requirements ...... 29

3.3 Policies of the World Bank ...... 31

3.4 Policies of MCC and Metolong Authority ...... 32

3.5 International Conventions ...... 33

4.0 DESCRIPTION OF ENVIRONMENT AND KEY ENVIRONMENTAL IMPACTS OF THE WTW ...... 35

4.1 Description of the Environment ...... 35

4.2 Assessment of Impacts ...... 36

4.3 Summary Matrix Table of Construction and Operation Impacts and Key Mitigation Measures of the WTW ...... 37

5.0 INSTITUTIONAL ARRANGEMENTS – ROLES AND RESPONSIBILITIES ...... 43

5.1 Metolong Board, Metolong Authority (Metolong Project Implementation Unit (MPIU)) and Metolong Project Management Unit (MPMU) ...... 43

5.1.1 Community liaison and coordination ...... 43

5.2 MCA-Lesotho ...... 44

5.3 Other Government Departments and Ministries ...... 44

5.3.1 Water and Sanitation Authority (WASA) ...... 44

5.3.2 Ministry of Natural Resources (MNR) ...... 44

5.3.3 Commissioner of Water ...... 45

5.3.4 Department of Rural Water Supplies (DRWS) ...... 45

5.3.5 Department of Traffic and Transport ...... 45

5.3.6 National Environmental Secretariat (NES) ...... 45

6.0 IMPLEMENTATION OF THE EMP ...... 47

6.1 Environmental Compliance Staff ...... 47

6.1.1 Environmental Compliance Officer (ECO) ...... 47

6.1.1.1 Role of ECO ...... 47

6.2 Community Relations ...... 49

6.2.1 Community Relations Officer ...... 49

6.3 Emergency Preparedness Plan ...... 50

6.4 Environmental training and awareness ...... 51

6.4.1 Contractor Staff Training ...... 51

6.5 Auditing and inspections ...... 52

6.6 Reporting Procedures during Construction, Assisted Operation and Operation ...... 54

6.6.1 Complaints Register and Grievance Procedure ...... 55

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6.6.2 Incidents and Accidents Register ...... 55

6.6.3 General Reporting ...... 56

7.0 ENVIRONMENTAL MANAGEMENT FOR THE PRE-CONSTRUCTION PLANNING PHASE ...... 57

7.1 Pre-Construction Activities ...... 57

7.1.1 Design-Build Contractor Responsibilities ...... 57

7.2 Social and Health Management ...... 57

7.2.1 Land and Compensation ...... 57

7.2.2 Labour recruitment ...... 58

Objectives of the LRP: ...... 58

7.2.3 HIV/AIDS Education and Awareness Programme ...... 58

7.3 Cultural Heritage ...... 60

7.4 On-site Planning and Design ...... 61

7.4.1 Aesthetic and sustainable design of buildings and infrastructure provision ...... 61

7.4.2 Layout of the site ...... 61

8.0 ENVIRONMENTAL MANAGEMENT DURING CONSTRUCTION ...... 63

8.1 Solid Waste Management ...... 63

8.2 Hazardous Waste Management ...... 63

8.3 Effluent Management ...... 64

8.4 Stormwater and Erosion Control ...... 65

8.5 Noise and Dust ...... 65

8.6 Blasting controls, warning and monitoring ...... 66

8.6.1 Dilapidation survey ...... 66

8.6.2 Early warning ...... 67

8.7 Control on Human Activities causing Disturbance and Damage to the Natural Environment ...... 67

8.8 Environmental Monitoring Requirements during Construction ...... 68

8.9 Environmental Protection Plan ...... 68

9.0 ENVIRONMENTAL MANAGEMENT FOR THE OPERATIONAL PHASE ...... 77

9.1 Use, Transport and Disposal of Chemicals ...... 77

9.1.1 Chemical Dosing ...... 77

9.1.2 Transport, storage and disposal of hazardous materials (chlorine gas) ...... 78

9.2 Disposal of effluents ...... 79

9.3 Emergency Response Plan for Chlorine Gas Leaks ...... 80

9.4 Disposal of Sludge (solids) ...... 82

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9.5 General requirements for the WTW ...... 83

9.5.1 Routine Operation and Maintenance ...... 83

9.5.2 Spares and consumables ...... 84

9.5.3 Tools and equipment ...... 84

9.5.4 Operating instructions and manuals ...... 84

9.6 Water quality assessment of the WTW ...... 85

9.7 Water Sampling ...... 86

9.8 Monitoring Requirements during Operation ...... 87

10.0 GENERAL CONTRACTOR COMPLIANCE STANDARDS ...... 95

11.0 SUMMARY AND RECOMMENDATIONS ...... 116

12.0 REFERENCES ...... 118

TABLES Table 2-1: Summary of sludge disposal options ...... 20 Table 2-2: Chemicals used in Water Treatment Works and their hazard ratings (where 0 = no hazard, and 3 = high hazard rating) ...... 21 Table 2-3: WTW 45-day chemical storage requirements ...... 22 Table 3-1: List of Legislation and Policies relevant to the WTW ...... 28 Table 3-2: Permit or licence requirements and relevance to the WTW study ...... 30 Table 3-3: Summary of World Bank Operation Policies and relevance to the Metolong Project (synthesised from SMEC 2008) ...... 31 Table 3-4: MCC policies of relevance to the Metolong Project ...... 32 Table 3-5: Metolong Authority policies of relevance to the WTW project ...... 33 Table 3-6: International Conventions and relevance to the WTW project ...... 33 Table 4-1: Summary matrix table of Construction Impacts ...... 37 Table 4-2: Summary matrix table of Operational Impacts ...... 41 Table 8-1: Summary of monitoring requirements for construction...... 70 Table 8-2: Mitigatory cost estimates for construction phase ...... 72 Table 9-1Operational record sheet - example 1 ...... 84 :Table 9-2 Operational record sheet - example 2 ...... 85 Table 9-3: Summary table monitoring requirements for the operational phase ...... 88 Table 9-4: Cost estimate for the proposed mitigatory measures for the operational phase ...... 91

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FIGURES Figure 1.1 Flow Chart of Construction Phase (Social Impacts) ...... 5 Figure 1.2: Flow Chart of Construction Phase (Biophysical Impacts) ...... 6 Figure 1.3: Flow Chart of Operational Phase (Environmental Impacts) ...... 7 Figure 2.1: Layout of the Metolong Dam and Water Supply Programme (MDWSP) ...... 9 Figure 2.2: Layout of the WTW showing position of the proposed dam wall in insert ...... 11 Figure 2.3: Layout of the WTW showing position and associated infrastructure...... 12 Figure 2.4: Schematic diagram of Water Treatment Process (LWJV November 2009) ...... 15 Figure 5.1: The environmental and communications reporting structure for the Metolong Dam ...... 46 Figure 6.1: Required team members for the development and maintenance of the Emergency Response Plan for the Metolong WTW (WASA 2007)...... 51

APPENDICES APPENDIX A TOR for Conducting ESIA and EMP for the Metolong WTW APPENDIX B B1: Adjustments to the Terms of Reference for ESIA and EMP B 2: Records of Decisions / Minutes of Meetings: a) NES meeting 26th May 2009 b) Technical meeting 15th April 2009 c) Minutes of meeting APPENDIX C Possible Template for Emergency Response Plan APPENDIX D Impact assessment methodology APPENDIX E Sludge management options specialist report (Golder 2009) APPENDIX F Standards applicable for Lesotho Effluent discharges to a natural water course (Otieno1997) and South African General Standards APPENDIX G MSDS for Chemicals to be used at the WTW APPENDIX H Drinking Water Standards: SANS 241 (2006) Edition 6.1 and WHO 2006 APPENDIX I Species List of in the WTW (Summer 2009) APPENDIX J Extracts from ‘FIDIC policy on HIV-AIDS in the construction sector’

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1.0 INTRODUCTION 1.1 Background to the Metolong Dam and Water Supply Project Maseru’s demand for water has continued to grow in recent years, with the expansion of the textile industry being a large factor in the increased demand. This demand has led to the development of the Metolong Dam and Water Supply Programme (MDWSP), the objective of which is to supplement Maseru’s potable water supply through the construction of the following infrastructure:  Metolong Dam  Metolong Water Treatment Works (WTW)  Downstream conveyance systems from the WTW to Maseru and other Lowland towns including, Roma, Mazenod, Morija and Teyateyaneng (TY).

The Programme is aimed at augmenting the water supply system to enable it to meet domestic and industrial requirements up to the year 2020 and possibly beyond. The present Maseru Water Supply System has the capacity to deliver 45 Mℓ /day. The MDWSP will provide up to a further 75 Mℓ/day (SMEC 2008). Studies since 2003 of various water supply options confirmed the Metolong Dam on the South Phuthiatsana River (30km east of Maseru) to be the preferred option to meet the growing water demand. These included a multi-disciplinary feasibility study by Mott MacDonald (2003) and the Lesotho Lowlands Water Supply Feasibility Study (LLWSFS) (Mouchel Parkman, 2005), followed by the Additional Feasibility Study by Mott MacDonald (2007). The Government of Lesotho (GoL) has given the project a high priority, and obtained funding from the US Millennium Challenge Corporation (MCC) for the WTW and conveyance component. The GoL established the Millennium Challenge Account – Lesotho (MCA-L) to implement the programme. The MCA-L appointed the Lowlands Waterworks Joint Venture (LWJV) consortium to undertake a conceptual design of the WTW and prepare tender documents for a Design-Build contract, as well as compile an Environmental and Social Impact Assessment (ESIA) and Environmental Management Plan (EMP). This EMP has been prepared by an independent team of sub-consultants.

The project site is located in the foothills of Lesotho, approximately 30km northeast of Maseru, in an area that is characterised by cultivated sloping plateaus and interspersed villages, adjoining the steep slopes and river valley of the Phuthiatsana River. The area is described in more detail in Chapter 4. 1.2 Project Team The project team subcontracted by the LWJV to compile the EMP included:  Dr Ralph Heath – Team Leader  Ms Jessica Hughes – Incorporation of ESIA aspects and EMP inputs  Mr Achim Wurster and Ms Annalien Toerien (Golder Associates) – Environmental Engineers (sludge management) Dr Ralph Heath holds a PhD in aquatic toxicology and has over 25 years in aquatic studies and Environmental Impacts Assessments (EIA’s) in southern Africa. Jessica Hughes holds Masters Degrees in Zoology and Environmental Science and has 16 years experience in EIA’s and EMP’s, particularly in Lesotho. Mr Achim Wurster and Ms Annalien Toerien have Chemical and Civil Engineering degrees respectively with post-graduate degrees with water treatment. They have extensive experience in water treatment design in southern Africa including sludge management.

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1.3 Objectives of this EMP The objective of this EMP is to provide a framework of management actions to mitigate negative impacts and enhance beneficial impacts of the project through the design and operational phases of the project. It is designed to give the regulatory authority (NES) confidence that the impacts will be addressed and managed correctly to a sufficient level for issuance of an Environmental Licence for the project to proceed. Each management action is designed to be practical, measurable and auditable. The defined target is designed to assist the Environmental Compliance Officer (ECO) (to be appointed by the contractor) and/or external auditor with identifying the specific aspects to be managed and audited. The findings of the ESIA report for the Metolong WTW were used as the basis for determining areas of management intervention in the EMP. The key impacts, and the methodology used to determine these impacts, are described and included in this EMP. This EMP has been developed for the construction and operational phases of the proposed Metolong WTW. Given the expected several decades lifespan of the project, an EMP for decommissioning is not warranted. Options for impact management include:  Measures to minimise on-site construction impacts through appropriate design, layout, construction procedures and compensation  Measures to optimise social benefits of construction  Operational procedures to minimise and dispose of waste, and manage pollution risks  Operational management measures to enhance social benefits and minimise social and biophysical impacts, and  Monitoring requirements to ensure environmental compliance. 1.4 Background to this EMP A multi-disciplinary and comprehensive ESIA covering the Metolong Dam and associated infrastructure was undertaken by SMEC International in Association with FM Associates and Southern Waters over a period of two years, (SMEC, 2008). However at the time of the SMEC study the details of the location and design of certain infrastructure (such as the WTW) as well as the quarry and sand sources had not been finalised and more detailed planning was still required. This necessitated the need for an updated ESIA for the WTW. An ESIA has been prepared for the WTW in accordance with the requirements of the project funder (Millennium Challenge Account-Lesotho, MCA-L). In terms of World Bank ESIA regulations and MCC requirements, any project with the “potential to have significant adverse environmental and social impacts that are sensitive, diverse or unprecedented”, or located in sensitive environments, require a full ESIA. This includes a regional water treatment works with a capacity exceeding 150,000 population equivalents, and therefore applies to the proposed WTW. The following listed activities of the Metolong Project require an EIA in terms of section 19 of the Environmental Act 10 of 2008: 3.Transportation including – (b) all roads in scenic, wooded or mountainous areas 4.Dams, rivers and water resources including- a) “Reservoirs…” b) “….water transfers”

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d) “Pipelines and water reticulation systems” 6.Mining, mineral extraction including quarrying and open-cast extraction of- d) “aggregates, sand and gravel” 10.Energy and electric infrastructure including- c) “electrical substations” 11.Waste handling, storage, transport, treatment and disposal including- a) “sites for solid waste disposal and waste water treatment” 17.Projects or activities that could affect any of the following areas or features which have been demarcated as such by central or local authority: a) “streams and river channels, and their banks. NES was informed that an ESIA and EMP would be undertaken for the WTW in accordance with the above legal requirements. However, NES requested that only a comprehensive EMP be submitted to their department as a basis for obtaining an Environmental Licence (Minutes of Meeting on 26 May 2009 in APPENDIX C). The scope of the EMP was to include:  An indication of deviations from the original Terms of Reference (ToR)  Methodology of the structured impact assessment process used, which should include a risk assessment  Identification of the key impacts  Focus on management measures for mitigating key impacts  Separation of general contractor standards  Presentation of advantages and disadvantages of options for sludge disposal (APPENDIX E) The ToR is contained in APPENDIX A, with adjustments described in APPENDIX B. 1.5 Layout of this document In summary it covers the following aspects:

Chapter 1: Background to the project and EMP Chapter 2: Project Description, Technology and Processes Chapter 3: Legal Framework Chapter 4: Description of the Environment and Key Environmental Impacts Chapter 5: Institutional Arrangements, Roles and Responsibilities Chapter 6: Implementation of the EMP Chapter 7: Environmental Management for the Pre-Construction Phase Chapter 8: Environmental Management during Construction Chapter 9: Environmental Management during the Operational Phase Chapter 10: General Contractor Standards

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Chapter 11: Recommendations and Conclusions Chapter 12: References The flow charts included in Figure 1.1 to Figure 1.3 give the reader a synopsis of the key impacts identified, and the nature of the mitigation measures and contractor standards for construction that should be implemented to ensure negative impacts of the project are minimised. All the construction-related mitigation measures are considered typical or standard practices for a development of this scale in a rural environment such as the Lesotho Lowlands, such as general pollution controls, stormwater/erosion management, dust and noise mitigation, job preference for locals, compensation for lost land, HIV/AIDS awareness and training, and discharge monitoring etc.

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Figure 1.1 Flow Chart of Construction Phase (Social Impacts)

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Figure 1.2: Flow Chart of Construction Phase (Biophysical Impacts)

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Figure 1.3: Flow Chart of Operational Phase (Environmental Impacts)

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2.0 PROJECT DESCRIPTION, TECHNOLOGY AND PROCESSES 2.1 Metolong Dam and Water Supply Programme Components The overall MDWSP envision the following activities:  Construction of the ~73m high and 210m long (at crest) Metolong Dam Wall made of roller compacted concrete in the Phuthiatsana River valley below the village of Ha Seeiso. The dam will have a full supply level of El. 1671, have an estimated reach upstream of approximately 16km and will flood an area of ~260ha (SMEC 2008). The reservoir volume would be 52 million m3.  Draw off of water from the dam will be via separate intake levels situated across the 44m operational height of the dam to enable draw off from the level with optimum water quality, which is generally in the upper 5-10m of the reservoir (Mott Macdonald AFS 2007).  The raw water will be pumped from the intake works at the dam with a varying water level between El. 1671 and El. 1630 to the inlet works at the WTW at a reduced level of ~ El. 1715 over an approximate distance of 770m (SSI IFB 2009). The raw water pipeline will be installed above ground between the dam and the top of the gorge from where it will run underground to the WTW. Friction and local head losses as well as surge pressures must be calculated and allowed for in the design of the raw water supply line  The treatment works output peak capacity of 93,4 Mℓ/day (75 Mℓ/day average) is based on the demands for the 2020 planning horizon and the yield of the reservoir, and excludes production losses. Provision shall be made in the design of the Works for a site for a future 93.4 Mℓ/d expansion of the Works after 2020.  The raw water pump station and raw water pipeline will be designed to supply an average of 75 Mℓ/day and a peak capacity of 93,4 Mℓ/day, pumped between 22 and 24 hours per day, depending on the demand from the WTW.  At the WTW (located at El. 1715m), water will be treated and pumped via the Ha Seeiso Pumping Station to a Command Reservoir, a distance of approximately 3700m. From here the water will flow by gravity to Maseru where it will feed into the High South and Mpilo Reservoirs, which will be connected to the Maseru distribution system. Mpilo Reservoir will be constructed of reinforced concrete founded on bedrock; will measure 120m long x 105m width with a height of 5m and have a capacity of 75,000m3, which will be drawn down each day.  Transmission of water to Roma, Mazenod and Morija will be taken via a branch from the Maseru main pipeline near Thaba Bosiu southwards to a second junction near Ha Makhalanyane with an eastern branch to Roma and a western branch initially to Mazenod and then south to Morija. Teyateyaneng will be supplied via a pump station and secondary command reservoir following a westerly route. A total of 98km of pipeline is involved. Lines to the smaller villages will be constructed at a later date. The layout of the MDWSP is shown in Figure 2.1.

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Figure 2.1: Layout of the Metolong Dam and Water Supply Programme (MDWSP)

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2.2 Metolong WTW components The Metolong WTW will have an average capacity of 75 Mℓ/day, and a peak capacity of 93,4 Mℓ/day. Components and processes will include the following:  inlet works and chemical dosing  aeration cascade  rapid mixing, water stabilisation, coagulation and flocculation  sedimentation, horizontal flow  rapid gravity dual media filtration  taste and odour removal with Powdered Activated Carbon (PAC)  future and Dissolved Air Flotation (DAF)  disinfection and pH correction  clean water contact and transfer tank  wash water recovery and supernatant discharge to the Phuthiatsana River  sludge drying beds or sludge lagoons  instrumentation and control  administration building, workshop, laboratory and storage facilities.  potable water high-lift pump station with a flow of 1297 ℓ/sec (using 20 hrs/day to give 93,4 Mℓ/day) and a static head of approximately 100 metres.  a short section of potable water rising main from the potable water pump station to the boundary fence of the WTW.  roads and storm water drainage, water and waste water reticulation, power, lighting and communication systems within the limits of the WTW. 2.3 Location and layout of the WTW site The WTW is located ~30km from Maseru on a plateau on the north side of the Phuthiatsana River. It will be situated as close to the dam site as topography permits, to limit the length of the raw water pipeline. A location approximately 600m from the dam site has been identified, offering relatively gentle terrain, and this location has been surveyed. The treatment works location in relation to the dam site and a provisional layout of the works is indicated in Figure 2.2 and Figure 2.3. The original location was slightly to the east of the current position but has been adjusted westwards to minimise impacts on the ruins of an 19th century village (Ha Makoanyane) that is considered a significant archaeological site. Measures to prevent damage to these ruins are under consideration as part of the Advanced Infrastructure project under the MDWSP and include fencing or relocation, and contractor awareness training.

In order to establish approximate depths to the basalt bedrock, 71 test pits were excavated at the proposed location by the LWJV (LWJV/Jeffares & Green 2009). The test pits indicated depths to bedrock varying between 0.0 and 3.0m. Bedrock is overlain by residual soils derived from the weathering of the basalt. The ground elevations at the treatment works location vary from El. 1715 m to El. 1705m. This is steep for the envisaged 4m head loss through the works and as a result the overall conceptual layout has been orientated across the direct slope of the ground to reduce the gradient.

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Figure 2.2: Layout of the WTW showing position of the proposed dam wall in insert

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Figure 2.3: Layout of the WTW showing position and associated infrastructure

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Most of the key treatment process facilities and administrative offices and laboratory are planned for the northern side of the site while the sludge ponds or drying beds are located down slope on the southern side closer to the river. Housing will be located on the eastern side of the WTW. 2.4 Water Treatment Standards for Water Quality Potable water quality guidelines are being developed for Lesotho. These guidelines are likely to be similar to those developed for South Africa. The treated water produced by the WTW shall comply with a Class I water as defined in the South African National Standard for Drinking Water (SANS 241:2006 Edition 6.1) or the World Health Organisation (WHO 2006) Guidelines whichever is the most stringent. Determinants and their limit values are shown in APPENDIX H. The agreement of these standards was discussed with WASA and extracts of these minutes are attached (Appendix B). It is clear from Appendix H that the SANS 241 (2006) limits are more stringent for all determinants with the exceptions of cobalt and lead. 2.5 Water Treatment Process Potable water production: The water treatment process outlined here has been designed by the LWJV in consultation with other stakeholders such as WASA and the Metolong Authority, and is the recommended process on which impacts and management measures have been identified in this report. The Contract Documents prepared by the Engineers (LWJV) include operating performance requirements, employer project requirements, and minimum technical criteria for the design and construction of the proposed facilities. The DB Contractor shall develop appropriate designs to achieve the performance requirements and to meet or exceed these minimum technical criteria for design and construction. The treatment process for a conventional rapid gravity filter system typically consists of the following process treatment steps:  raw water screening at inlet works  aeration  future Dissolved Air Flotation (if required due to algal problems) with clarification  potassium permanganate dosing for manganese removal (if needed)  coagulation and flocculation with polyelectrolyte (pH adjustment if required)  sedimentation, horizontal flow  lime dosing  Powdered Activated Carbon addition (intermittent for taste and odour)  rapid gravity dual medium filtration  chlorine dosing and disinfection (chlorine contact tank) Washwater and sludge treatment: The washwater and sludge treatment consists of the following process treatment steps:  clarifier sludge collection  backwash water collection and solids settlement  clarifier sludge thickening

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 sludge dewatering  Supernatant from sludge drying beds to return to the Phuthiatsana River if the quality complies with the Lesotho discharge standards (Otieno 1996, APPENDIX F). The Process Flow Diagram for the WTW is presented in Figure 2.4 as supplied by the LWJV on 18 November 2009. The principal process units proposed to treat the water to the SANS 241 (2006) and WHO drinking water standards (2006 APPENDIX H). It is proposed that the WTW be modular and that all process units are replicated with allowances made for redundancies to ensure a robust series of treatment trains. Metal removal The raw water that will be extracted from the Metolong Dam for treatment is likely to contain iron, manganese and aluminium in concentrations that would require removal in the WTW process to meet the water quality standards. The WTW shall incorporate an oxidation step at the inlet to the works to oxidize the iron and manganese into an insoluble form for removal in subsequent process steps. Pre-chlorination of the raw water as the principal oxidisation step will not be permitted in order to limit the risk of potential Disinfection By-products, such as Trihalomethanes, arising in the future. Manganese removal will be done by dosing potassium permanganate upstream of the filters. Water analyses conducted at the Welbedacht WTW (operated by Bloemwater) and supplied with water from the Caledon River, of which the Phuthiatsana is a tributary, showed that raw water containing elevated levels of aluminium was treated to potable standards well within the SANS 241 range. As Welbedacht WTW is a conventional WTW, this suggests that the aluminium is particulate and is removed through the standard processes of coagulation, flocculation, clarification and filtration.

Oxidation options include oxidation by aeration or oxidation using ozone: Oxidation using Aeration Aeration may be implemented by diffused air, injectors, multiple tray cascading or by mechanical means. Forced or induced draft aeration devices shall be designed to ensure even water distribution, adequate counter currents of air and proper external exhausting. However, energy efficiency throughout the WTW should be given high priority. The suggested aeration process is therefore by cascade. The design shall include cascade aeration as the first process step to reduce odours, carbon dioxide and introduce dissolved oxygen into the water for oxidation of iron and manganese. Where diffused aeration is proposed for oxidation purposes, consideration shall be given to compressed air quality and mixing, the scaling potential of the water and subsequent air release. Aerators should have a bypass and provisions shall be made for inspection and cleaning of the devices. If the tank is enclosed exhaust gases shall be vented outside the building. Oxidation using Ozone Ozone may be offered for the oxidation of the metals. Where ozonation is proposed it shall take place after the primary algae removal process to limit damage to algal cell walls with resultant lysis of cellular material and possible release of toxic material into the treated water.

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Figure 2.4: Schematic diagram of Water Treatment Process (LWJV November 2009)

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Algae Removal The raw water extracted from the Metolong Dam may be subject to algal blooms at certain times of the year. The magnitude of the algal problems will depend in part on the success of catchment management strategies (e.g. control of fertiliser and dung inputs), and the works will be designed to handle potential algal problems. However, the treatment process should be designed for the worst case scenario that assumes no or little catchment management success. The turbidity of the water is expected to be low due to pre-sedimentation in the dam, and there will be periods without excessive algal formation. Systems for algal removal should provide for a bypass for periods when no algal bloom is detected. The WTW design is to make provision for initial dosing with Powdered Activated Carbon (PAC) but should allow for a future Dissolved Air Flotation (DAF) clarifier for algal removal if required (see DAF below), Dissolved Air Flotation Clarifiers (DAF) A DAF unit would reduce the energy requirements for air injection when algal blooms are not present and should be included in the layout for future possible inclusion in the treatment process to remove algae from the raw water. The hydraulic profile design should provide for DAF in the treatment process operating under gravity flow when required, and de-commissioning during periods when the risk of algae in the raw water is minimal. Counter Current DAF Filtration is also an acceptable method to address algae issues. Taste and Odour Removal If the Metolong Dam becomes eutrophic and algal blooms develop, taste and odour may become an issue. The works will therefore be designed to incorporate PAC dosing. The preferred location of the PAC dosing would be downstream of the DAF units but upstream of the Rapid Sand Filtration. The proposed PAC dosing point and the storage facility will be indicated on the layout plans developed by the DB Contractor. Coagulation-Flocculation The suspended solids concentration in the raw water is expected to be low as settlement will occur in the Metolong Dam. Nonetheless, coagulation and flocculation will be required to remove turbidity, organic substances and microbiological contaminants. Coagulation shall be provided to destabilize the charge on colloids and suspended solids, including bacteria and viruses. High intensity rapid flash mixing is required to mix the coagulant into the raw water prior to coagulation. Rapid flash mixing may be accomplished by either providing an in-line mixing device, mixing in a separate process tank or cascade systems. Flocculation is the gentle mixing phase that follows the dispersion of coagulant by the flash mixing unit to condition the suspended material for subsequent removal. The design of the flocculation system shall provide low tapered velocity gradients and avoid rapid acceleration to ensure maintenance of a good floc. Hydraulic mixing shall be provided and the retention time for floc formation shall not be less than 20 minutes. Flocculation tanks shall be designed to permit flexibility of operation and for ease of maintenance and cleaning. Features that shall be provided are a minimum of two tanks and appropriate drainage and access for removal of sludge and basin cleaning. Sedimentation Clarification This process will be provided to remove the majority of the settleable solids formed during the flocculation process and to optimize the efficiency of the subsequent filtration process and reduce the backwashing frequency. Sedimentation clarification will involve gravitational settling in sedimentation tanks. The efficiency of sedimentation will depend on surface overflow rate (also known as surface loading rate), inlet and outlet arrangements, type of sedimentation tank, raw water characteristics, and local climate conditions. Sedimentation tanks will most likely comprise horizontal rectangular basins to maximise the available space at the site. Clarifiers shall be designed on the basis of surface overflow rates with due consideration given to the type of floc generated and water temperature. Inlets of the sedimentation tanks should provide equal distribution

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and uniform velocities that maximize the opportunity for particles to settle. Outlets shall be designed to maintain settling velocities and to minimize short-circuiting. The sedimentation tank shall incorporate an automatic sludge removal system. A positive sludge removal system shall be provided to ensure that sludge banks do not develop on the floor of the clarifiers. Consideration shall be given to bypasses and overflows to prevent flooding and means for observing the settling performance. Filtration Filtration will be required after pre-treatment to remove suspended solids, turbidity and reduce microbiological contamination. Dual media (sand/anthracite) filtration may be offered to reduce the works footprint as well as reduce taste and odour associated with possible algal blooms. The DB Contractor will design a filtration system based on technical considerations provided in the tender documentation. These considerations will include hydraulic gradients, head losses, filtration rates, back- wash rates in accordance with grain size of the medium used (e.g. sand/anthracite), overflows to prevent flooding, means of flow regulation, headroom for inspection and operation, drain capacity, amongst others. The initial filter water shall not be fed into the treated storage tank and pressure filtration will not be acceptable. Disinfection Disinfection is the final step in the water treatment process which is required to further reduce and/or inactivate the number of pathogenic organisms in drinking water, and can also serve other purposes such as taste and odour control. Chlorine disinfection shall be provided to maintain a residual chlorine concentration in excess of 0.5 mg/ℓ in the final treated water leaving the works in accordance with the requirements of SANS 241:2006 (Edition 6.1) and WHO (2006). On-line instrumentation to monitor the final chlorine residual and adjust the chlorine dosing rate shall be provided. A manual backup system shall be provided. The chlorination equipment shall have an adequate capacity to maintain a minimum free chlorine residual of 0.5 mg/ℓ at the outlet from the works. Gaseous chlorine installations shall be in conformance with the IFC Environmental, Health and Safety guidelines (IFC, 2002) as well as SANS 10298 – 2005 Edition 1.1 or equivalent standards. One ton chlorine gas tanks shall be used. Water Stability The raw water is relatively low in alkalinity, and chemical stabilization is required to ensure that aggressive waters do not develop.

Raw water will be stabilized with lime using a dry lime feeder. Calcium Carbonate Precipitation Potential (CCPP) should be used as the water stability index. Polyelectrolyte Dosing All chemicals used at the WTW (see section 2.7) shall be approved for use in WTW’s in Lesotho by WASA. Requirements for chemical safety in terms of labelling, storage, safety, spill control and other factors must comply with the chemical safety data sheets and will be required operational responsibilities of the DB Contractor. According to correspondence received by the Chief Executive of WASA (T Tlali dated 05/08/09) the following is the reason that WASA uses polymers and not alum:

 The amount of sludge from the organic coagulants (polymers) is relatively smaller compared to the sludge from inorganic coagulants (Alum etc.) because they are bio-degradable.  The effect of the use of organic coagulants is minimal on the pH as opposed to the use of inorganic coagulants which reduces the pH considerably requiring the use of costly additional pH correction.

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 Organic coagulants have higher molecular weight than the inorganic coagulants resulting in better coalescence of flogs at minimum turbidities.  The use of organic coagulants results in relatively less corrosive water as compared to the inorganic coagulants.  For the same amount of potable water produced fewer quantities of organic coagulants are used compared to the vast amounts of inorganic coagulants needed. Consequently, the use of organic coagulants is cost effective.  For the production of 75ML/d potable water at the Metolong Water Treatment Plant, the following are to be considered:

 Vast amounts of Alum shall be required hence a large storage facility will be required,

 The handling (transportation, off-loading and mixing) of Alum compared to polymers is cumbersome because in the Southern Africa region it is readily available in granular form of 50kg bags.

 Polyelectrolyte dosing shall be automatically controlled based upon streaming current measurements, with a manual back-up system provided.

It is likely that the two products listed below will be used as these are the products currently used by WASA, as coagulants and flocculants:  Südfloc 3TL  Südfloc 3456 These specific coagulants and flocculants have a low environmental toxicity (refer to MSDS’s included as Appendix G). Clear Water Storage A covered clear water tank shall be provided on site for storage of treated water and process water. Process Water Recovery The design of the WTW shall ensure that water losses through the works shall not exceed 10% of the incoming raw water. Process water recovery is not required. Effluent (waste and wash water) produced on site may only be discharged to natural environment if the quality complies with the Lesotho effluent discharge standards (Otieno 1997, APPENDIX H). Disposal of Waterworks Residuals The WTW process will be required to ensure adequate treatment and/or disposal of all WTW wastes. These include filter backwash, filter-to-waste and sludge. Disposal of residuals into the watercourse shall not be permitted. Sludge drying beds are considered appropriate technology in this location. If sludge drying beds are proposed the beds shall be sized for a planning horizon of 5 years and a minimum of two drying beds shall be provided with a decant system to aid sludge dewatering. The various waste streams that may arise from the works are described below. Sanitary, cleaning water and storm water wastes All sanitary wastes (sewage) will be segregated within the plant from process wastewaters. Sanitary wastes (sewage) shall be conveyed to a sewer connection point to be provided under the Advance Infrastructure project to drain sewage to the proposed Waste Water Treatment Works (WWTW) downstream of the WTW. All other waste water flows produced at the treatment works shall be collected in sumps and conveyed to the sewage treatment works to be constructed for the WTW and the Dam by others.

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Rain water from roofs and collected from other surfaces and not contaminated may be collected separately and discharged directly into the stormwater system. The DB Contractor is required to develop a Stormwater Drainage Plan. Filter Backwash The DB Contractor is required to come up with a method to manage the filter backwash so as to have the least environmental consequence. The following are possible options that are available for disposal of the filter backwash water from the Metolong WTW together with comments on the viability of the options:  Recycle back to the head of the work and put back through the sand filters. In Lesotho, this option could result in an accumulation of Giardia and Cryptosporidium oocysts (from upstream catchment activities) and is possibly not an acceptable option. This option would also require additional treatment, possibly with high-tech equipment that would in turn require a higher cost and level of training that is not currently expected to be available with this WTW.  Recycling of these waters may be possible after suitable treatment such as quiescent gravity settling to ensure settling and removal of solids. The supernatant from the settling tanks ponds could be returned prior to the point of primary coagulant addition. Re-cycling of these waters, however, is not considered viable for the Metolong WTW.  Evaporate off the water in evaporation pans (lagoons), which would require extra land and would also leave some residue (sludge) that would need to be disposed of, and is not considered a viable option.  Return of filter backwash water into the river. The polymers that WASA have suggested for use degrade readily. The water quality would however need to be tested for compliance with Lesotho discharge standards (Otieno 1997) to determine if this option is possible. This option is considered to be the mostly likely option for the final disposal of the filter backwash water.

Information gained from settling tests undertaken on the Maseru WTW’s filter wash (supernatant,LWJV IFB 2009) indicated declining concentrations of most variables the longer the wash water is allowed to settle, with the exception of faecal coliforms, ammonia and manganese. All other concentrations reduce with time and the concentrations were within the Lesotho discharge standards limits (Otieno 1997) after 72 hours of settling. However, reduction in the iron and manganese concentrations is expected to occur with blending of the sedimentation washwater and the filter backwash water. Manganese concentrations are expected to be lower in the raw water from Phuthiatsana River at Metolong compared to that from the Caledon River at Maseru. Maseru WTW also does not aerate the raw water nor have any treatment processes for iron and manganese removal. With effective treatment processes the iron and manganese should be oxidized to particulate form and settle out with the sludge. To bring the faecal coliforms to within limits, the final effluent may need to be chlorinated, but this may not be required with the solar UV irradiation that will occur at the sludge lagoons. It is recommended that the filter backwash water should be blended with the supernatant separated from the sludge drying beds, and if they comply with Lesotho discharge standards (Otieno 1997), then this waste water can be discharged to the Phuthiatsana River (refer to Figure 2.4). . If non-compliant then the supernatant will require treatment and/or dilution to meet the standards for release back to the river below the dam wall. Sludge’s from the WTW Sludge drying beds are the proposed technology for dewatering the residuals generated by the plant, as the technology is considered appropriate for the plant location. Solids will settle in sludge drying beds or lagoons, and clarified water (supernatant) will be removed by decanting and draining. The final disposal of the air-dried residuals may take place either to land (in the form of soil augmentation and/or donga rehabilitation) or to a landfill site. Land-based disposal for beneficial use is the preferred option if it complies with standards. The potential issues associated with the various options are discussed in APPENDIX E and the options summarised in Table 2-1 below.

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Table 2-1: Summary of sludge disposal options Sludge disposal options

Criteria for Agronomic Landfill cover or Donga Discharge to stream Reuse comparison application / land disposal rehabilitation spreading

Logistics / Requires soil and Requires investigation Requires soil and Easiest solution logistically Requires finding Administration sludge monitoring to to determine available sludge monitoring to but not supported by NES. entrepreneurs determine feasibility land fill disposal determine feasibility of Would require monitoring willing to take on and ongoing options, or if none using sludge for donga and effective treatment to and commit to monitoring to check suitable, investigation rehabilitation. Needs to ensure compliance with collecting and suitability. and authorisation to involve and get buy-in effluent standards. reusing sludge for establish new site of Soil Conservation. brick making etc. near Metolong.

Cost of Low, if sludge users High as need to be High, as will require Low Low if removed by disposal willing and able to trucked to landfill site bagging and transport entrepreneurs remove it free of in unknown location to places of use. charge

Potential Beneficial agronomic No land use benefit Potential land use No land use benefit High if sustainable social and use if sludge content benefit - donga use in brick making agronomic suitable But possible benefit rehabilitation and possible. benefit as landfill cover restoration of land use capacity.

Potential risks High, if sludge found Low, if landfill site High, if sludge found to High if sludge contains trace High probability to be high in trace suitably located. be high in trace metals metals and causes water that such metals and causes and causes soil toxicity pollution, possibly restricting entrepreneurs will soil toxicity and High, if landfill and inhibition of plant use for down-stream not fulfil long-term inhibits plant growth leachate causes soil growth (can be irrigation. Risk also depends commitment to its (can be regulated or water pollution regulated through on quantity of sludge use as bricks may through monitoring) monitoring) released and base flow of not be of the river (potential for sufficiently high dispersion) building standard.

Conclusions All the measures proposed will require analysis and monitoring of the sludge constituents once the WTW is operational.

Use of sludge for agronomic purposes or donga rehabilitation, if found to be suitable, provide a social and land use benefit, and could be sustainable disposal options provided sludge analysis shows that constituents are not toxic to soil and water and will not inhibit plant growth. However, these options will require more intensive analysis to establish the feasibility of its use for these purposes and to find users or entrepreneurs willing to be contracted to remove the sludge on a continual basis.

Landfill disposal should be considered as a back up option for instances when sludge quality is not suitable for agronomic or donga use, i.e. when trace metals are found to be higher than acceptable.

Sludge disposal for land augmentation (soil improvement or donga rehabilitation) is the preferred if sludge found to be compliant with standards and suitable for the receiving environment.

The estimated average residuals mass produced on a daily basis when the plant is operational (before future expansion in the longer term) is calculated below (APPENDIX E):

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 Residuals mass due to turbidity in raw water = 100 NTU x 75Mℓ/day = 7 500 kg /day  Average residual mass due to coagulant dosing = 990 kg/day  Average residual mass due to lime dosing = 768 kg/day  Total residuals mass = 9 258 kg TSS/day Where: NTU = Nephelometric Turbidity Units Facilities for the removal of concentrated sludge will be incorporated into the design of the WTW Supernatant from sludge drying beds The disposal of supernatant back to a river or dam is common practice in many waste water treatment works and some of the bigger ones have an on-line monitor/sensor that triggers if the water quality exceeds a certain threshold. This water is then collected and stored in a holding dam until the quality has been suitably diluted so as to meet the discharge standards. These supernatants can also be treated with a disinfectant such as chlorine and then put through a wetland to ensure that potential pathogens are removed before entering the receiving Phuthiatsana River. Return of supernatant to the river (if compliant with Lesotho’s discharge standards, Otieno (1997) and SA General Authorisation limits, APPENDIX F) is regarded as the most viable option for disposal of the filter backwash.

In summary, the proposed treatment process consists of cascade aeration; potassium permanganate dosing to oxidize the potentially elevated manganese and iron present; lime dosing to add alkalinity to prevent the risk of aggressive water; seasonal PAC dosing to reduce taste and odour associated with possible algal blooms, followed by coagulation, flocculation, clarification and rapid gravity filtration. Filtration would be followed by disinfection using gaseous chlorine. Chlorine would be dosed into the feed line into the clear water storage/transfer tank at the water treatment plant before the treated water is fed into the distribution system. 2.6 WTW Chemicals and Storage Requirements The chemicals and other additives that may be used in the WTW are listed in Table 2.2. Management requirements for chemicals are given in their Material Data Safety Sheets (MSDS) attached in APPENDIX G. Table 2-2: Chemicals used in Water Treatment Works and their hazard ratings (where 0 = no hazard, and 3 = high hazard rating) Chemical Purpose Health Hazard Fire Hazard Reactivity

Polymers Coagulation

SudFloc 3TL and 1 0 0 3456

Slaked lime Water conditioning 3 0 2

Potassium Manganese removal 1 0 0 permanganate

Powdered activated Odour and taste 1 1 1 carbon removal

Chlorine gas Disinfection 2 2 3

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Chemical storage capacity shall be sufficient for 45 days operation at maximum throughput. The storage capacity for each type of chemical shall be based on the supplier’s standard delivery quantity plus an allowance of 14 days. The storage requirements associated with 45-days of storage at the average dosing rate for the ultimate design flow are listed in Table 2-3. The management measures associated with the transport, storage, handling and disposal of chemicals are listed in Chapter 9. Table 2-3: WTW 45-day chemical storage requirements Chemical Dosing Rate Storage Remarks

Polymer 10 mg/litre 210 x 200kg drums Supplied in 200ℓ drums at 1kg/ℓ

Lime 10 mg/litre 42 tonnes Supplied in 50kg bags.

Powdered Activated 30 mg/litre 4200 x 30kg bags Supplied in 20 to 30 kg bags. PAC will be Carbon dosed seasonally as needed at a maximum rate of 30 mg/ℓ.

Chlorine gas 4 mg/litre 17 x 1000kg (1 ton) Supplied by bulk road tankers. portable tanks / Portable tanks are supplied as 925 / 900 / 1000 kg portable tanks. cylinders

It is expected that all chemicals will be imported into Lesotho by road from South Africa. See Chapter 9 for the management issues related to the transport of chemicals.

The design specifications for the WTW make provision for a chemical storage building and a chlorine storage facility. See Section 9.1 for the chemical handling, storage and disposal management measures. Due to the inherent dangers of gaseous chlorine dosing installations, the design of the dosing installation will make provision for strict control measures and for intervention in the event of a gas leak. The detection, containment and treatment of an area affected by a leak will be required. It is recommended that the chlorine gas detection, system containment and air scrubbing system with sodium hydroxide be installed. However, the final design and preparation of a detailed Emergency Response Plan (see Section 9.3) will be finalised by the operator using the WASA (2007 guidelines and the template in Appendix C).

2.7 The WTW DB Contract 2.7.1 WTW implementation The contract to undertake detailed design, layout and construction of the WTW will be undertaken through a Design-Build Contract. The short listed companies or consortia will be given the tender specifications, the Basis of Design Report, compliance standards and this EMP. The tender process commenced in August 2009 with the aim of securing a preferred contractor to start the construction in January 2011. The Contract Documents prepared by the Engineer include operating performance requirements, Employer project requirements, and minimum technical criteria for the design and construction of the proposed facilities. The Contractor shall prepare its own final design to achieve the performance requirements and meet or exceed these minimum technical criteria for design and construction. 2.7.2 Scope of the Design-Build Contract The work to be carried out under this Contract includes but is not limited to the following principal items:  a 600 m long by 1200 mm diameter raw water supply line from a connection point from the Metolong Dam pump station to the inlet works of the WTP to cater for the future raw water demand of 105 Mℓ/day (including a 10 % allowance for production losses);  a 93.4 Mℓ/day output water treatment work, including associated civil engineering work;

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 electrical switchgear and control panels;  a control and monitoring system;  a Computer-aided Maintenance Management System (CMMS);  administration building with offices, laboratory, break area, men and women locker rooms with toilets and showers, first-aid facilities; maintenance workshops, and storage facilities. The latter are to include: chlorine building for chlorine storage and feed facilities, including all safety equipment required; chemical building to provide for the equipment appropriate for the storage and addition feeding of both dry and liquid chemicals; buildings for spare parts storage, electrical and mechanical workshops, power feed and transformers, stand-by generator and field offices, and stand-by generator room designed to minimize noise from the operating generator;  potable water high-lift pump station with a flow of 1088 /sec to the Command Reservoir with a TWL of 1840 mMSL;  potable water high-lift pump station with a flow of 10.3 ℓ/sec to the future reservoir supplying the Metolong Village with an estimated TWL of 1838 mMSL;  potable water high-lift pump station with a flow of 2.78 ℓ/sec to the future reservoir supplying the future business centre, visitors centre, hotel and staff quarters with an estimated TWL of 1735 mMSL;  a short section of potable water rising main from each potable water pump station to 5 m beyond the boundary fence, including the connection to the rising main;  roads, storm water drainage, landscaping, security system, fencing, power, lighting and communication systems within the limits of the Water Treatment Works;  as-built drawings, and operation and maintenance manuals;  training of the water works operator's personnel in the operation and maintenance of the Works;  temporary facilities for use by the Engineer;  temporary facilities for the Contractor's use, in allocated works areas; Some of the specific support infrastructure and services required for the WTW are described below. The Contractor will be expected to obtain the necessary permits required for the abstraction of raw water for construction and potable use, inspection, construction or testing of the WTW. 2.7.3 Specific infrastructure and services Infrastructure and services available to or to be provided by the DB Contractor are indicated below and have been extracted from the Basis of Design Report (LWJV IFB 2009). 2.7.3.1 Roads and access Access to the site shall be from the existing asphalt road to the boundary of the site and shall be limited to one entrance. The Contractor will be required to provide additional access and haul roads and comply with all regulations governing use of national roads, rails, border crossings, load clearance limits and to make arrangements with appropriate government authorities governing passage of heavy construction vehicles. A 6 m construction servitude has been provided adjacent to, and outside of, the Site boundaries on the east, south and west to assist the Contractor in constructing the permanent fencing and to provide a location for any temporary security fencing needed by the Contractor prior to completion of the permanent fence. Any existing rights of way, pony tracks or roads running through the Site shall be diverted around the Site to prevent unauthorised persons from inadvertently entering the Site. Such rights of way, pony tracks, roads or diversions shall be kept open at all times except for short periods when construction activities such as

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surface blasting could require closure for safety reasons. All blasting will be done in accordance with the requirements of the IFB documentation, including a dilapidation survey and community notification system (see section 8.6). Blasting permits if required will need to be attained from the Lesotho department of Mines and Geology. 2.7.3.2 Fencing The site of the Water Treatment Works is to be enclosed with a permanent 2.4 m high palisade security fence with local stone posts and devil’s tongue or other like style metal fencing. The tops of the stone posts shall have anti-trespass devices. A heritage specialist appointed by the Department of Culture has assessed the significance of the ruins of an old 19th century wall and is currently surveying and mapping it. Sections of the wall within the WTW Site can be removed where required to make way for the WTW. Should any of the 19th century stone wall remain on site where not required to be removed for construction purposes, a 1.25 m high fence, with a pedestrian access gate, shall be erected around the remains. This fence shall remain in place and not be removed at the end of construction. Safety fences shall be erected around electrical and mechanical equipment before that equipment is connected to any electrical supply. A temporary Site security fence – 1.4 m above ground and with at least 7 strands of barbed wire - shall be erected on the outside edge of the construction servitude, and shall be erected prior to any other work commencing on the Site. Access points and gates in the fence shall be controlled by the Contractor to prevent unauthorised access to the Site. This fence is to be removed by the Contractor upon the completion of the Works. Signs in English and Sesotho shall be attached to the fence at intervals not greater than 300 m advising that unauthorised entry is prohibited and that the site may be dangerous to trespassers. Additional signs shall be erected at focal points of potential access to the Site. The signs shall be maintained in a readable condition for the duration of the Works. Where any temporary fence has to be erected alongside a road, footpath, or other public thoroughfare, it shall be of the type required by, and shall be erected to the satisfaction of, the Government authority concerned. 2.7.3.3 Electricity An 11 kV power supply with a total of 10 MVA capacity is available at the site. The dam and downstream conveyance and other contractors will also have access to this power supply. The WTW Contractor will be allocated 3.0 MVA for both the temporary and permanent works. The Contractor shall design, install, operate and maintain his 11 kV and low voltage distribution. 2.7.3.4 Telecommunications Intermittent cellular phone reception exists at the WTW. There is no landline service to the area but Telecoms Lesotho have been asked to provide a proposal to ensure cell phone coverage. 2.7.3.5 Water A small potable water treatment facility with a capacity of ~30 m3/day is being established near the WTW for potable water use during construction. Water from this plant will be shared by both the dam and water treatment works contractors and the permanent water treatment plant staff housing until the Metolong WTW is commissioned. Potable water shall comply with the requirements of the South African National Standards for drinking water (SANS 241:2006, WHO 2006, refer to APPENDIX H and section 2.4). Minutes of a meeting held as part of the Metolong Dam Programme (WTW: Developing DB Contract Documents & Conducting Environmental/Social Impact Assessment Contract WS-A-004-08, Technical Meeting (#010) 20 July 2009) are included in Appendix C. In this meeting it was confirmed that the treated water quality is to conform to the South African specification for treated water SANS241 and World Health Organization Guidelines. The Contractor shall be required to provide water for his construction activities from sources to be identified and developed by the Contractor. This is most likely to be taken from the Phuthiatsana River and will require

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a water abstraction permit from DWA, which the DB Contractor will be required to obtain. The Contractor shall provide an ample supply of clean water for construction purposes including but not limited to aggregate processing, concrete, washing down, and other uses on the Works. All temporary water treatment systems constructed by the Contractor are required to be removed on completion of the Works. 2.7.3.6 Sewage and waste water disposal An offsite wastewater treatment plant (WWTP) is to be constructed under the Advance Infrastructure Contract to treat flows from the permanent water treatment plant staff housing, contractor’s temporary management housing sites, contractor’s offices, and Engineer’s office. All sanitary wastes (sewage) should be segregated within the plant from process wastewaters. Sanitary wastes (sewage) shall be conveyed to a sewer connection point to be provided under the Advanced Infrastructure project to drain sewage to the proposed Waste Water Treatment Works (WWTW) downstream of the WTW. The WTW DB Contractor is required to furnish temporary sanitary facilities at the Site for the needs of all construction workers and others performing work or furnishing services on the Project. Sanitary facilities shall be of reasonable capacity, properly maintained throughout the construction period, sited 50m from water courses or springs, and hidden from public view to the greatest practical extent. If chemical toilets are used, at least one toilet will be furnished for every 20 workers. The Contractor shall design, install and maintain treatment facilities on site for disposal of wastewater from the Contractor's camp accommodation, camp amenities, workshops, stores, and other buildings constructed by the Contractor in the Works area and having wastewater flows in accordance with the appropriate requirements of SANS 1200. Temporary sewage and waste water facilities shall be removed on completion of construction. 2.7.3.7 Solid waste disposal The Contractor will be required to provide metal dust bins or equivalent plastic receptacles for the storage of solid waste at all accommodation facilities and works areas. Separate bins should be provided for municipal solid waste (general), industrial waste and hazardous waste. All storage of solid waste shall be fenced and locked to keep unauthorized persons from entering the area and stored in such a way to prevent vermin from accessing the waste. The storage area shall be kept clean at all times. No solid waste of any kind shall be left outside the bins at any time and no burning of waste will be permitted. The DB Contractor will be required to establish a refuse control system for the collection and removal of refuse to the satisfaction of the Engineer. The Contractor shall be responsible for the regular removal of solid waste and transport by licensed waste haulers to a licensed landfill or site approved by the regulatory authority or suitable waste disposal site (to be determined under the Advanced Infrastructure Project) at least twice per week or on an as needed basis. Hazardous waste, such as fuels, oils etc shall be transported by licensed waste haulers and disposed of in a licensed landfill capable of handling such wastes. Since no such facility occurs in Lesotho, the waste will have to be transported by a licensed hauler and disposed of in South Africa at a registered hazardous waste site. 2.7.4 Stages of the Design-Build Contract The Design-Build Contract involves three main stages: i) Construction - The Construction Stage includes design and physical construction of the Works to the point where it can be used for its intended purpose and is expected to take 30 months. ii) Tests on Completion -The Tests on Completion Stage is the stage after construction within which the Contractor shall operate the Works for a period of 180 days. At the conclusion of the Commissioning Period and after the Works has passed all tests required under the Tests on Completion, the Employer will issue the Taking Over Certificate. iii) Assisted Operation - During the Assisted Operation Stage the Works will be operated by the Employer staff under supervision of, and with the assistance of, the Contractor’s staff for a period of 185 days. It is

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the period during which Employer staff shall be trained in all aspects of the operation and maintenance of the Works. 2.7.5 Reporting Requirements of the DB Contract The following documents (environmental documents indicated in bold) are specified in the tender documents for the DB Contractor (LWJV IFB 2009): 2.7.5.1 Pre-construction Phase  Preliminary Design  Work Programme  Quality Assurance and Quality Control Program  Equipment List  Recruitment, Testing, Training And Employment Programme  Health and Safety Plan  Construction Risk Management Program  Dilapidation Survey (for blasting)  Environmental Protection Plan (EPP)  Subcontractor Lists  Guarantee Certificates 2.7.5.2 Construction Phase  Final design packages  Shop drawings which also includes samples with test results, product literature, catalogue data, Operation and Maintenance information, mix designs, training materials  Emergency action plans  Monthly Schedule Update  Contractor Pay Estimate  Monthly Progress Report  As-Built Drawings  Operation, Maintenance and Training Program  Maintenance Program  Computer Systems  Records 2.7.5.3 Post-construction Phase  Monthly Reports  Performance Tests

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 Written Notices of Substantial and Final Completion  Release of Liens and Waiver of Debts and Claims  Consent of Surety Final Payment  Final Application for Payment

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3.0 LEGAL FRAMEWORK The EMP has been compiled in compliance with the requirements of the Lesotho Environment Act of 2008, the 2002 EIA guidelines of the Lesotho Environment Authority (now National Environmental Secretariat - NES), and in accordance with World Bank Operational Guidelines and MCC guidelines, as well as best international practice. The EMP is a stand alone document and is designed to be as user-friendly as possible and is set out in such a way as to facilitate oversight by decision-makers and implementation by the Contractor and relevant authorities. 3.1 Relevant legislation and policies of Lesotho Table 3-1 is a synthesis of the key legal and policy provisions in Lesotho that are relevance to this study. Table 3-1: List of Legislation and Policies relevant to the WTW Legislation or Nature of Issue Specific requirements policy

Constitution of Protection of 1. Requires Lesotho to adopt policies to protect the natural and Lesotho (section 36) Environment, cultural environment and to assure all citizens a safe environment Culture and Social adequate for health and well-being. Health

Timeous 2. Stipulates a requirement for “prompt payment of full compensation” compensation for compulsory acquisition of moveable and immovable property for payments public purposes

Environment Act 15 of Environmental Requires an EA for projects dealing with water, reservoirs, pipelines 2008 Assessments and associated structures. Describes the requirements for the EA process and possession of an EA licence before proceeding with development or operation of a scheduled project.

Provision is made for regulations governing noise, effluent and air quality.

Permits and licenses Regulates the need for obtaining permits and licenses from NES for excessive noise (Noise permit); effluent discharge to sewage system (Effluent license), emission of dust or gases (Pollution license) or to operate a land fill site or store or transport hazardous waste (Waste License).

Land and Land Acquisition

Land Act of 1979 Compensation for 1. Regulates the determination of compensation and provides for a land (section 56-59) period of 3 months for submitting compensation claims from date of declaration notice although allows for extension of time frame.

2. Where remaining land after acquisition is less than 500m2, the affected land occupier can request acquisition and compensation for entire landholding.

3. Provides for compensation for damage to land within public servitudes (section 72).

Selected Provides for the setting aside of SDAs for development, construction Development Areas or readjustment of boundaries. It revokes all existing titles but (section 44) substitute rights may be granted.

Water Sector Compensation Establishes compensation principles, organisational arrangements Improvement Plan and design criteria to be applied to people affected by the project. It

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Legislation or Nature of Issue Specific requirements policy

(WSIP) Policy was designed incompliance with the requirements of the Lesotho Framework for Land government and World Bank (OP 4.12). Acquisition and Compensation It requires that land acquisition should be avoided where feasible or minimised and all viable alternatives should be explored. Where acquisition is unavoidable, compensation should be provided to the full value of the land or assets acquired, and any loss of livelihood as a result. It also specifies the categories of affected persons qualifying for compensation.

Entitlement for land losses is based on land swaps or by purchase at prevailing prices, while buildings and structures are replaced on an equivalent structure or with cash and/or credits based on replacement cost.

Water

Water Resources Act Water use and Provides for the use, control, protection and conservation of water 22 of 1978 (now pollution controls resources. Control and use of water for non-domestic purposes updated by new act of including bulk extraction, storage and treatment, requires a permit 2008) from the Minister.

The Act also defines water pollution in wide ranging terms and makes provision for regulations to control and prevent such pollution.

Permits for water extraction and treatment by DWA will be forthcoming from the Ministry via the office of the Commissioner of Water who is actively involved in the development of the project. A permit will also be required for water abstraction for construction.

Natural & Cultural heritage

Historical Monuments, Natural and cultural Provides for the protection of cultural sites and artefacts, as well as 16 Relics, Fauna and heritage types of fauna and 11 types of flora some of which occur in the study Flora Act No 41 of area (but which are not threatened in Lesotho). These include 1967 tortoises, terrapins, cranes, storks and herons, hammerkops, birds of prey and egrets).

National Heritage Bill Natural and cultural This Bill will provide for the protection, preservation and conservation (2006) heritage of cultural, natural and living heritage of Lesotho. The Dept of Culture is the agency responsible for the implementation and administration of the Act and its regulations. Also provides for the establishment of a Heritage Commission.

3.2 Permit Requirements Permits required for the WTW are listed in Table 3-2. The Contractor is required to obtain the necessary permits. No water may be discharged to the natural environment unless it complies with Lesotho’s effluent discharge standards (Otieno 1997, APPENDIX F).

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Table 3-2: Permit or licence requirements and relevance to the WTW study Act, Regulation or Permit or licence Requirements Implementing Responsibility By-law Agency for obtaining permit

Environment Act 10 Effluent Licence Licence to discharge effluent into NES Not relevant of 2008 sewage system. Validity: 1 year. Fee as prescribed.

Environment Act 10 Pollution Licence Licence to emit any gas, dust or NES Not relevant of 2008 smoke or any other atmospheric pollutant in excess of the prescribed standards. Validity: 1 year. Fee as prescribed.

Environment Act 10 Noise permit Permit to allow excessive NES Not relevant of 2008 emission of noise (in excess of the noise emission standards). Validity: to be specified. Fee as prescribed.

Environment Act 10 Ionising radiation Licence to import, process, mine, NES Not relevant of 2008 export, possess, transport use or dispose of radioactive materials or other sources of dangerous radiation. Validity: 1 year. Fee as prescribed.

Environment Act 10 Waste disposal site Licence required owning or NES Only relevant if of 2008 operating a waste disposal site or new landfill site plant, other than domestic waste; required. generating, storing, handling, transporting or disposing hazardous waste. Validity: 1 year. Fee as prescribed.

Water Resources Water abstraction Permit will be required from DWA DWA Relevant - Act 22 of 1979 and for abstraction of water from a Contractor should Water Resources river for construction. obtain a permit Regulations 22 of 1980

Mines and Minerals Mining (or An ESIA is a prerequisite for Ministry of Not Relevant (as Act, 1966 quarrying) Licence obtaining mining rights Natural using commercial Resources sources) but if blasting is required then a permit will be required

Municipal by-laws Building permit Have to have fulfilled all Municipalities Not relevant environmental requirements and and Ministry of include the ESIA Licence in the Local application for a permit Government

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3.3 Policies of the World Bank Policies of the World Bank have been reviewed and summarised here. Some are relevant to the overall Metolong project and not specifically to the Water Treatment Works but have been included for context. Table 3-3: Summary of World Bank Operation Policies and relevance to the Metolong Project (synthesised from SMEC 2008) World Bank Policy Key Provisions Relevance

OP/BP 4.01 Ensures appropriate level of environmental and social assessment is Yes Environmental carried out. Deals with public consultation and ensures that the views Assessment of project-affected persons and local NGOs are taken into account. Outlines the content of EA reports and EMPs for Category A projects

OP/BP 4.04 Natural Supports the conservation of natural habitats and the maintenance of No (not in the Habitats ecological functions as a basis for sustainable development. The WTW area) Bank does not support projects that involve the significant conversion or degradation of critical natural habitats.

OP/BP 4.09 Pest Promotes the use of biological or environmental control methods and No (not in the Management reduces reliance on synthetic chemical pesticides WTW area)

OP 4.36 Forests Aims to reduce deforestation and enhance through sustainable No (not in the economic development the environmental and social contributions of WTW area) forests. The bank does not support projects involving significant conversion or degradation of critical forest areas or related critical natural habitats.

OP/BP 4.11 Physical Cultural property includes remains left by humans (rock art, middens, Yes (19th century cultural resources shrines) and unique natural environmental features such as canyons village remains in and waterfalls. The bank does not support projects that will the WTW area). significantly damage non-replicable cultural property and assists only those projects that are sited or designed so as to prevent such damage.

OP/BP 4.12 Involuntary Requires projects to minimise involuntary resettlement and to explore Yes (for loss of resettlement all viable alternatives; where resettlement required, resettlement land in the WTW should be executed as sustainable development programs and area, and displaced persons should be meaningfully consulted and have possible opportunities to participate in planning and implementing resettlement resettlement from programmes. Projects must assist displaced persons to improve their quarry site) livelihoods and standards of living to pre-displacement levels. It requires prompt and effective compensation at full replacement cost for losses of assets directly attributable to the project; moving allowances and provision of residential housing or housing sites. Taking of land and related assets may only take place after compensation has been paid, and where relevant, where resettlement sites and moving allowances have been provided.

OP 4.37 Dam Safety and Not relevant to OP7.50 Projects on the WTW, but International waterways relevant to the whole MDWSP

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3.4 Policies of MCC and Metolong Authority MCC has its own set of environmental guidelines governing procedural and reporting practices for conducting environmental assessments. The guidelines are based on best practice and largely draw on World Bank requirements and reporting formats. Emphasis is placed on compliance with legal requirements of the host country and international best practice; participative and meaningful stakeholder participation; detailed assessment of feasible alternatives, and public availability of reports. EIA reporting requirements follow the World Bank Operational Manual 4.01. Table 3-4 indicate MCC policies of relevance to the WTW projects and Table 3.5 indicates relevant policies of the Metolong Authority. The Metolong Dam activity is a Category A project under MCC’s Environmental Guidelines due primarily to the potential environmental and social risks associated with the project, which include loss of communal resources, loss of traditional access routes across the river, inundation of cultural resources and alteration of downstream surface water hydrology. The entities funding the dam have agreed that the entire project, including the dam, reservoir and downstream bulk water conveyance system, will be designed and constructed according to common standards that meet MCC’s Environmental Guidelines, the MCC Gender Policy, GoL law, and World Bank Operational Policy 4.12 on Involuntary Resettlement. Compact funding for the bulk water conveyance system will be conditioned on strict adherence with the larger project’s environmental management plan (“EMP”) and resettlement and compensation action plan (“R&CAP”), completed earlier this year with World Bank funding. The urban, peri-urban and rural water activities are considered Category B and Category C projects under MCC’s Environmental Guidelines and do not pose significant adverse environmental and social impacts. Standard EMPs will be developed for each activity to assure compliance with MCC’s Environmental Guidelines and GoL legislation. Table 3-4: MCC policies of relevance to the Metolong Project MCC Policies Key Provisions

Guidelines for The purpose of the Environmental Guidelines is to establish a process for the review of Environmental and Social environmental and social impacts (such as involuntary resettlement and impacts on cultural property, for example) to ensure that the projects undertaken in a Compact Assessment (2006) are environmentally sound, are designed to operate in compliance with applicable regulatory requirements, and, as required by the legislation establishing MCC, are not likely to cause a significant environmental, health, or safety hazard. The guidelines reflect Section 605(e)(3) of the Millennium Challenge Act of 2003 that prohibits MCC from providing assistance for any project that is "likely to cause a significant environmental, health, or safety hazard." Municipal wastewater treatment plants with a capacity exceeding 150,000 population equivalent are specified as a listed activity requiring an EIA.

Standard EMPs are to be developed for each activity to assure compliance with MCC’s Environmental Guidelines and GoL laws for projects that can have significant environmental impacts. The guidelines are designed to review and screen projects for MCC funding, as well as to guide the Environmental assessments process. Guidelines for the contents of EIAs follow the World Bank Operational Manual OP4.01.

Gender Policy (2006) The gender policy guides MCC country partners in the integration of gender differences and gender inequality issues in the design and implementation of Compact projects, through recognition that these often create structural obstacles to economic growth and poverty reduction. Projects will be evaluated and monitored on the extent to which gender inequalities are addressed.

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Table 3-5: Metolong Authority policies of relevance to the WTW project Metolong Authority Key Provisions Policies

Resettlement and Describes the protocols for adjudicating compensation assets, compiling an asset Compensation Action Plan register, implementing compensation payments and record keeping. Policy and Procedures document

Labour recruitment policy Provides the objectives, principles, and framework for a transparent recruitment process (Draft 2008) that seeks to maximise job opportunities for local labour, including equal opportunities for men and women. Contractors are encouraged to use labour selected by Community Councils where labour meets the Contractors’ requirements.

HIV/AIDS policy (to be Metolong Authority is in the process of securing a consultant to draft an HIV/AIDS policy compiled) and management plan.

3.5 International Conventions Lesotho has ratified the following international conventions and protocols pertaining to the environment which are of relevance to the overall Metolong programme. Table 3-6: International Conventions and relevance to the WTW project International Key Provisions Agreements

United Nations Framework This convention aims to stabilise greenhouse gas concentrations in the atmosphere and Convention on Climate parties to this convention agree to promote sustainable management and promote and Change (UNFCCC) - 1992 cooperate in the conservation and enhancement of sinks and reservoirs of all greenhouse gases, such as terrestrial, marine and coastal ecosystems.

The Metolong programme will generate greenhouse gasses through the decomposition of plants after inundation for the dam; through the consumption of energy for pumping water and running the WTW, and from emissions from equipment and vehicles. Measures to reduce this is limited to maintaining all emission-generating to advance the SADC agenda of equipment and vehicles properly to minimise emissions; and designing pipelines to minimise pumping head thereby reducing energy for pumping needs

United Nations The convention requires member states to implement measures to control desertification Convention on Combating and land degradation. In Lesotho, the key focus is on sustainable land management Desertification (UNCCD) through a variety of approaches including tree planting, water provision, soil erosion control interventions, poverty reduction, and improved range management. Institutional structures have been formed to assist inter-governmental coordination.

The Metolong WTW may exacerbate soil erosion if sufficient controls on stormwater management and effluent drainage and sludge disposal are not implemented.

Stockholm Convention on This convention regulates the use and export/import of persistent organic pollutants Persistent Organic (POPs) which are recognised as toxic to humans and wildlife, and bioaccumulate in the Pollutants environment. It regulates the use of the following chemicals or products: aldrin, chlordane, dieldrin, heptachlor, hexachlorobenzene, mirex, toxaphene, and polychlorinated biphenyls.

Any pesticides or herbicides used to clear vegetation on the WTW site must be screened to ensure they do not contain these chemicals. Use on the site above the dam could pose a risk of such POPs washing into the reservoir and contaminating the drinking water

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International Key Provisions Agreements

supply.

The GoL is a signature of this convention. There are limited POPs expected to occur in the case of the WTW.

Basel Convention on the The convention obliges member states to minimise and control the generation and Control of Transboundary movement of hazardous wastes between states, and to protect the environment in the Movements of Hazardous transport and disposal of such waste. Hazardous waste includes waste mineral oils unfit Wastes and their Disposal for their originally intended use; waste oils/water; hydrocarbons/water mixtures, and – adopted 22 March 1989 emulsions. Therefore, any waste oils generated by the Metolong programme and exported to South Africa for disposal or recycling is subject to the Convention.

In terms of the Basel Convention requirements, the company who removes waste from the WTW has to prove that they have or will dispose of it at an accredited hazardous waste facility. The proof must be kept by the Contractor and be available for any auditor to verify. The waste removal company must liaise with NES’s Waste Manager in each instance and inform them that they have collected the hazardous waste and when they will dispose of it.

Convention on Biological This convention aims to protect biodiversity and in particular, to adopt measures for Diversity – 5 June 1992 recovery and rehabilitation of threatened species. This is of relevance to the Metolong Project, the affected areas of which are known to contain Red Data species. One Red Data species that is not regarded as threatened could occur in the WTW site: Dicoma anomola. This species was not found on the WTW site.

SADC Revised Protocol This protocol aims to foster closer cooperation for judicious, sustainable and coordinated on Shared Water Courses management, protection and utilisation of shared watercourse and integration and poverty alleviation. Parties to this convention are obliged to share information and consult each other, and if necessary to negotiate the possible effects of planned measures on the condition of a shared watercourse. This therefore has direct relevance to the Metolong Dam, situated as it is on a branch of a river (Phuthiatsana) that feeds a shared watercourse (Caledon). The CoW is responsible for informing member states of the Metolong Dam project, and this was done in December 2008 and agreement received from members states.

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4.0 DESCRIPTION OF ENVIRONMENT AND KEY ENVIRONMENTAL IMPACTS OF THE WTW This chapter provides a summary description of the environment and the key impacts identified in the ESIA. 4.1 Description of the Environment The WTW is located in the foothills of Lesotho on a plateau above the Phuthiatsana River. The site itself is comprises basaltic soils overlying sandstone of the Clarens Formation. Subsurface seepage occurs in some areas of the site. The predominant basalt-derived soils are highly erodible and thus proper slope stabilisation and stormwater management are critical in the design and construction of the WTW. This risk is compounded by the intense rainfall events during summer, which washes large amounts of sediment into the river. Annual rainfall is relatively low at ~770mm. The closest weather station is situated at the Maseru International Airport and the prevailing wind direction is westerly with lower summer wind speeds when compared to winter wind speeds. Average evaporation is 1500mm/year. Temperatures range from a maximum of 33ºC in summer to a minimum of 0ºC in winter (July). Climate change predictions expect Lesotho to become drier and hotter with increased intensity and frequency of extreme weather events, such as floods and droughts in the western and northern lowlands. Water quality of the Phuthiatsana River has a major influence on the water treatment process and the chemical inputs required to supply treated water, and has been discussed in section 2.4. Total coliform counts, including E. coli, are high, indicating wash-off of faecal matter from the catchment, which poses a health risk to local water users.

Terrestrial vegetation predominantly comprises grassland with scattered thickets and woodland on the foothill slopes above the river. Large parts of the plateaus have been disturbed by settlement and cultivation, mainly of maize and sorghum. The area of the WTW is transformed by cultivated fields. The WTW site is mostly arable land with small patches of uncultivated grassland and rocky outcrops. The results of a summer survey of the vegetation present in the WTW are attached as Appendix J. Only one red data plant species that may be expected to occur in the area of the Metolong Dam and the WTW site is Dicoma anamola – but this is a commonly found species with a wide distribution in southern Africa. Nonetheless, individuals found on site will be considered for relocation Few indigenous large mammal species remain in the area, as they have been almost eliminated by hunting and other human disturbance. All the remaining smaller mammals likely to occur are widely distributed. The same is true of snakes, which are targeted and tend to be killed on sight. All the reptiles, amphibians or birds likely to be recorded in the area are very common and widespread. The Bald Ibis is a Red Data bird species that is commonly seen feeding in fields near villages and nests in cliffs along that will be associated with the dam (approximately 1km from the proposed dam wall). The only Red Data species of fish likely to occur in the Phuthiatsana River is the Largemouth Yellowfish, although it was not recorded during sampling for the SMEC ESIA (2008) probably due to the turbid conditions. Other fish recorded: Smallmouth Yellowfish and Chubbyhead Barb – are hardy species. Current river condition below the proposed Metolong Dam is categorised as a C/D, where C is moderately modified (loss and change of natural habitat and biota has occurred but basic ecosystem functions largely unchanged) and D is largely modified (large loss of natural habitat, biota, and basic ecosystem functions occurred). Reasons for this categorisation include accelerated supply of sediment to the river (non-flow related) and down-cutting of the channel; sand-mining; removal of riparian vegetation; dominance of alien riparian vegetation; and assumed altered hydrological patterns as a result of land use activities. Extraction of 10% Mean Annual Runoff (MAR) in accordance with the recommended flow release schedule of 200ℓ in dry season (winter) and 100ℓ in the wet season (summer) and simulation of one Class 4 and four Class 2 floods per annum is expected to maintain the river in its current ecological condition of C/D (SMEC 2008). The population of villages around the reservoir area is estimated at around 7800 based on a social survey in 2006 for the Metolong Dam ESIA (SMEC 2008). The closest village on the west – Ha Seeiso – has an

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estimated population of 1145 in 206 households, while that on the east – Ha Sekantsi – has 211 people in 37 households. The majority of households are poor with a high age dependency of 42%; low education level and high level of unemployment. 70% of households earn less than M500 per month. Access to water, sanitation and health services is low: most villages rely on communal standpipes for water and live in traditional thatched dwellings with no electricity. The project will however improve access to sanitation and water for the majority of villages around the dam. Most households engage with subsistence farming of crops such as maize, wheat and sorghum and 84% of households own one or more fields. Most households do not own livestock and those that do have small herds with few households owning more than six head. Income sources of female-headed households were consistently lower than male-headed households with 86% of female-headed households earning M500 or less compared to 62% of male headed households, Male-headed households were more likely to have income sources in the form of a salary, remittances from South Africa or Lesotho, or from the sale of their own vegetable produce, while women were more likely to obtain income from pensions or the sale of beer. This underscores the importance of land for subsistence farming.

Cultural heritage of the area in and around the WTW comprises the ruins of a 19th Century village called Ha Makhoanyane dating from the 1880s and an old stone boundary wall which lies in the middle of the WTW area. These are recommended for protection and fencing while that part of the wall that occurs on the WTW is to be removed and the stones piled for future use. A museum and interpretative centre is proposed to preserve and show-case the rich cultural history of the area, house archaeological material for visitors and as an educational centre. Key social issues of concern to the community recorded in earlier surveys and meetings relate to employment, compensation and access to services, as well as risk of increased HIV/AIDS, loss of rock paintings, crossing points and opportunities for small business establishment. 4.2 Assessment of Impacts The potential impacts identified during the ESIA (separate document) were assessed in accordance with a structured methodology that combines the classical impact assessment methodology with a risk assessment approach through using the extent, intensity and duration ratings to define a score of “consequence” of the impact, which is then used to define impact significance. Significance ratings are defined to assist decision- makers determine the extent to which an impact should influence decision-making. The methodology is described and impact tables from the ESIA are contained in APPENDIX D. The overall matrix tables summarising the identified impacts are provided in this section. The approach is based on an explicit and transparent scoring system to avoid subjective and haphazard assignments of significance ratings. The approach has been used elsewhere in other environmental assessments with different categorisation of extent and duration depending on the nature of the project. The significance of an impact is defined as a combination of the consequence of the impact occurring and the probability that the impact will occur. Significance ratings are defined as follows:  Low: the potential impact may not have any meaningful influence on the decision regarding the proposed activity;  Medium: the potential impact should influence the decision regarding the proposed activity, and  High: the potential impact will affect a decision regarding the proposed activity.

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4.3 Summary Matrix Table of Construction and Operation Impacts and Key Mitigation Measures of the WTW Table 4-1: Summary matrix table of Construction Impacts Impact Significance Significance Summary of key recommended mitigation / optimisation measures without with mitigation / (*Note: mitigation measures discussed in more detail in section 8 - Construction mitigation / optimisation Phase and Section 9 - Operational Phase) optimisation

OVERALL BENEFITS OF METOLONG DAM AND WATER SUPPLY PROJECT (POSITIVE)

Construction jobs for local residents Low Medium Implement Metolong Authority’s Labour Recruitment Policy and encourage contractors to (Positive) source unskilled and semi-skilled labour from the Skills Register.

Improved services and facilities for local Medium HIGH Ensure ongoing implementation of the planned WATSAN project to supply water and VIP residents (Positive) latrines to 9, then a further 24 villages, as well as electricity to key community facilities.

Tourism benefits Low Medium Plan for a mix of tourism and recreational opportunities around the reservoir and provide (Positive) training to locals to maximise their role.

Regional and National Benefits from HIGH HIGH Project benefits would be optimised if allocation given to provide poor households with a Improved Water Supply (Positive) (Positive) certain amount of free water and implement appropriate tariff structures.

IMPACTS OF THE WTW CONSTRUCTION (NEGATIVE)

Loss of 96,000m2 of land, mostly agricultural, HIGH Medium Ensure timely payment of agreed compensation prior to construction and prioritise affected of which ~72,000m2 belongs to 12 owners landowners for jobs or livelihood enhancement projects.

Loss of grazing land Low Low None required.

Loss or pollution of village water supply HIGH Low Fence off and ensure protection of the existing spring. Ensure latrines or sewage disposal option provided for temporary work camp cannot pollute the spring or water course. Optimal solution, if possible, is to provide water borne sewage to the waste water treatment works.

Social disruption caused by influx of work- HIGH Medium Implement Metolong Authority’s Labour Recruitment Policy and encourage contractors to

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Impact Significance Significance Summary of key recommended mitigation / optimisation measures without with mitigation / (*Note: mitigation measures discussed in more detail in section 8 - Construction mitigation / optimisation Phase and Section 9 - Operational Phase) optimisation seekers source unskilled and semi-skilled labour from the Skills Register. Unskilled and semi-skilled labour to be sourced from reservoir area to the maximum extent practical. Any other unskilled labour to be bussed in from outside. No accommodation to be provided for temporary unskilled workers. Ensure that there is no recruitment at the WTW or dam site, and place notices to this effect on fencing around the site.

Increase in HIV/AIDS and STDs around the HIGH Medium Implement Metolong Authority’s Labour Recruitment Policy and encourage contractors to reservoir source labour from Skills Register. No accommodation for unskilled construction workers. All unskilled construction workers from outside the area to be bussed in daily. Do not allow any labour recruitment at the WTW or dam site and provide notice to this effect. Implementation of the HIV/AIDS education and awareness programme by MA and Contractor. Monitor to enforce compliance and implementation. This should include improved access to condoms at the WTW camp and clinics; and access to testing, counselling and treatment centres.

Increased noise from increased trucking and Low Low Restrict construction activities to day time hours 06h30 to 16h15 hours. site clearance

Increased noise and disturbance from Low Low No blasting to take place before 0800 and after 16h15. blasting Cordon off blasting areas and inform residents / herders when blasting to take place including through use of sirens. Provide ear protection to workers using pneumatic drills or doing blasting.

Increased dust from construction activities Medium Low Regular watering of exposed areas, especially in windy conditions. Consider planting windbreak of trees around the site, especially in prevailing wind directions. This will mainly result in a long term green belt and not really reduce dust. Cover topsoil and other temporary soil dumps with material/ shade cloth and cover trucks carrying wind-dispersive material. Provide respiratory protection (masks) to construction workers.

Increased traffic hazards from accidents HIGH Medium Environmental Compliance officers (ECOs) should check contractors’ vehicles are properly maintained and that drivers are trained in spill control and clean up. The ECOs should ensure recommended loads are not exceeded and drivers comply with speed limits.

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Impact Significance Significance Summary of key recommended mitigation / optimisation measures without with mitigation / (*Note: mitigation measures discussed in more detail in section 8 - Construction mitigation / optimisation Phase and Section 9 - Operational Phase) optimisation Maintain road signage e.g. speed limit signage near villages and close to schools, clinics and other social use areas and provide tarred road shoulders where a lot of pedestrian traffic. A roads engineer should be contracted to check road safety requirements and make recommendations for implementation. Encourage GoL traffic officers to periodically check roadworthiness, licences and enforce speed limits and to conduct road safety awareness in schools and put up posters in public places e.g. bus shelters.

Human risk from accidents involving Medium Low Vehicles used to transport chemicals or flammable materials should be equipped with clean chemicals up materials and fire fighting equipment and drivers properly trained in spill management. Chemicals must be properly labelled, secured and handled in accordance with their MSDS. Containers from hazardous or toxic chemicals to be disposed of in a secure area and not used for other purposes.

Increased littering and inappropriate disposal Medium Low Provide adequate refuse bins around the WTW site and train construction workers to use of waste them. Institute spot fines for anyone caught throwing waste away in the natural environment. Ensure regular emptying of bins into lidded skips in a contained or fenced area and regular trucking to an approved landfill site.

Loss of sense of place / rural character Medium Low Appropriate building design and construction, and landscaping e.g. screen of trees, to mitigate aesthetic impacts.

Loss of cultural heritage: Damage to ruins of Medium Low Cordon off the village area and inform contractors that the site is protected and no damage 19th Century village to the site will be tolerated. The old stone boundary wall, partially on the WTW site, will be excavated and relocated if test results currently underway recommend this. The cultural heritage potential of the site can be optimised by developing appropriate interpretative material in a museum, together with examples of rock art relocated from the reservoir.

Loss of indigenous woodland vegetation in Medium Low Separate and reuse topsoil on top of backfilled trenches to promote revegetation and soil pipeline corridor stabilisation. Reseeding or revegetation to promote more rapid revegetation should be undertaken in all disturbed areas once they are no longer required for construction. Ensure soil or other substrate imported into the area is free of alien seeds or weeds. Remove unusable spoil material from trenches.

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Impact Significance Significance Summary of key recommended mitigation / optimisation measures without with mitigation / (*Note: mitigation measures discussed in more detail in section 8 - Construction mitigation / optimisation Phase and Section 9 - Operational Phase) optimisation

Disturbance of cliff-nesting birds from Low Low Minimise blasting during breeding season of cliff-nesting birds (mainly September to May) blasting and human disturbance as far as possible. Fence the southern perimeter of the WTW (to decrease easy access to the river valley) and instruct workers to refrain from damaging flora or fauna.

Increased erosion from the WTW site HIGH Low Ensure appropriate management of stormwater drainage and dewatering activities during preparation (excavation); dewatering site preparation to minimise the risk of concentrated flows causing erosion and activities and stormwater drainage sedimentation. Adequate culverts or other design features must be implemented to maintain natural hydrological flow patterns from the site to maintain biodiversity (e.g. wetland vegetation and frogs) associated with these wet areas e.g. in areas of surface seeps such as south-east corner of site.

Soil and water pollution caused by chemical Low Low Ensure proper labelling and storage of chemicals in secure, weather proof area with limited spillages (e.g. diesel/oil or any access to authorised personnel. All handling of chemicals to be done in accordance with their Material Safety Data Sheets. No pesticides or herbicides containing chemicals listed in herbicides/pesticides) the Stockholm Convention on Persistent Organic Pollutants to be used (e.g. dieldrin, aldrin, chlordane, polychlorinated biphenyls etc). Ensure protective and fire-fighting equipment available at all times; staff properly trained to handle spills and spills cleaned up promptly. A register of incidents occurring on site should be kept.

Soil and water pollution from sewage Low Low Correct siting of temporary toilets at least 50m from water course and springs or water disposal from temporary camp supplies. Adequately secure toilets to prevent toppling in wind. Regular emptying of toilets to minimise spills. Care to be taken to avoid spills when emptying.

Table 4-2 summarises operational impacts.

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Table 4-2: Summary matrix table of Operational Impacts Impact Significance Significance Summary of key recommended mitigation / optimisation measures* without with mitigation / mitigation / optimisation (*Note: mitigation measures discussed in more detail in section 9) optimisation

OPERATIONAL IMPACTS

Increased traffic accidents Medium Low Licensing and maintenance of staff and supplier vehicles. Sludge removal trucks to also be checked for roadworthiness and validity of driver’s licences and this to be a condition in any contract.

Soil and water pollution caused by chemical Medium Low Suppliers to properly secure chemicals and have on-board clean up equipment; and adhere to spills during transport speed limits and drive cautiously.

Soil and water pollution caused by chemical Medium Low Appropriate drainage and containment for used or expired chemicals on site, proper storage spills on site and removal, and disposal at correct facilities.

Chlorine gas leak HIGH Low Chlorine detectors in place that triggers the appropriate level of emergency response. Chlorine scrubbers in place that removes any harmful gas so as not released in to environment.

Soil and water pollution caused by leakage Low Low Appropriate drainage and containment of stormwater or leakage on site, proper storage and of sludge from sludge ponds or drying beds removal, and disposal at correct facilities.

Soil and water pollution caused by sludge Cannot be Cannot be Sludge disposal for land augmentation (soil improvement or donga rehabilitation) preferred if disposal to landfill, donga rehabilitation, or assessed at this assessed at this sludge found to be compliant with standards and suitable for the receiving environment. soil augmentation (cannot be assessed time time Analyse sludge and conduct pilot tests of sludge disposal to land / dongas during initial years of reliably until sludge can be analysed for operation to ensure constituents suitable for such application. If not, then sludge should be compliance with effluent standards) transferred to landfill. Monitoring required of soil and plant productivity to ensure no build up of trace metals over time.

Erosion from stormwater runoff HIGH Low Stormwater drainage must be adequate to contain and provide for heavy storm event runoff without causing erosion at the outlet drains. Dispersive measures must be implemented at intervals to reduce concentration of flows. Drains, culverts and outlets must be inspected regularly, especially after big rain events, to check for erosion and assess additional mitigation needs. Any mitigation required must be implemented promptly. The WTW must be properly contoured and landscaped to increase

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Impact Significance Significance Summary of key recommended mitigation / optimisation measures* without with mitigation / mitigation / optimisation (*Note: mitigation measures discussed in more detail in section 9) optimisation infiltration and reduce runoff.

HIV/AIDS risks Low Low HIV/AIDS awareness training of staff and provision of condoms. Provide family accommodation for operational staff.

Employment benefits / job creation Low Low Maximise number of jobs for residents of neighbouring villages.

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5.0 INSTITUTIONAL ARRANGEMENTS – ROLES AND RESPONSIBILITIES The roles and responsibilities of the various institutions associated with the Metolong Project are described here. 5.1 Metolong Board, Metolong Authority (Metolong Project Implementation Unit (MPIU)) and Metolong Project Management Unit (MPMU) The Metolong Authority (MA) is responsible for planning and quality control and to oversee implementation of the Metolong Programme on behalf of the Ministry of Natural Resources (MNR), to whom it reports. The technical wing of the MA is known as the Metolong Project Implementation Unit (MPIU), headed by a CEO and small group of professional staff. This MPIU is assisted by the Metolong Project Management Unit (MPMU) which is managed by a multi-disciplinary team of consultants. The MPMU assists in detailed planning and in the supervision of all contracts associated with the project. The core function of the MA and its associated bodies is to improve sustainable access to safe water supply in Maseru and surrounding Lowland areas through the construction of the Metolong Dam and downstream bulk conveyance system in an environmentally sound, socially responsible and financially sustainable manner (Metolong Authority 2009).

The Metolong Dam, WTW, Conveyance System and associated works are being implemented with funding provided by a group of Arab banks, and the IDA of the World Bank and GOL, with MCC funding the Water Treatment Works design and construction and the design of the downstream conveyance system. Oversight for the project rests with an independent board, comprised of representatives from Government, NGOs and the private sector. Legislation is currently being prepared to formally establish the Metolong Authority as the MPIU. The Metolong Authority will oversee implementation of this EMP during construction and initial operation and ensuring contractors comply with the Metolong Authority’s plans, policies and guidelines. This will include undertaking periodic audits and inspections of construction progress. 5.1.1 Community liaison and coordination The Metolong Authority is committed to ongoing community consultation, and has two Community Liaison Assistants (CLAs) who operate from an office at Ha Seeiso village next to the dam wall and the WTW, and who report to the Community Relations Manager in the Metolong Authority. The Ha Seeiso office provides a local point of contact whereby community members can raise issues, lodge complaints or ask questions about the project, as well as assist with recording assets for compensation that will be affected by the project. In addition, two committees (the Dam Committee and the Joint Committee) were formed in March 2009 to replace the previous Metolong Dam Committee. These comprise members of the Community Council and other community representatives and form a key point of contact with the community. The committees and the CLAs will play an important role in facilitating the two way flow of information between the Metolong Authority and the community. The DB Contractor will appoint a Community Relations Officer (CRO) who will liaise with the CLAs (see section 6.2.1). To date, issues of key importance to community members associated with the WTW generally overlap with the issues raised for the dam project as a whole. These are mainly issues related to compensation, jobs, HIV/AIDS, traffic hazards, and dust/noise. None of the issues raised are specific to the WTW itself. Issues of concern to communities that are associated with the WTW are addressed through mitigation measures described in the EMP, as well as existing policies of the Metolong Authority (such as Labour Recruitment Policy, Resettlement and Compensation Action Plan, HIV/AIDS education and awareness programme, and the Emergency Response Plan). The structure and communication channels between the Metolong Authority, NES, the WTW Contractor and the Joint and Dam Committees are shown in Figure 5.1.

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5.2 MCA-Lesotho The MCC signed a compact or grant agreement with Lesotho in 2007 to fund three major sector projects: Water Sector Project (including the Metolong WTW and conveyance system), Health Sector Project and Private Sector Development Project. The MCA-L is an independent government entity governed by a board of directors with independent decision-making authority with respect to implementation and management of the Compact. MCA-L serves as central point of contact for the Government of Lesotho, MCC, other donors, contractors, consultants and the country’s citizens. It establishes financial and reporting systems and manages procurement and drafts and executes, with MCC assistance, work plans for Compact programs. The Board of Directors comprises 11 voting members representing: the Ministry of Finance and Development Planning; the Ministry of Foreign Affairs; the Ministry of Health and Social Welfare; the Ministry of Local Government; the Ministry of Natural Resources; the Ministry of Justice, Human Rights and Rehabilitation; three members from the private sector and two members representing non-governmental organizations. A representative of MCC and the chief executive officer of MCA-Lesotho serve as non-voting members of the MCA-Lesotho board of directors. The MCA will undertake auditing that is required to verify the targets that are set in the EMP i.e. to check at a lower frequency if the monitoring is being undertaken and it will be checking that all agreed upon outputs (reports) are being produced, inclusive of monitoring reports (see section 6.5). 5.3 Other Government Departments and Ministries A number of other government departments have a role or responsibilities in the implementation of the WTW. These are summarised below. 5.3.1 Water and Sanitation Authority (WASA) WASA is a public corporation, which was established by Order No. 29 of 1991. In terms of the Order, the Authority is responsible for the provision of potable water and sewerage services in declared urban areas of Lesotho. In terms of its mandate, WASA is currently responsible for providing potable water and sewerage services in the following 17 urban centres: Mokhotlong, Butha-Buthe, Leribe, Maputsoe, Mapoteng, Peka, Teyateyaneng (TY), Maseru, Semongkong, Thaba-Tseka, Roma, Mazenod, Morija, Mafeteng, Mohale’s Hoek, Quthing, and Qacha’s Nek. WASA also provides downstream services in terms of water and sanitation reticulation to both urban and peri-urban areas. WASA currently operate two dams – the Maqalika Dam (off- bank from the Mohokare River) in Maseru and the Rasebala Dam near Mafeteng. WASA’s stated vision is to provide potable water and safely dispose of treated waste water into the environment in all designated areas. The core technical functions of WASA are to operate and maintain both potable water and sewage treatment and conveyance systems. In addition to the technical aspects of this service delivery, WASA also undertakes metering, billing and revenue collection, and provides customer care to consumers. The infrastructure operated by WASA includes water and waste water treatment facilities, pump stations, reservoirs, and bulk and reticulation pipelines. WASA is the potential operator of the WTW responsible for implementing the provisions of the EMP relating to operation of the WTW. This will include all operational and monitoring activities. 5.3.2 Ministry of Natural Resources (MNR) The Ministry of Natural Resources has the portfolio responsibility of coordinating development and operational activities in the energy, water and minerals sector. Specific programmes and projects to fulfil these responsibilities are carried out by the Ministries' Departments (Department of Mines and Geology and Department of Water Affairs) and parastatals (LEC and WASA). The DWA was established within the Ministry of Natural Resources as the custodian of the country’s water resources. It now assists the Commissioner of Water (CoW) in managing the country’s water resources. This includes assessment of the quantity and quality of water, both surface and groundwater, and maintaining the water resources database. The DWA manages this through four technical Divisions and is facing a challenge of capacity in meeting this mandate due to equipment and human resources constraints. The regulatory responsibilities of the DWA focus solely on the assessment, development and management of water

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resources. The organisation keeps and provides records, information, results of monitoring activities (river flow, groundwater, water quality etc), research, and analyses to the CoW, who acts as the custodian of raw water resources. DWA is currently not involved in raw or treated water production or revenue earning services. MNR and DWA will be responsible for assisting with river and flow monitoring and collating and storing all river-related data collected for the WTW. 5.3.3 Commissioner of Water The CoW office acts as the custodian of raw water resources in Lesotho and co-ordinates water policies and strategies for the country. 5.3.4 Department of Rural Water Supplies (DRWS) Implementation of rural water supplies to rural areas is currently entrusted to the DRWS with the operation and maintenance of these schemes being the responsibility of local authorities and local committees. It currently serves approximately 1 million of the 1.6 million rural population of Lesotho. The DRWS has its headquarters in Maseru and it operates in three regions and ten districts. DRWS is not directly involved with construction or operation of the WTW but is responsible for delivery of water to the end user in rural areas. 5.3.5 Department of Traffic and Transport The Department of Traffic and Transport is responsible for ensuring road safety, and will therefore be required to ensure that:  Road signage is maintained along the new road to Metolong Dam  Sufficient and safe provision is made for pedestrian passage (e.g. crossing points near schools, clinics etc; tarred road edges with lines.  Road safety measures are enforced, including speed enforcement and checks on vehicular safety and loading, including compliance with transport of hazardous chemicals e.g. chlorine gas. 5.3.6 National Environmental Secretariat (NES) NES is responsible for environmental oversight of the Metolong Project on behalf of the Government of Lesotho. It reviews and approves EIAs and EMPs for projects, and for issuance of Records of Decisions and Environmental Licences and Permits. In respect of the Metolong WTW, NES was engaged throughout the project planning and development process and specifically requested submission of a stand alone EMP for the WTW. NES staff will be integral in the rollout of this EMP, its provisions and implementation, as well as to confirm the role and assignment of NES staff in project oversight. Specific tasks of NES in relation to WTW include:  Approval of EMP and issuance of a Record of Decision and Environmental Licence  Engagement in project implementation  attendance of workshops on the overall Metolong project coordinated by the MA  attend technical committee and project Steering meetings  compliance auditing.

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Figure 5.1: The environmental and communications reporting structure for the Metolong Dam

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6.0 IMPLEMENTATION OF THE EMP The contract documentation provided to the Design-Build Contractor includes:  Employer’s Requirements detailing the technical specifications for the construction and operation of the WTW with which detailed design must comply  This EMP, with which the DB contractor is legally bound to comply  Policies of the Metolong Authority  The IFB (LWJV 2009), which specifies a number of requirements for environmental compliance that the Contractor will be required to implement. This includes the appointment of staff to handle different aspects of environmental and social safeguards, the roles of which are discussed in Section 6.1. 6.1 Environmental Compliance Staff The contract makes provision for the following staffing to ensure environmental (and social) compliance:  Environmental Compliance Officer (reporting to the Engineer)  Community Relations Officer The roles and responsibilities of each of these are described below. 6.1.1 Environmental Compliance Officer (ECO) In terms of the Contract documentation, the Contractor is required to appoint an Environmental Compliance Officer (ECO). 6.1.1.1 Role of ECO The role of the ECO will be to:  Provide input into the Environmental Protection Plan (EPP) that the DB Contractor is required to submit as a basis for all work undertaken on site during construction.  Conduct regular monitoring of the site and operations in accordance with these specifications.  Report non-compliance to the Engineer, as applicable and recommend corrective action.  Attend site meetings to be able to report on and respond to any environmental issues and be issued copies of minutes of such meetings.  Provide input on method statements drafted by the DB Contractor and other environmental issues within the defined work areas.  Take photographs (digital) of the site prior to, during and immediately after construction and rehabilitation as a visual reference.  Inform the Engineer immediately where clearly defined and agreed “no-go” areas are violated or in danger of being violated,  Inform the Engineer immediately when prescriptive conditions are violated or in danger of being violated,  Provide input into the Engineer’s environmental compliance documentation and monitor compliance. Prior to commencement of work on site, the Contractor shall be briefed by the Engineer and ECO on obligations related to environmental controls and methodologies in terms of the EMP. The briefing will take the form of an on-site talk and demonstration and any other written or graphic material applicable to the project.

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In terms of the contract documentation the ECO is required to:  be qualified to perform the necessary tasks and should be an experienced environmental officer with 10 years experience in environmental oversight on similar types of construction projects.  be appointed at a level of seniority that he/she can interact effectively with the Contractor.  be appointed throughout the construction and assisted operations phases, starting prior to the commencement of on-site activities.  be expected to perform daily observations of the entire project site and to maintain a physical presence during the full length of construction activities.  monitor all construction activities to observe whether the Contractor abides by the requirements of the EPP and the EMP  monitor compliance with all permit conditions, and conditions attached to the Record of Decision for issuance of the Environmental License, as well as broad compliance with policies of the MA. The ECO is charged with four broad responsibilities:  To monitor design and construction activities with emphasis on avoidance and minimization and to determine whether environmental commitments and requirements are incorporated into the construction of the project.  To monitor modification(s) to the original plans for environmental compliance, prepare modification requests for submittal to the Engineer, and monitor accurate execution of the modifications during construction.  To function as a source of environmental expertise to the Engineer, including making recommendations to the Engineer of measures and actions to reduce impact and to rectify non-compliance issues.  To function as a liaison with the Community Liaison Assistants and the Community Liaison Officer appointed by the contractor with respect to environmental commitments. The ECO is to be involved in monitoring the following aspects:  Impact Avoidance and Minimization Documentation Effectiveness of the stormwater management system  Erosion, vegetation protection and restoration/rehabilitation  Construction staging areas (environmental clearances)  Cultural and historical issues and commitments  HIV/AIDS education and awareness programme  Environmental education and awareness training  Compensation and Resettlement Action Plan, and  Other commitments made in the environmental ROD Specific on-site administration the ECO will be required to do includes:  Conduct quarterly or six monthly environmental audits during the construction phase to check adherence to the management provisions of the EMP.

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 Compile a quarterly or six monthly environmental audit report based on the findings of the regular audits and submit to Engineer.  Liaise as needed with the Engineer on implementation and compliance issues.  Monitor the Contractor’s record of environmental incidents (Incident Book) such as spills, impacts, transgressions, including nature and extent of the incident, cause, responsibility, and corrective and preventive actions taken. All incidents must be reported to the Engineer and a summary of recorded incidents must be included in the monthly audit reports.  Monitor Contractor’s complaints register in which all social and environmental complaints and any actions taken are recorded.  Liaise with the Contractor’s Community Relations Officer (CRO), through the Engineer, on issues of concern to the local community e.g. to keep the CRO informed of scheduled activities that may concern the community such as blasting.  Liaise regularly, through the Engineer, with Metolong’s Community Liaison Assistants (CLAs) at the project office in Ha Seeiso on public/community issues. All issues and responses or action taken should be recorded in a Public Complaints Register. 6.2 Community Relations 6.2.1 Community Relations Officer In terms of the IFB (LWJV 2009), the Contractor is required to appoint a “suitably qualified and experienced CRO acceptable to the Engineer with all necessary support staff and facilities”. The CRO is to be appointed within 14 days of the commencement date, and should remain in this position until the Taking Over Certificate is issued. The CRO shall be responsible for liaising and co-operating with the Employer’s Representative Public Relations Manager (PRM) for the purpose of:  Keeping the local communities advised about the general progress of the Works  Giving advance notification to the local community when particular operations will commence and finish, particularly those which might inconvenience the inhabitants of the area or against which they should take safety precautions  Receiving and replying to complaints from the general public about all matters related to the Works.  Ensuring that remedial and corrective action is taken wherever necessary in response to complaints from the public  Arranging tours of the Works by approved visitors  Supporting community awareness programmes and local development programmes  Publicising training and job opportunities  Discouraging and controlling proliferation of informal settlements in and around the site, and  Upholding the Metolong Authority’s Labour Recruitment Policy through discouraging non-local persons from seeking employment at the site and monitoring that procedures for recruiting, employing and accommodating employees are effective. The IFB requires the Contractor to prepare and submit to the Engineer for approval a Community Relations Programme within 45 days of award. The Community Relations Programme shall detail the specified activities of the CRO, including examples, forms, schedules, products and descriptions as well as detail intended communications with the Employer’s Representative, Engineer and the public.

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The Community Relations Programme will also be required to include a Grievance Mechanism or protocol based on the IFCs (2009) guidelines for grievances for project affected communities. The steps on which this grievance mechanism should be based include:  Publicising grievance management procedures  Receiving, registering and keeping track of grievances  Reviewing and Investigation grievances  Developing resolution options and preparing a response  Notification of the response This grievance mechanism will require establishing the relationship between the DB Contractor’s Community Relations Officer and the Metolong Authority’s Community Liaison Assistants and Community Councils. The CRO shall report complaints received from the public to the Engineer at weekly intervals together with details of any action taken or proposed to be taken in connection therewith. A summary of the weekly reports shall be included in each monthly progress report. All inquiries from outside bodies or private parties, which cannot be dealt with as part of the community relations programme, shall be directed to the Engineer. No photographs or other documents shall be issued to the press or to any other parties without the prior written approval of the Engineer. The Contractor shall co-operate with the Employer’s Representative and the local communities in discouraging job seekers and others from making speculative visits to the Site and in controlling the proliferation of informal settlements in and around the Site, with the development of unsightly littering and insanitary conditions. In this regard, all recruitment is to be done off-site, and all procedures for recruiting, employing and accommodating employees shall minimise the necessity for non-local persons to visit the Site without authority or invitation. 6.3 Emergency Preparedness Plan The Water and Sewerage Authority (WASA) under the auspices of the Lesotho Water Sector Improvement Project of the Ministry of Natural Resources of the Government of the Kingdom of Lesotho commissioned a WASA Emergency Preparedness Plan, which was finalised in October 2007. This generic document was designed to be used to plan, develop and implement an Emergency Preparedness Plan for WASA and each of its different offices and different works. In this document the following aspects are covered:

 The functions for the Emergency Management Considerations are listed and discussed to make it easy for WASA to follow when developing specific plans  The specific threats and risks that should be looked for are listed, the assets that need to be assessed are discussed,  The different components one should address in a Emergency Preparedness Plan and how it should be addressed are discussed,  The generic actions to prevent emergency situations are documented and the information that should be displayed on Material Safety Data Sheets in locations where the materials are handled, stored and used, are given.  A spreadsheet identifying the most likely emergency at each of the Works, the responses needed for that emergency and the procedures to respond when that emergency occurs. As part of this EMP a suggested generic Emergency Preparedness Plan (EPP) has been included in Appendix C. In order for a specific EPP to be developed for the Metolong WTW for construction and operation (before the WTW is commissioned) the contractor and operator (WASA) will be required to refine

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the EPP using the team members as indicated in Figure 6.1. The team members will be staff of the Operator of the WTW and will be required to develop and maintain the EPP for the Metolong WTW.

The operator of the Metolong WTW (WASA) should have a dedicated person (e.g. Emergency Officer) to prepare the response of the organisation for an emergency situation and to oversee the technical aspects of the response, as well as interfacing with the community, the media, outside response organisations and regulatory agencies, as required. The Emergency Officer must be an employee and a member of management with the authority to make decisions. He/she will be responsible for frontline management of the incident, for tactical planning and execution, for determining whether outside assistance is needed and for relaying requests for internal resources or outside assistance through an Emergency Operations Centre (EOC).

Figure 6.1: Required team members for the development and maintenance of the Emergency Response Plan for the Metolong WTW (WASA 2007). 6.4 Environmental training and awareness 6.4.1 Contractor Staff Training Environmental Awareness Training Objectives: Before starting training or regular work, all employees will be required to attend an induction programme, which shall include site safety procedures (e.g. blasting), emergency procedures, health and safety (e.g HIV/AIDS), and environmental safeguards. The Contractor must ensure that all people involved in the project (including sub-contractors, casual workers, drivers etc.) are aware of and familiar with the environmental requirements for the project. Environmental Induction should ensure that the workforce:  understands the key environmental features of the Site and environs and the kind of activities that impact on them

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 are thoroughly familiar with the environmental management measures contained in this EMP and the environmental protection requirements as they apply to the WTW  are trained in the identification of archaeological artefacts and flora and fauna of special interest that may occur on site and the measures that must be applied when they are encountered, and  are fully aware of all rules regarding general behaviour on site e.g. littering, noise, toilet behaviour, etc. Targets: All staff members on site have received environmental awareness training, are informed of, and apply the codes of conduct and required management measures. Management and mitigation: It is the Contractor’s responsibility to ensure that all people involved with the project receive environmental awareness training before starting work on site. This shall include all new staff recruited during the construction phase. A signed register should be kept of each employee attending the course. Environmental training shall include but not be limited to the following:  Awareness-raising of how different construction activities can impact on the environment, why it is important to avoid environmental damage and what steps can be taken to mitigate the impacts of construction activities.  Identification of possible archaeological or historical objects and the requirement to notify the ECO or Engineer if such an object is found, and to be informed of ‘No Go” areas of cultural heritage.  General conduct on site such as noise levels (e.g. shouting and hooting), alcohol consumption, use, toilet behaviour, littering, no firearms, no pets, no harvesting of firewood / plants, no trespassing or damage to property, no throwing of cigarette butts into the veld etc.  Responsible handling of chemicals and spills and correct disposal of chemical containers and other waste objects.  Emergency procedures and incident reporting.  Location of fire-fighting equipment and its use.  HIV/AIDS awareness, including use of and access to condoms; and behaviour towards the local community. The Contractor must maintain a record of all staff that have received Environmental Awareness Training and shall monitor the performance of the construction staff to ensure that the points that were relayed during their induction have been understood and are being followed. If required, a translator may be requested to explain aspects of the environmental requirements or acceptable social behaviour that are unclear. Consideration should be given to the feasibility of introducing fines for workers who transgress the rules e.g. littering, use of the veld as a toilet, damage to property, etc. 6.5 Auditing and inspections Prior to commencement of work on site, the Contractor shall be briefed by the Engineer and ECO on obligations related to environmental controls and methodologies in terms of the EMP. The briefing will take the form of an on-site talk and demonstration and any other written or graphic material applicable to the project. In this briefing the auditing requirements and responsibilities will be specified. Auditing of the compliance of the Contractor to the requirements of this EMP and the IFB (2009) documentation will be the responsibility of several organizations namely:  D-B Contractor (internal compliance) undertaken by the ECO

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 NES  MCA-L  WASA  MNR and DWA The ECO is to be involved in auditing the on-site issues as specified in the EMP that includes quarterly or six monthly environmental audits for the construction phase to check adherence to the management provisions of the EMP. The Contractor must appoint an external auditor to undertake regular audits (e.g. every six months) during construction phase and the operator similarly appoints an auditor to do annual audits during operational phase. Ideally, the external auditor should submit a TOR to NES for approval prior to the audit. The environmental audits that are undertaken should for instance:  Analyse the results obtained from monitoring.  Assess whether objectives and targets have been met and whether there are variances from the stipulated EMP and legal requirements.  Assess whether EMP implementation has been undertaken according to planned arrangements and that the EMP itself is being appropriately updated.  Confirm that identified corrective actions have been undertaken and then assess the effectiveness of such actions. The ECO is responsible for the maintenance of the environmental audit information that is required prior, during and after an audit.

The MCA-L and the Metolong Authority will undertake ad hoc internal compliance audits to ensure the contractor is environmentally compliant. The MCA-L level of auditing verifies the targets that are set in the EMP. This includes whether the agreed upon outputs (reports) are produced, inclusive of monitoring reports. NES will do audits on issues that are specified in the Record of Decision (ROD) for the WTW. Typically this will include the following:  Checking if required reports are submitted  Checking the information in these reports  Random attendance of meetings, especially with the community  Random verification sampling of the effluents produced and compared to licensed standards specified in the EMP and ROD DWA will be responsible for assisting with river and flow monitoring and collating and storing all river-related data collected for the WTW. They may audit the compliance of the Metolong Dam with respect to environmental flows and water quality in the river downstream of the dam and WTW. Site inspections will be undertaken as part of many of the audits indicated above as well as many of the mitigatory measures indicated in Chapters 8 and 9. The Engineer and ECO will be on site daily and will constantly check whether the objectives of the EMP are being met. Random site inspections are encouraged to be undertaken by the following organizations:  NES  MCA-L

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 WASA  MNR and DWA

6.6 Reporting Procedures during Construction, Assisted Operation and Operation The required reporting procedures for the construction and operation are specified. These will likely include information on who will be responsible for compiling what reports; who must receive copies; information to be contained in these reports; pro forma or template structure for each report; timing and frequency of response; approvals required, and where copies should be kept. However, reports that are required to ensure adequate record-keeping are specified below. The issues identified in this EMP need to be documented in a format that is readily available for review/auditing. The ECO should meet with the Contractor/Engineer on a regular basis, e.g. weekly to discuss the contractors’ tasks and review the progress from the past week. The ECO and the Contractor should discuss and agree on the issues in the EMP and how they should be managed and mitigated as well as agree on the QA/QC targets as specified in the EPP The agreed upon mitigation measures should be documented and the agreed upon QA/QC targets signed off. The key legal and policy provisions in Lesotho that are relevance to this study are indicated in Table 3.1. During the Operational phase of the project the quality of the water produced by the WTW will need to be monitored in accordance to the SANS 241 (Appendix C) requirements. The frequency, locality and variables recommended for a WTW of the size of Metolong should be followed. The OHS requirements as specified by WASA (2007) in their EPP template also need to be followed. The following types of reports are required during the construction and operational of the WTW:

Document Handling and Record Keeping All meetings and site inspections should be recorded and field (in hard copy and electronically) for future reference and to provide input into monthly reports. Minutes of meetings: Regular meetings should be held between the ECO, CRO, Engineer and Contractor to discuss the schedule of construction activities and requirements for adherence to the EMP requirements on a weekly basis, at least, or more frequently if required. The minutes of such meetings should be recorded immediately, and shall include the activities to be done, the responsibilities for carrying them out, and deliverable dates. The minutes should be circulated to those concerned and hard and electronic copies filed for safe-keeping. These minutes should provide the basis for follow up at subsequent meetings.

Monthly reports: Monthly review meetings should be held with the MA, ECO, CRO, and the Contractor to confirm the status of the construction progress and issues associated with implementation of the EMP. The meetings should aim to collate the inputs for preparation of a monthly report. The monthly report should synthesise all information on work progress, scheduling changes, recorded incidents and complaints, monitoring results, site problems and risks/hazards, areas of compliance and non-compliance with the EMP targets, and measures take or required to rectify problems. Monthly reports should be circulated by email and in hard-copy to all on-site managers (ECO, Engineer, CRO and contractor supervisor) as well as MA and the QAO. The targets and reports relating to the EMP that NES has approved in the Record of Decision should be documented in the form of minutes with agreed upon targets, outputs, QA/QC and deliverable dates. The documents/minutes should be signed off by the ECO and the Contractor once a week to indicate progress and confirmation with prescribed QA/QC with regards to the EMP. The approved documents/minutes need to be archived in paper and electronic format (MS Word) on a communal network supported by the MA.

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In addition to the day to day and monthly reports mentioned above, the following types of reports will be produced by the Contractor (6.6.1 - 6.6.3): 6.6.1 Complaints Register and Grievance Procedure All queries and complaints raised by the local community shall be recorded in a Complaints Register located at the Metolong Authority office in Ha Seeiso and staffed by two Community Liaison Assistants. All complaints relevant to the WTW construction project shall be forwarded to or discussed with the Contractor through the Community Relations Officer and Engineer for handling and response. All queries and/or complaints from Interested and Affected Parties (I&APs) are to be addressed with the shortest possible delay in accordance with the defined grievance procedure. The CRO and CLA’s will play an important role in keeping the community informed of key project activities such as labour recruitment, or scheduled activities, in order to create and maintain a level of trust and avoid expectations, and thereby minimise complaints. All complaints and claims will be recorded in a central register managed by the CRO and CLAs, and acknowledged and responded to within 28 days of receipt. The following information must be recorded in the Complaints Register:  the complainant’s name and contact details (if not anonymous)  the date, time and nature of the complaint  the response and investigation undertaken  the actions taken and the name of the person responsible for the action  Follow up within a specified time frame, e.g. one month to determine whether the issue has been resolved The CLAs must inform the Contractor and Engineer within 24 hours of any complaints relating to the WTW activities that require rectifying or a response. Where an investigation fails to satisfy a complainant, the issue will follow an agreed grievance procedure developed by the Metolong Authority in line with International best practice (e.g. IFC guidelines). Issues that are not resolved satisfactorily by the CRO and CLAs will be referred to the Dam Committee that represents the Community Councils for further consideration and resolution. The ECO, through the Engineer and the CRO, should inform the CLAs of any project activities that may be of concern to the local community and where early notification can pre-empt problems and complaints arising. 6.6.2 Incidents and Accidents Register The ECO should compile and keep an Incidents and Accidents Register on site in which all incidents and accidents are recorded, e.g. chemical spills, fires, accidents involving workers and vehicles, etc. The following information must be recorded in the Incidents Register:  the name and contact details of the persons involved  the person recording the incident  the date and time of incident  the nature, extent and cause of the accident  the name and contact details of any persons notified of the incident  the actions taken to deal with the incident and whether the accident has been sufficiently dealt with  additional steps required to prevent recurrence of the incident

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6.6.3 General Reporting The DB Contractor is required to specify all reports and reporting procedures, including those required for monitoring environmental compliance, as part of the Quality Control Management System. Reports that will be required to monitor implementation of the EMP and provide a paper trail for effective auditing, or which are required to prevent or respond to accidents, include (but are not limited to):  Site inspection reports  Site instructions  Weekly report  Monthly reports (CRO, ECO and Engineer)  Monitoring reports (e.g. water quality / effluent monitoring). Effluent monitoring data and reports are required in terms of section 41 of the Environmental Act 10 of 2008. The frequency of the monitoring will be daily with regards to the drinking water quality and potential supernatant disposal (see section 8)  Auditing reports  Safety and Health Plan, and  Emergency preparedness and response procedures (e.g. in the event of a chlorine gas emergency) (see section 9.3).

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7.0 ENVIRONMENTAL MANAGEMENT FOR THE PRE- CONSTRUCTION PLANNING PHASE 7.1 Pre-Construction Activities 7.1.1 Design-Build Contractor Responsibilities The first phase of work under the Design-Build Contract involves, inter alia:  detailed design and layout of the WTW  obtaining permits e.g. water abstraction  confirming services and infrastructure provision e.g. telecommunications  preparation of layout plans and method statements  sourcing of labour and other key staff  Environmental training and awareness raising of labour  workshops with Engineer and Metolong Authority to confirm communication channels, reporting, approvals and schedule of activities  compilation and approval of a Quality Control Management System  investigation of solid waste disposal operators, and  finalise record keeping and reporting systems. 7.2 Social and Health Management The Metolong Authority is currently defining a number of policies that govern social and health management on the MDWSP which contractors on the project will be required or encouraged to comply with. The policies on labour recruitment, HIV/AIDS education and prevention, Compensation and Resettlement, will largely be administered by the Metolong Authority with the assistance of the Project and Dam Committees. Key elements of the policies with relevance to the Water Treatment Works are summarised below. 7.2.1 Land and Compensation The land required for the Metolong WTW has been surveyed and landowners and the size of their properties identified for compensation. A R&CAP has been compiled for the MDWSP which describes the protocols for adjudicating compensation assets, compiling an assets register, implementing compensation payments and record keeping. The administration and payment of compensation is to be handled under a separate contract to the Metolong Authority. Compensation will be paid to affected landowners in accordance with the Policy at agreed rates for the replacement of arable land. Objective: To ensure that those negatively impacted by the MDWSP through direct and indirect losses are fairly compensated, and are enabled to participate in the planning and implementation of related mitigating measures intended for reconstruction of their productive activities and income sources (Mateka, B, R&CAP 2008). Management Measures: Metolong Authority to ensure that all land required for the WTW has been secured from affected landowners, all assets compensated, and boundaries marked prior to the start of construction.

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Any assets identified by the community as not having been compensated for or where damage is caused that was not foreseen and which comes to the attention of the Contractor should be referred to the CLAs for further investigation with the Joint Committee. 7.2.2 Labour recruitment A Labour Recruitment Policy (LRP) has been drafted by the Metolong Authority to guide contractors on recruitment issues and which is designed for application to all construction activities for the project involving semi-skilled and unskilled labour. It stresses the importance of transparency in the recruitment process to avoid conflicts over job allocation given the high unemployment in the area and the relative number of jobs that will be available. The Policy aims to promote job allocation and benefit maximisation for the local population. Policy implementation will be done in accordance with the Metolong Authority’s Community Engagement Guidelines, working closely with the elected Community Councils. Contractors will be encouraged to source their unskilled and semi-skilled labour requirements from a Skills Register that will be compiled and made available to them. Objectives of the LRP:  Maximize the employment opportunities for local communities by making optimal use of existing skills.  Minimize disputes over job opportunities.  Recognize the facilitating role of relevant local government structures.  Provide a recruitment mechanism that ensures that contractors’ labour requirements are met in an efficient and effective manner.  Encourage contractors to accept, within reason, suitably qualified and physically fit labour recommended by local government structures.  Local recruitment of labour will minimise the need for accommodating a large temporary workforce at the dam site which tend to have attendant problems of social disruption, increased crime and increased risk of spread of HIV/AIDS. Target: Source as many as possible of the unskilled labour from villages around the reservoir with priority given to residents who lose arable land to the WTW, and those living immediately around the dam wall and the WTW. Management Measures: Contractors are required to provide MA with a list of unskilled, semi-skilled and skilled labour requirements which is to be given to the relevant Community Council as a basis for selecting potential construction staff Encourage the Contractor to select as many unskilled and semi-skilled staff as possible from the register of skills that is provided by the Community Council, including the replacement of dismissed or additional staff during the course of work. The Contractor is encouraged to source additional unskilled and semi-skilled labour needs that cannot be met within the Metolong catchment, from nearby towns and villages, to the extent practical. 7.2.3 HIV/AIDS Education and Awareness Programme The Metolong Authority is in the process of awarding a subcontract to produce an HIV/AIDS education and prevention policy and programme, and compliance monitoring programme. This programme will include specific provisions outlining Contractor’s responsibilities for managing HIV/AIDS issues within the workforce and all formal and informal workers engaged in construction. These provisions will be a contractual obligation of the Contractor.

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Objective: To minimise the risk of HIV/AIDS infection of the workforce and local community through increased HIV/AIDS awareness and education. Target: All staff able to communicate on the existence of HIV/AIDS; the consequences of transmission to or from the local community, and to recall and communicate the mode of HIV transmission and preventative measures, including the proper use of condoms. Management Measures: Management measures that are likely to be contained in the HIV/AIDS education and prevention programme are likely to be similar to those contained in the FIDIC HIV/AIDS Education and Awareness Programme policy which requires the Contractor to (see Appendix J for the current FIDIC HIV/AIDS document which can be used as a reference until the MA policy is in place):  Provide and HIV/AIDS Awareness Programme for personnel on site within two weeks of arrival and to repeat at intervals not exceeding 4 months.  Make condoms complying with requirements of ISO 4074 available to employees at readily accessible points on site.  Place and maintain HIV/AIDS awareness posters of at least A1 size in areas well used by construction workers or provide workers with a pamphlet in the appropriate language.  Encourage voluntary HIV/STI testing.  Provide information on counselling, support and care of those who are infected, and  Report on actions taken with regard to HIV/AIDS education and awareness programme including a schedule listing the names, identity numbers, trade/occupation and name of employer of all construction workers exposed to the programme.  Local recruitment of labour (section 7.2.2) may assist in minimising the risk of spread of HIV/AIDS by avoiding the need for a large temporary work camp of migrant labour during construction of the WTW. In support of these FIDIC requirements, the contractor is to implement an HIV/AIDS Awareness Programme, as follows: Implementation:  sub-contracts with an Approved Service Provider to provide an HIV Awareness Programme to the Contractor’s Personnel and the Local Community as soon as practicable after the Contractor’s Personnel arrive at the Site but in any case within two weeks after the Contractor’s Personnel arrive at Site and to repeat the HIV/AIDS Awareness Programme at intervals not exceeding four months;  gives any representative of the Approved Service Provider, the Employer and the National HIV/AIDS Authority all reasonable access to the Site in connection with the HIV/AIDS Awareness Programme;  if the National Aids Authority has not provided the names of available Approved Service Providers within two weeks after being asked the contractor may select its own service provider after consultation with the appropriate UNAIDS office;  instructs the Contractor’s Personnel to attend the HIV/AIDS Awareness Programme in the course of their employment and during their normal working hours or any period of overtime provided for in the relevant employment contracts and uses all reasonable endeavours to ensure this instruction is followed;

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 provides suitable space for delivery of the HIV/AIDS Awareness Programme and does nothing to dissuade the Contractor’s Personnel from attending the HIV/AIDS Awareness Programme;  as soon as practicable, notifies the National HIV/AIDS Authority of its sub-contract with an Approved Service Provider to facilitate the National HIV/AIDS Authority’s audit of Approved Service Providers; and  gives all reasonable co-operation to the National HIV/AIDS Authority if it exercises its right to audit the provision by the Approved Service Provider of the HIV Awareness Programme.  make condoms complying with the requirements of ISO 4074 available to all contractor’s employees at readily accessible points on the site, suitably protected from the elements, for the duration of the contract;  either place and maintain HIV/AIDS awareness posters of size of not less than A1 in areas which are highly trafficked by construction workers, or provide construction workers with a pamphlet, in languages largely understood by construction workers, which reinforce the outcomes of the HIV Awareness Programme stated below;  encourage voluntary HIV/STI testing;  provide information concerning counselling, support and care of those that are infected. Outcomes The outcomes of the HIV/AIDS Awareness Programme shall as a minimum, result in contractors personnel exposed to such a programme being able to:  communicate the existence of problems of HIV and be able to outline the consequences of transmission of HIV/AIDS to or from the local community;  recall and communicate the mode of HIV/AIDS transmission and preventative measures including the proper use of the condom. It is evident that the necessary mechanisms are in place for HIV/AIDS education and awareness to be implemented during the Metolong Project, both at the project level by the Metolong Authority, and at the site specific level by the DB Contractor. The monitoring programme, to be developed by a separate consultant to the Metolong Authority, will be critical to verifying whether the HIV/AIDS interventions implemented during construction have been successful in increasing awareness and reducing the rate of HIV/AIDS transmission in the project area. 7.3 Cultural Heritage The ruins of a 19th Century village are located to the east of the construction site and portions of an old stone boundary wall lie within the south east corner of the construction site. The significance of the old stone wall is being assessed by an archaeologist, and once the findings are available the wall will either be fenced, removed or relocated. No graves or other cultural or archaeological remains are known to occur on the site and there is a low likelihood that significant artefacts will be found during excavation and construction. Objective:  To minimise the impact of construction activities on cultural heritage, in and adjoining the site, in particular to the ruins of a 19th Century village and boundary wall. Target:  Ensure protection of all significant cultural and archaeological artefacts found in the construction site.

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Management Measures: The 19th century boundary wall is being surveyed and mapped. It has been agreed that portions of the wall that interfere with the construction site can be removed and the remaining portion will be fenced. While no graves are known or thought to occur on the WTW site, in the event that any graves or other sensitive cultural remains are uncovered during site clearance, all construction activities that pose a danger to the site must be stopped and the ECO informed immediately. The ECO is to inform the Engineer, the CLAs and the Dept of Culture in order for a site visit to be made to evaluate the find. Depending on the significance of the find, a qualified archaeologist may be required to inventory the area for additional artefacts that may be present. All artefacts should be recorded and catalogued and stored for future display in the visitor’s / interpretative centre. The DB Contractor and relevant staff should coordinate with government officials, local stakeholders and the archaeologist in developing a suitable mitigation plan as needed. No construction activities may commence within a demarcated area around the site until clearance has been granted by the Department of Culture. 7.4 On-site Planning and Design Proper planning of the WTW requires detailed layout plans for the location of all buildings, infrastructure, services, earthmoving and polluting activities listed in the Contractor Specification in Chapter 10. Key requirements are summarised here. 7.4.1 Aesthetic and sustainable design of buildings and infrastructure provision Appropriate design, layout and provision of facilities can significantly reduce potential social impacts of the WTW project and create a more sustainable development. This includes aesthetic / visual impacts, social impacts on neighbouring community, impacts on services (water and electricity), and waste issues. Measures that can be taken to mitigate these impacts are described here. Objectives:  To minimise aesthetic / visual impacts of the WTW on the natural environment and maintain sense of place / rural character  To achieve a more sustainable WTW by minimising the requirement for services such as water and electricity Targets:  Maximise sustainability of design to minimise impact on service provision. Management / Design Measures:  Landscape plan to include berms and planting with trees and indigenous shrubs to soften the aesthetic impact.  Restrict building height to two storeys.  Ensure laboratory provides for separate disposal for chemical waste.  Incorporation of low energy consumption options (e.g. energy efficient light bulbs); water saving measures (e.g. low flow shower heads and toilets; rainwater tanks), and building design and construction methods that optimises heat retention in winter and cooling insulation in summer. 7.4.2 Layout of the site The layout plan for the site is required to detail the location of all infrastructure, services and construction activities (see Chapter 10).

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Objectives:  To minimise the construction footprint on the site and to minimise damage to surrounding areas  To create ease of access to operational areas of the site Targets:  Minimal impact on adjacent properties and easy access to all areas of the site. Management measures: The Layout plan of the site should:  Locate works areas and chemical and fuel stores away from environmentally sensitive areas and protected from stormwater runoff, fire, and access by unauthorised persons.  Indicate access routes, temporary loading and packing areas, and allow for sufficient turning circles for large vehicles.  Locate chemical toilets so that they are easily accessible for servicing and at least 50m from water courses or water supplies.  Locate temporary waste bins and skips so that they are easily accessible for removal and situated away from accommodation areas.  Plan lighting to avoid disturbance of nearby residents and construction staff.

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8.0 ENVIRONMENTAL MANAGEMENT DURING CONSTRUCTION This chapter deals with the management of construction activities that are likely to cause negative impacts on the biophysical and/or social environment. The majority of these measures are standard operating measures that are contained in the design specifications for the DB Contractor and the Contractor Standards contained in Chapter 10. Key management, mitigation and monitoring measures are contained here. 8.1 Solid Waste Management The Metolong WTW is likely to generate a large volume of solid waste during construction, with an amount that will be dependent on the size of the residential temporary work force accommodated on site. Significantly less waste will be generated during operation when only around 24 families will be resident. Solid waste will include general household refuse, office waste, as well chemical waste generated during construction and operation of the plant. DB Contractor will be required to use licensed haulers to remove solid waste from the WTW site and staff housing and take it to a licensed waste facility or one approved by the regulatory authority (or one determined by the Advanced infrastructure team). Investigation and determination of options for waste disposal is expected to be conducted under the Advanced Infrastructure Contract. Given the largely unregulated waste disposal system in Lesotho and lack of licensed waste sites, waste minimisation should be a key feature of solid waste management on the Metolong WTW project. This should include attention to aspects such as replacement of waste-rich products with alternatives, such as replacing bottled water with water filters. Objectives:  To initiate procedures to prevent, minimize, recycle and reuse domestic and construction waste material.  To dispose of residual wastes in an environmentally acceptable manner. Targets: Disposal of solid waste minimised, all solid waste disposed of in correct receptacles on site, and waste disposed of in an environmentally-acceptable waste site. Management measures:  Train and inform all construction workers regarding waste minimisation, location and use of waste bins, and general waste management.  The Contractor shall provide metal dust bins to BS 792 or equivalent plastic receptacles for the appropriate storage of garbage at all accommodation facilities and works areas. The Contractor shall be responsible for the removal of garbage off site by a licensed hauler to a registered disposal facility or a facility approved by the regulatory authority at least twice per week throughout the duration of the contract.  All storage of solid waste shall be fenced and locked to keep unauthorized persons from entering the area. The storage area shall be kept clean at all times. No solid waste of any kind shall be outside the bins at any time. Vermin and insect controls shall be imposed. 8.2 Hazardous Waste Management A small amount of hazardous waste will be generated by the project in the form of used or waste oil, oily rags or oily adsorbents from spillages, and possibly small quantities of empty containers of solvents, pesticides or herbicides, batteries, and medical waste.

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This will be removed by licensed haulers for disposal at registered recycling or disposal facilities, as appropriate. Objectives:  To recycle oil waste and dispose of non-recyclable hazardous wastes in an environmentally acceptable manner. Targets:  All spent oil to be recycled, and all hazardous waste disposed in an appropriate licensed hazardous waste facility. Management measures:  Waste oil from workshops and other areas shall be stored separately, and collected by a licensed hauler and taken to a licensed recycling company. 8.3 Effluent Management The DB Contractor will be expected to implement best practice pollution controls such as the IFC Environmental, Health and Safety Guidelines (IFC, 2003) to ensure that all effluent from the site does not cause soil or water pollution. Waste water flows during construction will comprise effluent from operational areas such as concrete batching, wash areas, and temporary accommodation areas. The Contractor is responsible for implementing appropriate measures to handle waste water to meet the required Lesotho’s effluent discharge standards (Otieno 1997). Effluent cannot be returned to the river unless it complies with these effluent standards. These measures are detailed in the contractor specifications in Chapter 10 and summarised here. Monitoring requirements for effluent discharge are specified in section 8.8. Objectives: To ensure handling and disposal of waste water complies with Lesotho effluent standards in APPENDIX F and is done in such a way so as to pose no or minimal risk to the natural environment. Targets:  Full compliance at all times with the Lesotho’s effluent standards.  No discharge of polluting effluent to any stormwater drain, or watercourse. Management measures:  Prevent discharge of concrete, lime, cement, chemicals and fuels into any water course.  All waste water generated during construction must be contained in a suitable area such as lined sedimentation ponds prior to disposal. Such ponds are to be appropriately sited to ensure no inflow of stormwater and shall be not be allowed to overflow by ensuring water is treated and discharged within 24 hours of the water level reaching discharge levels. Solid material from such ponds should be periodically collected and disposed of in an appropriate manner, such as disposal to landfill.  Site sanitation to comply with effluent guidelines and to the satisfaction of the Engineer and ECO.  Water from concrete batching shall be disposed via the waste water management system designed by the Contractor  Fuel stores to be kept in a bunded area on an impervious surface with a ready supply of absorbent materials in case of spillage. Bunded areas to have a minimum containment capacity of 110% of the largest storage tank or container or 25% of the combined volume in order to contain accidental spills from a leak or rupture.

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 Hydrocarbon spills should be absorbed with absorbent material and collected and disposed of off-site in an approved landfill site.  All effluent from wash bays, fuel stores or from pumps shall be collected and disposed of through an oil trap to remove oil residues prior to release to sedimentation ponds.  The Contractor shall arrange to take water samples at each discharge point on a monthly basis, or more frequently should the effluent not comply with the specified standard. The Contractor shall have the samples analysed for suspended solids, faecal coli and oil and grease in an ISO 9000 accredited laboratory and shall submit copies of the reports to the Engineer within 7 days of the tests having been carried out. 8.4 Stormwater and Erosion Control Poor management of stormwater has a high potential to cause erosion on the site causing loss of top soil and reduced rehabilitation potential on site as well as contributing to sedimentation of the river downstream. Objectives:  To ensure the site is developed with sufficient stormwater management measures to minimise erosion and sedimentation of nearby watercourses. Targets:  No evidence of erosion on site throughout construction Management measures:  The Contractor must compile a stormwater drainage plan for approval by the Engineer, which shall include proposals for protection against stormwater damage, and containment of flows, and rehabilitation measures should any damage arise. The stormwater plan should show the location of stormwater channels, silt traps, dispersive measures, sedimentation ponds, and any other special measures to control or collect water flow. Sedimentation ponds should be sized to contain a 1:10 year rainfall event and lined to prevent soil contamination.  All activities involving pumping or release of water must ensure water is dispersed in such a way as to avoid soil erosion.  Any runnels or erosion channels that develop during construction must be backfilled and compacted and measures taken to prevent further scouring.  Cleared areas likely to be subject to erosion from heavy rainfall events or stormwater flows should be stabilised with mulch, straw or geofabric until they can be revegetated or are constructed upon. 8.5 Noise and Dust Noise and dust will be generated by increased use of the access road to Metolong WTW by cars, trucks and busses; use of heavy excavation machinery during site clearance, and occasional blasting (see section 8.6). Site clearance activities, leaving exposed soil and soil dumps, will also generate dust. Dust and noise will create a nuisance to the local community and should be controlled as far as possible to maintain or protect the residents’ quality of life. Dust generated by the WTW construction may smother crops adjoining the WTW and may affect crop yields. Objectives:  To minimise the impact of noise and dust on the surrounding communities. Targets: Comply with applicable noise standards of (SANS 10103 and the Lesotho Government Gazette Extraordinary Legal Notice No. 137 of 1996) at the edge of the construction site.

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In terms of IFC guidelines, noise levels for an industrial site is 70dB, while noise levels at the nearest receptor site should not exceed 3dB above normal ambient noise levels. The Contractor shall provide all his plant and equipment with suitable silencers or adopt other measures such that the noise level in villages adjacent to the work areas will not increase by more than 7 dB(A)leq60 above residual sound levels. In villages adjacent to access roads maximum noise levels shall not exceed 60 dB(A)leq60 and maximum sound pressure levels shall not exceed 70 dB(A). Management measures:  Normal work hours are restricted to between 06h15 and 16h15 Monday to Friday (unless otherwise agreed with the Engineer, local community and adjacent residents).  Local residents are kept informed of the nature and duration of intended construction activities.  Record community complaints in the Complaints Register and respond by taking reasonable action to ameliorate the impact or inform the complainant of the likely duration.  Where possible, equipment should be equipped with suitable silencers.  The Engineer shall use a sound level metre to monitor noise levels during specific activities or in response to a complaint.  Dust control measures should include regular watering of access roads and exposed areas during windy conditions and water spraying of aggregate areas to meet applicable standards.  Exposed soil mounds should be covered with netting or other shade cloth until re-vegetated or constructed upon. 8.6 Blasting controls, warning and monitoring Blasting shall meet the requirements of the South African Explosives Act (Act No 41 of 1958) and a permit will be required from the Lesotho’s Mines and Geology. The Contractor shall make his own arrangements. The use of explosives are described and discussed in Section IX, Schedule 1.19, Clause 25 of the IFB document. Blasting of rock outcrops on site may result in vibration damage to nearby properties, flying rock and noise disturbance. Blasting management requires:  Benchmark monitoring (dilapidation survey)  Notification of residents and warning system  Clearance of humans and livestock from the area and definition of a no-go area during blasting where there is risk of fly rock. 8.6.1 Dilapidation survey The tender documentation requires the DB Contractor to undertake a dilapidation survey of all properties around the site. Objectives:  To provide a benchmark or baseline of the condition of nearby structures in order to enable monitoring of any claims for damages linked to blasting activities. Target:  All structures within 500m of the blasting area included and fully reported in the dilapidation survey.

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Management measures: Blasting on the site may result in the development of cracks on nearby properties. To provide a record of pre-blast conditions as a benchmark for monitoring or incidents that are recorded, the IFB requires a Dilapidation survey to be undertaken of any structures within a 500m radius of blasting areas. This is to be done in the form of colour photographs, video surveys, and shall provide a record of the following features:  Identification of the owners and tenants  General type of construction, foundation type, age and use  Photographs shall be provide the location and date and shall show signs of settlement or stress cracks, signs of poor construction, areas of standing water adjacent to the site wet for extended periods and signs of settlement and tilting. The Contractor shall perform a location survey of all off-site buildings and surface features around the work sites within the survey limits specified herein. A qualified and experienced land surveyor, satisfactory to the Engineer, shall perform the location survey and survey plans shall be prepared including on and off-site buildings. All buildings shall be uniquely identified and/or numbered and the dilapidation survey and monitoring reports shall refer to the buildings identifications throughout the project. 8.6.2 Early warning Objectives: Notify residents of blasting activities in order to be forewarned of blast noises and to ensure livestock and people are evacuated from out of the area of possible disturbance and fly rock. Target: All occupants of houses informed of blasting activities within specified time frames and all persons including contractor employees absent from the blast and fly rock area. All workers involved in blasting provided with protection equipment and be appropriately trained for health and safety. 100% safety record attained and no blasting accidents recorded. Management measures:  All occupants of nearby buildings will be notified of blasting at least 24 hours in advance.  Blasting activities will be pre-warned through the use of sirens sounded for a full 5 minutes before, and 1 minute after blasting has occurred.  Contractor shall station personnel on roads and elsewhere with red flags to prevent persons, animals and traffic entering or remaining within the danger zone. Care shall be taken to ensure that all possible approach routes to the danger zone are covered by these warning arrangements.  After blasting, no person shall approach the area until it has been examined by the blasting supervisor or other responsible person and declared safe. 8.7 Control on Human Activities causing Disturbance and Damage to the Natural Environment The presence of a workforce in the WTW area may lead to uncontrolled trampling and damage to plants, disturbance of local fauna, defacement of rock overhangs and boulders, as well as fouling of the area with litter and excrement, unless human activities are controlled. The plant site will be fenced with 2.4m palisade fence. Objectives:  To ensure that increased human activity in the area does not disturb or damage the natural environment outside the WTW site.

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Target:  No damage caused to natural flora and fauna and the surrounding area remains litter-free and unpolluted by human waste. Management measures:  Workforce is instructed to use existing paths when leaving the WTW area and to spend break times in a specific dedicated area.  Workers are made aware of prohibitions on littering, trampling of vegetation, use of the veld as a toilet and risk of fires from disposal of cigarette butts. 8.8 Environmental Monitoring Requirements during Construction Key aspects to monitor during construction include:  All effluent discharge points or runoff areas, which may include workshop and vehicle maintenance areas, fuel bund areas, chemical store and handling areas, waste storage areas, sedimentation ponds and toilets and wash areas in the temporary camp, waste water drains  Solid waste storage sites (general and hazardous)  Chemical storage areas for general tidiness and good housekeeping  Noise and dust levels  General site cleanliness The most potentially significant aspect to monitor is effluent discharges on the construction site. Effluent cannot be discharged to the natural environment unless it complies with the discharge standards of Lesotho (APPENDIX F). Monitoring requirements fro construction are contained in Table 8-1 and mitigatory cost estimates in Table 8.2. 8.9 Environmental Protection Plan In accordance with the IFB (LWJV 2009), the DB Contractor, in consultation with the ECO, is required to prepare an Environmental Protection Plan (EPP) within 28 days of commencing work and submit it to the Engineer for approval. The Plan is to include and adhere to provisions of this EMP; recommendations in the RoD from NES, the relevant environmental laws and regulations, and the contractor specifications detailed in the tender documents. WASA (2007) has developed a generic Emergency Response Plan (ERP) for its works in Lesotho and this template should be used in consultation with WASA. For more details see section 6.3 and Appendix C.

The EPP shall:  cover all environmental protection works and shall also include descriptions of environmental safeguards, mitigation measures, and emergency procedures  include a description of the administrative structure and lines of communication which shall be established within the Contractor's and his subcontractors' workforce for the implementation of environmental protection procedures and mitigation measures.  provide details of the expertise available for the implementation of environmental protection procedures and mitigation measures.

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 include a site layout plan showing the final positions and extent of all permanent and temporary site structures and infrastructure.  ensure that the Construction Schedule and the EPP relate to one another by:  addressing any limitations of the environment including the seasonality of water bodies, growth and dormancy period of fauna and flora etc.

 considering conditions imposed in an environmental authorisation

 planning to make optimum use of the dry season for construction works

 indicating that the rehabilitation will immediately be executed, per phase, upon the completion of the civils-related Works and include allowance for harvesting of seeds and seedlings for future use during rehabilitation. The Contractor shall inform the ECO of any changes to the approved Construction Schedule as submitted. After approval by the Engineer, the EPP shall be strictly adhered to.

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Table 8-1: Summary of monitoring requirements for construction. Aspect Objective Method Frequency Sampling Detection limit Responsibility Reporting locations

Effluent To minimise risk of soil Surface water quality Monthly and after flow Runoff from fuel Lesotho water ECO Weekly records discharges – and water pollution from sampling events when bunds bunds; chemical quality standards for and summarised in Water Quality effluent discharge from bunds or cause handling areas, discharge to natural monthly report construction site uncontrolled discharge waste storage environment into the natural areas, vehicle environment storage / wash areas, and sedimentation ponds

Bunds To minimise risk of Visual check of bund Daily (when in use) All bunded areas Bunds are ECO Inspection notes bunds overtopping in volume maintained below and monthly report rainfall events or major discharge levels and spill can accommodate a major rainfall event.

Sedimentation To minimise risk of Visual check of pond Weekly or after Sedimentation Ponds are ECO Inspection notes ponds / detention discharge of polluted level significant discharge or ponds maintained below and monthly report basins water to the natural rainfall events discharge level and environment can accommodate a major rainfall event

Oily/diesel water To minimise risk of oily Surface water quality Weekly or after Discharge points Lesotho water ECO Monthly report water contamination monitoring significant spill or for oily wastes quality discharge rainfall events standard of 2.5mg/l

General solid To minimise risk of soil Check waste is Weekly At all waste storage Waste components ECO Inspection notes waste & and water pollution and separated into areas muddled (not clearly and monthly report Hazardous waste human health risks from different separated); leakage Health and components; stored of waste or Safety officer

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Aspect Objective Method Frequency Sampling Detection limit Responsibility Reporting locations

poor waste management in sealed containers tampering evident, in fenced or walled and/or bad odours. area, and no leakage or tampering by vermin evident.

Traffic hazards To ensure risk of traffic 1. Visual spot 1. Daily At WTW and along 1. Un roadworthy 1 and 2. ECO Weekly inspection hazards kept to a checks of supplier roads approaching vehicles reports and minimum. vehicles (tyres, WTW Monthly report

loading, etc.) and general driving 2. Increase in public behaviour. 2. Weekly complaints 2 to 3 per 2. Check public week complaints register Regularly or on request 3. Potholes, unsafe 3. GoL 3. Monitor road of Metolong Authority roads and condition and inadequate signage signage and traffic calming needs

Noise To ensure noise levels Class 1 noise Monthly on average or Boundary of the Noise standards Engineer Monitoring records maintained below level monitor set 1.5m during certain WTW site and at SANS, Lesotho and and Monthly report that is a danger to above ground and construction activities. distance of nearest IFC. Estimated 65dB hearing or creates a 3m from wall or Weekly (complaints house limit on site and long-term nuisance to reflecting surface. register) 50dB in residential local residents. Check public area. complaints register.

Dust To ensure that dust Visual observation of Daily (visual Boundary of the Strong prevailing ECO (dust Monitoring records produced during dust nuisance level observation of dust WTW site and at winds and dry

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Aspect Objective Method Frequency Sampling Detection limit Responsibility Reporting locations

construction does not and dust traps. levels); distance of nearest conditions creating levels); and Monthly report create significant Checks of public houses in NE windblown dust from nuisance to nearby complaints register Weekly (complaints direction the site and road CSO (public residents and staff register) traffic. Increase in complaints) complaints to more than 2 per week.

HIV/AIDS Minimise risk of Observations of Weekly Public areas and Condoms and ECO / Safety Weekly inspection HIV/AIDS spread due to records that toilets (condoms & posters at all times. and Health report and Monthly presence of construction HIV/AIDS posters) Officer report. work force awareness training All staff listed as done in accordance WTW staff having attended with schedule and HIV/AIDS involving all staff; awareness sessions. condoms available at all times, posters displayed in public areas, particularly where construction staff live/eat and in toilets.

Table 8-2: Mitigatory cost estimates for construction phase Impact Mitigation Responsibility Cost estimate (M) Loss of mostly agricultural land Compensate 12 owners MA To be developed as part of the RCAP Loss or pollution of village Fence off and ensure protection of the existing spring. Contractor Capital costs water supply Ensure latrines or sewage disposal option provided for temporary

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work camp cannot pollute the spring or water course. Optimal 27 500 solution, if possible, is to provide water borne sewage to the waste water treatment works. Water quality testing 5 000/annum Increase in HIV/AIDS and Implement MA’s Labour Recruitment Policy and encourage MA STDs around the reservoir contractors to source labour from Skills Register. No accommodation for unskilled construction workers. Ensure implementation of the HIV/AIDS education and awareness programme and include in Contractor’s contract. Monitor to enforce compliance and implementation. This should include improved access to condoms at the WTW camp and clinics; and access to testing, counselling and treatment centres. Increased noise from Restrict construction activities to day time hours Contractor D-B Contractor must also increased trucking and site comply with noise level limits clearance for all his plant and equipment. Costs borne by the D-B Contractor Increased noise and No blasting to take place before 0800 and after 16h15. Contractor Dilapidation survey will require disturbance from blasting Cordon off blasting areas and inform residents / herders when MA social scientists to blasting to take place including through use of sirens. accompany D-B Contractor. Provide ear protection to workers using pneumatic drills or doing blasting. Sum 100 000

Community awareness 10 000/annum

All other costs related to blasting will be part of the construction costs borne by the

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D-B Contractor.

Increased dust from Regular watering of exposed areas, especially in windy conditions. Contractor The mitigation cost will be part construction activities Consider planting windbreak of trees around the site (mainly as a of the construction costs borne green belt), especially in prevailing wind directions. Cover topsoil by the D-B Contractor. and other temporary soil dumps with material/ shade cloth and cover trucks carrying wind-dispersive material. Provide PPE (respiratory protection masks) to construction workers. Increased traffic hazards from Check contractors’ vehicles are properly maintained and that drivers ECO/MA/Contractor Additional road signage, media accidents are trained in spill control and clean up. and community awareness Recommended loads are not exceeded and drivers comply with 10 000/annum speed limits. Maintain road signage e.g. speed limit signage near villages and close to schools, clinics and other social use areas and provide tarred road shoulders where a lot of pedestrian traffic. A roads engineer should be contracted to check road safety requirements and make recommendations for implementation. Encourage GoL traffic officers to periodically check roadworthiness, licences and enforce speed limits and to conduct road safety awareness in schools and put up posters in public places e.g. bus shelters. Increased littering and Provide adequate refuse bins around the WTW site and train Contractor and Contractual obligations of inappropriate disposal of waste construction workers to use them. ECO D-B Contractor. No additional Ensure regular emptying of bins into lidded skips in a contained or costs to Employer. fenced area and regular trucking to an approved landfill site Loss of cultural heritage: The old stone boundary wall be excavated and relocated. Contractor/ECO Archaeological survey th Damage to ruins of 19 35 000 Century village Mitigation of Stone wall 100 000

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Loss of indigenous woodland Separate and reuse topsoil on top of backfilled trenches to promote Contractor/ECO Rehabilitation costs are all vegetation in raw water revegetation and soil stabilisation. borne by the D-B Contractor pipeline corridor Reseeding or revegetation to promote more rapid revegetation Community Compensation 150 000 Increased erosion from the Culverts or cutoff trenches must be implemented to maintain natural Contractor Contractual obligations of WTW site hydrological flow patterns around the site. D-B Contractor. No additional costs to Employer Soil and water pollution caused Ensure proper labelling and storage of chemicals in secure, weather Contractor/ECO Contractual obligations of by chemical spillages (e.g. proof area with limited access to authorised personnel. All handling D-B Contractor. diesel/oil or any of chemicals to be done in accordance with the Material Safety Data Sheets. herbicides/pesticides) WASA will also have its own No pesticides or herbicides containing chemicals listed in the Emergency Recovery Plans in Stockholm Convention on POP to be used. place Ensure protective and fire-fighting equipment available at all times; staff properly trained to handle spills and spills cleaned up promptly. Communication with Authorities A register of incidents occurring on site should be kept. (DWA, Dir. Natural Resources) by MA 10 000/annum Soil and water pollution from Siting of temporary toilets at least 50m from water courses. Regular Contractor/ECO Contractual obligations of sewage disposal from emptying of toilets to minimise spills. Care to be taken to avoid spills D-B Contractor. No additional temporary camp when emptying. costs to Employer Training Appropriate training for the construction workers and ECO so as to Contractor Construction workers training undertaken various mitigatory measures such as on site health and staff/ECO will be borne by safety, community engagement, effluent control and water quality D-B Contractor monitoring Community awareness 25 000/annum

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WASA OHS training 50 000

WASA Emergency Response Plans 100 000

WASA Monitoring and water quality sampling 50 000

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9.0 ENVIRONMENTAL MANAGEMENT FOR THE OPERATIONAL PHASE 9.1 Use, Transport and Disposal of Chemicals 9.1.1 Chemical Dosing The following chemicals will most likely be used at the Metolong Water Treatment Works:  Polymers for flocculation and coagulation processes  Hydrated lime for water conditioning  Potassium permanganate for the oxidisation of manganese  PAC for the removal of tastes and odours  Chlorine gas for disinfection All chemicals used for the treatment of water will be approved for use by WASA The operator of the WTW will need to comply with the specific mixing and dosing requirements as indicated by the producer of the chemicals used. This will include the clear identification of mixing needs, chemical dosing points, and dosage control. Furthermore polyelectrolyte dosing shall be automatically controlled based upon streaming current measurements, with a manual back system provided.

The chemicals that are likely to be used are indicated in Table 2.2 and the MSDS’s for these chemicals are located in APPENDIX G. Objective:  To prevent and minimize potential environmental impacts during the operational phase associated with chemicals used for dosing the WTW. Target:  Use of least toxic chemicals with minimum quantity applied to achieve the SANS and WHO potable water quality standards. Management measures:  Chemicals shall be stored and handled in accordance with their MSDS .  Containers should be fully labelled to include chemical name, purity and concentration and supplier name and address.  Segregated, interior storage space shall be provided with consideration given to:  maintenance of inventory for at least 45 days supply

 unloading and handling conveniences

 maintenance of dry conditions

 compatibility of chemicals or special hazards

 protection from adulteration and spills by bunded walls, and

 appropriate ventilation.  MSDS for all chemicals contained in the store room should be kept in a dedicated place.  Protective clothing, such as masks, overalls and gloves, must be provided.

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 Materials and equipment for cleaning up general spills must be provided.  The chemical store room should be kept locked at all times when not in use and access strictly controlled to authorised staff only.  Notices should clearly identify the chemical store room and of prohibitions such as smoking and eating or drinking.  All staff with access to the chemical store must be trained in handling of chemicals and cleaning-up of spills. 9.1.2 Transport, storage and disposal of hazardous materials (chlorine gas) The only hazardous material involved with the water treatment process that is cause of concern in the event of an accident is chlorine gas, a designated hazardous chemical. Its’ storage, handling or transport is subject to a license from the NES in terms of the Environmental Conservation Act 15 of 2008. Its transport across the South African – Lesotho international boundary is subject to the Basel Convention regulations. The MSDS for chlorine indicates that it is a toxic, corrosive gas that can cause severe burns if inhaled or upon skin contact. It is a greenish-yellow non-flammable liquefied compressed gas packaged in cylinders under its own pressure. Inhalation may cause coughing, choking, nausea, vomiting, headache, dizziness, difficulty breathing, and delayed pulmonary edema, which can be fatal. Chlorine can be detected by its odour below the permissible limit; however, due to olfactory fatigue the odour may not always provide adequate warning of the harmful concentrations of this substance. Chlorine is an oxidizer and will support combustion, resulting in other toxic products. All chemicals will be imported from South Africa, most probably from Gauteng by road. A licensed chlorine supply and transportation company (e.g Chlorochem) will be contracted to supply chlorine, in compliance with relevant transport regulations / legislation requirements of both RSA and of Lesotho. Any accident that might occur during transportation will be handled as an emergency (see section 9.3). All companies which transport chemicals are required by law to have safety plans in place in case of chemical spills or hazard risk to the public. Due to the inherent dangers of gaseous chlorine dosing installations, the design of the dosing installation will make provision for strict control measures and for intervention in the event of a gas leak. The detection, containment and treatment of an area affected by a leak will be required. It is recommended that the chlorine gas detection, system containment and air scrubbing system with sodium hydroxide be installed. However, the final design and preparation of a detailed Emergency Response Plan (see Section 9.3) will be finalised by the operator using the WASA (2007 guidelines and the template in Appendix C).

Chlorine will be supplied and stored as 1 ton gas cylinders and stored in a separate chlorine installation in compliance with occupational health and safety requirements, the MSDS, as well as SANS 10298. The chlorine installation will be required to be compliant with international best practice, including gas leak detector alarm, containment and treatment through scrubbers in the event of a gas leak and provision of safety equipment and emergency kits. The installation shall contain an automatic emergency safety shower and eye wash system outside the chlorine room. The design of the chlorine storage and dosing facility will be the responsibility of the DB Contractor and as a minimum should be well secured to stop access from non- competent personnel, have chlorine gas detectors, a gas scrubbing facility, be bunded to minimise contamination from wash water etc. Empty containers will be stored in a separate area in accordance with the MSDS and replaced on delivery of new supplies. The likelihood of leakage of chlorine gas directly from the dosing system is remote, as chlorine is always applied under vacuum. The pressurised cylinders are also factory tested upon refilling and the chance of failure is also remote. However, there is a possibility of cylinder damage during handling. The leakage of chlorine within the dosing building would normally be detected immediately by means of simple detection devices, although any leakage would not be detected if damage is to tanks prior to arrival in the dosing room (CEC et al 2003). In the case of release of large volumes of chlorine gas under still air conditions the gas, which is much heavier than air, would drift in a downhill direction and may cause a hazard to people living

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near the dam wall and in the gorge. The gas may also be driven by wind, in which case the direction of flow is unpredictable, but in this case is unlikely to be life-threatening at a range of more than 1 km due to the effects of atmospheric dispersion (CEC et al 2003). The DB Contractor will also be required to draft standard operational practices for handling, storage, use and response to leaks for chlorine gas, and to develop a detailed emergency response plan (see Section 9,3, Appendix I). Objective:  To ensure the safe transport, use and disposal of chlorine in such a way as to minimise risk of accidents and leakage. Target:  100% accident and leakage free record. Management measures: Management measures for transport, storage and handling of gaseous chlorine include:  Transport:  Use licensed chlorine suppliers and haulers

 All chlorine must be transported in accordance with the specifications of international signage protocols clearly visible

 All vehicles used to transport chlorine should be roadworthy and driven by licensed and qualified driver, with the necessary skills and equipment to handle an accident.  Storage and handling:  The chlorine gas storage room and gas feed room should be clearly marked with warning signs

 Store tanks in a secure area with no other chemicals

 Provide emergency ventilation equipment and leak detection alarm

 Provide self controlled breathing apparatus in case of leaks

 Provide all other protective equipment such as gloves, face shield, apron and goggles

 Conduct weekly inspections and maintain valves and all equipment in good condition according to specifications

 Provide Material Safety Data Sheet (MSDS), standard operating procedures, and Emergency Response Plan in an accessible area

 Keep inventory records, and inspection and maintenance records

 Comply with Standard Operating Procedures for Pre-Entry, Start Up and Shut Down and Leak Detection. 9.2 Disposal of effluents The various waste streams that may arise from the WTW are sanitary, cleaning water, supernatants from filter backwash water and clarifier sludge, sludge and storm water wastes. The total wastewater stream that could be discharged to the natural environment, after settlement in the sludge lagoon, is estimated at 5 250m3/day. The quality of the waste water must comply with the permitted effluent standards for discharge of effluent to natural streams (Otieno 1997 and SA General Authorisation limits). Clarified water (supernatant) will be removed by decanting and draining.

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If the water quality of the supernatant from the sludge drying beds or that does not meet the effluent discharge standards then chlorination and passing through a wetland before discharge should as a minimum take place. Monitoring of the compliance of this effluent to the Lesotho discharge standards is required before discharge can take place. Objective:  To initiate prevent and minimize potential environmental impacts during the operational phase associated with disposal of effluents produced by the WTW. Management measures: The supernatant must comply with the Lesotho prescribed discharge standards and it is proposed that the supernatant be discharged directly to the Phuthiatsana River (See APPENDIX F for Lesotho discharge standards). A facility to dewater the sludge shall be provided. All sanitary wastes (sewage) should be segregated within the plant from process wastewaters. Sanitary wastes (sewage) shall be conveyed to a sewer connection point to be provided under the Advance Infrastructure project to drain sewage to the proposed WWTW downstream of the WTW. All other waste water flows, including sanitary and cleaning water, which is produced at the premises of the treatment works shall be collected in sumps and conveyed to the sewage treatment works to be constructed for the WTW and the Dam. This includes water from polluted surfaces. Rain water from roofs and collected from other surfaces and not contaminated with pollution may be collected separately and discharged directly to surface water. The DB Contractor shall develop a Stormwater Drainage Plan. 9.3 Emergency Response Plan for Chlorine Gas Leaks The transport, storage and handling aspects of Chlorine gas were discussed in Section 9.1, and the MSDS for chlorine gas is contained in APPENDIX G. Appendix C is a template of a potential Emergency Protection Plan.

Chlorine is a highly toxic gas that requires precautionary handling in strict compliance with occupational, health and safety regulations. Most chlorine leaks are trivial, caused by a loose connection which may occur while the WTW personnel are changing tanks. In these cases, the amount of gas leakage is so small as to not pose a threat to occupants of the room. These are immediately remedied by shutting the gas off and tightening the fitting. More significant leaks can occur as a result of damage caused to tanks during moving and installation. This section serves to identify the components of the required Emergency Protection Plan (Appendix C). Objective:  To initiate prevent and minimize potential environmental and social impacts during the operational phase associated with chlorine gas dosing at the WTW. Target:  No record of chlorine gas emergencies and no workers or residents affected by such event. Management measures: Chlorine is a hazardous chemical which requires extreme care in transport, handling and use. The WTW will be expected to implement best international practice with regard to chlorine safety to reduce the risk of accidents, ensure prompt response to accidents, and inform the public of these actions. In accordance with IFB Environmental Health and Safety Guidelines (IFB 2007), the following steps are recommended to guide the management of hazardous materials.

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 Hazard Assessment Evaluate the level of risk posed by use of hazardous materials through analysis of potential spill and release scenarios; potential for uncontrolled reactions, and potential consequences of such spill based on the physical-geographical characteristics of the project site. The scale of risk will determine the handling, storage, and use requirements.  Prevention Program Review all critical components of the chlorine feed system and prepare a spill control and prevention programme (as a component of the Emergency Preparedness and Response Plan). This should include:

 the training of operators and conducting of drills,

 an inspection programme to maintain the integrity of all systems involved with chlorine dosing;

 preparation of Standard Operating Procedures for filling and transfer operations, and spill prevention and response, and including pre-entry, start-up and shut-down procedures.

 prepare an emergency plan site map showing the location of hazardous materials and associated activities.

 document the availability of personal protective equipment and training needed to respond to an emergency, and the availability of spill response equipment sufficient to handle minor leaks or initial stages of an emergency.

 description of response activities in the event of a spill (internal and external notification procedures; specific responsibilities of individuals or groups; assessing severity of release and determining appropriate actions; evacuation routes; post-event cleanup and disposal, incident investigation, employee re-entry, and restoration of spill response equipment.

 Review of manufacturer’s Operation and Maintenance Manuals  Control Measures  Installation of containment measures such as bunds which should contain 25% of the combined tank volumes with a total storage volume equal or greater than 1000 litres, or 110% of the largest tank, and made of impervious, chemically resistant material.

 Installation of leak detection equipment and alarms

 Installation of automatic scrubbers and emergency eye wash equipment,

 Provision of protective equipment.

 Implementation of regular staff training and drills to respond to minor and major leaks.  Emergency Response Plan (ERP) The ERP included in Appendix C is to be updated by the DB Contractor, includes the following aspects as a minimum:

 Identification of facilities and transport routes

 Emergency response procedures, including first aid and emergency medical treatment

 Designation of community and the WTW facility coordinators to carry out the Environment Response Plan,

 Emergency notification procedures for informing the public and emergency response agencies.

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 Methods for determining if chemical release has occurred and probable affected area and population

 Evacuation plans

 Description of training programme for emergency response personnel, including a list of the employees to be trained, specific training objectives, method of training to achieve the objective ways of measuring the effectiveness of training, and schedule for refresher courses.

 Methods and schedule for carrying out emergency response plans.

 Procedures for inspecting, testing and maintaining the emergency response equipment.

 Training  Community Awareness The contents of the ERP should be approved by NES and MA and should be work-shopped with members of the local community so they are familiar with actions that are required to be taken in the event of an emergency. Information to be given to the community should include the nature of the project operation and prevention and control measures in place; the potential for off-site effects due to an accident during transportation or operation; and specific information on behaviour and safety measures to be adopted in the event of an accident. 9.4 Disposal of Sludge (solids) Options for sludge disposal have been discussed and compared in Chapter 2 and APPENDIX E. Research by Hughes et al (2005, Effects of Land Application of Water Treatment Residues, WRC Report No. 1105/1/05) concludes that water treatment sludge’s or residues IWTR) have a beneficial effect on the receiving soil. Water Treatment Residues have no toxicity or constituents that harm the environment. In comparing the constituents of the Phuthiatsana River and the chemicals to be fed into the Metolong WTW treatment processes, it is not envisaged that the residues produced at the Metolong WTW will have any material difference to those cited in this report.

It is estimated that the quantities of sludge that will be produced from the treatment process as between 8 and 10 tons of sludge per day and 5 250m3 of wastewater based on raw water with a turbidity of 100 NTU. The most cost effective means of treatment and disposal of these residuals is the use of sludge lagoons to concentrate the sludge while releasing the supernatant to the river. Lagoons can be left to dry the sludge and this sludge will be removed and transferred to neighbouring agricultural land where the residuals will be spread and incorporated into the soils. The current sizing and design allows for a minimum 3 – 5 years of sludge storage in sludge drying beds (lagoons). Other cost effective forms of sludge disposal for the Metolong WTW include the following (Golder 2009, Appendix E):  Use in soil conservation measures or the rehabilitation of areas where soil erosion is prevalent  Landfill disposal or use as landfill cover  Brick making The recommended option is for use as a soil conservation measures in areas where soil erosion has occurred. Should WASA want to change this recommendation, it is recommended that pilot projects be initiated on these alternatives before implementation.

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Objective: To initiate prevent and minimize potential environmental impacts during the operational phase associated with disposal of sludge produced by the WTW. Management measures: Management requirements for chemicals are given in their MSDS. Those relevant to some chemicals that may be used at the Metolong WTW are provided in APPENDIX G and include the following:

Under no circumstances may sludge be discharged directly to any watercourse.

Sludge generated at the WTW shall be treated and disposed to neighbouring agricultural lands.  Appropriate access to and from the sludge lagoons to load and remove concentrated sludge shall be designed for to transport the dried sludge out of the site to the identified lands.  WASA (the proposed WTW operator) may identify alternative disposal options and initiate pilot studies as funds become available.  The quality of the sludge should be tested before any disposal takes place to confirm the findings of the Hughes (2005). The list of chemical constituents to be tested for is indicated in Golder 2009 (APPENDIX E). The approving authorities (Ministry of Natural Resources, Dept Agriculture, Dept Water Affairs must be approached and licences obtained before any disposal takes place. 9.5 General requirements for the WTW The Metolong WTW will have to be registered with DWA. The operator will be obliged to employ operators of the requisite grading. It has been agreed by WASA that the guidelines used in South Africa can be used. Under the South African Regulation R2834 of 1985 a minimum number of operators are required. In every case this minimum must be compared with the number of operators physically required to man the works at all times during its operation. The DB Contractor should provide graded operators and management during the pre-commissioning, commissioning, training and handover phases of the project to ensure that there will be a programme of tuition, training, and institutional development for the operator’s management and personnel. Apart from the operating staff for the treatment process, additional operating staff for dams and pump stations etc., as well as maintenance staff may be required. The Operator may also be responsible for providing staff to operate the Metolong Dam. The selected Operator will eventually be responsible for running the raw water pump station at the dam, and a process of coordinating training for the WTW and for the operation of the raw water pumps will need to be coordinated between the DB Contractor and the Dam contractor. The WTW is generally categorized in the Class B range. In terms of the South African Department of Water Affairs regulations, these works will require a Class IV operator (Grade 11 or NTC II education with 15 years appropriate experience plus Operators certificate) per shift. The regulations do not specify how many shifts are required or the number of labourers required. However, the South African Department of Water Affairs guidelines indicate that where a works is in continuous operation a minimum of four operators is recommended to take into account time off. In water treatment works that have significant mechanical equipment and supply drinking water to the communities they serve, it is recommended that the water works be attended by at least one qualified operator at all times. The South African Department of Water Affairs recommendations for general operation and maintenance requirements as well as staffing level for the WTW are described below (South African Regulation R2834 of 1985). 9.5.1 Routine Operation and Maintenance The operation and maintenance requirements of water treatment works consists of the routine operation and maintenance tasks listed below:

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 Adjustment of raw water flow rates depending on demand and reservoir levels;  recording of inflow and treated water produced by the works;  recording of visitors to the works;  adjustment of chemical dosing rates;  de-sludging of clarifiers;  backwashing of filters;  sludge disposal;  testing and recording of water quality data  basic maintenance and housekeeping;  chemical handling and make up;  ordering and stocktaking of chemicals;  basic works calculations;  liaison with other operators and supervisors; and  safety inspections and toolbox meetings. 9.5.2 Spares and consumables The DB Contractor will be responsible for the supply of spares and consumables (excluding chemicals) for a period of 5 years and for the supply of chemicals for 6 months of operation after successful commissioning. 9.5.3 Tools and equipment The DB Contractor will be responsible for the supply of all tools and equipment necessary for the effective and efficient operation and maintenance of all the WTW equipment as per the respective manufacturers’ or suppliers’ instructions. These tools are to be of good and robust quality and shall carry a 5-year warranty against faulty workmanship or sub-standard materials. 9.5.4 Operating instructions and manuals The operators must be given operating and maintenance manuals indicating the frequency at which these tasks should be done. Daily operational record sheets should be completed, examples of the minimum data to be collected is shown in the Tables 9.1 and 9.2. Table 9-1: Operational record sheet - example 1

Month Year

Raw Water Treated Water

Date Residual Comments ºC Turbidity pH Turbidity pH Chlorine 1 2 3 ……

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29 30 31 Min Ave Max

Table 9-2: Operational record sheet - example 2

Month Year

Chemical Rainfall Flow Maintenance Date consumption (mm) Inflow Outflow Loss Poly. Lime Cl Pumps Equip.

1

2

3

….

29

30

31

Min

Ave

Max

9.6 Water quality assessment of the WTW It is recommended that the SANS 241 (2005, Edition 6) and WHO (2006, APPENDIX H) drinking water guidelines document is used for to determine the following:  water quality compliances of the WTW against water quality standards  water quality monitoring program It is recommended that Class I water is considered for the WTW as this is acceptable for lifetime consumption. During the commissioning phase, the DB Contractor is obliged to record data on both flow (quantity) and water parameters (quality) to run the WTW. Tests should be done routinely, sometimes several times a day until a pattern emerges and then performed as and when required. SANS 241 (2006) gives the quality testing requirements as well as the reporting frequency (Appendix H).

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9.7 Water Sampling It is important that the Operator monitors the drinking water at strategic points within the water reticulation system. This will ensure that the minimum requirements legislated for the quality of the drinking water is being met at all times.

Sample taps are to be provided to enable collection of representative water samples to assess the performance of each of the various treatment units included in the process train. As a minimum, sampling taps are to be provided at the following locations (see IFB 2009):  Raw water inlet before chemical dosing  Before flocculation chamber  After clarification  After filtration  After chlorine contact basin.  A sample tap shall be provided to collect representative water samples of combined filter effluent. Analytical equipment and laboratory facilities shall be provided with consideration given to:  source water quality and its variability;  treatment processes - their complexity, adjustment opportunity and performance assessment;  operating personnel capability;  optional analytical availability; and  acquisition of reagents and equipment parts. As a minimum, analytical equipment shall be provided for conducting the following tests:  free and total chlorine residual determination;  jar tests;  pH  turbidity and conductivity;  total hardness  total dissolved solids  alkalinity  iron  manganese and  E. coli  Colour  UV

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Appropriate forms shall be devised for maintenance of water treatment records for water usage, process operations and analytical test data. The works shall be provided with automatic measurement of raw water inflow and treated water outflow with cumulative flow totalisers. 9.8 Monitoring Requirements during Operation Table 9.3 outlines the monitoring requirements for the Operational Phase and Table 9.4 the cost estimates for the EMP for the operational phase.

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Table 9-3: Summary table monitoring requirements for the operational phase Aspect Objective Method Frequency Sampling Detection limit Responsibility Reporting locations

Effluent To minimise risk of Surface water Monthly and after Runoff from fuel Lesotho water WASA – ECO Weekly records discharges – soil and water quality sampling flow events when bunds; chemical quality standards and summarised Water Quality pollution from effluent bunds or cause handling areas, for discharge to in monthly discharge from uncontrolled waste storage natural report construction site discharge into the areas, vehicle environment natural environment storage / wash areas, and sedimentation ponds

Bund volumes To minimise risk of Visual check of Daily (when in use) All bunded areas Bunds are WASA – ECO Inspection notes bunds overtopping in bund volume maintained below and monthly rainfall events or discharge levels report major spill and can accommodate a major rainfall event.

Sedimentation To minimise risk of Visual check of Weekly or after Sedimentation Ponds are WASA – ECO Inspection notes ponds / discharge of polluted pond level significant discharge ponds maintained below and monthly detention basins water to the natural or rainfall events discharge level report environment and can accommodate a major rainfall event

Oily/diesel water To minimise risk of Surface water Weekly or after Within bunded Lesotho water WASA – ECO Daily visual oily water quality monitoring significant spill or areas and quality discharge inspection notes contamination from grab sample to rainfall events workshop waste standard of and monthly bunded areas and test for oil and collection 2.5mg/l soaps, report (if spill or workshops diesel oils and grease potential removal of

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contaminants)

General solid To minimise risk of Check waste is Weekly At all waste Below standard WASA – ECO Inspection notes waste & soil and water separated into storage areas of general good and monthly Hazardous pollution and human different housekeeping report waste health risks from poor components; practice waste management stored in sealed containers and no leakage or tampering by vermin evident.

Noise To ensure noise Class 1 noise Monthly on average Boundary of the Noise standards WASA – ECO Monitoring levels maintained monitor set 1.5m or during certain WTW site and at SANS, Lesotho records and below level that is a above ground and construction distance of and IFC. Monthly report danger to hearing or 3m from wall or activities nearest house Estimated 65dB creates a long-term reflecting surface limit on site and nuisance to local 50dB in residents. residential area.

General Keep site neat and Visual Daily WTW site Visual mess and Operator and ECO Daily housekeeping tidy observations waste observed inspections and on site (littering, domestic Weekly waste disposal) inspection reports

Traffic hazards To ensure risk of 1. Visual spot 1. Daily At point where 1. Un roadworthy 1 and 2. ECO Weekly traffic hazards kept to checks of supplier effluent is to be vehicles inspection a minimum. vehicles (tyres, discharged from reports and

loading, etc.) and sludge points Monthly report general driving 2. Increase in behaviour. 2. Weekly public complaints 2. Check public 2 to 3 per week complaints register Regularly or on 3. Potholes, 3. GoL unsafe roads and

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3. Monitor road request of Metolong inadequate condition and Authority signage signage and traffic calming needs

Erosion from the Minimise erosion from Drains, culverts Daily and especially Drainage canal No erosion Operator and ECO ECO/Operator WTW site WTW site and outlets after big rain events, below WTW, canals after and contracted to check for erosion Drains, culverts storms chemical and assess and outlets supplier additional mitigation needs

Chemical Minimise risk of Vehicles Vehicle inspections Vehicle log book, No road ECO/Operator and Vehicle transportation potential roadworthy, full when on site MSDS’s and accidents contracted chemical inspections accident transportation chemical signage, chemical inventory associated with supplier when on site aversion accident driver trained on chemical H&S and clean up transportation in emergency

Chlorine gas Minimise risk of gas Chlorine detectors Daily On line monitors to No chlorine gas ECO/Operator and ECO/Operator leak leaks in place check chlorine gas leaks and if leak contracted chemical and contracted levels no harmful gas supplier chemical Chlorine scrubbers released in to supplier in place that environment. removes any gas that escapes or to be used in the case of a gas leak

Supernatant Effluent meets Effluent tested Before any planned If effluent does not Must meet ECO/Operator Weekly disposal discharge standards before released to discharges meet standards Lesotho inspection determine if it then pre-treatment discharge reports and meets Lesotho is required and standards Monthly report discharge retesting quality (Otieno 1997) or when effluent

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standards. until it meets is to disposed required standard. Tests to be done in the WTW laboratory

Table 9-4: Cost estimate for the proposed mitigatory measures for the operational phase Impact Mitigation Responsibility Cost estimate (M) Increase in HIV/AIDS and Implement MA’s Labour Recruitment Policy and encourage operator to MA An allocation of USD 250 000 has STDs around the reservoir source labour from Skills Register. been set aside to implement this Ensure implementation of the HIV/AIDS education and awareness plan programme to all staff of WTW. Monitor to enforce compliance and implementation. This should include improved access to condoms at the WTW and clinics; and access to testing, counselling and treatment centres. Increased traffic hazards from Check suppliers and operators’ vehicles are properly maintained and that ECO/MA/ Additional road signage, media and accidents drivers are trained in spill control and clean up. Operator/GoL community awareness Recommended loads are not exceeded and drivers comply with speed limits. traffic officials Capital cost Maintain road signage e.g. speed limit signage near villages and close to 50 000 schools, clinics and other social use areas and provide tarred road shoulders where a lot of pedestrian traffic. A roads engineer should be contracted to check road safety requirements and make recommendations for 10 000/annum implementation. Encourage GoL traffic officers to periodically check roadworthiness, licences and enforce speed limits and to conduct road safety awareness in schools and put up posters in public places e.g. bus shelters. Increased littering and Provide adequate refuse bins around the WTW site and train staff to use Operator and WASA domestic waste removal inappropriate disposal of them. ECO Capital cost waste Ensure regular emptying of bins into lidded skips in a contained or fenced 200 000 area and regular trucking to an approved landfill site

36 000/annum

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Increased erosion from the Drains, culverts and outlets must be inspected regularly, especially after big Operator Storm water management plan by D- WTW site rain events, to check for erosion and assess additional mitigation needs. B Contractor would be part of contractual obligations Ensure WTW site gardens and planted areas are maintained. WASA Estate management/garden services 36 000/annum Soil and water pollution Ensure proper labelling and storage of chemicals in secure, weather proof Operator /ECO WASA caused by chemical spillages area with limited access to authorised personnel. Implementation of Emergency (e.g. diesel/oil or any Response Plans herbicides/pesticides) All handling of chemicals to be done in accordance with the Material Safety Data Sheets. Auditing

25 000/annum No pesticides or herbicides containing chemicals listed in the Stockholm

Convention on POP to be used. Materials

50 000/annum Ensure protective and fire-fighting equipment available at all times; staff properly trained to handle spills and spills cleaned up promptly. Practice drills 10 000/annum A register of incidents occurring on site shall be kept. Human risk from accidents Suppliers vehicles used to transport chemicals or flammable materials Operator and None involving chemical should be equipped with clean up materials and fire fighting equipment and licensed transportation drivers properly trained in spill management. Chemicals must be properly chemical labelled, secured and handled in accordance with their MSDS. Containers supplier from hazardous or toxic chemicals to be disposed of in a secure area and not used for other purposes. Soil and water pollution Test sludge monthly to ensure constituents suitable application. Operator/ECO WASA caused by sludge disposal to Chemical and physical testing of preferred option (agricultural sludge lands and donga rehabilitation) 25 000/annum Sludge disposal transportation Licensing and maintenance of staff and supplier vehicles. Sludge removal Operator/ECO WASA

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trucks to also be checked for roadworthiness and driver’s licences and this to and sludge Plant and equipment be a condition in any contract removal 2 500 000 contractor Operation and maintenance 250 000/annum

Personnel 250 000/annum Chlorine gas leak Chlorine detectors in place that triggers the appropriate level of emergency Operator WASA response. Chlorine scrubbers in place that neutralise chlorine gas with Spares and consumables sodium hydroxide. This ensures no releases of hazardous gases to 50 000/annum environment. Supernatant disposal Effluent must be tested before released to determine if it meets Lesotho Operator WASA discharge standards. If effluent does not meet standards then pre-treatment Chemical analysis of supernatant is required and retesting quality until it meets required standard. Tests to be 25 000/annum done in the WTW laboratory. Soil and water pollution Appropriate drainage and containment of stormwater or leakage on site, Operator/ECO Stormwater management and control caused by leakage of sludge proper storage and removal, and disposal at correct facilities. berms will be built by D-B from sludge ponds or drying Contractor. These costs are all beds borne by the Contractor.

Detention facilities will also be built on site to store excessive stormwater runoff. These will also control any leakage from site. Training Appropriate training for the construction workers and ECO so as to Contractor Construction workers training will be undertaken various mitigatory measures such as on site health and safety, staff/ECO borne by community engagement, effluent control and water quality monitoring D-B Contractor

Community awareness 25 000/annum

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WASA OHS training 50 000

WASA Emergency Response Plans 100 000

WASA Monitoring and water quality sampling 50 000

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10.0 GENERAL CONTRACTOR COMPLIANCE STANDARDS The following contractor compliance standards have been drafted for use by the DB Contractor during the WTW construction. Guidelines for Contractors developed for the Cape Metropolitan Council by Ninham Shand (2002) and relevant to the expected construction phase of the WTW were extracted and modified as the basis for this schedule of Contractor Standards. The Contractor for the WTW will use these as a basis for preparing an Environmental Protection Plan for construction activities. Identification of targets helps to identify the desired outcome of implementing the management measure can assist in deriving an audit report. As far as possible, the table has been set out in accordance with the general phasing of a construction project, as follows:

A. Pre-Construction Planning  A1. Design, Layout, Method Statements and Permits  A2. Social sustainability  A3. Training and Capacity Building B. Site Establishment and Construction  B1. Excavation / Site clearance  B2. Pollution Controls  B3. Human Safety, Nuisances and Cultural Heritage  B4. General Environmental Safety and Protection Measures C. Post-Construction Phase

Abbreviations used in the following table are: ECO = Environmental Compliance Officer

CRO = Community Relations Officer MA = Metolong Authority

The same table can be used during the operational phase with more emphasis on the following aspects:  Quality control of the produced water (SANS 241 and WHO for sampling protocols and water quality standards)  Quality control of any discharges (supernatants, Lesotho discharge standards, Otieno 1997)  Health and safety issues associated with chemicals used on site  Sludge disposal quality control (Herselman 2008)

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

A. PRE-CONSTRUCTION PLANNING

A1. DESIGN, LAYOUT, METHOD STATEMENTS AND PERMITS

1 General environmental Construction camp  The Contractor shall present a proposed layout plan of construction work areas and Contractor & ECO MA Layout plan shows protection layout plan present this to MA for approval prior to starting construction activities. This plan shall different work areas. take account of provisions of this EMP and shall demarcate the different works areas including: Plan approved by Metolong Authority  All buildings and structures including: contractors’ accommodation; contractors’ camp and lay down areas, site offices, laboratory, chemical and chlorine storage buildings, fuel stores, toilets and ablutions, construction materials stores, vehicle and equipment stores, workshops, wash bays and solid waste storage and disposal sites, including hazardous waste  Works areas such as batching plants, crusher plants (if required),  Roads and access routes  Gates and fences  Essential services (permanent and temporary water, electricity and sewage and substations)  Rubble and waste rock storage and disposal sites.  Firebreaks.  Prospecting boreholes, excavations and test pits.  Excavations and trenches, borrow areas, cut and fill areas, trench and berm systems, spoil areas, rubble and waste rock storage and disposal sites, topsoil stockpiles and sand extraction points.  Features and plants to be conserved.  No Go areas (e.g. cultural heritage site)  All temporary and permanent water management structures including water abstraction points, pipelines and irrigation systems, sludge dams, bunds and sumps, settlement ponds, waste discharge points (including energy dissipation specifications) and water testing points  Sewage water management systems and positions

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

 Stormwater system

2 General environmental Method statements The contractor shall compile Method Statements for activities such as: Contractor MA Method statements protection (Engineer & ECO) completed for:

o Access routes: Location of proposed access routes, rehabilitation of temporary access Access routes routes;

o Blasting: details of all methods and logistics Blasting

o Bunding: method of bunding the static plant Bunding

o Camp establishment: layout and preparation; method of installing fences for no go Camp Establishment areas; working areas and construction camp areas. o Cement/concrete batching: Location, layout, and preparation of cement/concrete Cement/concrete batching facilities including methods employed for mixing concrete and management of batching run off water. o Contaminated water: including containment of runoff and disposal of polluted water Contaminated water

o Dust control methods Dust control

o Clearance of vegetation: method during site establishment. Vegetation clearance

o Earthworks: method for control of erosion during bulk earthwork operations, and Earthworks method of undertaking earthworks, including hand excavation and spoil management. o Emergency: response to possible emergencies on site Emergency

o Environmental awareness: logistics for environmental awareness for contractors’ Environmental employees and management staff. Awareness

o Fire, hazardous and poisonous substances: handling and storage of hazardous Fire, hazardous and wastes; emergency spillage procedures and compounds to be used; emergency

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

procedures for fire; use of herbicides and other poisonous substances; poisonous substances

o Fire and fuel spills: methods of refuelling vehicles; methods for cleaning up fuel spills; Fire and fuel spills refuelling of construction vehicles;

o Piling, jacking and thrust boring: the method of piling operation (e.g. driven or bored) Piling, jacking and thrust or in situ casting or pre-cast pile structures. boring o Rehabilitation: methods for disturbed areas, and revegetation after construction is Rehabilitation complete; retaining walls and gabions.

o River corridors: methods of release of construction related effluent water into any River corridor protection natural stream or river course; method of construction activities within 1:50 year floodplain; and details of methods to control downstream sedimentation or to cross rivers during construction. o Rock breaking: details of methods used for rock breaking Rock breaking

o Settlement ponds and sumps: layout and preparation of settlement ponds and sumps. Settlement ponds and sumps

o Solid waste management: solid waste control and removal of waste from the Site. Solid waste management o Sources of material: details of materials to be imported to the site. Sources of material o Stream diversion: methods of diverting a water course and reinstatement Stream diversion o Traffic safety measures: entry and exit off public roads, Traffic safety o Wash areas: location, layout, preparation and operation of all wash areas including Wash areas vehicle washing, workshop wash, and painting wash and cleaning. o Water abstraction: methods of abstraction and use of water from natural water Water abstraction courses. 3 Erosion risks / water Stormwater  Ensure site layout plan provides for adequate stormwater drainage to avoid ponding or Contractor Metolong Stormwater system ponding Management erosion from culverts. Water slowing and dispersion measures should be installed. Authority shown on site plan

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

including dispersion measures.

4 Minimise risk of water and Toilet facilities for  Plan the location of toilet facilities at least 50m away from nearby water course and Contractor MA / ECO Toilets situated 50m soil pollution temporary camp downstream of any springs, and more than 50m from work areas. away from water course and downstream of spring

5 Aesthetic impacts Housing &  Ensure layout and design of plant is as aesthetic as possible and softened or screened Master plan ECO Landscaping plan shows infrastructure design by low berms and tree planting, around the fence and within the grounds. consultants & trees planted around & landscaping  All buildings to be restricted to two storeys. contractor perimeter of camp and landscaping inside camp

6 Sustainability of plant Eco-design of  Consider incorporation of eco-design principles into building design including solar Master plan ECO Energy & water saving design infrastructure panels, energy-saving light bulbs, water collection, water saving landscaping, low flow consultants & measures installed showerheads and other recycling systems. contractor

7 Pollution prevention from Management of  Design must make provision in the testing laboratory for separate collection and Contractor ECO Chemical disposal chemical waste chemical waste disposal of chemical waste. system in place and used

8 River flow Water abstraction  Abstraction of water from the river will require a Method Statement prior to approval by Contractor ECO Water abstraction permit the Engineer. obtained and abstraction  A permit is required from DWA for river abstraction. done in accordance with  Conditions of the water permit must be complied with. permit conditions

A2. SOCIAL SUSTAINABILITY

9 Minimise social disruption Temporary  Job preference for unskilled workers from the nearby villagers to the maximum extent Contractor MA / ECO Unskilled workers and accommodation accommodation for practical or possible is encouraged. preferentially sourced needs and costs for  Minimise requirement for providing temporary accommodation for unskilled workers. from local villages

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

labour workers Temporary camp houses only workers from outside area 10 Job creation for local Skills register used  Contractor is encouraged to source local labour from the local community by providing a Contractor Metolong Skills Register compiled. list of skills required and number of workers to the Metolong Authority. Contractors are residents to source local Authority Labour sourced locally. workers not obliged to select their workforce from the local community but may wish to do so to reduce the size of the temporary work camp and to avoid other attendant social effects of accommodating a large workforce. If local residents are given job preference by the Transport to be provided DB Contractor, those losing land to the WTW and dam should be given priority. If workers are selected from nearby towns, transport should be provided. for workers 11 Minimise social disruption Notification of local  Notify local communities and put up notices around the dam basin to inform people that Metolong Authority Local communities communities of no recruitment of workers will be done at the dam site, and provide alternative numbers CLOs notified of recruitment recruitment protocol and address for application to the skills register. policy. Notices erected around the project site  Contractor to turn away any work-seekers arriving at the project site and direct them to Contractor ECO/CRO No problems apply at the recruitment office. experienced by work- seekers appearing at the construction site. 12 Minimise raised Good community  Information boards: containing background information on the construction activity and Contractor / ECO Metolong Large info board erected expectations in local relations the relevant contact details for complaints shall be erected near the entrance to the site. Authority at the site. community and limit  Notification of onset of construction: Notify Employer, relevant authorities and local Correct information social disruption community in writing as well as verbally of the onset of construction activities, including provided (contact contact details for complaints. details)  Community liaison assistants to inform the local community members of the recruitment process and onset of construction and schedule. Proof of notification of onset of construction to Employer, relevant authorities and local community.

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

13 Minimise risk of social No on-site  Enforce requirements forbidding the contractor from recruiting labour at the construction Contractor Metolong Records kept of source disruption associated with recruitment of labour site and include penalties in the contractor’s contract for infringement. Authority of labour influx of workers

A3. TRAINING AND CAPACITY BUILDING 14 General environmental Environmental  The Contractor will be required to employ a full-time ECO at the construction site. Contractor ECO and MET ECO on site full-time damage awareness training  The Contractor or his representative (e.g. ECO) shall provide training and guidance to officers of workers site workers before commencing work on relevant components of the EMP, including any new site workers taken on during the course of work. Proof of training of  Workers shall understand the dos and don’ts of working on the site and controls on workers / Signed causing environmental damage. This should include notification of regulations on attendance register harvesting wild fauna and flora from the surrounding area, damage to cultural heritage, littering, use of formal latrines, sexual engagement with locals, etc. Information posters  Information posters should be put up in worker eating areas depicting typical prohibited displayed in social areas activities that should be complied with on and off site. on site Evidence that workers complying with regulations (e.g. no littering) 15 Improved institutional Environmental  Workshops should be held with the environmental ministry and other key departments EMP consultants MA Workshops held with capacity for training of involved with environmental oversight to familiarise them with the provisions of the EMP and ECO government staff. environmental monitoring government officers and monitoring requirements. Workshops should be coordinated by the ECO to develop a working relationship with staff of these institutions at an early stage. An attendance Attendance register for project oversight register with contact details should be kept and notes of workshop proceedings compiled. Workshop notes kept

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

B. SITE ESTABLISHMENT & CONSTRUCTION PHASE

B1. SITE CLEARING AND PREPARATION ACTIVITIES

Note: Some site preparation activities relating to layout or siting of infrastructure are covered under section A1 as they should be planned for at an early planning stage.

16 Damage to flora and Excavation / site  Notify the local community, including traditional herbalists, they can remove any plants Contractor ECO / CRO Local community fauna clearance they require prior to site clearance. notified prior to site  Search and rescue the Red Data plant Dicoma anomola and relocate to the proposed clearance to remove any nursery associated with the dam or replant in a suitable location useful plants. Dicoma anomola individuals relocated 17 Damage to cultural Excavation  During excavation, if any archaeological, cultural remains or grave sites are unearthed, Contractor ECO & Dept of Excavation halted and heritage work should cease immediately. Staff at the Department of Culture should be informed to Culture authorities consulted if assess whether excavation can proceed or if remains must be exhumed or subjected to cultural remains found further archaeological investigation. 18 Erosion and Excavation / site  Areas subject to erosion shall be protected by installing temporary and permanent Contractor ECO Drainage works installed sedimentation clearance drainage works at an early stage in site preparation. Measures to prevent surface water during site preparation from being concentrated in streams and from scouring the slopes must be implemented in accordance with the Method Statement. Erosion channels  Any runnels or erosion channels developed during the construction period or during vegetation establishment shall be backfilled and compacted, and the areas restored to a restored to proper proper condition. condition at early stage  Stabilisation methods for cleared areas shall consider the following options: mulch or chip Exposed slopes cover, straw bales (1 bale per m2 rotated into the top 100mm of earthworks); watering, stabilised. planting/sodding; hand or hydroseeding; soil binders and/or mechanical methods such as gabions, geofabric; hessian; armourflex; log/pole fencing or retaining walls. Access over newly  Traffic over stabilised areas shall be restricted and controlled and damage to stabilised stabilised areas areas repaired and maintained. controlled.

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

 Anti-erosion compounds shall be proved to suppress dust and erosion, and should not Revegetation inhibit re-vegetation. implemented with  Re-vegetation should be carried out using indigenous grasses and shrubs native to the indigenous species project area. native to Lowlands. 19 Erosion and Stormwater  The contractor shall implement all reasonable measures to control erosive effects of Contractor ECO Stormwater sedimentation controls / stormwater runoff. management effective at management  Silt screens shall be used to prevent overland flow of water, which can include straw minimising erosion bales as filters placed across the flow of water.  Flow dispersive measures to reduce the velocity / intensity of runoff should be Flow dispersion implemented. measures implemented 20 Human / animal safety Blasting  Blasting shall be done in accordance with the method statement and all applicable laws Contractor ECO Blasting complies with and noise and regulations. laws and regulations  A qualified and registered blaster shall supervise blasting and rock splitting at all times.  Ensure that appropriate pre-blast monitoring records (dilapidation survey) are in place Blasting done by (e.g photographic and inspection records of all structures within 50m radius of the blast qualified supervisor area). Monitoring should be done in the presence of the owner and any cracks or defects pointed out and recorded. Dilapidation survey done  Allow for good quality vibration monitoring equipment and record keeping on site at all in accordance with IFB times during blasting.  Take all necessary precautions to prevent damage to special features including removal Vibration monitoring of fly rock. undertaken and records  Provide adequate warning (one week) to Community Liaison Assistants (CLAs) to ensure kept community members and herders are notified when blasting will occur.  Use a siren to signal when blasting is likely to take place, giving two warning signals, half Precautions taken to an hour before blasting is due to commence. prevent damage by fly  Ensure that no-go areas, where there is a risk of fly rock, is evacuated prior to blasting. rock  Blast mats should be used as cover during blasting, not soil. Blasting warnings given prior to blasting in accordance with IFB

Blast mats (not soil) used as cover

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

21 Dust Borrow pits /  Existing borrow pits and suppliers shall be used for new material. Contractor ECO Additional material quarries  Vehicles leaving borrow pits shall be not over-filled to the point that debris can be obtained from existing deposited onto roadsides, and truck loads should be covered with tarpaulin to minimise borrow pits and wind blown dust. (Note: applies to use suppliers of existing quarries) Trucks not overfilled and material covered

22 Erosion and Culverts  No water course or stream may be diverted or dammed or modified without the approval Contractor ECO Approval obtained from sedimentation of NES and will require a Method Statement. NES for stream  When installing culverts, ensure continuity of base water flow. diversion  Water quality monitoring will be required before onset of construction activities within a water course. Base water flow maintained during culvert installation

Water quality monitoring done and records available.

B2. POLLUTION CONTROLS

23 Prevention of soil / water Fuel storage areas  All liquid fuels should be stored in sealed tanks, situated on a smooth impermeable Contractor ECO Fuels stored in sealed pollution & human safety and tanks surface (plastic or concrete) with an earth bund. If plastic used it should have sand on tanks on impermeable top to prevent perishing. The impermeable lining shall extend to the crest of the bund surface. and the volume shall be able to contain 25% of the total capacity of all storage tanks or 110% of the capacity of the largest tank. The floor of the bund shall slope towards an oil Fuels stored in bunded trap or sump to enable any spilled fuel or fuel soaked water to be removed. area of sufficient capacity. Fuel trap or sump provided.

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

 Areas for storage of fuel and other flammable materials must comply with standard fire Contractor ECO Complies with fire safety safety regulations. regulations.  Fire fighting equipment must be available and in working order at the fuel stores. Contractor ECO Fire fighting equipment available and working.  No smoking to be allowed near the fuel storage area. Contractor ECO No smoking evident

 Notices depicting “No Smoking”, “No Naked Lights” and “Danger” to be erected at the Contractor ECO Signs placed at fuel fuel storage site. storage site.  The fuel storage area shall be kept locked at all times. Contractor ECO Fuel storage locked.

 Only empty and externally clean tanks to be stored on bare ground. Dirty tanks must be Contractor ECO No empty dirty tanks on stored on protected ground. unprotected ground  Proper dispensing equipment must be used to dispense fuel from 200 litre drums and Contractor ECO Dispensing equipment these shall not be tipped to dispense fuel. Dispensing area to have concrete floor and available and used for collector sump. Dispensing equipment shall be stored in a water proof container when dispensing fuel from not in use drums.  Any electrical or petrol driven pump shall be equipped and positioned so as not to cause Contractor ECO Electricity and fuel pump any danger of ignition of the product. safely positioned.

 Fuel storage tanks should not have a capacity exceeding 9000 litres. Contractor ECO Fuel tanks <9000 litres

 Tanks shall be erected at least 3.5m from buildings or any other combustible or Contractor ECO Tanks further than 3.5m flammable materials. from buildings or flammable materials. 24 Pollution controls from Toilet facilities for  Adequate ablution facilities must be provided for staff. Contractor ECO Adequate toilets ablution facilities temporary workers  Excretion or urination will be prohibited other than at provided facilities. provided with toilet  Facilities for washing hands to be provided as part of or immediately next to all toilet paper facilities.

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

 Toilet facilities to be situated at least 50m away from water courses, springs or water Toilets not within 50m of points. water course or spring.  Discharge of waste from toilets and burial of waste is strictly prohibited.  Ensure no spillage occurs when toilets cleaned or emptied. Toilets kept clean and  Portable toilets shall be properly secured to prevent toppling in wind. no sign of sewage spills  At least 1 toilet per 20 workers to be provided. Toilets to be maintained in hygienic state and serviced and emptied regularly. Toilet  Toilet entrances paper to be provided. shielded from public  All entrances to toilets to be screened from public view. view 25 Prevention of littering and Solid waste  The contractor shall set up a solid waste control and removal system in accordance with Contractor ECO Bins emptied daily and soil/water pollution from management the Method Statement. not overflowing waste  Bins shall be emptied on a daily basis and shall not be left in an overflowing state.  Waste and litter shall be disposed of in scavenger and weatherproof bins stored in a Waste bins scavenger fenced and covered area and weather proof  Waste shall be collected and removed from the site at least once a week  Hazardous waste to be separated from general waste stream. Waste collected and  Waste disposed of in suitable landfill site to be confirmed and approved by the regulatory authority. removed at least once a  Workers must clean up the Contractors camp and work areas once a week. week  If recycling facilities available, the Contractor is encouraged to separate waste into glass, paper and tins and dispose of these at recycling depots. Waste disposed in  Refuse screens and oil traps shall be installed at runoff concentration points from wash suitable landfill site bays, stormwater outlets, workshop areas and eating areas.  No waste, including plastic waste, is to be burned on site No hazardous waste disposed of with general waste Screens and oil traps installed at runoff points.

26 Soil and water pollution Contaminated  Prevent discharge of any pollutants such as concrete, cement, lime, chemicals and fuels Contractor ECO No evidence of concrete water into any water sources or courses. or chemical spills to  Contractor to design, construct, maintain and operate temporary pollution control

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

facilities to prevent discharge of polluting water or suspended material into rivers, water courses streams or drainage system (e.g. settlement ponds).  All waste water generated during construction must be contained in a suitable area such as sedimentation pond prior to disposal. Solid material from such ponds should be periodically collected and disposed of in an appropriate manner. Grey water disposal to  No construction fluids to be allowed to enter the waste water system and no waste water conservancy tank to be disposed of to soil.  Monthly water testing to be conducted at discharge points to test compliance with effluent standards, especially suspended solids, faecal coli and oil and grease. Runoff from workshop &  Site sanitation to be provided by the Contractor and to comply with effluent guidelines concrete batch areas and to the satisfaction of the Engineer and ECO. contained  Washing areas shall be placed and constructed in such a manner to ensure surrounding areas are not polluted. Wash areas suitably  A Method Statement is required for all wash areas where hydrocarbons and hazardous located and constructed materials and pollutants expected to be used, including vehicle wash and workshop areas; paint wash and cleaning areas, and runoff from construction of new bitumen roads.

27 Soil and water pollution Pumps and Sumps  Pumps shall be placed over a drip tray in order to prevent fuel spills and leaks from No pollution of soil and contaminating the soil or water in the pumped area. water observed.  Contaminated water may not be discharged into existing water courses  Silt laden water shall be cleaned using a perforated 200 litre drum containing sand and Silty water cleaned in stone separated by geotextile fabric with a central delivery water pipe or equivalent effective manner method.  Silt-laden water shall be cleaned by ensuring that the overland flow of water disperses

through vegetation in a controlled and dispersed manner to avoid erosion or shall be cleaned through the use of silt traps including filtration through a geotextile fabric. 28 Soil and water pollution Settlement ponds  The Contractor shall size settlement ponds in accordance with the scale of operations Settlement ponds sized and the volume of water or effluent that may need to be stored, while making provision to contain required for inputs from rainfall. effluent discharges  Settlement ponds shall be sited to prevent natural groundwater or stormwater flowing into the ponds. Frequent removal of  Suspended solids and contaminants including oils shall be removed and disposed of by contamination recorded the Contractor at frequent intervals at a site approved by the Engineer. in maintenance

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

 Water in the ponds shall be treated and discharged within 24 hours of the water level schedule and no reaching discharge levels, and shall be emptied by discharge from outlet pipes. excessive waste build up observed Settlement pond level maintained below discharge level 29 Minimise dust and Cement and  Concrete mixing may not be done directly on the ground and shall be located in an area Contractor ECO Concrete mixing done soil/water contamination concrete batching of low environmental sensitivity, in particular away from areas with a shallow water as shown on site layout table. plan in area of low  Concrete batching areas will be shown on the Site Layout Plan and approved by the sensitivity. Engineer.  All waste water from concrete batching shall be disposed of via the waste water Runoff from batching management system designed by the Contractor and wash areas  Runoff from concrete batching areas shall be controlled and cement containing water collected and disposed shall be collected, stored and disposed of at a site approved by the Engineer. Dagga of appropriately. boards, mixing trays and impermeable sumps shall be used at all mixing and supply points. Contaminated water  Contaminated water storage facilities shall not be allowed to overflow and will require storage protected from appropriate protection from rain and flooding. rain and not overflowing.  Unused cement bags should be stored safely in dry area.  Used cement bags should be stored in weatherproof containers to prevent wind blow Cement stored in cement dust and water contamination, and should be disposed of on a regular basis weather-proof areas with solid waste.  Cleaning of equipment and mixers shall not result in pollution of surrounding area. Care Contaminated water must be taken to collect contaminated water and dispose of it in manner approved by from rinsing of cement the Engineer. trucks collected and  Ready mix trucks shall rinse off the delivery chute into a suitable sump prior to leaving disposed of the site. appropriately.  Suitable screening and containment shall be in place to prevent wind blown contamination from bulk cement silos, loading and batching. All waste cement  In relation to exposed aggregate finishes, the Contractor shall collect all contaminated collected and stored for water and fines and store it in sumps for disposal at an approved waste site. correct disposal at  All physical remains of excess concrete shall be collected and removed on completion waste site.

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

of plaster or concrete pour section and disposed of at an appropriate landfill site. No excess cement waste visible after completion of concrete works 30 Soil and water pollution Pipeline cleaning  Cleaning and flushing of pipelines shall not contaminate downstream baseline water Contractor ECO Water from flushing of quality. Water quality of receiving waters shall be monitored by the contractor. pipelines complies with  Materials used in the sterilisation of pipelines, e.g. chlorine solutions, shall be treated standards if released to as hazardous substances and stored in a separate lined area in sealed drums for natural environment regular removal and disposal by licensed haulers at a licensed facility within South Africa. Chemical effluent  Excavation of pipeline trenches across areas with surface or subsurface water flow exceeding standards shall make provision for temporary diversion of flow such that water will not be collected and disposed contaminated or cause erosion e.g. through the use of geotextile curtains. of correctly. Temporary flow diversion provided where pipeline cross surface flows. 31 Soil and water pollution Hydrocarbon spills  The site shall have a supply of absorbent material readily available to absorb any Contractor ECO Suitable absorbent emergency hydrocarbon spills to a volume of at least 200 litres. material readily  Other absorbent or encapsulating products for containing hydrocarbon spills that should available for spills. be considered include Spill-Sorb (oil and chemical absorbent & encapsulating product); Drizzat Pads; Enretech Powder (absorbent and encapsulation); and Peat Moss. Spills attended to  Remediation of spill areas shall be done immediately, the area cordoned off, and the immediately. Spills source of spillage isolated. Spillages can be contained using sand berms, sand bags or isolated and contained. sawdust.  Examples of products used for treatment and remediation include Chemcap (aqueous Spillages fully silicate, releases and encapsulates); BioSystems B110 series; and Enretech products. documented in Incident  Any spillages should be documented in the Incident Register, including information on Register cause, amount spilled, remedial actions taken and responsible persons. B3. SOCIAL ISSUES

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

32 Human safety Fencing and site  Access to the site should be off-limits to the public at all times. Contractor ECO Site suitably fenced. access  A diamond mesh or bonnix fence with minimum height of 1.8m shall be erected around the site. Public access restricted.  Fencing shall be maintained throughout construction.  Temporary fencing shall be removed and loose wire removed from the site. 33 Aesthetic impacts & dust Aesthetics (and  The contractor shall visually screen the site in an aesthetically pleasing manner prior to Contractor ECO Site screened to dust control) commencing construction activities. The use of indigenous trees as a green belt should minimise visual impact be considered. during construction  Since the site will be used in the long-term consideration should be given to constructing berms and planting trees around the perimeter of the site at an early stage to maximise Landscaping opportunities for establishment. implemented for long  Temporary or shorter term measures can include use of shade cloth or hessian. term screening 4 Dust Nuisance Dust control  The Contractor shall take all reasonable measures to minimise the generation of dust Contractor ECO Dust minimisation from construction activities. implemented  Removal of vegetation shall be limited in extent as far as possible and to times when soil stripping is required. Exposed areas should be stabilised and revegetated with Bare areas covered or indigenous grasses endemic to the area as soon as they are no longer required for revegetated soon after construction activities.  Excavation, handling and transport of erodible materials shall be avoided windy vegetation removal conditions or when a visible dust plume is present. In high winds where dampening methods are insufficient, consideration should be given to the need to cease soil Excavation avoided in stripping activities until winds drop. high wind conditions,  Dust suppression methods shall be used when dust generation is unavoidable including dampening with water, particularly during dry periods; or other stabilising methods such Dust suppression as use of chemical soil binders, straw, brush packs, chipping etc. measures implemented.  Straw stabilisation shall be applied at a rate of one bale/10m2, harrowed into the top 100mm of material for all completed earthworks. Stockpiles covered with  Stockpiles should be located in sheltered areas where possible and covered with dust material suppressing material. 35 Human nuisance Lights  For authorised night work, low flux and frequency lighting shall be used. Contractor ECO Night work using low flux & frequency lights

36 Human nuisance Noise  Noise levels exceeding 85dB shall only be permitted where approved by the Engineer or Contractor ECO Noise levels in nearby

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

during an emergency situation. villages comply with SANS 10103 and Lesotho Government Gazette Extraordinary Legal Notice No. 137 of 1996. 37 Human safety Fire control  No fires will be allowed on site. Contractor ECO No fires caused by the  Basic fire-fighting equipment must be available at all fire risk areas including living deliberate lighting of quarters, site offices, kitchen areas, workshops, store areas, and must be maintained in fires. good working condition.  Smoke free areas should be declared and appropriate signage erected. Fire fighting equipment  Staff must be provided with sufficient fuel for cooking and heating to avoid the need to readily available. light fires. Demarcated smoke free areas.

B4. GENERAL ENVIRONMENTAL PROTECTION AND SAFETY MEASURES 38 Minimise accident risks Transport of  Ensure transport companies are properly equipped and registered to transport Contractor ECO Transporters equipped during chemical and chemicals, diesel chemicals and diesel. and registered. diesel transport and other materials  Ensure loads are properly secured, and that sand, soil, stone, refuse, cement etc are covered during transit to prevent spilling or windblown material along roadsides. Loads properly secured and covered Incident Register indicates no transportation incidents 39 General environmental Construction camp  Construction camp to be kept neat and clean at all times. Contractor ECO Camp clean and neat  Refuse and waste storage to be positioned away from buildings. protection maintenance Refuse stored away  Drip trays to be inspected and emptied daily and closely monitored during rain events. from buildings Drip trays emptied daily & monitored

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

40 General environmental Access roads  Access to the site and works area shall use existing roads or tracks wherever possible. Contractor Engineer & ECO No new access tracks protection and control of  Induction and training shall include the use of permitted roads and highlight prohibition created unless nuisances of making new tracks. necessary and existing  All temporary access roads shall be rehabilitated to the satisfaction of the Engineer ones kept as narrow as  Erect and maintain marker pegs or painted stones along the boundaries of work areas, access roads or tracks to prevent unauthorised movement outside designated areas. possible  Mud and sand deposited onto public roads shall be cleared regularly Access tracks marked to  Upgrading of access roads should limit activities as far as possible within the existing control vehicle confines of the road. movement  Users of haul roads within the site shall not exceed 15km per hour  Implement dust control measures where windblown dust can create a nuisance. Mud and sand cleared  The Contractor shall repair any damage caused to the existing access road as a result from roads regularly of construction activities. Speeds limits  Install and maintain appropriate traffic warning signs. maintained  Trained and equipped flagmen shall be used in the event that construction activities (e.g. delivery of large unnatural loads) may create a traffic hazard on public roads. Existing access roads  Asphalt / Bitumen Paving: Bitumen used for access roads shall be stored on maintained in good impermeable bunded area sloped towards a sump. Heating of bitumen shall be condition undertake using LPG or similar zero emission fuels. Excess or waste bitumen shall be removed to an approved landfill site. Care must be taken to prevent overspray of Traffic warning signs bitumen outside of the road surface and onto roadside vegetation. and flagmen used where necessary Bitumen stored on impermeable bunded area with sump. Bitumen sprayed within road area only and not on adjacent vegetation.

41 General environmental Crane operations  Drive plants shall be well maintained and drip trays position at potential leak areas. Contractor Engineer & ECO Equipment maintained protection and human  Over-greasing of crane cables shall be avoided. and drip trays positioned  Lighting used during crane operations shall not cause a nuisance to surrounding to contain leaks

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

safety communities. No incidents of oil  Movement and lifting of hazardous materials shall be undertaken such that they do pollution from crane not cause pollution, spillage or safety risk e.g. concrete buckets. operations. 42 General environmental Drilling and jack-  The Contractor shall take all reasonable measures to limit dust generation from drilling Contractor Engineer & ECO Drilling done to limit dust protection and human hammering operations. generation and pollution, safety  Noise and dust nuisances must comply with applicable standards. and damaged areas  The Contractor shall ensure that no pollution results from drilling operations from oil, rehabilitated. fuel, or drilling fluid.  Any areas or structures damaged by drilling and associated activities shall be Loose rock from drilling rehabilitated by the Contractor to the satisfaction of the engineer.  Loose rock generated from drilling must be removed to a suitable area marked on the not found as scree on layout plan, and not tipped down slope or into the river course. slopes above river

43 General environmental Earthworks  All earthworks shall be undertaken in such a manner so as to minimise the extent of Contractor Engineer & ECO Earthworks minimise protection any impacts caused by such activities and shall be limited to demarcated areas. environmental damage  No earthworks equipment shall be allowed outside demarcated areas unless permitted by the Engineer. 44 General environmental Retaining walls and  Rocks for use in gabion baskets or reno mattresses shall be obtained from a source Contractor ECO No rocks for gabions protection gabions approved by the Engineer & ECO and not from a watercourse. sourced from a water course. 45 General environmental Stream diversion  The Contractor shall not divert, dam or modify any water course or stream without the Contractor ECO Stream diversion done protection approval of the Engineer and ECO where necessary and to  Any temporary diversions required (e.g. for trenching and pipeline installation) shall be the satisfaction and reinstated to its natural condition where possible to the satisfaction of the Engineer signed approval of the and ECO. Engineer & ECO 46 General environmental Trenching  Trenching for services shall be kept to a minimum through the use of single trenches Contractor ECO Trenching minimised protection for multiple service provision. and done in accordance  The planning and selection of trench routes shall be undertaken in liaison with the with requirements. Engineer and cognisance shall be given to minimising the potential for soil erosion.

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

 Trench routes with permitted working areas shall be clearly defined and marked with No evidence of dumped painted stakes prior to excavation. stockpiles of trench  The stripping and separation of topsoil shall occur as stipulated by the Engineer. Soil material shall be excavated and used for refilling trenches using the roll over method, i.e. soil from the first trench section shall be stockpiled. Thereafter soil excavated from No evidence of erosion subsequent trench lengths shall be used to backfill the trench behind it once the services or pipe have been laid. Trench lengths to be kept as short as practically around or downslope of possible before backfilling and compacting. the trench  Trenches shall be re-filled to the same level as the surrounding land surface to minimise erosion (or slightly higher to allow for settlement). Excess soil shall be stockpiled in an appropriate manner to prevent dust nuisances or sedimentation of Successful revegetation nearby areas. of the refilled trench  Immediately after refilling, trenches and associated disturbed working areas shall be planted with a suitable plant species and regularly watered. Geojute or similar material should be used in addition to planting in particularly erodible areas. C. END OF CONSTRUCTION PHASE / SITE CLOSURE 47 General environmental Temporary site During temporary site closure ensure: Contractor Engineer & ECO Temporary site closure protection closure complies with the Fuels, flammables and hazardous chemicals: specified provisions.  Fuel is stored in low volumes and no stores within 1:50 year floodline  No leak, outlet secure / locked and adequate ventilation present  Bund is empty  Fire extinguishers serviced and accessible  Area secured from accidental damage, e.g. vehicle collision  Emergency contact numbers are displayed.  Safety office checks the stores prior to closure of the site. Safety  All trenches and manholes secured and fencing and barriers in place  Notice boards applicable and secured  Emergency and management contact details displayed  Security persons briefed and have facility for contact.  Night hazards checked e.g. reflectors, lighting and traffic signage  Fire hazards identified and precautions taken to limit risks e.g. wood stockpiles, fuels

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# Reference impact Construction Management / mitigation measures Responsibility Responsibility Auditable goal / activity for implement for monitoring target

 Scaffold and pipe stockpile wedged / secured  Inspection schedule and log by security or contracts staff Erosion  Wind and dust mitigation in place e.g. straw / covering material or irrigation  Slopes and stockpiles at stable angle  Re-vegetated areas watering schedule in place  Detention ponds or channels in place and with sufficient capacity for storm events.

Water contamination and pollution  Fuel hazards and flood precautions taken  Banks stabilised for expected normal flow  Structures in water courses secured  Cement and material stores secured  Refuse bins and Toilets emptied and secured  Bunds clean and treated  Drip trays empty and secure  All structures secured against wind damage 48 General Environmental Permanent All equipment, storage containers, temporary fencing, temporary services, fixtures and solid Contractor Engineer & ECO Construction site clear Protection Construction site waste shall be removed from site at the end of construction of all construction waste, Specific measures include: closure materials and equipment  Clear and completely remove from site all equipment, storage containers, temporary fencing, temporary services, fixtures and any other temporary works. at the start of Assisted  Ensure that all access roads utilised during construction (which are not earmarked for Operation. closure and rehabilitation) are returned to a usable state and/or a state no worse than prior to construction.  Clear the site of all inert waste and rubble, including surplus rock, foundations  and batching plant aggregates.  Remove from site all domestic waste and dispose of in the approved manner at a registered waste disposal site.

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11.0 SUMMARY AND RECOMMENDATIONS

The MDWSP, comprising the Metolong Dam, the WTW and conveyance systems, is designed to augment water supplies to the lowland towns of Lesotho by an amount of 75 Mℓ/day over and above the existing 45 Mℓ/day supplied by the Maseru water supply system. Various studies have been undertaken since 2002 that confirmed Metolong as the preferred location for the dam and the WTW. The project is rated as high priority by the Government of Lesotho (GoL). The WTW and conveyance system will be constructed with funding from the MCC administered through the MCA-L. The MCA-L appointed the LWJV consortium to undertake a conceptual design of the WTW and prepare tender documents for a Design-Build contract, as well as compile an ESIA and EMP. The ESIA and this EMP has been prepared by an independent team of sub-consultants to the LWJV. This EMP has been compiled based on a conceptual design and layout of the WTW within a defined footprint, and a set of technical design specifications that will be given to a Design-Build Contractor to undertake detailed design and construction. The details of the WTW are contained within the IFB (2009) documents (Volumes 1 to IX). Based on the management measures proposed in this EMP, the detailed design phase will involve in-depth technical planning of the infrastructure components, treatment process and layout, including aspects such as determination of specific quantities of chemicals required, verify proposed chemical storage and handling arrangements, staffing roles and responsibilities, preparation of a health and safety plan and update and further develop the ERP included as Appendix C. This EMP provides a comprehensive overview of the mitigation and monitoring requirements for construction and operation of the proposed WTW. Adherence to these mitigation measures and management requirements will minimise the impacts of the WTW to the extent that no significant residual impact of construction or operation is likely to occur.

Key tasks for implementation of the EMP during the planning and construction phases include (but are not limited to):  Layout planning and compilation of detailed layout plans to ensure environmental impacts are minimised (e.g. toilets more than 50m from water courses or springs; siting of “no go” or sensitive areas such as ruins of 19th Century village, location of bunded areas, chemical stores, effluent ponds and discharge monitoring points).  A stormwater layout plan designed to ensure adequate diversion and dissipation of stormwater to prevent erosion and sedimentation.  Encouragement of preferential labour recruitment from the local communities to minimise social impacts associated with influx of a large labour force such as increased HIV/AIDS, increased crime, social disruption, alcoholism etc.  Regular dialogue between the Contractor’s Community Relations Officer (CRO) and the Metolong Authority’s Community Relations Manager (CRM) and Community Liaison Assistants (CLAs) to keep the community abreast of work schedules and activities, and to hear and address concerns.  Awareness raising and training of the workforce to ensure they are familiar with all on-site rules and requirements relating to aspects such as solid and chemical waste disposal; use of toilets; prohibition on using the veld as a toilet; for littering; trampling and harvesting of fauna and flora, or the lighting of fires. Other aspects covered include workforce awareness of communication channels and key points of contact for specific workforce issues.  Implementation of the Contractor Standards for construction that are designed to mitigate erosion and sedimentation risks, pollution risks, and to manage social impacts (e.g. visual, dust/noise, blasting,

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traffic accidents etc) and other biophysical impacts (e.g. loss of flora and fauna, general habitat disturbance).  Rehabilitation of disturbed areas within and around the WTW, and appropriate landscaping of the site, will minimise the visual impacts of the construction activities and the development as a whole, while minimising the risk of erosion.  Auditing, monitoring, site inspections and reporting will be implemented in accordance to the EMP by the Environmental Compliance Officer (ECO), the site Engineer and the regulatory organisations such as NES, WASA, DWA etc. Key tasks for implementation of the EMP during the operational phase include:  Encouragement of preferential labour recruitment from the local communities to be trained and used in the WTW.  Ongoing dialogue between the CRO and the Metolong Authority’s Community Relations Manager (CRM) and CLAs to keep the community abreast of the operational issues associated with the WTW and to hear and address concerns.  Awareness raising and training of the WTW workforce to ensure they are familiar with all on-site rules and requirements relating to aspects such as solid and chemical waste disposal. Other aspects covered include workforce awareness of communication channels and key points of contact for specific workforce issues.  Testing of sludge produced to confirm that the preferred long-term sludge disposal solution, which is land application for soil augmentation, is environmentally acceptable. The results will be checked against guideline values specified.  Monitoring of supernatant (liquid draining from the sludge) to determine whether it complies with effluent standards for disposal back to the river. If non-compliant then the supernatant will require treatment and/or dilution to meet the standards for release back to the river below the dam wall.  The operator with their staff must further refine (making sure of accountability and responsibility) and implement the ERP (Appendix C), which addresses aspects such as hazardous material accidents, e.g. chlorine gas emission; compilation of an emergency contacts list; protocols for remedial action; and training of key staff to deal with incidents and accidents Auditing, monitoring, site inspections and reporting will be implemented in accordance to the EMP by the Environmental Compliance Officer (ECO), the site Engineer and the regulatory organisations such as NES, WASA, DWA etc. Various programmes being are in the process of being developed by the MA with which the DB Contractor will be required to comply. These include a Health and Safety Plan, HIV/AIDS education and awareness, community outreach and RCAP. A key issue of the WTW arising from operation of the WTW is the disposal of sludge and supernatant liquid. The WTW site has capacity of 5 years of sludge storage. The EMP has presented various options for sludge disposal (APPENDIX E), with land disposal being recommended as the preferred option. Supernatant will be returned to the river in compliance with Lesotho’s discharge standards (Otieno 1997), which may require some form of pre-treatment.

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12.0 REFERENCES CEC (Jordan), Mott Macdonald and Groundwater Consulting. 2003. Metolong Dam Feasibility Study. Final Report. Dec 2003. DWAF. 1996. Department of Water Affairs and Forestry (1996) South African Water Quality Guidelines: Volume 1: Domestic Water Use Second Edition, 1996. Gill, S. 2009. Metolong WTW ESIA/EMP: Cultural and Heritage Resources – Actions Already Taken and Recommendations. March 2009. Herselman, J.E, 2008. Guidelines for further utilisation and disposal of water treatment residues. WRC Proj No. K5/1723. Hughes (2005) Effects of Land Application of Water Treatment Residues, WRC Report No. 1105/1/0 Invitation for Bids(IFB# WS-A-016-09) Design-Build of Metolong water treatment works bidding documents (volume i to ix) December 2009. IFC 2002. Environmental, Health and Safety Guidelines. International Finance Corporation. www.ifc.org IFC 2009. Guidance for Projects and Companies on designing grievance mechanisms. Good Practice Note: Addressing Grievances from Project-Affected Communities.

LWJV/Jeffares & Green. 2009. Geotechnical Investigation for the Metolong WTW. March 2009.

LWJV 2009. Metolong Dam Treatment Works: Basis of Design Report. Contract No. WS-A-004-08 for the Metolong Authority. Mahlelebe, T. 2008. Metolong Dam Environmental and Social Impact Assessment. The Ecology of the Metolong Storage Area, Transmission Lines and Proposed Quarry Sites. Feb 2008. Mateka, B. 2009. Resettlement and Compensation Action Plan. Report for Metolong Authority. March 2009.

Metolong Authority. 2009. Metolong Dam Environmental and Social Work Plan. Draft Report. May 2009. Mott Macdonald Ltd. 2007. Metolong Dam Additional Feasibility Study. Interim Report. Feb 2007. SANS 241 (2006) Edition 6.1: Drinking Water.

SMEC 2008. Metolong Dam Environmental and Social Impact Assessment. Final Report. Volume 1. SMEC in association with FM Associates and Southern Waters. Feb 2008. Southern Waters Ecological Research and Consulting. 2008. Metolong Dam Environmental and Social Impact Assessment – Instream Flow Assessment. Feb 2008. Walmsley,B & Tshipala K.E., 2007. Handbook on Environmental Assessment Legislation in the SADC Region. Published by the DBSA in collaboration with SAIEA. Midrand, 420pp. WASA (2007) Emergency Preparedness Plan.

World Health Organization (2006) Guidelines for drinking-water quality [electronic resource]: incorporating first addendum. Vol. 1, Recommendations. – 3rd ed.

World Bank, 2009. First Report of the Social and Environmental Panel of Experts. Compiled by Lawrence Haas and Kotelo-'Molaoa. 31 March 2009.

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APPENDIX A TOR for Conducting ESIA and EMP for the Metolong WTW

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TOR FOR CONDUCTING ESIA AND EMP FOR THE METOLONG WTW Objective To prepare a comprehensive environmental and social impact assessment, supplemental to the Metolong Dam Environmental and Social Impact Assessment (SMEC, 2008a) for the areas affected by the WTW Description The WTW, whose surface area is estimated at 14 ha (SMEC, 2008a), will be located on the north side of the valley, approximately 600 m from the dam as described in the Metolong Dam Additional Feasibility Study Update (Mott MacDonald, 2007). The study area will also cover the trace of the pipeline from the dam to the WTW and proposed quarry areas as described in Mott MacDonald (2007). In the case of quarries and other sources of construction material, the consultant should try as much as possible to synergize them with other Metolong Dam construction activities. The consultant will carry out the following tasks: Task 1: Inception Report Including a Detailed Work Plan. The consultant will examine the Metolong Dam Environmental and Social Impact Assessment (SMEC, 2008a), the Metolong Dam ESIA Resettlement Report (SMEC, 2008b), the Metolong Dam Additional Feasibility Study Update (Mott MacDonald, 2007), the NES Record of Review and Record of Decision on the SMEC reports and any other relevant documents to identify data gaps in relation to the WTW. On the basis of this review, the consultant will prepare an inception report highlighting the methodology to be used for additional data collection, impact analysis and a detailed work-plan. The consultant, MCA-Lesotho and the CoW will develop and agree upon performance targets for the assignment as part of the inception report. The detailed work plan will also include the consultant's proposal for the Public Participation Process. The consultant will identify and consult with the various public groups living in the vicinity of any of the proposed structures. Other interested groups to be consulted include but are not limited to; Non-Governmental Organizations (NGOs), Government Departments, representatives of the general public and other groups or agencies that may have a stake in the project. Such consultations are to be undertaken in local language, be coordinated through the GoL, specifically the Project Implementation Unit and office of CoW in collaboration with local village chiefs. The process should explore various media currently used to engage stakeholders. The inception report will clearly indicate additional work, if any that is required to ensure that all landholders and/or affected persons have been identified and are included in the ongoing property survey efforts under the Environmental Management Programme. Task 2: Environmental and Social Impact Assessment and Reports. The consultant will prepare an ESIA in accordance with Section 29.5 of the Lesotho Environment Act, 2001 (Note: this has now been replaced by the Lesotho Environmental Act 10 of 2008). The ESIA report (EIS under Lesotho legislation) shall as a minimum include the following:  A detailed description of the proposed project and its activities.  A description of the potentially affected environment including specific information necessary for identifying and assessing the environmental impacts of the proposed project or activity.  A description of the technology, method and processes that shall be used in the implementation of the project or activities and the main alternatives and reasons for declining to use those alternatives.  Reasons for selecting the proposed site and rejecting alternative sites.  Environmental impact of the proposed activity or project including the direct, indirect, cumulative, short term or long term effects on the environment of the project.

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 An identification and description of measures proposed for eliminating, minimizing or mitigating the anticipated adverse impacts of the project or activity on the environment.  Give a brief description of how the information provided in the report has been acquired or generated.  An identification of gaps in knowledge and uncertainties which were encountered in completing the required information.  The social, economic and cultural impacts of the project.  Irreversible and irretrievable commitment of resources required for the project.  Any other matters that the Authority, NES may prescribe. Annexes to the ESIA report may include, but not be limited to:  Specialist report on flora and fauna.  Specialist report on cultural and archaeological heritage.  Specialist report on socioeconomic conditions in the study area.  A report on health and sanitation conditions,  Minutes of the public consultation meetings.  A bibliography. Task 2.1 Additional Environmental and Social Baseline Data The consultant will collect supplementary data in order to fill data gaps identified in the inception report, and additional data that may be required by NES. Currently it is anticipated that additional data will be required for the following:  Physical environment: geology, topography, soils particularly their susceptibility to erosion.  Biological environment: flora; fauna; medicinal value, occurrence of alien invasive species, rare and endangered species, etc. The study area was partially investigated during the SMEC study, as illustrated by the vegetation map shown in Figure 22 of SMEC, 2008a. It will be necessary to extend this vegetation map to cover the full study area. Particular attention should be paid to the identification and inventory of medicinal plants and plants of socio-economic importance with a view to their salvage for transplanting prior to construction.  Socio-cultural environment: Cultural and historical heritage sites present in the proposed site for project development; current land uses in the study area; individuals who are likely to be negatively affected by the project either through inconvenience or loss of property.  The Cultural Heritage Impact Assessment carried out as part of the Metolong Dam ESIA (SMEC, 2008a) included an Archaeological Reconnaissance Survey, which was limited to the Metolong dam footprint. It may therefore be necessary to conduct a specialist cultural heritage assessment as part of the WTW ESIA. The project includes a more detailed, long-term cultural heritage program (the first phase of this study is scheduled for completion by end-December 2008), and so the consultant will coordinate efforts with the GoL to avoid unnecessary repetition of studies1.

1 The Environmental Management Programme includes a Cultural Resources Management and Development Plan which includes further studies to determine whether there are additional sites within the project footprint, thus field study may not be required. During preparation of the inception report the consultant will determine whether additional studies are required to include the WTW footprint.

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 The Metolong Dam ESIA Resettlement Plan (SMEC, 2008b) identified 22 households which would potentially be affected by the WTW. This included an indicative recording of assets. The proposed site for the WTW, which has been surveyed, lies to the north of the area covered by the SMEC study. It will therefore be necessary for the consultant to verify that all affected persons have been identified and taken account of in ongoing resettlement activities. The consultant will need to coordinate in detail with MCA-Lesotho and the GoL in this activity. Task 2.2 Determination of Biophysical, Health, Environmental and Social Impacts The identification of the project impacts should be informed by among others: baseline data collected; the consultative process and consultant’s experience of similar projects. In order to effectively carry out the task, the Consultant should develop a system that will facilitate identification and registration of all aspects and associated impacts. In addition, the consultant should establish an impact scoring process that should be based on among others: the level of significance and magnitude of impacts; probability of occurrence; the extent to which the impacts could be reversed; residual impact after mitigation; cumulative impacts; adverse and beneficial impacts, etc. Key issues to be addressed by the consultant include:  Construction Impacts  The consultant will describe the baseline situation and assess all impacts related to the construction phase, with particular attention to:  Noise, dust and other aspects of air quality related to construction activities.  Use of explosives (if required).  Introduction of any migrant construction workers, construction camps, laydown areas, and hauling of materials and equipment.  HIV/AIDS, other health and safety-related measures for workers and those living close to construction areas.  Sources of construction materials.  Employment generation by construction activities, including preferential employment for affected persons.  Direct and Indirect Operational Impacts  The consultant will describe the baseline situation and address key ESIA issues and impacts over the long term. At a minimum these should include issues in the list below. In no way should this list be interpreted as categorizing or grouping impacts.  Terrestrial Ecology and Biodiversity  Assessment of the effects on biodiversity.

 Assessment to document any effects on rare, endangered or threatened species or their habitats.

 Identification, inventory, salvage and transplant of medicinal species and/or species of socio- economic importance.  Surface Water, Aquatic Ecology and Biodiversity (concentrating specifically on potential impacts of the WTW operations)

 Assessment of impacts on habitats, and rare and endangered species.

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 Assessment of any impacts related to aquatic ecology.

 Assessment of any changes in water quality or flows in streams.  Soils, Geology and Groundwater  Documentation of issues related to soils.

 Impacts of changes in drainage.

 Impacts on groundwater resources, if any.  Air Quality  Documentation of air quality impacts related to increased dust generation and vehicular traffic.  Noise  Documentation of noise impacts on neighbouring populations  Hazardous materials management.  Management, transport and storage of hazardous chemicals  Sludge  Sludge management and disposal. In the event where Rapid Sand Filters (RSF) is a viable option, the impact of backwash water should be determined.  Cultural Resources  Protection, conservation and management of sacred sites.

 Investigations of archaeological and historic sites, assessment of their importance and protection, conservation and management.  Socio-economics  Impacts related to additional employment (numbers and likely beneficiaries).

 Impacts related to land acquisition/resettlement (derived from ongoing resettlement related activities).

 Impacts on social or economic conditions of neighbouring villages.  Gender  Differential impacts of the project on men and women, including labour and trade. Induced and Cumulative Impacts The consultant will identify significant induced and cumulative impacts within the immediate vicinity of the project and in areas extending beyond it. Key areas and sectors related to cumulative impacts will be specifically identified in the ESIA, mitigation measures already incorporated into design explained and others recommended, as needed. Evaluation of Alternatives Such an analysis is required under both the Lesotho Environmental Impact Assessment Guidelines and the MCC Environmental Guidelines, which describes the evaluation of alternatives as examining "alternatives to the project, including ways of improving project selection, siting, planning, design, and implementation in order to prevent, minimize, mitigate, or compensate for adverse environmental and social impacts and

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enhance positive impacts. The ESIA systematically compares feasible alternatives to the proposed project site, technology, design and operation - including the "without project" situation - in terms of their potential environmental and social impacts; the feasibility of mitigating these impacts; their capital and recurrent costs; their suitability under local conditions; and their institutional, training and monitoring requirements. For each of the alternatives, it quantifies the environmental and social impacts to the extent possible and attaches economic values where feasible. It states the basis for selecting the particular project design proposed and justifies recommended emission levels and approaches to pollution prevention and abatement." The consultant will consolidate information about the project from previous work and other sources as needed to present the range of alternatives, the selection of the particular site and the nature of the design in order to demonstrate that impacts have been considered and avoided, diminished or compensated for in the process. Standards and Norms Where qualitative or quantitative standards or norms for emissions, effluents or other impacts are not yet developed in Lesotho legislation or are not at a level considered acceptable in international practice, the standards of the WHO or the most recent Environmental, Health and Safety Guidelines of the International Finance Corporation (private sector investment arm of the World Bank Group) will be used. Where these sources do not provide norms or standards, the consultant will recommend standards from other sources in consultation with NES. Task 3. Environmental Management Plan (EMP) The consultant will prepare an EMP covering both construction and operations and describing a set of feasible and cost-effective mitigation, monitoring and institutional measures to avoid adverse environmental and social impacts, reduce them to acceptable levels or to compensate for them. The EMP must cover all adverse environmental impacts, including those that may result from involuntary resettlement and linkages to the existing Resettlement Action Plan as appropriate. The EMP will provide the technical details for each mitigation, monitoring and institutional measure, including the impact(s) to which it relates and the conditions when it is required, together with designs, equipment descriptions and operating procedures. The EMP will specify for each mitigation measure timing, cost, locations, and institution responsible.

In addition to the general set of mitigation measures, an, HIV/AIDS awareness plan will also be incorporated. The project includes a comprehensive program of community outreach related to HIV, as a result of which the consultant will develop and HIV /AIDS awareness plan for the construction contractor2. The EMP will specify the monitoring objectives and the types of monitoring needed (plus the regularity of such monitoring) to ensure that the mitigation measures have been put in place and are working as intended. It will also specify any additional environmental monitoring that is considered appropriate to ensure that unanticipated environmental impacts do not occur. Specifically, the monitoring section of the EMP will provide a specific description, and technical details, of monitoring measures, including the parameters to be measured, methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and definition of thresholds that will signal the need for corrective actions. The EMP will also specify the monitoring and reporting procedures and responsibilities to ensure early detection of issues and provide information on progress and results of mitigation. The EMP will recommend capacity building efforts to strengthen environmental management capability that will be needed to carry out the mitigation measures and their monitoring, including formation of specific units, training and institutional arrangements, e.g., who is responsible for operation, supervision, enforcement, monitoring of implementation, remedial action, financing, reporting, and training.

2 Although the Environmental Management Plan includes an HIV/AIDS awareness and prevention component, this only concerns community outreach; contractors are responsible for HIV/AIDS awareness and prevention programs for their employees. The HIV/AIDS awareness and prevention plan forming part of the EMP required under these terms of reference will be directed towards the contractors.

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For all three aspects (mitigation, monitoring, and capacity development), the EMP will provide an implementation schedule for measures that must be carried out as part of the project, showing phasing and coordination with overall project implementation plans; and the capital and recurrent cost estimates and sources of funds for implementing the EMP. As part of the EMP the consultant will prepare an Emergency Response Plan which will describe the measures required to manage emergencies both at the WTP site and during transportation of hazardous materials to the WTP. The Emergency Response Plan will include but not be limited to:  The objectives of the plan  Persons (name, position) authorized to set the emergency procedures in motion  Person in charge of and co-coordinating the on-site mitigation.  Safety of persons both on and off-site.  Arrangements for:  Providing early warning of the incident to local authorities.  Initiating the off-site emergency plans.  The type of information that should be contained in the initial warning.  Provision of more detailed information as it becomes available.  Training of personnel for emergency response  Arrangements for assisting with the off-site effects of the incident  Human resources required to manage the response to the incident, identify specialists who can provide information to the emergency services  Key contacts and their coordinates at the WTP and for local and national emergency response authorities.  Hazard scenarios and identify the environmental consequences and environment pathways  Resources available for the restoration and clean up of the environment following a major accident. The consultant will recommend what level of environmental and social monitoring should be done by the construction contractor, by the implementing agency, by the sponsor (MCA-Lesotho), and by NES and whether independent monitoring is needed.

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APPENDIX B B1: Adjustments to the Terms of Reference for ESIA and EMP B 2: Records of Decisions / Minutes of Meetings: a) NES meeting 26th May 2009 b) Technical meeting 15th April 2009 c) Minutes of meeting

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B1: ADJUSTMENTS TO THE TERMS OF REFERENCE FOR ESIA AND EMP The following points describe aspects of the work scope that were adjusted during the course of study and the reasons. The Inception Report (2009) that was approved also indicated these changes. These are separated into scope of assessment and procedural aspects. Scope of Assessment 1) Quarries and borrow areas – One of the original requirements of this ESIA was to assess and evaluate the impacts and management needs of quarries for aggregate and ‘borrow’ areas for sand. This requirement has since fallen away when it was decided and agreed at the Technical meeting of 15 April 2009 (APPENDIX C) that the responsibility of securing adequate aggregates for concrete from commercial sources will lie with the selected contractors. The contractors will be required to be licensed and operate in accordance to good environmental practice. 2) Electrical supply and access roads – Separate ESIAs have been done for electricity and access roads to the Ha Seeiso area (Metolong Authority 2009, Advanced Infrastructure project). Provision of electricity and access roads will only be considered in this ESIA in so far as it is required within the footprint of the WTW. 3) Raw water pipeline – There is uncertainty over the exact location of the dam wall and position of the intake, and whether the raw water pipeline will be aligned across the dam wall or traverse the adjacent slope. The ESIA and technical design of the raw water pipeline is required to start at a defined position above the dam wall and it is the responsibility of the Advance Infrastructure consultant (LWJV) to design and assess options for delivering raw water to this point. Procedural Aspects 1) Stakeholder consultation – Extensive consultation was undertaken during the ESIA of the dam, including associated infrastructure, by SMEC (2008), and other dam related ESIAs, and consultation is ongoing under the Metolong Authority (who have a project office and Community Liaison Officers operating in the dam area). This led the National Environmental Secretariat (NES) to indicate to the ESIA team that a Social Consultant and further community engagement is not required as part of the WTW ESIA (APPENDIX C).

The MCA-L have agreed that public consultation can be limited to a) including key community issues in the ESIA based on minutes and records held by the Metolong Authority, and b) a workshop with community members to inform the affected community on the findings of the assessment and key provisions of the Environmental Management Plan. Key issues of import to the WTW relate to sludge and chemical management. The records of this workshop are appended to the ESIA report. 2) Impacts on river flow – The original ToR required the Consultant to assess impacts of the WTW on river flows. A preliminary IFR was done for the SMEC ESIA for the Metolong Project (2008) based on flow release scenarios recommended in the feasibility study. The results of this IFR study were summarised in the ESIA for the WTW (LWJV 2009), which concluded that the flow release scenarios would maintain the river in its current condition. A further study is still planned which will identify IFR monitoring sites and needs. The available data in the SMEC ESIA, including preliminary IFR was deemed adequate for the needs of the WTW ESIA. Furthermore the MA will commission an consultancy where the environmental flows and operational procedures from the dam will be reviewed and revised if necessary. 3) Verification of affected persons – The original ToR required the consultant to verify all affected persons have been identified and taken account of in ongoing resettlement activities, coordinating this in detail with MCA Lesotho and GoL. However, this task is an on-going activity under the Metolong Authority, and includes adjudication and compilation of a full assets register to record all affected persons and their assets that will be affected. In relation to the WTW, the project engineers in the

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LWJV have surveyed the WTW site and mapped land parcels and ownership and these data have been used in this assessment. The data on land ownership will be checked for gender implications. EMP Aspects A number of specific requirements of the ToR for the EMP cannot be met due to the fact that detailed design and operation of the WTW, and the long-term operator of the WTW is still to be finalised. The staffing structure and roles and responsibilities of the D-B Contract, amongst other aspects, still have to be clarified. The lack of detailed information has restricted the degree to which the EMP is able to provide detailed management requirements on the following; 1. Capacity building - The ToR requires the EMP to recommend capacity building requirements to strengthen environmental management capability including formation of specific units, training and institutional arrangements e.g. who is responsible for operation, supervision, enforcement, monitoring of implementation, remedial action, financing, reporting, and training. Without detailed design and operation of the WTW, including staffing arrangements, it is difficult to specify these requirements to this level of detail. The EMP has however specified activities requiring environmental oversight by the Contractor and where the Contractor or ECO should engage with NES. It is anticipated that the strategic EMP, currently out to tender, will assess institutional capacity of relevant agencies to administer the project.

2. HIV/AIDS education and awareness programme for the contractor – the ToR required the Consultant to compile an HIV/AIDS awareness plan for the contractor. However, this task will be undertaken by a consultant to the Metolong Authority and to avoid duplication, the contractor will be referred to this plan (M Moffett pers. comm. 12 May 2009). Contractors will be required to comply with the HIV/AIDS plan in terms of their contract. 3. Social monitoring – Requirements for monitoring of socio-economic variables to assess changes to the socioeconomic status of local communities within the project area is the task of a separate contract and will not be included in the WTW EMP (M Moffett pers. comm).

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B1: MINUTES OF NES MEETING 26TH MAY 2009

METOLONG WTW EMP INCEPTION MEETING NES BOARD ROOM 26 MAY 2009

Attendance

Dr Ralph Heath (EMP team Golder Associates Africa [email protected] leader)

Me Bernice Khoachele NES [email protected]

Mr Tsikoe Busa NES [email protected]

Me Matlhokomelo Mathaba NES [email protected]

Ms Jessica Hughes Independent EIA Consultant [email protected]

Ms Melissa Moffett Metolong Program [email protected] Management Unit

Apologies: Mr. Lira Molape – MCA-Lesotho Ms. Palesa Monongoaha - WASA

1 Welcome Dr Heath thanked NES for the opportunity to meet and discuss the Metolong WTW EMP process and format of report. NES stated that their expectation of the meeting was to discuss the methodology and approach that was required for the Metolong WTW EMP Inception Report. 2 Discussion and Action Points The following are action points from the discussions:  NES confirmed that the key impacts identified are to be taken forwards into the EMP. 13.0 NES confirmed that no further public consultation is required as part of this ESIA/EMP.  NES indicated that the consultants needed to highlight in the ESIA any deviations from the original TOR such as quarries, social impact assessment and public consultation.  It was confirmed that NES has approved the EMP team (refer to NES correspondence in this regard). 14.0 Sludge is not to be disposed into the Phuthiatsana River.  A standard approach must be followed regarding discharge of effluent to the environment and the same Standards to be used. WASA is to be consulted in this regard. EMP is to recommend that the same Standards are used that WASA is using for the Maseru water treatment works upgrade.

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3 EMP Scope  Focus of EMP is on mitigation of key impacts raised in the ESIA and not standard contractor compliance measures, e.g. dust management. Generic or standard EMP issues are to be incorporated as a separate chapter of the EMP. This separate chapter/section would include information typically contained in the Contractor’s Method Statements.  EMP is to highlight linkages between impacts and management measures. The Risk Assessment approach is recommended for the EMP as this approach is logical and easy to understand.  EMP has to present the methodology used to quantify the impacts and key issues (extracted from EIA).  Treatment process to present the inputs and expected outputs in a flow chart.  Present sludge disposal options, uncertainties and gaps in understanding are to be described. One option may be to promote the beneficial uses of sludge amongst local communities. A cost - benefit analysis should be used to determine the preferred option of the sludge disposal. This should comprise a qualitative presentation of the disadvantages and advantages of each option and recommendations for further investigation that may be required to establish feasibility of the different disposal options during the first 2-3 years of years of the WTW operation. [It was noted that sludge content and its compliance with standards could not be established until the WTW was operational and that the sludge drying capacity at the WTW allowed for 2-4 years of sludge before a disposal option had to be implemented. WASA would be the agency responsible for implementing sludge disposal].  The comprehensive EMP to include appropriate specialist appendices (such as sludge management). The different sludge management options are to be described and presented in the EMP.

4 Inception report NES require an EMP Inception Report to be submitted to them prior to the EMP report. The Inception Report is to present the proposed format of the EMP.

A quantifiable approach for assessing and determining the key impacts that are to be included in the EMP must be described.

5 Way forward  The consultants to submit the EMP Inception Report to NES for review (5 copies).  NES to review and give the consultants feedback  Consultants to finalize EMP Inception Report  Consultants to prepare the EMP for review by NES  Consultants to finalize the EMP

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B2: EXTRACTS OF MINUTES OF TECHNICAL MEETING 15TH APRIL 2009

METOLONG DAM PROGRAMME WTW: Developing DB Contract Documents & Conducting Env/Soc Impact Assessment Contract WS-A-004-08 Technical Meeting (#006) Date: 15 April 2009; Time: 10:00 a.m. to 1:00 p.m. Location: Metolong Authority Boardroom

MINUTES The following is a summary of the discussions and required follow-up actions from the above referenced meeting.

Item Action Due Subject / Discussion No By Date

6.1 Welcome and Attendance:

6.1.1 All parties were welcomed to the meeting by the chairperson, Mr Evan Painting, and an attendance register was circulated. Copy attached.

6.1.2 Apologies

No apologies were received

6.1.3 Introductions The following new members to the team were introduced:

 Mr Keketso Chalatse MCA-L: Head – Infrastructure

 Mr Lira Molapo MCA-L: Head – Environmental & Social Assessment

 Mr Malia Makhetha WASA: Maintenance Planner

6.2 Approval of the Minutes of Previous Meeting The minutes of Technical Meeting #005 was approved with minor corrections.

6.3 Contractual Issues

6.4 Programme Overview

6.4.3 Environmental MCA environmental to send the environmental inception report to MCC for comment. Work is to continue in the meantime. LM 30 Apr

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6.5 Reference Documents

The following documents were received from MPMU by the LWJV for use in developing the IFB, prequal, eval strategy, etc

 The Municipal Water and Wastewater Design-build Handbook  Example of request for qualifications  Example of request for proposals (Vol 1)  Example of design-build contract 6.6 Develop DB Documents

6.6.1 Plant Basics Subsequent coordinates of the initial heritage site investigation will be SL 22 Apr sent to the LWJV.

It was proposed that a fence will be erected during construction of the (5.6.1) WTW 2m on both sides of the stone boundary wall. Protection limits will be confirmed with Charles Arthur. E&S will advise as to whether the DHa 30 Apr stone boundary wall has to be preserved or not.

Information of affected properties was received by the LWJV. Information to be imposed on the layout drawing and forwarded to RH LWJV 17 Apr and SL

6.6.2 Location A suggestion from the PoE to move the dam wall was received but not yet approved or confirmed. The raw water pipeline may best be designed by assuming a connection point at the boundary of the respective WTW and the Metolong Dam sites. A position for the connection point to the raw water supply line needs to LWJV 17 Apr be forwarded to RH and SL

6.6.3 Early Access for Survey , Geotech etc Nothing to record

6.6.4 Water Quality Data Test results from WASA and DWA are being received. Flow data were received from DWA. (5.6.4) The color issue is being investigated and a report from CDM was received by LWJV.

Flow and rainfall data must be superimposed on the graphs. Manganese levels must also be checked. In order to determine the expected algae growth in the dam it was proposed that samples be taken from other dams within the catchment LWJV 30 Apr or with similar environmental conditions. Collett Dam was identified. LWJV 24 Apr A baseline survey on the quantities of fertilizer used will be made available to the LWJV Chlorination will be done at the works and re-chlorination will be done at

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the reservoirs by others. DHa 30 Apr

6.6.5 Quarries and materials The estimated volumes of concrete need to be given in the bid documents. The contractor will have to make his own arrangements for aggregates. LWJV 30 Apr Information regarding distances from site and quality of material of commercial sources need to be included in the bid documents. LWJV 30 Apr

6.6.6 Standardization of the Plant

WASA to submit a list of all preferred equipment to the LWJV. This list will be included in the bidding documents. Any available performance analysis and motivations for the use of specific equipment must accompany the list. WASA 17 Apr

6.6.7 Level of Operation / Automation A discussion was held on 14 April 2009 and it was agreed that the minimum standard for level of operation and automation must be that which is currently used at the Maseru WTW. A site visit to the Maseru LWJV 24 Apr WTP will be made next week. LWJV to coordinate.

It was also agreed that a generator set must be allowed for with the capacity to run the WTW at full capacity.

6.6.8 Sludge

LWJV to determine how sludge is to be handled based on the LWJV 30 Apr environmental and tech constraints. RH 23 Apr The ESIA team will investigate possibilities in terms of sludge disposal.

The Lesotho effluent discharge to natural water courses standards were requested from the MCA Lira Molapo. LM 23 Apr

6.6.9 Plant Staffing It was proposed that an electrician and operator (with a back-up for each person) from WASA be involved on site from the first day of construction of the new Metolong WTW. WASA to provide names. FS 15 May

6.6.10 Surveys Geotechnical Geotechnical report was received from J&G. Copy to be sent to SL, EP 17 Apr MCC and MCA-L

Topographical

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Survey has been completed with 0,5 m contours. MPMU and DH requested an electronic copy of the survey. Adjustments will be made to be consistent with the Conveyance survey. (4.6.10) EP 24 Apr

6.6.11 Pre-qualification and Tender Documents Comments were received on the pre-qualification documents. MCA-L does not have an evaluation strategy and the World Bank DM 17 Apr version has shortfalls. SL submitted a proposal, LWJV to comment. Evaluation strategy needs to be submitted urgently.

It was requested that any information forming part of the bid documents ALL 23 Apr to be forwarded to DM as a matter of urgency. (5.6.11) An outline for the tender document as well as sections 1-4, 6 & 7 need DM 23 Apr to be submitted to the MPMU.

6.6.12 Reporting Draft final environmental inception report was submitted.

Outline of the IFB was submitted to MPMU for comment. MPMU provided comments 15 Apr.

Final technical inception report to be submitted. LWJV 17 Apr

6.7 Conduct of ESIA

6.7.1 ESIA and EMP It was accepted that the raw water pipeline for the WTW will start at a LWJV 30 Apr point on the boundary of the respective WTW and Dam sites. This position will be investigated by the LWJV.

6.7.2 Permits Technical information should be forwarded to RH in order for the ESIA ALL 24 Apr team to compile the list of required permits

6.7.3 Land Acquisition (4.7.3) Survey to determine the pipeline routes have been completed by the LWJV 30 Apr LWJV and the details of the pipeline routes will be forwarded to the MPMU in the next two weeks.

6.7.4 Terms of Reference and mobilization (4.7.4) Information regarding the chemicals likely to be found in the sludge was

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made available to the ESIA team. Jar test samples will be taken next week LWJV 24 Apr

6.8 Co-ordination

6.8.1 Survey Information Confirmation of the benchmark used by the surveyor of AP required. EP/AP 24 Apr

6.9 Project Schedule

6.9.1 MA Master Schedule Housing and wastewater services will not be available to the WTW contractor. Water, electricity and telecom services should be completed under the AI contract by the time the WTW contractor commence work.

6.9.2 LWJV Schedule - Milestones Basis of Design Report 07 May 2009

Issue Pre-Qualification documents 16 April 2009 Draft ESIA 23 April 2009 Draft EMP 30 April 2009

6.10 General

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B3: EXTRACTS OF MINUTES OF TECHNICAL MEETING 20 JULY 2009

METOLONG DAM PROGRAMME WTW: Developing DB Contract Documents & Conducting Env/Soc Impact Assessment Contract WS-A-004-08

Technical Meeting (#010)

Date: 20 July 2009 Time: 09:00 a.m. to 12:50 p.m. Location: Sechaba Consulting

MINUTES

The following is a summary of the discussions and required follow-up actions from the above referenced meeting. For a list of those present, see the attached attendance register.

Water Quality Data

Raw Water Quality Flow and rainfall data must be superimposed on the graphs. Manganese levels LWJV 24 Jul must also be checked.

Suspicious looking data were removed from the data sets from DWA.

Bloem Water is experiencing the same type of raw water quality at the Welbedacht WTW (Caledon river). Conventional treatment at this plant proved to be effective.

Sampling of raw water to be continued.

Tests for Chlorophyll-A was done on samples taken in May 2009 from the Collett dam. No indication of algae growth was found. The plant must still be designed to treat possible algae growth

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Jar tests were done using Alum and polymers. The tests have shown that both Alum and polymers could be used in the process. Alum dosage required was approximately twice that of polymers.

WASA indicated that their preference is to use polymers instead of Alum, based on the fact that it is less labour intensive to dose and the large storage area required for Alum. WASA need to submit a preference report with regard to this issue.

The LWJV will get feedback from Bloem Water on the use of Alum and polymers WASA 31 Jul as well as the treatment processes used to treat Crypto Spiridium and Giardia

Treated Water Quality

The laboratory at the works must be able to do all tests. It will be operating as a regional laboratory. Treated water to conform to the South African specification LWJV 31 Jul for treated water SANS241 and World Health Organization Guidelines.

Supernatant and Wash Water It is expected that the supernatant water will shown high concentrations of Iron EP 03 Jul and Aluminium. Data of supernatant water on sludge lagoons need to be submitted.

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APPENDIX C Possible Template for Emergency Response Plan

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EMERGENCY RESPONSE PLAN

DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

TABLE OF CONTENTS

1 INTRODUCTION ...... 1 1.1 DEFINITIONS ...... 1 1.2 SCOPE ...... 1 2 EMERGENCY PREPAREDNESS ...... 2 2.1 CAUSES OF EMERGENCIES ...... 2 2.2 RESPONSIBILITY FOR EMERGENCY PREPAREDNESS AND THE ERP ...... 2 2.2.1 Responsibilities of the Plant Manager ...... 2 2.2.2 Mission Statement ...... 3 2.2.3 The Safety Committee/Planning Team ...... 3 2.2.4 Aspects to consider during development of Emergency Response Plan ...... 4 2.2.4.1 Schedule and Budget...... 4 2.2.4.2 Review internal plans and policies ...... 4 2.2.4.3 Meet with Outside Groups ...... 5 2.2.4.4 Identify External Resources ...... 5 2.2.4.5 Insurance Review ...... 5 2.2.4.6 Conduct a Vulnerability Analysis ...... 6 2.2.5. Evaluation and Revision of the ERP ...... 6 2.2.6 Training ...... 6 2.3 EMERGENCY RESPONSE PLANNING ...... 6 2.3.1 Normal vs. Emergency Operations ...... 7 2.3.2 Flexibility ...... 7 2.3.3 Coordination ...... 7 2.3.3.1 Internal Coordination ...... 7 2.3.3.2 External Coordination ...... 7 2.3.4 Communications ...... 7 2.3.5 Special Aspects of Civil Disturbance ...... 8 2.3.6 Special Aspects of Telephoned Bomb Threats ...... 8 2.3.7 Special Aspects of Hazardous Material ...... 9 2.3.8 Evacuation of the Facility ...... 9 2.4 ACTIVATION OF EMERGENCY RESPONSE PLANS ...... 9 2.5 EMERGENCY RECOVERY ...... 9 2.6 DEVELOPMENT OF EMERGENCY RESPONSE PLAN...... 9 3 EMERGENCY RESPONSE PLANS ...... 11 3.1 POWER OUTAGES ...... 11 3.1.1 Power Outage Causes ...... 11 3.1.2 Emergency Preparedness for Power Outages ...... 11 3.1.3 Emergency Response Plan for Power Outages ...... 11 3.1.3.1 Normal Operation ...... 12 3.1.3.2 Manual Operation ...... 12 3.2 FIRE ...... 13 3.2.1 Emergency Preparedness for Fire ...... 15 3.2.2 Emergency Response Plan for Fire ...... 15 3.2.2.1 High Threat Fires ...... 15 3.2.2.2 Low Threat Fires ...... 16 3.2.3.3 Recovery ...... 16 3.3 ON-SITE POTABLE WATER CONTAMINATION ...... 17 3.3.1 Emergency Preparedness for On-Site Potable Water Contamination ...... 17 3.3.2 Emergency Response Plan for On-Site Potable Water Contamination ...... 17

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3.3.2.1 Notification Procedures ...... 17 3.3.2.2 Corrective Action Procedures ...... 17 3.4 PUBLIC POTABLE WATER SUPPLY CONTAMINATION ...... 17 3.4.1 Emergency Preparedness for Public Potable Water Supply Contamination ... 17 3.4.2 Emergency Response Plan for Public Potable Water Supply Contamination . 18 3.4.2.1 Initial Response ...... 18 3.4.2.2 Biological Contamination ...... 18 3.4.2.3 Chemical Contamination ...... 18 3.4.2.4 Contamination from External Sources ...... 19 3.5 HYDRAULIC RUPTURES AND STOPPAGES ...... 19 3.5.1 Pipe Failure and Ruptures ...... 19 3.5.2 Stoppages ...... 19 3.6 HAZARDOUS MATERIALS ...... 19 3.6.1 Emergency Preparedness for Hazardous Materials ...... 20 3.6.2 Emergency Response Plan for Hazardous Materials ...... 20 3.7 CIVIL UNREST ...... 21 3.7.1 Emergency Preparedness for Civil Unrest ...... 21 3.7.2 Emergency Response Plan for Civil Unrest ...... 21 3.7.2.1 Civil Unrest in the Immediate Area ...... 21 3.7.2.2 Civil Unrest in the Local Area ...... 21 3.8 EARTHQUAKES ...... 21 3.8.1 Emergency Preparedness for Earthquakes ...... 21 3.8.2 Emergency Response Plan for Earthquakes ...... 22 3.9 EXPLOSIONS ...... 22 3.9.1 Emergency Preparedness for Explosions ...... 22 3.9.2 Emergency Response Plan for Explosions ...... 23 3.10 STRUCTURAL COLLAPSE ...... 24 3.10.1 Emergency Preparedness for Structural Collapse ...... 24 3.10.2 Emergency Response Plan for Structural Collapse ...... 24 3.11 CHLORINE LEAKS ...... 25 3.11.1 Emergency Preparedness for Chlorine Leaks ...... 25 3.11.2 Emergency Response Plan for Chlorine Leaks ...... 25 4 ADDITIONAL REQUIREMENTS ...... 27 4.1 EMERGENCY CONDITION EVALUATION REPORT ...... 27 4.2 SAFETY EQUIPMENT INSPECTIONS ...... 27 4.3 SAFETY EQUIPMENT LOCATIONS ...... 27 4.4 PERSONNEL TRAINING ...... 27 4.5 EMERGENCY CONTACT TELEPHONE NUMBERS ...... 27 4.6 EVACUATION PLAN ...... 27 4.7 PERSONAL EMERGENCIES ...... 28 4.8 MANAGED DELIVERIES ...... 28 4.9 VERIFICATION OF SUPPLIERS ...... 28 4.10 SECURE CHEMICAL STORAGE AREA ...... 28 4.11 MONITORING OF SOURCES AND PRODUCT ...... 29 4.12 PROTECTION OF VENTS AND OVERFLOWS...... 29 4.13 SYSTEM BY-PASS FACILITIES ...... 29

Tables Table 1: WTP Fire Hazards...... 14

ii DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

Figures

Figure 1: Electrical Feeder System One-Line Diagram ...... 12

Appendices Appendix A, Emergency Contact List Appendix B, Evacuation Routes Appendix C, Fire Extinguisher Locations

iii DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

1 INTRODUCTION One of the great threats to good emergency functioning, at any facility similar to the water treatment plant (WTP), is the prevalence of the "it can't happen here" syndrome. This real possibility underscores the need for heightened awareness of possible emergencies, even those as remote physically as to escape initial appraisal by planners. Either the events themselves, or their side effects, should be considered for the problems they could cause the facility. Note: The job titles used herein reflect job responsibilities, not necessarily the actual titles of the personnel who carry out the job responsibilities. 1.1 DEFINITIONS Emergency - An emergency can be defined as any unplanned event that can cause deaths or significant injuries to employees, customers or the public; or that can shut down the enterprise, disrupt operations, cause physical or environmental damage, or threaten the facility's financial standing or public image.

1.2 SCOPE The Emergency Response Plan (ERP) is intended to provide the means by which WTP personnel can prepare for emergencies and respond in an effective manner when they occur. This plan can only succeed if personnel understand the plan, practice emergency response, and know when to activate the plan. Where appropriate, reference has been made to the Emergency Preparedness Plan prepared in 2007 for WASA by Africon (Louw and van Zyl, 2007) as it is likely that WASA will operate the WTP. The ERP covers the most common emergencies that can be expected to occur at the WTP and provides detailed action plans for such emergencies. The emergencies covered herein, include:  Power Outages  Severe weather (snow, wind, storm events and flooding)  Fire  Potable Water Supply Contamination  Hydraulic Ruptures, and Stoppages  Hazardous Material Spills  Civil Unrest  Earthquake  Explosions  Structural Collapse  Chlorine Leaks  Transportation Accidents This ERP is not intended to prevent an emergency from occurring, but to effectively deal with emergencies when they do occur. Coordination of the requirements contained herein and the requirements contained in the Environmental Management Plan (EMP) is critical to successful emergency planning and general facility safety.

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2 EMERGENCY PREPAREDNESS Emergency Preparedness is an internal planning process that must not only come from within the organisation, it also cuts across all divisions and disciplines in the organisation, needs communication with outside Response Organisations, needs to have agreements in place before an emergency happens, and very important, needs to establish beforehand who will be in charge for each situation, make sure that person knows what to do, has the authority to take decisions, can enforce his/her decisions. Furthermore communications is very important to the clients and general public before an incident, during an incident and after the incident.

The ERP addresses the most common emergencies that can be expected to occur, and provides detailed response plans for those emergencies. However, this does not relieve WTP management personnel of the responsibility to consider other possible emergencies that might occur and make provisions for dealing with such emergencies, no matter how unlikely they might seem. Furthermore, existing emergency response plans and emergency preparedness planning must be continuously evaluated and revised to accommodate changing circumstances, both within the facility and within the community; and to correct any deficiencies within existing plans, which are brought to light as a result of emergency response drills. 2.1 CAUSES OF EMERGENCIES Emergencies have a variety of causes, all of which must be considered in effective emergency preparedness planning. Among the most common are natural disasters such as earthquakes and floods; mass food poisoning; industrial or transport accidents involving explosion or release of toxic chemicals to the environment; civil disturbances; building fires; extensive or prolonged utility failure; and collapse of buildings or other occupied structures. The ultimate disaster, nuclear warfare, must be given consideration in disaster planning. Conventional bombing in warfare is another possibility that cannot be overlooked. Arson attempts and bomb threats have been made on public facilities and must therefore be considered, as must the potential for facility visits by VIPs. While the last does not involve mass casualties or the potential of mass casualties, the degree of disruption of normal routine will be sufficient that it may qualify as a disaster-like situation. 2.2 RESPONSIBILITY FOR EMERGENCY PREPAREDNESS AND THE ERP Ultimately, all personnel at the WTP are responsible for safety, and responsible for carrying out effective responses to emergency situations. However, specific individuals and groups must assume overall responsibility for directing emergency operations and preparing WTP personnel to effectively respond to emergencies. 2.2.1 Responsibilities of the Plant Manager There must be an individual or group in charge of developing the emergency preparedness plan. Typically, the Plant Manager is responsible for overall emergency planning within the facility, for activation of the plan in event of an emergency, and for termination of emergency procedures under the plan, with return to normal operations. The Plant Manager is also responsible for decision making during emergency operations. He will often delegate some of these responsibilities, particularly those involved with emergency planning, which are normally delegated to the Safety Committee members. The job of emergency planning is rarely full-time.

2 DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

Since emergencies can occur in the absence of the Plant Manager, he must designate an authorized alternate to activate, implement, and terminate emergency response plans in his absence. This alternate should be the senior administrative manager or supervisor on duty at the time the emergency occurs. Only the Plant Manager, or his designated alternate, should have the authority to activate or terminate emergency response plans. 2.2.2 Mission Statement It is important to have the chief executive or plant manager issue a mission statement to demonstrate the company's commitment to emergency management. The statement should:

 Define the purpose of the plan and indicate that it will involve the entire organization  Define the authority and structure of the planning group 2.2.3 The Safety Committee/Planning Team The Safety Committee, chaired by the Plant Manager or his designated alternate, is responsible for all safety issues at the facility, including emergency preparedness. The Safety Committee is comprised of the personnel listed in the figure below (Louw and van Zyl, 2007). Other members may be added to the committee, as deemed appropriate by the committee and the Plant Manager. Typically, the Safety Committee members may include the following:  Plant Manager, or his designated alternate  Maintenance Manager  Laboratory Manager  Operations Supervisor  Safety Supervisor

The Plant Manager, in conjunction with the Safety Committee, must take an active role in safety and provide the leadership necessary to ensure safe facility operations and the implementation and maintenance of the ERP. The size of the Safety Committee will depend on the facility's operations, requirements and resources. Usually involving a group of people is best because:

 It encourages participation and gets more people invested in the process.  It increases the amount of time and energy participants are able to give.  It enhances the visibility and stature of the planning process.  It provides for a broad perspective on the issues.

Determine who can be an active member and who can serve in an advisory capacity. In most cases, one or two people will be doing the bulk of the work. At the very least, one should obtain input from all functional areas.

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2.2.4 Aspects to consider during development of Emergency Response Plan 2.2.4.1 Schedule and Budget The team needs to establish a work schedule and planning deadlines. Timelines can be modified as priorities become more clearly defined. An initial budget is to be developed for aspects such as research, printing, seminars, consulting services and other expenses that may be necessary during the development process. 2.2.4.2 Review internal plans and policies The next step it so review internal plans and policies. Documents to look for include:  Evacuation plan  Fire protection plan  Safety and health program  Environmental policies  Security procedures  Insurance programs  Finance and purchasing procedures  Plant closing policy  Employee manuals  Hazardous materials plan  Process safety assessment  Risk management plan  Capital improvement program  Mutual aid agreements

If one or more of these documents do not exist, it must be considered whether the organisation needs such a document and then it can be compiled.

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2.2.4.3 Meet with Outside Groups Plant Manager and/or Safety Committee are to meet with government agencies, community organisations and utilities. Ask about potential emergencies and about plans and available resources for responding to them. Sources of information include (Louw and van Zyl, 2007) and a list of contact details where available is listed in Appendix A:

 Community emergency management office  Mayor or Community Administrator's office  Local Emergency Planning Committee (LEPC)  Fire Department  Police Department  Emergency Medical Services organisations  Red Cross  National Weather Service  Public Works Department  A National Planning Department  Telephone companies  Electric utilities (Lesotho Electricity Corporation)  Neighbouring businesses 2.2.4.4 Identify External Resources There are many external resources that could be needed in an emergency. In some cases, formal agreements may be necessary to define the facility's relationship with the following organisations:

 Local emergency management office  Fire Department  Hazardous materials response organization  Emergency medical services  Hospitals  Local police  Community service organisations  Utilities  Contractors  Suppliers of emergency equipment  Insurance carriers 2.2.4.5 Insurance Review The Plant Manager and other appropriate management members are to meet with insurance companies to review all policies as part of the development of an ERP. Most companies discover that they are not properly insured only after they have suffered a loss. The following topics should be discussed with the insurance advisor to determine the facility’s individual needs:

 How will facility be valued?  Does the policy cover the cost of required upgrades to code?  How much insurance is the facility required to carry to avoid becoming a co- insurer?

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 What perils or causes of loss does the policy cover?  What are the deductibles?  What does the policy require the facility management to do in the event of a loss?  What types of records and documentation will the insurance company want to see?  Are records in a safe place and where they can be obtained after an emergency?  To what extent are covered for loss due to interruption of power? Is coverage provided for both on- and off-premises power interruption?  Is the facility covered for lost income in the event of business interruption because of a loss?  Does the facility have enough coverage? For how long is coverage provided? How long is coverage for lost income if this business is closed by order of a civil authority?  To what extent are covered for reduced income due to customers' not all immediately coming back once the business reopens?  After a site emergency, assess the impact of the event on business neighbours and the community and take appropriate action. How one handles this issue will have long-lasting consequences.  How will the facility’s emergency management program affect the facility’s rates? 2.2.4.6 Conduct a Vulnerability Analysis The next step is to assess the vulnerability of the WTP facility and the probability and potential impact for each identified emergency listed in Section 1.2 (Scope). Typical emergencies that could occur at this facility include Fire; Chemical Spills; Sewage ponds; Storage Dam Failure; (Flooding of) Abstraction works; Main pipe bursts; Power outages; Outbreak of water borne diseases; and Failure of Service Reservoirs. 2.2.5. Evaluation and Revision of the ERP The Safety Committee has the responsibility to continually evaluate the effectiveness of the ERP and make revisions to the ERP, as appropriate. If the Safety Committee deems it necessary to make revisions to the ERP, it will do so. The Plant Manager must approve all revisions to the ERP. Revisions to the ERP must be reviewed with all personnel and additional training necessitated by such revisions must be provided, as appropriate.

2.2.6 Training The safety supervisor is responsible for providing adequate emergency response training and related safety training. Of significant importance here, is the need for adequate evacuation procedures training to ensure that each person on site knows what their role and responsibility is during an evacuation. The safety supervisor is also responsible for conducting emergency response drills and, in conjunction with the Safety Committee, responsible for evaluating the results of such drills and recommending improvements.

2.3 EMERGENCY RESPONSE PLANNING A number of aspects must be considered when developing effective emergency response plans. The following paragraphs discuss the most important of these aspects.

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2.3.1 Normal vs. Emergency Operations A "difference" that is conjured up by inexperienced emergency planners is the false contrasting of normal versus emergency modes of functioning. On the contrary, proper plans have ERP using the same skills (and preferably in or near the same places) under all circumstances. 2.3.2 Flexibility The key to effective emergency preparedness planning is flexibility, which is attained by contingency planning (i.e., consideration of all likely possibilities and development of options for action that are maximally effective under each such possibility). Thus, the first step in emergency planning is to review the various types of emergencies that can occur, emphasizing the types of emergencies most likely to affect the WTP. The second step in emergency planning is the assessment of resources (facilities, material, and personnel), including resources on hand, resources required to effectively cope with emergency, and potential remaining resources following degradation due to internal disaster. The final step is the meshing of emergency type and magnitude (number of casualties and/or extent of damage) with the potentially available resources in each given case into options for action. The key element of an effective emergency response plan is that it be functional for any time of day or night, any day of the year. The plan should not rely on any special individual or group to be put into effect; rather, the ERP on duty at the time of the emergency should be capable of implementing it. The overall coordination, which must be developed and rehearsed regularly, is the critical issue. 2.3.3 Coordination It is essential that plans be coordinated both internally and externally. 2.3.3.1 Internal Coordination Internal coordination is necessary to assure that each staff member is aware of his individual role under the ERP, and to assure that all available resources are most efficiently and effectively utilized. Each supervisor at each level of organization within the facility must assure that his or her staff and employees are aware of their individual roles and responsibilities during an emergency, stressing the flexibility of such roles and responsibilities. All roles and responsibilities must be delineated in written form so they can be studied, incorporated into training programs, and then rehearsed, drilled, and evaluated for effectiveness. 2.3.3.2 External Coordination Since the WTP is not completely self-sufficient, external coordination is essential if the facility is to effectively function under emergency conditions. Such external coordination is best accomplished through arrangements with community emergency medical services, representatives of the local fire department, law enforcement agencies, civil defense officials, military units, local hospitals, and other entities as appropriate. 2.3.4 Communications The better the internal and external communications systems available to the facility in an emergency situation, the more effectively it can respond to the emergency. Functional communication systems, effectively utilized, can provide the facility with advance warning of

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certain emergencies, thus permitting time to better prepare response; and can be used to mobilize mutual aid and other emergency assistance.

The simplest communication system is face-to-face verbal communication, using runners; this system can be used to contact those areas of the facility without other means of communication. Telephone communications are invaluable in an emergency situation, providing such systems remain intact. However, it must be emphasized that even with intact telephone systems, switchboards, in a number of emergency situations, are invariably swamped with incoming or outgoing calls, thus effectively canceling out the use of routine telephone systems.

If possible, an FM radio system should be employed, consisting of handheld radios and a base station. Such a system not only provides essential communications during an emergency, but also provides communications support for security and maintenance/operations activities during normal operations. During an emergency, radios should be distributed as necessary to provide communications to effectively deal with the emergency. In some emergencies the radios may be needed primarily for security communications, while other emergencies might necessitate the use of radios by operations and maintenance personnel dealing with the emergency. 2.3.5 Special Aspects of Civil Disturbance Large-scale civil disturbances in recent years have shown that public facilities and their personnel are not immune to the direct effects of human violence in such disturbances. Facilities must make special provisions in their emergency response plans to assure the physical safety of their employees. In extreme cases it may be necessary to house employees within the facility itself during such civil disturbances.

Provisions for securing areas that have windows accessible from the ground, and may therefore be subject to items thrown from hostile crowds, should be included in civil disturbance plans. Items such as heavy window screens or guards and/or substantial drapes or window shades might be considered as reasonable precautions. 2.3.6 Special Aspects of Telephoned Bomb Threats The emergency potential inherent in the telephoned bomb threat warrants consideration of this emergency contingency in the emergency response plans. Experience has shown that facility personnel must accompany police or military bomb demolition personnel in searching for the suspected bomb, since speed is of the essence and only individuals familiar with a given area can rapidly spot unfamiliar or suspicious objects in the area. This is particularly true in laboratory areas in which police are usually totally unfamiliar with the appearance of standard laboratory apparatus. The facility switchboard operator must be provided with a checklist to be kept available at all times, in order to obtain as much information as possible from the caller concerning location of the supposed bomb, time of detonation, and other essential data, which must be considered in deciding whether or not to evacuate all or part of the facility.

Note: Police and fire authorities vary considerably from locality to locality with regard to response to bomb threats. Knowing exactly what assistance local authorities provide will dictate the level of activity the facility will need to provide for them.

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2.3.7 Special Aspects of Hazardous Material The facility may contain within its boundaries varying amounts of hazardous materials, especially in custodial and maintenance areas. A spill of highly volatile chemical such as gaseous chlorine can quickly contaminate an entire structure by way of air ducts and/or normal air movement. Finally, contaminated staff may pose a risk to all staff, through a more localized contact basis. Usually removal of contaminated clothing will reduce this risk materially. In any case, staff must be prepared to seek outside advice on unknown hazards. 2.3.8 Evacuation of the Facility Emergency response plans must consider the possibility of evacuation of the facility. Total or partial evacuation, as might be required because of an earthquake, fire, arson attempt, telephoned bomb threat, chlorine leak, etc., must be considered. Historical experience has shown that planning for an execution of a total evacuation of staff can be both difficult and complex if loss of life is to be precluded. In order to avoid loss of life in such situations, careful planning and repeated practice is mandatory. 2.4 ACTIVATION OF EMERGENCY RESPONSE PLANS The Plant Manager, or his duly authorized alternate, is responsible for activating emergency response plans. In the event of an emergency, the Plant Manager will immediately activate the appropriate response plan, recall any off-duty personnel who are an integral part of the plan, and set up an emergency control center, located in a safe, centralized area, in such a manner as to provide centralized control over emergency response efforts. 2.5 EMERGENCY RECOVERY As the stresses of an emergency begin to abate, there is often a tendency for staff to slip back into a "business as usual" mode. While restoration of pre-emergency effectiveness is always an objective, the wind-down must be managed as carefully as the buildup. In some cases, damage to the facility may dictate the sequence of events. In any case, the unusual location and distribution of equipment, supplies, and staff will require proper guidance in order to accomplish a smooth transition to a more normal state. Only rarely will an "all-clear" signal be received from outside authorities; more often, management will note that, for example, all victims are accounted for, or that the fire is out. It is at this point that restoration and recovery measures must be thoughtfully initiated.

2.6 DEVELOPMENT OF EMERGENCY RESPONSE PLAN The plan should include the following basic components:

Executive Summary The executive summary gives management a brief overview of:  The purpose of the plan  The facility's emergency management policy  Authorities and responsibilities of key personnel  The types of emergencies that could occur  Where response operations will be managed

Emergency Management Elements This section of the plan briefly describes the facility's approach to the core elements of emergency management, which are:  Direction and control

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 Communications  Life safety  Property protection  Community outreach  Recovery and restoration  Administration and logistics

These elements are the foundation for the emergency procedures that this facility will follow to protect personnel and equipment and resume operations.

Emergency Response Procedures The procedures are to spell out how the facility will respond to emergencies. Whenever possible, they are to be developed as a series of checklists that can be quickly accessed by senior management, department heads, response personnel and employees.

Support Documents Documents that could be needed in an emergency include:  Emergency call lists - lists (wallet size if possible) of all persons on and off site who would be involved in responding to an emergency, their responsibilities and their 24-hour telephone numbers.  Building and site maps that indicate: o Utility shutoffs o Water hydrants o Water main valves o Water lines o Gas main valves o Gas lines o Electrical cut-offs o Electrical substations o Storm drains o Sewer lines o Location of each building (include name of building, street name and number) o Floor plans o Alarm and enunciators o Fire extinguishers o Fire suppression systems o Exits o Stairways o Designated escape routes o Restricted areas o Hazardous materials (including cleaning supplies and chemicals) o High-value items  Resource lists - lists of major resources (equipment, supplies, services) that could be needed in an emergency; mutual aid agreements with other companies and government department.

Finally, the ERP needs to be approved and then implemented through training.

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3 EMERGENCY RESPONSE PLANS 3.1 POWER OUTAGES Power outages may occur at any time. Since operations personnel are the only staff on duty at night, other than security personnel, operations personnel are responsible for the execution of this plan, except where noted below. When a power failure occurs, operations staff on duty (i.e., the Shift Supervisor and Shift Operators) responds to the outage and carry out the actions defined in Paragraph 3.1.C.2).

3.1.1 Power Outage Causes Power outages may be caused by either the incoming feed line failing, or a failure of the facility internal electrical system. Some possible causes of power outage are:  Substation failure  Excavation (cut cable)  Storms (very strong wind may damage overhead lines)  Human error  Faulty equipment

3.1.2 Emergency Preparedness for Power Outages Unlike other potential emergencies, power outage is a fairly common occurrence. However, the fact that power outage is relatively common does not alleviate the need to properly respond to this type of emergency.

It is the Operations Manager's responsibility to insure that all operations personnel follow emergency response plans during a power outage.

Transportation must be available should a power outage necessitate bringing electrical maintenance personnel into work on an emergency basis. It will be the decision of the Plant Manager, or his duly authorized alternate, to bring in maintenance personnel on an emergency basis. 3.1.3 Emergency Response Plan for Power Outages Electrical supply and distribution feeders are described below and also shown on the one-line diagram in Figure 1 (this is a typical example and will need to be updated once the final designs are available).

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Figure 1: Electrical Feeder System One-Line Diagram

The electrical system is normally operated with:  Incoming utility feeder circuit breaker on the 11kV switchgear “CLOSED”.  Both genset alternator output circuit breakers “CLOSED”.  Controls set to “AUTO” on both gensets.  Both gensets not running. Operation of the electrical system is automatic and does not require operator intervention unless there is a power outage and auto transfer does not take place.

3.1.3.1 Normal Operation When failure of utility power occurs, the gensets are automatically started and automatic transfer to generator power takes place. Upon restoration of utility power, retransfer from generator power to utility power is automatic. After an engine cool down period, the gensets automatically shut down. When power is transferred and retransferred, plant equipment must be checked to ensure proper operation. Some equipment may require restarting after a power transfer occurs. 3.1.3.2 Manual Operation If an ATS controller is disconnected or fails, perform the following procedure to transfer power for either or both 380V feeder systems:  In the event of a power outage on the incoming utility feeder:

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o At the 11kV switchgear, “OPEN” the outgoing feeder circuit breaker and at the associated genset, “OPEN” the alternator output circuit breaker. o At the 380V switchgear, open the ATS front panel door. o Using the maintenance handle (Figure 2), manually operate the transfer switch from the normal (N) position to the emergency (E) position. o At the genset control panel, switch the engine control switch to the “RUN” position and manually start the genset, if necessary. o At the genset, monitor generator voltage and frequency until they stabilize at 380V and 50Hz, respectively. o At the genset, “CLOSE” the alternator output circuit breaker. o The genset is now providing power to the 380V switchgear.  When power is restored on the incoming utility feeder: o Shut down any equipment in operation. o At the genset, “OPEN” the alternator output circuit breaker. o At the 380V switchgear, open the ATS front panel door. o Using the maintenance handle (Fig. 2), manually operate the transfer switch from the emergency (E) position to the normal (N) position. o At the 11kV switchgear, “CLOSE” the incoming utility feeder circuit breaker. o The normal utility feeder is now providing power to the 380V switchgear via the 11kV switchgear and transformer.  At the genset control panel, move the engine control switch to the “STOP” position. The genset shuts down after the preset cool-down period has elapsed.

Figure 2: ATS Manual Handle

3.2 FIRE Fire is probably the most potentially dangerous emergency faced by the facility. The potential for loss of life or injury to personnel and the potential for significant damage to facility equipment and structures are extremely high. The following fire classifications are applicable to the facility and relate directly to portable fire extinguisher classifications. Class A Fires Fires in ordinary combustible materials, such as wood, cloth, paper, rubber and many plastics.

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Class B Fires Fires in flammable liquids, oils, greases, tars, oil-based paints, lacquers, and flammable gases. Class C Fires Fires that involve energized electrical equipment where the electrical non-conductivity of the extinguishing media is of importance. Note: When electrical equipment is de-energized, fire extinguishers for Class A or B fires may be used safely. The following hazard ratings are applicable to the facility: Low Hazard – Locations where the total amount of Class “A” combustible materials, including furnishings, decorations, and contents is of minor quantity. This includes rooms occupied as offices, meeting rooms, etc. This hazard classification assumes that the majority of content items is either noncombustible or are so arranged that fire is not likely to spread rapidly. Small amounts of Class “B” flammables used for office equipment, etc., are included provided that they are kept in closed containers and safely stored. Moderate Hazard – Locations where the total amount of Class “A” combustibles and Class “B” flammables present are present in greater amounts than expected in the low hazard occupancy described above. These types of areas include storage rooms and the warehouse, assuming that flammable materials and liquids are stored elsewhere and other combustible materials are stored with suitable air space and segregation. High Hazard – Locations where the total amount of Class “A” combustibles and Class “B” flammables present, in storage and/or use is over and above that expected in the moderate occupancy described above. These areas consist of vehicle and other equipment repair areas, laboratory areas where flammable gases and/or flammable liquids and combustible chemicals are in use, storage and usage areas for paints, solvents, fuel, and other flammable liquids. Class “C” (energized electrical equipment) fires are not taken into consideration when making the hazard determinations above, because, electrical fires are normally confined to the equipment where the fire originated unless substantial amounts of Class “A” combustibles or Class “B” flammables are present and could be ignited by an electrical fire. In most cases, electrical equipment which is de-energized is considered to be a Class “A” fire. The facility is provided with the following type of fire extinguishers: Multi-purpose Dry Chemical: Rated for Class “A”, “B”, and “C” fires. The potential fire hazards and levels of risk for the various areas of the facility are shown in Table 1.

Table 1: WTP Fire Hazards Hazard Rating and Potential Fire Extinguisher Media Area Classifications Requirement Offices, Corridors, etc. Low Hazard - Class “A” Dry Chemical Maintenance Areas High Hazard - Class “A” and “B” Dry Chemical Storage Areas High Hazard - Class “B” Dry Chemical Electrical Areas Low Hazard - Class “C” Dry Chemical Control Areas Low Hazard - Class “A” and “C” Dry Chemical Equipment Rooms Low Hazard - Class “A” and “C” Dry Chemical Outside Equipment Areas Low Hazard - Class “A” and “C” Dry Chemical

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3.2.1 Emergency Preparedness for Fire In preparing for fire emergencies, a number of things must be considered. These considerations include, but are not limited to, the following requirements:  Proper training of WTP personnel in the use of fire extinguishers and evacuation procedures.  Maintenance of current evacuation maps and plans. Evacuation maps and plans are the direct responsibility of the safety supervisor. An evacuation map will need to be finalized once the final designs have been completed and WTW built.  Properly maintained escape routes and exits, kept free of obstructions, and provided with directional signs, in English and Sesotho, posted and easily visible under conditions of poor visibility.  Properly maintained fire and smoke alarms, with personnel properly trained in fire and smoke alarm response and maintenance.  Fire extinguishers, of proper type and distribution, maintained and inspected monthly by the safety supervisor, with annual or greater time period inspections performed by an authorized fire extinguisher company, as required. Fire extinguisher locations must be clearly marked and kept free of obstructions. Refer to Appendix C for fire extinguisher locations and other requirements (will need to be finalized once the final designs have been completed and WTW built).  Coordination with the local fire department is essential to effective preparedness for fire. Local fire officials should be invited to inspect the facilities and WTP officials should provide the fire officials with a review of the types of fire hazards expected to be encountered at the various locations throughout the facility. Based on this review and input from participating fire officials, a facility plan showing the locations of the various fire hazards should be developed and kept available for reference by both the local fire department and the safety supervisor. 3.2.2 Emergency Response Plan for Fire The Plant Manager, or his duly authorized on-site alternate, must immediately after relocating to a safe area if necessary, make every effort to determine the extent of the fire and the threat to human life and property. If an assessment of the emergency reveals a high potential threat, or if the threat cannot be rapidly determined, proceed to Section 3.2.2.1. If it is rapidly determined that the immediate threat is low, proceed to Section 3.2.2.2.

Note: Any fire in the generator area, or any flammable liquid fire, must be considered a high threat fire, regardless of the initial size of the fire. Upon notification of a fire or receipt of a fire alarm the procedures outlined below must be carried out. 3.2.2.1 High Threat Fires High threat fires are defined as; any fire which poses an immediate threat to human life or property.

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1. Initiate evacuation procedures for areas threatened by smoke or fire. This action may be limited to a single structure or area within a structure, or may involve a number of structures depending upon the size of the fire. 2. Notify the local fire department and other civil authorities, as appropriate. 3. Position a person at the facility entrance, such that they can lead or direct emergency personnel to the location of the emergency. 4. Immediately upon evacuation, perform a roll call of on-duty personnel in order to determine if any personnel are missing and possibly trapped. 5. Treat injured personnel with first aid and transport such personnel to the nearest suitable medical facility, as necessary. Note: This activity may involve a combination of ambulances and WTP transportation, depending upon the number of injured ERP and the extent of their injuries. Also, continuation of this activity, for some period of time, may be necessary if personnel are trapped or missing in the fire. 6. Upon arrival of the fire department, alert fire officials to any potential hazards in the fire area and, if any personnel are missing, advise fire officials of the missing personnel and the most probable locations of such personnel. 7. Once the fire has been extinguished and it is safe to return to the facilities or areas affected, proceed to Section 3.3.3.3 (Recovery). 3.2.2.2 Low Threat Fires Low threat fires are defined as; localized, isolated fires that do not pose an immediate threat to human life or property. 1. Dispatch someone from the fire area to notify the senior manager on duty of the fire. In cases where there is only one person present, call in the alarm and proceed to step 2. Refer to Appendix A for emergency telephone numbers. 2. On-location personnel extinguish the fire using portable fire extinguishers of the proper type. WARNING: Should attempts at extinguishing a fire with portable fire extinguishers fail and/or the fire begins to grow in intensity or spread; vacate the immediate area, call in the alarm and proceed with the actions defined in Section 3.2.1. 3. Upon extinguishment of the fire, perform any clean-up activities necessary to return the area to normal. 3.2.3.3 Recovery These procedures should not be accomplished until such time as the fire has been extinguished and it has been determined that it is safe to return to the affected areas. 1. Recall off-duty Safety Committee members and other staff, as appropriate, to assist in damage evaluation and clean up. 2. Safety Committee members or the most senior staff members available perform a visual inspection of the damage in order to ensure that such damage does not present a further threat to personnel. 3. Based upon damage evaluations, the Safety Committee and other staff, as appropriate, develop and implement a recovery plan to quickly and safely return facility operations to normal. 4. Under the direction of facility managers and supervisors, facility personnel perform general clean-up operations.

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3.3 ON-SITE POTABLE WATER CONTAMINATION Contamination of on-site potable water supplies poses a threat to the health of facility personnel and, if unchecked, can significantly impact facility operations. 3.3.1 Emergency Preparedness for On-Site Potable Water Contamination An on-site supply of bottled potable water should be maintained, in sufficient quantity to provide for potable water needs for a period of not less than two days. Alternatively, a local source of bottled potable water should be assured. Such a source of supply must be capable of supplying the facility with potable bottled water, in sufficient quantities, within an hour of notification. 3.3.2 Emergency Response Plan for On-Site Potable Water Contamination This procedure only pertains to dealing with contaminated potable water within the facility. 3.3.2.1 Notification Procedures 1. Warn all facility personnel to not drink tap water until further notice. 2. Post the following warning at all potable water outlets. "WATER IS UNSAFE TO DRINK" 3. Alert local public health authorities to the water contamination problem. 4. Proceed to Section 3.3.2.2 and carry out corrective action procedures. 3.3.2.2 Corrective Action Procedures 1. Locate the source of contamination and correct the problem. 2. Disinfect the potable water system in accordance with the disinfection instructions in the EMP. 3. Test the water supply, or have the water supply tested, for contamination of the following:  Coliforms bacteria  Other contaminants, as necessary 4. Return the potable water system to normal operation after it has been determined that the water is safe to drink. 5. Notify personnel that the water is safe to drink and remove all posted warnings. 3.4 PUBLIC POTABLE WATER SUPPLY CONTAMINATION There is a significant risk of public water supply contamination from within the WTP. Such contamination could be the result of equipment failures, inadvertent spills of contaminants, contaminated raw water or an act of terrorism. 3.4.1 Emergency Preparedness for Public Potable Water Supply Contamination The nature of this type of emergency and its possible impact on public health is such that containment and resolution of the emergency must involve the outside authorities responsible for public health and safety. If plant operating parameters are normal, the first hint of a problem with the water supply may come from public sources, i.e., complaints or people becoming ill from drinking the water.

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In addition to the response plan public health and safety authorities, such as the Ministry of Health and Social Welfare (MOHSW) and local police, must be consulted and a joint response plan developed that clearly defines the roll of each entity in an emergency of this type. 3.4.2 Emergency Response Plan for Public Potable Water Supply Contamination Caution: Plant personnel must take appropriate safety precautions to prevent unprotected contact with contaminants.

3.4.2.1 Initial Response 1. Regardless of the cause or type of contamination, plant operations must be shut down immediately. 2. Notify public health and safety authorities, such that they can take immediate steps to warn and protect the public. 3. If not already known, examine the raw and treated water in the plant to determine the type and source of contamination. 4. Working with outside authorities, examine the water in the distribution system to determine the extent of contamination.

3.4.2.2 Biological Contamination Coordinate and work with public health and safety authorities as necessary to accomplish the following procedure. 1. Clean up or stop the source or cause of contamination. 2. Disinfect contaminated components of the plant or distribution system.  If the contamination involves a process unit in the plant, isolate the unit and treat the contamination with a dose of 10-20 mg/ℓ of chlorine for 24 hours or until testing verifies complete disinfection.  Short sections of pipeline may be flushed and disinfected with a 50 mg/ℓ dose of chlorine in order to return the line to service as soon as possible. For longer sections of pipeline, a 50 mg/ℓ dose would be prohibitive and a lower dose of chlorine may be used, with a longer retention time. In any case testing is necessary to verify complete disinfection. Caution: Water containing high concentrations of chlorine must be drained to waste. Do not allow such water to flow normally through the distribution system. 3. Obtain the consent of public health and safety authorities prior to returning the plant to normal operations. 3.4.2.3 Chemical Contamination Coordinate and work with public health and safety authorities as necessary to accomplish the following procedure. 1. Clean up or stop the source or cause of contamination. Refer to Section 3.6 for procedures on hazardous material emergencies.

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2. Flush contaminated components of the plant and distribution system with good treated water as necessary to remove all traces of contamination. Caution: Water containing high concentrations of contaminants must be drained to waste. Do not allow such water to flow normally through the distribution system. 3. Obtain the consent of public health and safety authorities prior to returning the plant to normal operations. 3.4.2.4 Contamination from External Sources If the source of contamination is outside of the facility, work with public health and safety authorities to facilitate clean up of the source and decontamination of the system. Return to normal operations only with the consent of the public health and safety authorities. 3.5 HYDRAULIC RUPTURES AND STOPPAGES These types of emergencies do not normally threaten human life or property, unless unchecked. These operational emergencies are dealt with by operations personnel and, when necessary, maintenance personnel. 3.5.1 Pipe Failure and Ruptures 1. By closing appropriate valves, isolate the area or system that has experienced a pipe failure or rupture. If isolation is not practical, then shut down the system or close off flow at the source. 2. Notify the maintenance supervisor and have maintenance personnel make repairs and/or replacements, as necessary. 3. After repairs have been satisfactorily completed, restore the affected system to normal operations. 3.5.2 Stoppages 1. Locate and isolate the stoppage. If isolation is not practical, then shut down the system or close off flow at the source. Set up a bypass flow line, if necessary. If the stoppage is causing low flow in the line, proceed with step 2. If the stoppage has closed of the flow completely, proceed to step 3. 2. Stoppage that causes low flow in the line may be flushed with water, thus clearing the stoppage. If this action fails to clear the stoppage, proceed with step 3. If this action successfully clears the stoppage, proceed to step 4. 3. Stoppage that closes off flow completely should be cleared by pumping out the line and clearing the stoppage manually. 4. After clearing the stoppage, restore the affected system to normal operation. 3.6 HAZARDOUS MATERIALS The potential for hazardous materials contamination at the WTP is high. Such hazardous gases include chlorine, and other gases that are incidental to industrial spills or accidents. In addition to hazardous gases, the WTP employs a number of hazardous substances during normal operation of the facility. Such substances are normally found when performing custodial and maintenance activities.

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3.6.1 Emergency Preparedness for Hazardous Materials The safety supervisor is responsible for maintaining data on all hazardous materials in use at the facility and any hazardous materials from outside sources, which may affect the facility. Hazardous material data must include quantities, locations, types of hazard, and information on procedures for neutralizing spills and decontamination. Furthermore, the safety supervisor must maintain procedures for providing first aid to personnel affected by hazardous materials and procedures for decontaminating such personnel.

The equipment necessary for detecting hazardous gas concentrations must be provided and maintained. Other safety equipment must be provided and maintained, as appropriate.

Whether hazardous material contamination is caused by sources internal to the WTP or from sources outside the facility, the emergency response to such contamination is the same. Hazardous material contamination may affect a particular area or part of the facility, or it may affect the entire facility depending upon the type and extent of the contamination.

Spills or contamination involving flammable/explosive liquids or gases, present the potential hazard of fire. For spills or contamination involving such materials, evacuation of personnel must be given primary consideration. 3.6.2 Emergency Response Plan for Hazardous Materials The Plant Manager, or his duly authorized on-site alternate, must immediately after relocating to a safe area if necessary, make every effort to determine the extent of the contamination and the threat to personnel. 1. Identify the area of contamination, and the potential extent of contamination. Evacuate the immediate area. If the contamination is airborne, evacuate any areas downwind of the contamination. In such cases, ensure that personnel are evacuated upwind of the contamination. 2. If contamination involves materials that are explosive or flammable in nature, notify the local fire department. 3. Position a person at the facility entrance, such that they can lead or direct emergency personnel to the location of the emergency. 4. Take any measures necessary to decontaminate affected personnel. Provide first aid as necessary, and transport injured personnel by ambulance to the closest suitable medical facilities, as necessary. Refer to Appendix A for emergency telephone numbers. 5. If hazardous gas is causing contamination, use the proper metering device (gas meter or detector) and appropriate safety precautions. Test the air for hazardous gases in and around affected areas. 6. Taking appropriate safety precautions remove or clean up the contamination. Such actions may involve actions as simple as ventilating affected areas, or as complicated as removing contaminated soil and other materials to a safe disposal area. 7. Ensure that personnel do not return to evacuated areas until such time as there is no potential hazard from contamination. Where contamination is from an outside source, determine the source and ensure that there is no immediate danger of recontamination from such a source, prior to allowing personnel to return to affected areas.

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3.7 CIVIL UNREST Whether the facility is directly involved or not, civil unrest has the potential to severely impact the facility’s ability to function normally. Even if civil unrest occurs a distance from the facility itself, the ability of personnel to travel to and from the facility may be severely impacted.

3.7.1 Emergency Preparedness for Civil Unrest A primary consideration in preparing for the potential of civil unrest is the safety of facility personnel. A secondary consideration is the potential of damage to WTP property. If civil unrest impacts the safety of personnel and their ability to travel to and from work, consideration must be given to housing personnel on-site for the duration of period of unrest.

3.7.2 Emergency Response Plan for Civil Unrest Section 3.7.2.1 outlines procedures to follow for civil unrest that has the potential of directly affecting the facility. Section 3.7.2.2 outlines procedures to follow if civil unrest occurs in the local area, but some distance from the facility, and could affect personnel as they travel to and from work.

3.7.2.1 Civil Unrest in the Immediate Area 1. Keep personnel at their workstations, unless they are directly threatened. 2. Notify local police and military authorities and request help, as appropriate. 3. Security guards will secure the facility perimeter. If necessary, additional staff may be used to monitor the perimeter. 4. Alert all facility personnel. Personnel should be prepared to report any problems. 5. If the perimeter security of the facility is breached, evacuate all personnel to a secure indoor area. 6. After the period of unrest has past, restore the facility to normal operation. If security of the facility was breached, a thorough inspection of the facility and equipment must be accomplished prior to restoring normal operation. 3.7.2.2 Civil Unrest in the Local Area 1. Increase perimeter security of the facility, as appropriate. 2. Ensure that the ability of personnel to travel to and from work is not impacted. If necessary, house the personnel needed to maintain facility operation on-site. 3. After the period of unrest has past, restore normal operations. 3.8 EARTHQUAKES In addition to the hazards normally associated with earthquakes, particularly structural damage to buildings and the potential of injuries associated with such damage, consideration must be given to the potential for the loss of electrical power, cut off or contaminated water supplies, and disrupted means of communication and transportation, which may last for an extended period of time.

3.8.1 Emergency Preparedness for Earthquakes Depending upon the severity of an earthquake, structural damage to the facilities, disruption of electrical service, and other factors make shutdown of the WTP for an extended period of time a distinct possibility. Furthermore, disruption in communications and transportation may severely impact the ability of the WTP to maintain normal operations after an earthquake of even moderate proportions.

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3.8.2 Emergency Response Plan for Earthquakes 1. Stay calm; seek refuge under desks, doorways, main structural beams, etc. DO NOT enter stairways during an earthquake. Remember, most earthquakes last less than a minute, there is no time to evacuate, seek refuge in the immediate area, away from potential falling objects. 2. After the earthquake stops, proceed to the nearest exit and evacuate the buildings and other structures in an orderly fashion. Evacuation should follow the routes defined in Appendix B. 3. Immediately upon evacuation, perform a roll call of on-duty personnel in order to determine if any personnel are missing and possibly trapped. 4. Treat injured personnel with first aid and transport such personnel by ambulance to the nearest suitable medical facility, as necessary. Note: This activity may involve a combination of ambulances and WTP transportation, depending upon the number of injured people and the extent of their injuries. Also, continuation of this activity, for some period of time, may be necessary if personnel are trapped or missing. 5. Initiate other emergency procedures, such as fire procedures, power outage procedures, etc., as appropriate. If the WTP has incurred significant damage, it may be necessary to shut down the facility. 6. Notify off-site personnel on the emergency notification list, as appropriate. 7. The Safety Committee should proceed to evaluate all buildings and structures for damage and potential hazards prior to entering areas to look for victims. Where damage has occurred to structures, it may be necessary to have a qualified structural engineer evaluate the integrity of damaged structures before allowing any personnel to enter the area. 8. Only allow personnel to return to work after it has been determined that no hazards exist. Remember, it is not unusual for strong after shocks to occur following a major earthquake. 3.9 EXPLOSIONS Explosions can be a catastrophic emergency, not only because of the potential for extreme damage from the initial blast, but because explosions generally ignite fires. Therefore, WTP personnel are not only faced with the potential for structural damage and injury caused by the explosion, but must also contend with fire in the aftermath of an explosion. The potential for loss of life or injury to personnel and for significant damage to facility equipment and structures is extremely high. 3.9.1 Emergency Preparedness for Explosions In preparing for explosion emergencies, a number of things must be considered. These considerations include, but are not limited to, the following requirements:  Proper training of WTP personnel in the use of fire extinguishers and evacuation procedures.  Maintenance of current evacuation maps and plans for the facility. Evacuation maps and plans are the direct responsibility of the safety supervisor. Refer to Appendix B for the facility evacuation map.

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 Properly maintained escape routes and exits, kept free of obstructions, and provided with directional signs, in English and Sesotho, posted and easily visible under conditions of poor visibility.  Fire extinguishers, of proper type and distribution, maintained and inspected monthly by the safety supervisor, with annual or greater time period inspections performed by an authorized fire extinguisher company, as required. Fire extinguisher locations must be clearly marked and kept free of obstructions. Refer to Appendix C for fire extinguisher locations and other requirements. 3.9.2 Emergency Response Plan for Explosions The Plant Manager, or his duly authorized on-site alternate, must immediately after relocating to a safe area if necessary, make every effort to determine the extent of the explosion and the threat to human life and property. Any fires resulting from an explosion necessitate activation of the emergency response plan for fire, in accordance with Section 3.3.2. Any structural collapse resulting from an explosion necessitates activation of the emergency response plan for structural collapse, in accordance with Section 3.11. 3.9.2.1 Initial Response 1. Initiate evacuation procedures for the immediate area where an explosion has occurred. This action may be limited to a single structure or an area within a structure depending upon the size of the explosion, the extent of damage, the potential for further structural collapse, and the possibility of spreading fire resulting from the explosion. Evacuation of the WTP should follow the routes defined in Appendix B. 2. Notify the local fire department and other civil authorities, as appropriate. 3. Position a person at the facility entrance, such that they can lead or direct emergency personnel to the location of the emergency. 4. Initiate other emergency procedures, such as fire procedures, power outage procedures, etc., as appropriate. If the facility has incurred significant damage, it may be necessary to shut down the facility. 5. Immediately upon evacuation, perform a roll call of on-duty personnel in order to determine if any personnel are missing and possibly trapped. 6. Treat injured personnel with first aid and transport such personnel by ambulance to the nearest suitable medical facility, as necessary. Note: This activity may involve a combination of ambulances and WTP transportation, depending upon the number of injured people and the extent of their injuries. Also, continuation of this activity, for some period of time, may be necessary if personnel are trapped or missing in the fire. 7. Upon arrival of the fire department, alert fire officials to any potential hazards in the area of the explosion and, if any personnel are missing, advise fire officials of the missing personnel and the most probable locations of such personnel. 8. Once the area of the explosion has been inspected and any resultant fires have been extinguished and it is safe to return to the facilities or areas affected, proceed to Section 3.9.2.2. 3.9.2.2 Recovery

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These procedures should not be accomplished until such time as the structure in the area of the explosion has been inspected by qualified personnel and any resultant fires have been extinguished and it has been determined that it is safe to return to the affected area. 1. Recall off-duty Safety Committee members and other staff, as appropriate, to assist in damage evaluation and clean-up. 2. Safety Committee members or the most senior staff members available perform a visual inspection of the damage in order to ensure that such damage does not present a further threat to personnel. Where damage has occurred to structures, it may be necessary to have a qualified structural engineer evaluate the integrity of d aged structures before allowing any personnel to enter the area. 3. Based upon damage evaluations, the Safety Committee and other staff, as appropriate, develop and implement a recovery plan to quickly and safely return facility operations to normal. 4. Under the direction am of section managers and supervisors, facility personnel perform general clean-up operations. 3.10 STRUCTURAL COLLAPSE In addition to the hazards normally associated with structural collapse, particularly the potential of injuries associated with such damage, consideration must be given to the potential for loss of electrical power, cut off or contaminated water supplies, and disrupted means of communication and transportation, which may last for an extended period of time. 3.10.1 Emergency Preparedness for Structural Collapse Depending upon the severity of a collapse (i.e., the structural damage to the facility), disruption of electrical service, and other factors make shutdown of the WTP, for an extended period of time, a distinct possibility. Furthermore, disruption in communications and transportation may severely impact the ability of the WTP to maintain normal operations after a structural collapse of even moderate proportions. Structural collapse may occur with some warning (i.e., a roof or wall beginning to crack or sag) or may occur with little or no warning. 3.10.2 Emergency Response Plan for Structural Collapse 1. If a collapse occurs with no warning, Stay calm; seek refuge under desks, doorways, main structural beams, etc. DO NOT enter stairways. After the collapse stops, proceed to the nearest exit and evacuate the building and other structures in an orderly fashion. Evacuation should follow the routes defined in Appendix B. 2. If some warning of imminent collapse is evident, alert the senior WTP official on-site, proceed to the nearest exit, and evacuate the building and other structures in an orderly fashion. Evacuation should follow the routes defined in Appendix B. 3. Immediately upon evacuation, perform a roll call of on-duty personnel in order to determine if any personnel are missing and possibly trapped. 4. Treat injured personnel with first aid and transport such personnel by ambulance to the nearest suitable medical facility, as necessary. Note: This activity may involve a combination of ambulances and WTP transportation, depending upon the number of injured people and the extent of their injuries. Also, continuation of this activity, for some period of time, may be necessary if personnel are trapped or missing.

24 DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

5. Initiate other emergency procedures, such as fire procedures, power outage procedures, etc., as appropriate. If the WTP has incurred significant damage, it may be necessary to shut down the facility. 6. Notify off-site personnel on the emergency contact list (Appendix A), as appropriate. 7. The Safety Committee should proceed to evaluate all buildings and structures for damage and potential hazards prior to entering areas to look for victims. Where damage has occurred to structures, it may be necessary to have a qualified structural engineer evaluate the integrity of damaged structures before allowing any personnel to enter the area. 8. Based upon damage evaluations, the Safety Committee and other staff, as appropriate, develop and implement a recovery plan to quickly and safely return facility operations to normal. 9. Under the direction of section managers and supervisors, facility personnel perform general clean-up operations.

3.11 CHLORINE LEAKS The potential for chlorine leaks represents a significant hazard at the WTP.

3.11.1 Emergency Preparedness for Chlorine Leaks Emergency preparedness for chlorine leaks includes the requirements contained in Section 3.6, Hazardous Materials, above. In addition, self-contained breathing apparatus and 1-ton container emergency repair kits must be provided and maintained on-site. A chlorine leak may affect a particular area or part of the WTP, or it may affect the entire facility and the surrounding area, depending upon the type and extent of the leak. Evacuation of personnel within the facility and ERP working and/or residing in the surrounding area must be given primary consideration. Detailed procedures for use of emergency equipment and performing chlorine leak repairs are addressed in the EMP. 3.11.2 Emergency Response Plan for Chlorine Leaks The Plant Manager or his duly authorized on-site alternate must, immediately after relocating to a safe area if necessary, make every effort to determine the extent of the leak and the threat to personnel and other ERP in the area. 1. Evacuate the facility immediately. Ensure that personnel are evacuated upwind of the leak and a safe distance away. It is recommended that all ERP in the surrounding area be evacuated, upwind and downwind of the leak, since wind direction can change suddenly. Particular attention must be paid to evacuating nearby schools, if schools are in session. 2. Notify the local fire department and police department immediately. Their help in evacuating residences, businesses, etc., and controlling traffic in the area of the facility will be needed. 3. If the leak is extensive, it may be necessary to stop traffic on the road next to the facility and on other roads behind the facility. Stop traffic in both directions, at least ½ kilometer away from the facility. 4. Identify the area where the leak is, and the potential extent of the leak.

25 DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

5. Take any measures necessary to decontaminate affected personnel. Provide first aid, as necessary, and transport injured personnel to the closest suitable medical facilities, as necessary. 6. Repair the leak while taking appropriate safety precautions. Ventilate affected areas, as necessary. In most cases, the leak will occur where the chlorine scrubber system will effect decontamination of the air in the affected areas. 7. Ensure that evacuated people do not return to the area until such time as there is no potential hazard from the leak or residual chlorine gas. The following typical measures are to be applied in terms of the instructions on the MSDS of chlorine gas: FIRST AID MEASURES INHALATION: If adverse effects occur, remove to uncontaminated area. Give artificial respiration if not breathing. If breathing is difficult, oxygen should be administered by qualified personnel. Get immediate medical attention. SKIN CONTACT: Wash skin with soap and water for at least 15 minutes while removing contaminated clothing and shoes. Get immediate medical attention. Thoroughly clean and dry contaminated clothing and shoes before reuse. Destroy contaminated shoes. EYE CONTACT: Immediately flush eyes with plenty of water for at least 15 minutes. Then get immediate medical attention. INGESTION: Contact local poison control center or physician immediately. Never make an unconscious person vomit or drink fluids. Give large amounts of water or milk. Allow vomiting to occur. When vomiting occurs, keep head lower than hips to help prevent aspiration. If person is unconscious, turn head to side. Get medical attention immediately. NOTE TO PHYSICIAN: For inhalation, consider oxygen. Avoid gastric lavage or emesis.

HANDLING AND STORAGE STORAGE: Store and handle in accordance with all current regulations and standards. Protect from physical damage. Keep separated from incompatible substances. Store outside or in a detached building. Notify State Emergency Response Commission for storage or use at amounts greater than or equal to the TPQ (U.S. EPA SARA Section 302). SARA Section 303 requires facilities storing a material with a TPQ to participate in local emergency response planning (U.S. EPA 40 CFR 355.30).

ACCIDENTAL RELEASE MEASURES AIR RELEASE: Reduce vapors with water spray. Collect runoff for disposal as potential hazardous waste. SOIL RELEASE: Dig holding area such as lagoon, pond or pit for containment. Dike for later disposal. Trap spilled material at bottom in deep water pockets, excavated holding areas or within sand bag barriers. Absorb with sand or other non-combustible material. Add an alkaline material (lime, crushed limestone, sodium bicarbonate, or soda ash). WATER RELEASE: Add an alkaline material (lime, crushed limestone, sodium bicarbonate, or soda ash). Absorb with activated carbon. Collect spilled material using mechanical equipment. OCCUPATIONAL RELEASE:

26 DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

Stop leak if possible without personal risk. Avoid contact with combustible materials. Keep unnecessary people away, isolate hazard area and deny entry. Ventilate closed spaces before entering. Notify Local Emergency Planning Committee and State Emergency Response Commission for release greater than or equal to RQ (U.S. SARA Section 304). 4 ADDITIONAL REQUIREMENTS 4.1 EMERGENCY CONDITION EVALUATION REPORT After an emergency has occurred and operation of the facility has returned to normal condition, the Safety Committee prepares an emergency condition evaluation report and submits it to the Plant Manager. The Emergency Condition Evaluation Report includes the following information:  Cause(s) of the emergency  Effect of the emergency on plant operation  Type and extent of damage to plant equipment/facilities  Estimated cost of necessary repairs and/or recovery  Estimated time out-of-service for damaged equipment  Completed accident reports in case of personal injury 4.2 SAFETY EQUIPMENT INSPECTIONS Safety equipment must be maintained in working order. Such equipment must be inspected at least every thirty (30) days, and tested as appropriate. Such equipment must be maintained and tested as part of the on-going preventive maintenance program. 4.3 SAFETY EQUIPMENT LOCATIONS Floor plans showing safety equipment locations must be prepared and maintained. Such floor plans must be posted at every entrance/exit, at every corridor intersection, and every stairway entrance. Normal and emergency exits must also be shown on such floor plans. 4.4 PERSONNEL TRAINING Personnel must be trained on emergency response procedures. The frequency of repetitive training must be such that personnel are proficient, well versed and well practiced in responding to various emergencies. Such training must be a part of the on-going training program. 4.5 EMERGENCY CONTACT TELEPHONE NUMBERS A list of emergency contact telephone numbers must be maintained and kept current. Appendix A contains an initial list of names and telephone numbers. It is the responsibility of the safety supervisor to maintain this list and keep it updated. 4.6 EVACUATION PLAN Evacuation maps for the facility are yet to be developed but typically would be contained in Appendix B. It is the responsibility of the safety supervisor to maintain this information and keep it updated. The safety supervisor is to designate primary and secondary evacuation routes and exits. These routes are to be clearly marked and well lit. Signs are to be posted. Emergency lighting is to be installed in case a power outage occurs during an evacuation.

27 DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

The safety supervisor is to ensure that evacuation routes and emergency exits are wide enough to accommodate the number of evacuating personnel and that they are:  Clear and unobstructed at all times  Unlikely to expose evacuating personnel to additional hazards Ideally, evacuation routes are to be evaluated by someone not in the WTP organization. 4.7 PERSONAL EMERGENCIES In some cases emergencies affect individuals or small groups of individuals, but do not affect the facility as a whole. Such emergencies would include personal injury, confined space rescue and other similar occurrences. The following reference materials should be housed in the WTW offices library to provide information and procedures for:  First aid  CPR  Confined space retrieval  Personal injuries  Heat stroke  Dehydration  Electrocution and shock  Drowning  Dismemberment  Asphyxiation  Drowning  Poisoning  Poisonous bites (snakes, spiders, scorpions and other insects) 4.8 MANAGED DELIVERIES Establish a policy that an authorized person, designated by the water system, must accompany all deliveries. Verify the credentials of all drivers. This prevents unauthorized personnel from having access to the water and wastewater works. 4.9 VERIFICATION OF SUPPLIERS Verify that facility suppliers take precautions to ensure that their products are not contaminated. Chain of custody procedures for delivery of chemicals should be reviewed. Facility Stores Manager is to inspect chemicals and other supplies at the time of delivery to verify they are sealed and in unopened containers. Match all delivered goods with purchase orders to ensure that they were, in fact, ordered by your water system. Stores manager is to keep a log or journal of deliveries. It should include the driver’s name (taken from the driver’s photo I.D.), date, time, material delivered, and the supplier’s name 4.10 SECURE CHEMICAL STORAGE AREA All chemicals should be stored in an area designated for their storage only, and the area should be secure and access to the area restricted. Access to chemical storage should only be available to authorized employees.

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4.11 MONITORING OF SOURCES AND PRODUCT Monitoring of raw and treated wastewater can establish a baseline that may allow you to know if there has been a contamination incident. Some parameters for raw wastewater include: pH, suspended solids, total and faecal coliform count, electrical conductivity. Ammonia, nitrate/nitrite, kjeldal nitrogen, phosphate, BOD and COD.

To assess whether a plant is working efficiently analyses would be taken of the final effluent and be analysed for the following parameters: pH, Conductivity, Suspended Solids, OA, COD, BOD, Ammonia, Nitrates, Phosphates. 4.12 PROTECTION OF VENTS AND OVERFLOWS Air vents and overflow pipes are direct conduits to the finished water in storage facilities. Secure all vents and overflow pipes with heavy-duty screens and/or grates. The use of tamper-proof padlocks at entry points (hatches, vents, and ladder enclosures) will reduce the potential for unauthorized entry to reservoirs and distribution tanks. If facility has towers, consider putting physical barriers on the legs to prevent unauthorized climbing. 4.13 SYSTEM BY-PASS FACILITIES Install shut-off or bypass valves to allow you to isolate the storage tank in the case of a contamination problem or structural damage. Consider installing a sampling tap on the storage tank outlet to test water in the tank for possible contamination.

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Appendix A Emergency Contact List (to be further developed and expanded on once plant is operational and agreements with external parties are in place)

DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

Organisation Contact Number 1 Appointed and elected emergency response plan (to be appointed once plant is leaders operational) 2 Fire 3 Police 00266-22317262 4 Emergency medical services personnel 5 Local Emergency Planning Committee (LEPC) members 6 Emergency management director To be appointed 7 Department of Public Works & Transport 8 American Red Cross 9 QE II Hospital (will change to new Referral Hospital) 00266-22312501 10 Tele-Com Lesotho 00266-22211000 11 Lesotho Electricity Corporation (LEC) – 24 Hours 00266-22312236 Service 12 Neighbourhood groups (e.g. Dam Committee) 13 Neighbourhood groups (e.g. Dam Committee) 14 Andrew’s Fire and Alarms (Fire extinguisher +27834399014 company) 15 The National Environment Secretaria 00266-22311767

DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

Appendix B

Emergency Evacuation Routes (to be prepared once layout is finalised by Design Engineers)

DRAFT METOLONG WTW EMERGENCY RESPONSE PLAN

Appendix C Fire Extinguisher Locations

(to be prepared once layout is finalised by Design Engineers)

METOLONG WATER TREATMENT WORKS

APPENDIX D Impact assessment methodology

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IMPACT ASSESSMENT METHODOLOGY The potential impacts identified during the ESIA (separate document) and summarised in Table 4.1 in Chapter 4, were assessed in accordance with a structured methodology that combines the classical impact assessment methodology with a risk assessment approach through using the extent, intensity and duration ratings to define a score of “consequence” of the impact, which is then used to define impact significance. Significance ratings are defined to assist decision-makers determine the extent to which an impact should influence decision-making. The approach is based on an explicit and transparent scoring system to avoid subjective and haphazard assignments of significance ratings. The approach has been used elsewhere in other environmental assessments with different categorisation of extent and duration depending on the nature of the project. For example, in an offshore environment, deep sea oil drilling is associated with impacts of very different extent and duration than the WTW, which is more localised. The ESIA and EMP have used a different scoring system with former using six levels and the EMP using three levels of significant rating. The six levels of significance ratings in the ESIA where combined into three after recommendations from NES and these three levels used in this EMP. The six levels used in the ESIA were combined as follows:  insignificant, very low and low are represented as Low in EMP;  Medium will still be medium in both documents;  High and very high could be represented by High in EMP

Significance ratings as used in the EMP are defined as follows:  Low: the potential impact may not have any meaningful influence on the decision regarding the proposed activity;  Medium: the potential impact should influence the decision regarding the proposed activity;  High: the potential impact will affect a decision regarding the proposed activity, and Criteria used to determine the Consequence of the Impact.

Rating Definition of Rating Score A. Extent– the area in which the impact will be experienced Local Confined to within a 2km radius around the WTW 1 Regional Confined to within a 30km radius around the WTW 2 (Inter) >30km radius - effects extend at National (Lesotho) level and possibly 3 National International (RSA) level B. Intensity– the magnitude or size of the impact Low Natural and/or social functions and processes are negligibly altered 1 Medium Natural and/or social functions and processes continue albeit in a 2 modified way High Natural and/or social functions or processes are severely altered 3 C. Duration– the time frame for which the impact will be experienced Short-term A few months or periodically during construction 1 Medium-term Whole of construction 2-3 years 2 Long-term More than 5 years 3

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The combined score of these three criteria corresponds to a consequence rating, as set out in the table below. Method used to determine the consequence score

Combined Score 0 – 2 3 – 4 5 6 7 8 – 9 (A+B+C) Consequence Rating Not Very low Low Medium High Very significant high Once the consequence is derived, the probability of the impact occurring is considered, using the probability classifications presented in the table below. Probability classification

Probability of impact – the likelihood of the impact occurring Improbable < 40% chance of occurring Possible 40% - 70% chance of occurring Probable > 70% - 90% chance of occurring Definite > 90% chance of occurring The overall significance of impacts is determined by considering consequence and probability using the rating system prescribed in the table below. Impact significance ratings

Significance Rating Consequence Probability Very Low & Improbable Very Low & Possible

Very Low & Probable Very Low & Definite Low Low & Improbable

Low & Possible Low & Probable Low & Definite Medium & Improbable Medium & Possible Medium Medium & Probable Medium & Definite High & Improbable High & Possible High & Probable High & Definite

High Very High & Improbable Very High & Possible Very High & Probable Very High & Definite

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Finally the impacts are considered in terms of their status (positive or negative) and the confidence in the ascribed impact significance rating is noted. The classification for considering the status of impacts and the confidence in assessment is laid out in the table below. Impact status and confidence in classification

Status of impact Indication whether the impact is adverse + ve (positive – a ‘benefit’) (negative) or beneficial (positive). – ve (negative – a ‘cost’) Neutral Confidence of assessment The degree of confidence in predictions based Low on available information, the Consultant’s judgment and/or specialist knowledge. Medium High Impacts were evaluated with and without the implementation of mitigation or optimisation which gives an indication of the effectiveness of mitigation or optimisation in managing or enhancing the consequences of the impact. Key impacts and their significance ratings and summary mitigation requirements are contained in Table 4.1 in Chapter 4.

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APPENDIX E Sludge management options specialist report (Golder 2009)

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APPENDIX E: SPECIALIST STUDY - SLUDGE HANDLING FROM METOLONG WATER TREATMENT WORKS

Metolong Wastewater Works EIA

Submitted to:

REPORT

Report Number: 12280

SPECIALIST STUDY - SLUDGE HANDLING

Executive Summary

The Lesotho Lowlands feasibility project identified a need for additional potable water for the rapidly growing city of Maseru. The Metolong Dam and Water Treatment Works have been proposed to address this issue. The proposed Water Treatment Works would consist of pre-chlorination, coagulation, sedimentation, dissolved air floatation, filtration (rapid sand filtration), stabilisation, disinfection and distribution. There may also be the need for UV processes and Powdered Activated Carbon (PAC). Waste streams from the process include a sludge stream and filter backwash water. It has been proposed that the filter backwash water will be recycled in the process or if it meets discharge effluent standards that is returned to the Phuthiatsana River. It is recommended that the water is settled prior to recycle and the solids disposed of with the sludge stream. The sludge produced at the works would need to be managed in an environmentally acceptable manner. The volume of sludge produced is estimated to be 14.5 tons/day. This value is based on average suspended solids water quality readings from samples taken on the Phuthiatsana River which is possibly a conservative approach as the suspended solids levels in the dam are typically lower than that in a river feeding a dam. The sludge will consist primarily of clay material, with approximately 5.6 % Lime, 0.25 % Iron, 0.01 % Manganese and 0.22 % Aluminium. Trace amounts of Cadmium, Copper, Calcium, Magnesium, Potassium, Sodium and Sulphate will also be present. Several reuse options are being considered for the sludge that will be produced in the process including the following:  Land application – blending with soils – Preferred option  Daily cover to landfill site – reduce the need for soil cover at the land fill site  Brick making additive – The clay rich sludge can be blended with clays used to produce bricks  Additive in the manufacture of cement – option is still being investigated and further testing will be required.  Blending with sewage waste – Acts as a conditioner and can assist with settling  Discharge to river – Not recommended due to environmental impacts associated. Estimates sludge volumes reported in this report are based on limited data available on samples taken from the Phuthiatsana River, at the future site of the Metolong Dam. It is recommended that bench scale testing and waste characterisation studies are undertaken by the Contractor prior to the detailed design phase of the project.

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Table of Contents

1.0 INTRODUCTION ...... 1

2.0 PROCESS ...... 1

2.1 Description ...... 1

2.2 Chemicals used ...... 10

2.2.1 Lime...... 10

2.2.2 Coagulants ...... 10

2.2.3 Powdered Activated Carbon ...... 10

2.3 Waste streams ...... 10

2.3.1 Sludge ...... 10

2.3.1.1 Volume ...... 10

2.3.1.2 Quality ...... 11

2.3.2 Supernatant & Filter backwash ...... 12

3.0 POSSIBLE MANAGEMENT MEASURES FOR SLUDGE ...... 12

3.1 Land application ...... 13

3.2 Daily cover on landfill sites ...... 14

3.3 Erosion control ...... 14

3.4 Brick making additive ...... 14

3.5 Additive in the manufacture of cement ...... 15

3.6 Blending with sewage sludge ...... 15

3.7 Discharge to river ...... 15

4.0 EVALUATION OF OPTIONS CONSIDERED ...... 15

5.0 CONCLUSIONS ...... 16

6.0 WORKS CITED ...... 16

TABLES Table 1: Water quality at Phuthiatsana River and treated water quality requirements from the Metolong WTW (as supplied by the LWJV). Highlighted values indicate exceedance of the SANS 241 standards for drinking water ...... 3 Table 2: Estimated volume of sludge ...... 11 Table 3: Estimate of metal and lime content in WTW sludge ...... 11

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1.0 INTRODUCTION The Lowlands Water Feasibility Study identified a need for an additional water source to Maseru. The purpose of the Metolong Dam, together with the Metolong Water Treatment Works (WTW), is to supplement Maseru’s current potable water supply. The WTW will produce waste in the form of sludge. The sludge will be settled, resulting in the liquid supernatant and residual solids. The waste produced will need to be managed in an environmentally sound manner. Increased costs associated with waste handling and land availability results in a need for further investigations into the characteristics of the waste produced and management options available. The majority of residuals from typical WTW fall into one of four categories (Golder 2009):

 Naturally occurring, colloidal / particulate matter, e.g. clay, silt algae, removed from raw water by sedimentation, filtration, membrane or other processes and inert material in treatment chemicals, e.g. grit in lime.  Naturally occurring, soluble substances, e.g. iron, manganese, calcium and magnesium converted to their insoluble precipitate forms by oxidation or pH adjustments.  Precipitates formed, e.g. Al(OH)3, Fe(OH)3 when chemicals are added to water.  Spent materials, e.g. powdered activated carbon, filter media (sand, anthracite coal) that must periodically be removed from unit treatment processes after exceeding their useful lives.

Various management options that are typically used to dispose of residuals including the following:

 on-site and off-site disposal;  direct discharge to source stream; and  sludge reuse. Discharge of residuals to the source stream is not permitted on this project. Supernatant can be discharged to the source stream if Lesotho discharge effluent limits are met, or recycled to the headworks of the WTW. The various potential management options and the potential impacts associated with each option are described below.

The purpose of this report is to quantify the sludge produced and to investigate methods of disposal or reuse of the residuals.

2.0 PROCESS The water treatment process will consist of pre-chlorination, coagulation, dissolved air floatation, sedimentation, filtration, stabilisation and disinfection. Two systems are currently being proposed due to the uncertainty of whether there will be an algal problem or not. Refer to Appendix 1 for the WTW process flow diagrams of the proposed conventional process and a proposed slow sand filtration process (as supplied by SSI on 1 July 2009).

2.1 Description The proposed WTW will be designed to treat an average of raw water flow rate of 75 Mℓ/day, and peak flow rate of 93.4 Mℓ/day. Two potential processes are being considered, these being the conventional and slow sand filtration process with lime and coagulant dosing at the inlet works (Appendix 1),  Flocculation or Aeration cascade area to ensure oxidation of iron and stripping of volatiles present,  Sedimentation,  Powder activated carbon (PAC) dosing if algae becomes problematic

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 Filtration (either rapid media or slow filtration),  pH correction, stabilisation and disinfection,  Clean water storage tanks (command reservoir or distribution system),  Sludge balancing tanks,  Sludge thickeners,  Sludge drying beds,  Wash recovery for filter backwash and overflow from sludge thickener.

The conventional process will require a dissolved air floatation unit to float the solids and algae to the surface for removal. At the time of this report, the need to treat for algae has not been established. If such treatment is needed, the probable means will be Dissolved Air Flotation or the use of Powdered Activated Carbon (PAC). Similarly, a decision on recycling supernatant from the sludge ponds to the headworks or upstream side of the filters is still under consideration. If recycling is used, then a UV system may be required to inactivate Giardia and Cryptosporidium that is presumed to exist in the watershed.

The WTW will be designed to manage at least 75 % of the full load during period where maintenance is required.

The works will be designed to meet the Class 1 Treated Water Standards, as defined in the South African National Standard for Drinking Water SANS 241:2006 Edition 6.1. While the actual inlet water quality reporting to the Metolong WTW is not available at present, as the result of the dam not being constructed as yet, samples taken by the LWJV from the Phuthiatsana River at the Metolong Dam site indicate that iron, colour, turbidity and aluminium concentrations in the raw water exceed the SANS 241 standards. (Refer to Table 1) Treatment should therefore target these constituents. Samples taken by the DWAF, SMEC and Mott MacDonald (April 2003 – April 2006) during previous studies indicate high levels of Manganese. Additional sampling will be taken by the LWJV (October 2008 to February 2009) and a decision made whether treatment for manganese should be included.

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Table 1: Water quality data available for the Phuthiatsana River and treated water quality requirements from the Metolong WTW: A: as supplied by the LWJV). Highlighted values indicate exceedance of the SANS 241 standards for drinking water

Sample ID 1 2 3 4 5 6 Av Max SANS 241 standards Sample date 29/10/2008 05/12/2008 19/01/2009 30/01/2009 13/02/2009 23/02/2009 Location Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Class I River at River at River at River at River at River at River at River at Metolong Metolong Metolong Metolong Metolong Metolong Metolong Metolong (recommended Dam site Dam site Dam site Dam site Dam site Dam site Dam site Dam site operational limit)

Determinant Unit Colour (aesthetic) mg/ℓ Pt 288 28 44 233 130 70 132 288 < 20 Colour (apparent) PtCo < 550 62 183 < 550 123 183 Conductivity at 25 ºC (aesthetic) mS/m 17.66 14.9 13.5 10.5 11.5 15.5 14 18 < 150 Total Dissolved Solids (aesthetic) mg/ℓ 136 119 100 91 98 126 112 136 < 1 000 Total Dissolved Solids (calculated) mg/ℓ 114.8 96.8 87.7 68.3 74.7 100.7 91.0 115.0 < 1 000 Odour (aesthetic) TON 4 2.5 3.3 4.0 < 5 pH value at 25 ºC (aesthetic operational) pH units 7.25 8.31 7.7 7.3 7.51 7.7 7.6 8.3 5,0 - 9,5 Taste (aesthetic) FTN < 5 Turbidity (aesthetic/operational/indirect health) NTU 137 15.5 23.1 414 311 285 198 414 < 1 Temperature °C 20 24 25 24 25 24 24 25

Suspended solids mg/ℓ 105 20.5 42.9 499 723 1065 409 1065 Ammonia as N (operational) mg/ℓ 0.219 0.17 0.127 0.097 0.044 0.213 0.145 0.219 < 1.0 Calcium as Ca (aesthetic/operational) mg/ℓ 18.7 17.3 13.3 10 13.7 16.5 14.9 18.7 < 150 Chloride as CI (aesthetic) mg/ℓ 6.57 3.3 2.26 3.92 3.87 3.64 3.93 6.57 < 200 Fluoride as F (health) mg/ℓ 0.06 0.05 0.02 0.02 0.02 0.15 0.05 0.15 < 1.0 Magnesium as Mg (aesthetic/health) mg/ℓ 7.6 6.2 5.3 4.8 4.8 7.3 5.99 7.60 < 70 (Nitrate and nitrite) as N (health) mg/ℓ 0.68 0.15 0.32 1.06 1.06 1.09 0.73 1.09 < 10 Potassium as K (operational/health) mg/ℓ 1.7 1.39 0.96 0.91 0.96 0.92 1.14 1.70 < 50 Sodium as Na (aesthetic/health) mg/ℓ 9.3 6.74 6.1 10.3 6.3 9.59 8.06 10.3 < 200

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Sample ID 1 2 3 4 5 6 Av Max SANS 241 standards Sample date 29/10/2008 05/12/2008 19/01/2009 30/01/2009 13/02/2009 23/02/2009 Location Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Class I River at River at River at River at River at River at River at River at Metolong Dam Metolong Dam Metolong Dam Metolong Dam Metolong Dam Metolong Dam Metolong Dam Metolong Dam (recommended site site site site site site site site operational limit)

Determinant Unit Sulphate as SO4 (health) mg/ℓ 15.3 10.4 8.7 12.26 11.39 12.29 11.72 15.30 < 400 Zinc as ZN (aesthetic/health) mg/ℓ 0.006 0.005 0.007 0.006 0.009 0.01 0.007 0.01 < 5.0 Total Hardness mg CaCOз/ℓ 78 69 55 45 54 71 61.93 77.99 Moderately Moderately Moderately Soft Moderately Moderately Moderately Moderately soft soft soft soft soft soft soft

Alkalinity mg CaCOз/ℓ 74 72.50 61.80 44.10 50.00 70.90 62.22 74.00 pH Saturation 8.24 8.22 8.36 8.61 8.45 8.21 8.35 8.61 Langelier Saturation Index -0.99 0.09 -0.66 -1.31 -0.94 -0.51 -0.72 -0.30 <-0,5 aggressive tendencies >+0,5 scale forming tendencies

Comments on LSI value Aggressive Balanced Aggressive Aggressive Aggressive Aggressive Aggressive Balanced tendencies tendencies tendencies tendencies tendencies tendencies

Aluminum as Al (health) μg/ℓ 42 394 89 579 611 998 452 998 < 300 Antimony as Sb (health) μg/ℓ < 6 < 6 < 6 < 6 < 6 < 6 < 6 < 6 < 10 Arsenic as As (health) μg/ℓ < 6 < 6 < 6 < 6 < 6 < 6 < 6 < 6 < 10 Cadmium as Cd (health) μg/ℓ 1 1 1 < 1 < 1 1 1 1 < 5 Total Chromium as Cr (health) μg/ℓ 7 < 6 < 6 < 6 < 6 < 6 7 7 < 100 Cobalt as Co (health) μg/ℓ < 5 < 5 < 5 < 5 < 5 < 5 < 5 < 5 < 500 Copper as Cu (health) μg/ℓ 16 15 6 7 10 8 10 16 < 1 000 Cyanide (recoverable) as CN (health) μg/ℓ 2 < 2 < 2 < 2 2 < 2 2 2 < 50

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Sample date 29/10/2008 05/12/2008 19/01/2009 30/01/2009 13/02/2009 23/02/2009 SANS 241 standards Location Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Phuthiatsana Class I River at River at River at River at River at River at River at River at Metolong Dam Metolong Dam Metolong Dam Metolong Dam Metolong Dam Metolong Dam Metolong Dam Metolong Dam (recommended site site site site site site site site operational limit)

Determinant Unit Iron as Fe (aesthetic/operational) μg/ℓ 401 261 143 889 471 873 506 889 < 200 Lead as Pb (health) μg/ℓ 10 < 10 < 10 < 10 < 6 9 9.5 10 < 20 Manganese as Mn (aesthetic) μg/ℓ 27 8 4 25 17 17 16 27 < 100 Mercury as Hg (health) μg/ℓ 0.1 0.1 < 0.1 < 0.1 < 0.1 < 0.1 0.1 0.1 < 1 Nickel as Ni (health) μg/ℓ 10 < 10 < 10 < 10 10 < 10 10 10 < 150 Selenium as Se (health) μg/ℓ 6 < 6 < 6 < 6 < 6 < 6 6 6. < 20 Vanadium as V (health) μg/ℓ 5 < 5 < 5 6 < 6 8 6 8 < 200 Dissolved organic carbon as C (aesthetic/health) mg/ℓ 4.34 1.84 1.63 3.26 3.26 4.4 3.13 4.4 < 10 Total organic carbon (TOC) mg/ℓ 2.91 3.35 3.35 5.04 3.66 5.04 Total trihalomethanes (health) μg/ℓ < 200 Phenols (aesthetic/health) μg/ℓ 3 < 3 < 3 < 3 < 3 < 3 3 3 < 10

Chemical Oxygen Demand mg/ℓ O2 39 < 10

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B:Water quality statistics from SMEC (2008) report

SAMPLE NAME SANS 241 Sample ID123456789101112 QUALITY RANGE Sample date 2001/08/06 2001/11/06 2001/08/06 2001/11/06 2001/08/06 2001/11/06 2001/08/06 2001/11/06 2001/08/06 2001/11/06 2001/11/06 Location MET 1 MET 2 MET 3 MET 4 MET 5A MET 6 Class I Class II Class II S29 19 19,0 E27 49 18,2 S29 18 21,7 E27 50 21,5 S29 19 03,6 E27 48 58,0 S29 20 10,5 E27 47 16,4 MET 5B S29 22 18,8 (recommend (max. water MET 5 E27 48 58,6 ed allowable for consumptio S29 20 18,2 E27 41 43,9 operationla limited n period, limit) duration) max. a Determinand Unit Physical and organoleptic requirements Conductivity at 25 ºC (aesthetic) mS/m 22.2 23.8 14.7 13 23.9 22.4 15.2 13.2 17.6 15.9 14.6 20.2 < 150 150 - 370 7 years Total Dissolved Solids (calculated) mg/ℓ 144.3 154.7 95.55 84.5 155.35 145.6 98.8 85.8 114.4 103.35 94.9 131.3 < 1 000 1 000 - 2 400 7 years pH value at 25 ºC (aesthetic operational) pH units 8.53 8.14 8.15 7.96 8.28 7.95 8.07 8.02 8.1 7.99 7.85 7.87 5,0 - 9,5 4,0 - 10,0 No limit c Turbidity (aesthetic/operational/indirect health) NTU 6.6 4.04 24.1 686 7.49 7.58 14.7 477 16.6 134 569 4.7 < 1 1. - 5. No limit d Suspended solids mg/ℓ 8.13 14.3 32.5 633 13.7 10.7 18.5 479 26.1 172 682 15.9 Chemical requirements - Macro-determinand Ammonia as N (operational) mg N/ℓ 0.04 0.04 0.01 0.06 0.02 0.04 0.03 0.08 <0.01 0.02 0.2 0.06 < 1.0 1.0 - 2.0 No limit d Calcium as Ca (aesthetic/operational) mg Ca/ℓ 27.2 28.1 18.2 19.8 28.9 26.7 19.2 19.1 21.7 20.4 21.1 24.9 < 150 150 - 300 7 years Magnesium as Mg (aesthetic/health) mg Mg/ℓ 12.8 13.5 6.81 11.6 13 12.2 7.54 9.27 8.68 8.11 10.2 9.91 < 70 70 - 100 7 years (Nitrate and nitrite) as N (health) mg N/ℓ 1.19 0.73 0.95 0.96 1.79 1.06 0.91 1.02 1.24 1.02 0.95 1.37 < 10 10 - 20. 7 years Potassium as K (operational/health) mg K/ℓ <1.0 <1.0 <1.0 1.2 <1.0 <1.0 <1.0 1.02 <1.0 <1.0 1.23 <1.0 < 50 50 -100 7 years Total Hardness mg CaCOз/ℓ 121 126 74 97 126 117 79 86 90 84 95 103 see Kunin Slightly hard Slightly hard Moderately Moderately Slightly hard Slightly hard Moderately Moderately Moderately Moderately Moderately Slightly hard soft soft soft soft soft soft soft

Alkalinity mg CaCOз/ℓ 97.90 115.00 60.90 55.30 96.90 97.70 63.60 59.30 78.30 64.40 66.80 91.80 Chemical requirements - Micro-determinand Iron as Fe (aesthetic/operational) µg Fe/ℓ 120 430 520 14900 150 460 200 8150 290 1610 10300 510 < 200 200 - 2 000 7 years b Manganese as Mn (aesthetic) µg Mn/ℓ 10 140 10 670 10 20 10 380 10 10 370 30 < 100 100 - 1 000 7 years

Chemical Oxygen Demand mg /ℓ O2 <20.0 <20.0 <20.0 73.6 <20.0 20.5 <20.0 50.5 <20.0 <20.0 51 <20.0 < 10 10 - 70. No limit b

outside Class I limits outside Class II limits

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C: Water quality statistical analysis from Mott MacDonald (2003 – 2006)

SAMPLE NAME SANS 241

Sample ID 1 2 3 4 5 6 7 QUALITY RANGE

Sample 04/04/200 2003/04/0 16/05/200 16/05/200 2006/02/0 2006/07/0 2006/04/0 date 3 4 3 3 8 8 8

Location Raw water Raw water Raw water Raw water Raw water Raw water Raw water Class I Class II Class II Phuthiuatsana Phuthiuatsana Phuthiuatsana Phuthiuatsana Phuthiuatsana Phuthiuatsana Phuthiuatsana (recommende (max. water River at River at River at River at River at River at River near d operationla allowabl consumptio Metolong Metolong Dam Metolong Metolong Metolong Metolong airport limit) e for n period, Dam site site Dam site Dam site Dam site Dam site limited max. a duration)

Determinant Unit

Physical and organoleptic requirements

Colour (aesthetic) mg/ℓ Pt-Co 4 3 4 4 181 7 189 < 20 20 - 50 No limit b

Colour (apparent) mg/ℓ Pt- >550 70 >550 Co

Conductivity at 25 ºC (aesthetic) mS/m 19.4 20 20.3 22.4 18.7 21.9 16.7 < 150 150 - 370 7 years

Total Dissolved Solids (aesthetic) mg/ℓ 112 154 150 136 < 1 000 1 000 - 2 7 years 400

Total Dissolved Solids (calculated) mg/ℓ 126.1 130 131.95 145.6 < 1 000 1 000 - 2 7 years 400

Odour (aesthetic) TON None None none none < 5 5. - 10 No limit b

pH value at 25 ºC (aesthetic operational) pH units 8.3 8.2 8.2 8.4 7.82 8.09 7.84 5,0 - 9,5 4,0 - 10,0 No limit c

Turbidity (aesthetic/operational/indirect NTU 1 0.2 0.3 0.9 164 13.6 259 < 1 1. - 5. No limit d

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health)

Chemical requirements - Macro-determinant

Ammonia as N (operational) mg/ℓ < 1.0 1.0 - 2.0 No limit d

Calcium as Ca (aesthetic/operational) mg/ℓ 24 22 22 25 < 150 150 - 300 7 years

Chloride as CI (aesthetic) mg/ℓ 6 <5 <5 <5 < 200 200 - 600 7 years

Fluoride as F (health) mg/ℓ <0.2 <0.2 <0.2 <0.2 < 1.0 1.0 - 1.5 1 year

Magnesium as Mg (aesthetic/health) mg/ℓ 11 10 11 10 < 70 70 - 100 7 years

(Nitrate and nitrite) as N (health) mg/ℓ 0.8 1 0.8 0.5 < 10 10 - 20. 7 years

Potassium as K (operational/health) mg/ℓ < 1 0.7 0.8 1.1 < 50 50 -100 7 years

Sodium as Na (aesthetic/health) mg/ℓ 5 4 5 6 < 200 200 - 400 7 years

Sulphate as SO4 (health) mg/ℓ 10 11 10 11 < 400 400 - 600 7 years

Zinc as ZN (aesthetic/health) mg/ℓ < 5.0 5.0 - 10 1 year

Total Hardness mg 105 96 100 104 115 99 101 CaCOз/ℓ

Slightly Moderatel Slightly Slightly Slightly Moderatel Slightly hard y soft hard hard hard y soft hard

Alkalinity mg 88 88.00 92.00 104.00 62.00 82.00 74.00 CaCOз/ℓ

Chemical requirements - Micro-determinant

Iron as Fe (aesthetic/operational) μg/ℓ < 25 60 88 123 860 120 1560 < 200 200 - 2 7 years b 000

Manganese as Mn (aesthetic) μg/ℓ < 25 < 25 < 25 < 25 < 100 100 - 1 7 years

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000

Chemical requirements - Organic determinant

Dissolved organic carbon as C mg/ℓ 1.2 2.4 2.1 2.5 < 10 10 - 20. 3 months e (aesthetic/health)

Total Coliform Bacteria TCC/100m 40 50 150 l

Faecal Coliform Bacteria FCC/100m 10 10 10 l

Heterotrophic Plate Count count/ml 840 170 150 400

outside Class I limits

outside Class II limits

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2.2 Chemicals used Lime dosing and coagulant for the flocculation will be used. PAC is one option being considered for management of algae if required. Write out before abbreviating Material Safety Data Sheets (MSDS) for the reagents can be found in EMP document.

2.2.1 Lime Lime addition increases OH- ion concentration in the water. The OH- reacts with the metals in the water which will precipitate out. The calcium will react with the natural alkalinity of the water and precipitate out as calcium carbonate. The main purpose of adding lime is it aids in the floc formation, thus reducing the turbidity of the water. A pH correction step will be added at the end of the process.

2.2.2 Coagulants Two coagulants are currently being considered to act as coagulants (WASA personal communication). These include:  Sudfloc 3456  Sudfloc 3TL The polyelectroytes will act as flocculation aids to facilitate floc formation, coagulation and settling. WASA has indicated that alum is not the preferred coagulant due to operational and performance issues. Jar tests have been completed and the results are still pending.

2.2.3 Powdered Activated Carbon PAC will be added if and when needed to absorb odour and taste causing particles from the water. These particles arise as the result of algae in the water. It has not been established as yet on whether algae will be present. The PAC will be removed from the process with the sludge. This would add to the sludge volume produced. PAC will only be used seasonally.

2.3 Waste streams Two waste streams will be produced. The solid waste in the form of sludge from the sedimentation basins and DAF units and backwash from the filters. 2.3.1 Sludge Sludge will be removed by mechanical means from the sludge drying beds 2.3.1.1 Volume The volume of waste produced depends on the type of coagulant and the raw water quality. (Total suspended solids in sludge) = (Total suspended solids due to natural turbidity of water) + (“Additional” suspended solids from the addition of coagulant or flocculants) + (oxidised metals) … (1) Factors have been determined for “Additional” suspended solids from the flocculants. For polyelectrolyte flocculants, which are being considered for the Metolong WTW, the factor is 1; (i.e. for every 1 g of polymer added, 1 g of sludge will be added as additional solids). For lime a factor of 1.873 is used. (Water Research Commission, 2006)

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The average suspended solids value obtained from the analyses carried out on the samples taken from the Phuthiatsana River is 143 mg/ℓ, (143 kg/Mℓ). Suspended solids in the dam may be considerably less as solids will settle in the reservoir. It is anticipated that the water abstracted from the reservoir would have a suspended solids concentration of 40mg/ℓ. The highest suspended solids concentration made available from a limited data set supplied by the LWJV is 1065 mg/ℓ (Table 1). While this was during the dry season and is highly unlikely from the reservoir, it was used to estimate the maximum possible sludge volume. The dose rate of polymer used to assist with coagulation has been assumed as 40 mg/ℓ, (40 kg/Mℓ). Lime was assumed dosed at a rate of 10 mg/ℓ. Sludge from potable water treatment plants generally has a very high moisture content and an SG of about 1.03. Table 2: Estimated volume of sludge Low Average High Suspended solids (mg/ℓ) 40 143 1065 Sludge resulting from SS (tons/day) 3 11 80 Sludge resulting from Polymer 3 3 3 (tons/day) Sludge resulting from Lime as CaO 0.8 0.77 0.77 (tons/day) Total dry mass (tons) 6.8 14.5 83.65 Volume sludge (m3/day) 6.6 14.08 81.21

2.3.1.2 Quality It is recommended that bench scale jar testing is carried out on the water and leachate tests carried out on the resulting sludge by WASA who will be operating the water treatment works. The waste will need to be characterised before the final disposal option or re-use option can be implemented. For the purpose of this report, it was assumed that a 95 % removal efficiency, would be achieved for the metals in the raw water. This is typically the removal efficiency of metals in this type of water. The metals of concern in the samples analysed were aluminium, iron and manganese. The metal content based on preliminary investigations is presented in Table 3. It was further assumed that 10 mg/ℓ of hydrated lime would be used. The lime content of the sludge would be 5.6 %. Trace amounts of cadmium, copper, Calcium, Magnesium, Potassium, Sodium and sulphate will also be present. The polymers being considered have a low hazard rating. The sludge volume based on average suspended solids concentrations was used. Table 3: Estimate of metal and lime content in WTW sludge Average concentrations Volume in sludge Percentage of Metals (mg/l) 95 % removal (T/day) total sludge (%)

Iron as Fe 0.506 0.481 0.036 0.25

Manganese as Mn 0.016 0.0152 0.0011 0.01

Aluminium as Al 0.452 0.429 0.032 0.22

Lime 0.77 5.6

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2.3.2 Supernatant & Filter backwash There are three ways to deal with the supernantant from the sedimentation beds – waste to the source stream after ensuring effluent discharge regulations are met, or recycling to the head of the works: . Recycle back to the head of the work and put back through the sand filters. . Evaporate off the water. This requires evaporation pans (lagoons) and extra space and would also leave some residue (sludge that would need to be disposed of) and is not a good option. . Dispose of supernatant back into the river.

Pending further analysis, it is proposed that the supernatant from the sedimentation beds and the filter backwash water is recycled to the head of the works. This practice reduces water losses from the system and recycles some residuals to aid in flocculation and reduce the volume of coagulants required. Recycling can however upset the process and result in a negative impact on the finish water quality.

Risks associated with the recycle streams include:  Potential for higher levels of Manganese and Iron recycled from the supernatant should carryover occur,  Potential for Giardia and Cryptosporidium cysts and oocysts from the spent filter backwash,  Increased levels of total trihalomethane formation potential (TTHMFP) and Total organic carbon may be high in the waste streams.  High solids concentration returned to the process These risks may be easily reduced by treating the waste stream. In most cases, flocculation or thickening is sufficient. A polymer or coagulant may be required to increase the removal efficiency of the solids. In some cases, disinfection of the recycle stream by means of UV, ozone, chlorine dioxide, potassium permanganate or chlorine may be required. (American Water Works Association, 1999) It is recommended that the backwash stream is thickened and the supernatant recycled. If the supernatant is to be discharged back to the river the polymers degrade quickly but the water quality should be tested and determined if this option is possible. Further jar tests will need to be undertaken during the summer months and this information will be made available to the Contractor before the final design and construction takes place. The disposal of supernatant back to a river or dam is common practice in many waste water treatment works and some of the bigger ones have an on line monitor/sensor that triggers if the water quality exceeds a limit. This water is then collected/stored in a holding dam until the quality has been suitably diluted so as to meet the local discharge standards.

Once the process in operational and the impacts of recycling on the finish water quality can be determined a decision will be made on whether to discharge the supernatant and filter backwash to the receiving water or recycle the stream in the process. The recycle option can lead to an added cost of treatment and pumping and possibly with high-tech equipment that exceeds operational capability of presumed operator. These issues will need to be taken into consideration.

3.0 POSSIBLE MANAGEMENT MEASURES FOR SLUDGE Large volumes of sludge (14.5 T/day on average) will be produced as a result of the water treatment process. Disposal to a sludge disposal facility would require substantially sized ponds. Alternative uses for the sludge therefore need to be investigated by the operator of the WASA Alternative sludge reuse/disposal options are summarised in this section.

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Note that the sludge will need to be dried by means of a mechanical filtration process (Gravity belt thickener or filter press) for most of these disposal options. 3.1 Land application Typically, residues from WTW are sent to landfill for disposal but an option that is gaining acceptance internationally is land application where residuals are applied directly onto land (Golder 2009). This approach has been used by WASA for the Maseru Water Treatment works where the sludge is collected by farmers for land application (Palesa Monongoaha, personal communication 2008). Common land application techniques include:  Land application on residential land,  Land application on forest land,  Land reclamation. Aspects that must be considered when looking at land application include:  pH and chemical content of sludge,  leaching characteristics of sludge,  Rate and frequency of application,  The soil type,  The cation exchange capacity of the soil,  Rainfall and irrigation rates,  The intended use of the land,  The nutrient requirements of the plants. (Golder 2009) Research has shown that physical, chemical and biological properties of soil can improve with sludge application without inducing negative effects on soil quality, groundwater or plant growth.

As shown above, the residuals from the Metolong WTW will have small amounts of metals and trace elements, These elements may be present in different fractions including total, plant available and leachable (mobile) fractions. Only the plant available and mobile fractions have an influence on land application and disposal of sludge. If the chemicals proposed for use in the Metolong WTW and retained in the sludge that is sent to nearby drying beds and then collected by farmers. According to the Material Safety Data Sheets (MSDS, See EMP), these chemicals are not known to cause any adverse human health effects and pose a minimal hazard to the environment and humans. The compounds are stable and hazardous polymerisation does not occur. The agronomic application of sludge to land presents an attractive and potentially sustainable management option for the Metolong WTW. Successful implementation of this management option requires an understanding of the effects of sludge residuals on soil fertility and physical properties. The physical characteristics of soil that determine whether it can support vegetative growth include cohesion, aggregation, strength and texture. These parameters directly affect the hydraulic properties of a soil, such as moisture- holding capacity, infiltration, permeability, and drainage. Any adverse impact on these hydraulic soil characteristics from land-applied sludge residuals can effect crop growth and ultimately degrade groundwater quality.

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Land disposal of sludge residuals, has been described by Overcash and Pal (1979) (cited -(LW Titshall, 2005)) as the intimate mixing or dispersion of sludge residuals into the upper zone of soil-plant system, with the objective of micro-stabilisation, adsorption, immobilisation, selective dispersion or crop recovery. The lime-rich sludge residuals can act as an enriched topsoil additive for farming in the area. Care must be taken by WASA to identify any constituents that can negatively impact vegetation. The initial estimate of metals of concern in the sludge residuals indicates that this would not be a problem. Certain crops are more tolerant than others to various constituents found in sludge. Sludge characterisation studies and pilot studies are recommended in order to ascertain the feasibility of agricultural use of the sludge. The application rate can also be determined in these studies. Such studies are to be carried out by WASA the proposed operator of the Metolong treatment works once the plant has produced suitable quantities of residuals. Appendix 2 indicates some suggested soil and analytical tests that should be undertaken to determine the practical application of sludge on lands. 3.2 Daily cover on landfill sites Domestic landfill sites utilise large volumes of soil material for daily cover on deposited waste. This soil material is expensive and scarce. The sludge produced at the WTW can be used for the daily cover on landfills. General landfill sites will not accept sludge with a liquid or viscous consistency. (Golder 2009). The sludge will need to be dried to and transported for this application by a subcontractor. The viability of this option depends on the locality of the land fill sites in the area. Currently, there are no operational landfill sites in close proximity to the proposed project. The suggested ratio of sludge to waste is 1:10. Depending on the leaching properties of the sludge, this may require a lower ratio. (Golder 2009). As there is currently no operational landfill site in close proximity to the Metolong WTW, a landfill site would need to be established. The new proposed landfill site for Maseru is too far from the Metolong WTW to be a viable alternative. If a local site was to be established this method of sludge disposal would be a viable option. A sedimentation characterization will be required by WASA (or the operator of the WTW) before a final decision is made on this option,

The potential negative effects resulting from land application and disposal can be managed by specifying management requirements as described above. This option may be a more beneficial option compared to disposal by landfill in that the local communities would benefit from the sludge application. It would however require a detailed initial investigation of the land to be used and ongoing monitoring is required. Disposal to landfill would be more costly and would not benefit the local community. Land application is thus a more environmentally and economically sound management option when compared to disposal on landfill. 3.3 Erosion control The highly dispersive soils in the locality of the Metolong WTW has lead to severe erosion. The sludge, if characterised as inert, can be used in conjunction with gabions to backfill areas where erosion has taken place. The sludge can then be seeded appropriate vegetation so as to reduce further erosion. This option will need to be approved by the appropriate government departments that are responsible for agriculture, forestry and environment. 3.4 Brick making additive The high clay content in the sludge can make it a useful additive in the brick making industry. The sludge produced will need to be characterised to determine the components such as organic and water content as this will affect the process. Trials are required to determine the optimal percentage incorporation. A study indicated that waterworks sludge, especially ferric sludge, provided energy saving in the brick making process by acting as a fluxing agent (Babatunde & Zhao, 2007). WASA (or the operator of the WTW) will

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need to arrange for conducting such tests. An example of such an initiative can be found at the eMalahleni Water Treatment Works in South Africa. Properties in terms of shrinkage and compressive strength will differ with sludge produced at different operations and this needs to be investigated. 3.5 Additive in the manufacture of cement Studies on incorporating waterworks sludge in the cement making process have proved successful. It was reported that adding the sludge in the cement clinker increased the compressive strength of the concrete and benefited the clinker burn ability without any detrimental effects of the long term strength property.(Babatunde & Zhao, 2007). It was further noted that chlorine levels in the sludge must be kept to a minimum as this can lead to corrosion of the cement kiln. It was recommended that more research is carried out on the various components of waterworks sludge on the compressive strength of the sludge cement. This process is currently being trialled by PPC in South Africa. 3.6 Blending with sewage sludge Sludge produced in water treatment works are often blended with sludge produced at sewage treatment plants. Blending can enhance the composting properties of the sewage sludge. The compost can be sold to farmers in the area to recover costs of transportation, storage and handling. The Maseru WWTP is 35 kms from the WTW site, so this option is not considered cost effective. 3.7 Discharge to river NES have indicated that due to the changed environmental flows in the Phuthiatsana River that this option would not be acceptable. The supernatant, however, could be discharged if it meets the effluent requirements.

4.0 EVALUATION OF OPTIONS CONSIDERED

In general WTW may have negative environment impacts unless well designed and managed. The table below describes the potential options considered and comments on their overall applicability.

Option Comment

Land application Potential impacts to human health resulting from contaminants been absorbed into crops will need to be carefully evaluated. Low risk based on current chemical analyses. Preferred option.

Daily cover on landfill Negotiations required with managers of landfill site to ensure that the disposal costs will be reduced or negated, as cost for disposal to landfill can be high. Using sludge reduces the need for soil cover.

Brick making additive Pilot testing will be required to evaluate optimal blends

Additive in the Pilot testing required to determine optimal blend, feasibility Transport costs need manufacture of cement to be determined and proximity of nearest cement plant

Blending with sewage Sewage treatment not available in the area and the costs of transporting of the sludge waste will need to be evaluated

Discharge to the river Not permitted by NES

June 2009 Report No. 12280 15

SPECIALIST STUDY - SLUDGE HANDLING

Option Comment

.

Erosion Control Will need to be approved by relevant government organisations. Low risk basked on current chemical analyses.

5.0 CONCLUSIONS The water treatment works would produce approximately 14.5 tons/day on average of sludge. Initial estimates indicate that the metal content in the sludge will be low and would not represent a hazard. Several options for reuse exist and should be considered within a 2 to 3 year timeframe. Reuse options would require a dry sludge and it is recommended that mechanical filtration options such as filter presses or gravity belt thickeners are considered as part of the plant design. Land application as a form of disposal is the suggested option for this WTW’s sludge. It is strongly recommended that bench-scale testing is carried out on the sludge characterised in order to assess the various reuse options and to optimise the usage potential of the sludge. 6.0 WORKS CITED American Water Works Association. (1999). Water Quality and Treatment - A handbook of community water suplies (5th Edition ed.). (R. D. Letterman, Ed.) McGraw-Hill Handbooks. Babatunde, A. O., & Zhao, Y. Q. (2007). Constructive approaches toward water treatment works sludge management: An international review of beneficial reuses. Critical reviews in Environmentla Science and Technology , 129 - 164. Golder. (2009). Guidelines for the utilisation and disposal of water treatment residues. Pretoria: The Water Research Commission.

LW Titshall, J. H. (2005). Characterisation of some South African water treatment residues and implications for land disposal. Water SA , 31 (3), 299 - 307. Water Research Commission. (2006). Handbook for the operation of Water Treatment Works. (F. Schutte, Ed.) Pretoria: Water Institute of South Africa.

June 2009 Report No. 12280 16

SPECIALIST STUDY - SLUDGE HANDLING

Report Signature Page

GOLDER ASSOCIATES AFRICA (PTY) LTD

P Dama-Fakir A Toerien Environmental Engineer Senior Process Engineer

PDF/AT/RH/pdf

Reg. No. 2002/007104/07

Directors: FR Sutherland, AM van Niekerk, SAP Brown, L Greyling, SM Manyaka

c:\documents and settings\jnaude\local settings\temporary internet files\content.outlook\npem9ml8\met emp app e sludge report (3).docx

June 2009 Report No. 12280

SPECIALIST STUDY - SLUDGE HANDLING

APPENDIX 1 Process flow diagram

June 2009 Report No. 12280

SPECIALIST STUDY - SLUDGE HANDLING

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SPECIALIST STUDY - SLUDGE HANDLING

APPENDIX 2 Extracts from Golder Associates Africa 2009 on Sludge Management

June 2009 Report No. 12280

SPECIALIST STUDY - SLUDGE HANDLING

The agronomic application of sludge to land presents an attractive and potentially sustainable management option for a Water Treatment Works. Successful implementation of this management option requires an understanding of the effects of sludge residuals on soil fertility and physical properties. The physical characteristics of soil that determine whether it can support vegetative growth include cohesion, aggregation, strength and texture. These parameters directly affect the hydraulic properties of a soil, such as moisture- holding capacity, infiltration, permeability, and drainage. Any adverse impact on these hydraulic soil characteristics from land-applied sludge residuals can effect crop growth and ultimately degrade groundwater quality. Management strategies need to be implemented and parameters such as pH control, crop selection and availability, application rates, and fertilizer requirements must be included in the management planning. If land application is selected as the preferred disposal option, the next step is to evaluate the land application site, the costs associated with that site and the potential social and environmental impacts on the site. An initial site investigation will enable the producer to collect baseline data which could help to assess the impact of land application over time. Quality of Sludge – the following constituents and properties of sludge need to be determined due to their potential negative effects:

 Nutrients – the nutrient content will determine whether sludge could be used as a fertilizer while high concentrations of certain nutrients could pose a negative environmental impact due to soil, surface and groundwater contamination.  Trace elements and metals – when present in high concentrations the metal content of sludge may have negative impacts on several receptors, and  Physical characteristics – the physical properties of sludge may impact on the soil properties, air quality and surface water.

The residuals could contain relatively high metal concentrations, depending on the form of coagulant used during the rainy season due to the dosing of metal coagulants and the residuals may not be suitable for land disposal at these times. In general, sludge application rates are determined using agricultural methods, as with fertilizer. In the case of sludge, this fertilizer recommendation is at least two fold; the nutrient requirements for the crop are based on the expected yield and the available nutrients in the soil.

The first nutrient to consider is nitrogen. Sludge tends to be very low in this nutrient. Basing the application rate on nitrogen alone, however, may cause problems with the crop yield because aluminum and/or iron hydroxide solids present in sludge are strong adsorbents of inorganic phosphorus. The low concentrations of phosphorus in sludge may further diminish total phosphorus in soils, restricting plant growth. It is therefore recommended that both the N and P concentrations be considered when the application rate is calculated. Additional P fertilizer might be necessary.

It is recommended that the NH4NO3 extractable trace element and metal concentration be determined before sludge application. If the available metal concentrations exceed the maximum available threshold (MAT) (Table C1), land application of sludge is not permissible. The concentration of aluminium (Al), Iron (Fe) and manganese (Mn) should also be considered because the concentrations of these elements in the sludge might be elevated and additional application might induce toxicity symptoms in crops.

June 2009 Report No. 12280

SPECIALIST STUDY - SLUDGE HANDLING

Table C1: Maximum available threshold limits for sludge-amended soils

Maximum Available Maximum Available Element Element Threshold (MAT) Threshold (MAT)

As 0.014 Pb 3.5

Cd 0.1 Hg 0.007

Cr 0.1 Ni 1.2

Cu 1.2 Zn 5.0

At least 3 composite samples of sludge must be collected and the following analyses are recommended:

 NH4NO3 extractable trace element and metal concentration;  Kjeldal digestion to determine N; and  Bray 1 extraction to determine available.

Quality of Soil - Soil quality is to be determined during the investigation. The concentration of nutrients, trace elements and metals will give baseline concentrations to determine incremental effects of land application on the soil. The soil pH will indicate whether acidic conditions could cause metals to be available for plant uptake or leach through the soil profile and whether lime softening residues can be used to alleviate acidity. A soil monitoring programme is recommended to determine nutrient requirements before application, as well as the plant available trace element and metal concentrations in the soils. The following programme is proposed:

 Collect soil samples from all areas where sludge application is considered  Determine the nutrient requirement for the particular crop to be cultivated using the following methods: - Kjeldal digestion to determine N - Bray 1 extraction to determine available P

 Determine the NH4NO3 extractable concentration of trace elements and metals to establish whether the soil can continue to receive sludge

Impact The impact of sludge disposal to either agricultural land or to landfill is a localised, definite, medium intensity impact of low significance is appropriately managed. If not managed and monitored, it is an impact of medium significance.

Mitigation The required management measures include an initial site investigation of the lands where sludge is to be applied and sludge analysis.

June 2009 Report No. 12280

Golder Associates Africa (Pty) Ltd Thandanani Park Matuka Close Midrand South Africa T: [+27] (11) 254 4800

METOLONG WATER TREATMENT WORKS

APPENDIX F Standards applicable for Lesotho Effluent discharges to a natural water course (Otieno1997) and South African General Standards

January 2010 Report No. 12280-9299-2 145

METOLONG WATER TREATMENT WORKS

Constituent (Otieno Unit Value Comment 1997) Colour mg/l Pt-Co nil Waste water shall not contain any substance in concentrations capable of producing colour

Electrical Conductivity mS/m <75 + intake pH 5.5 - 9.5 Total suspended solids mg/l TSS 25 Total Kjeldahl Nitrogen mg/l N NS Ammonia mg/l N <10 Nitrates * mg/l N NS Chloride mg/l Cl NS

Sulphate * mg/l SO4 NS Calcium mg/l Ca NS Magnesium mg/l Mg NS Potassium mg/l K NS Sodium mg/l Na <90 Chemical Oxygen Demand mg/l COD <75 (unfiltered) Chemical Oxygen Demand mg/l COD NS (filtered)

Oxygen absorbed mg/l O2 <10 Total phosphate * mg/l P NS

Total alkalinity mg/l CaCO3 NS Fluoride mg/l F <1.0 Boron Mg <1.0 Cadmium mg/l Cd <0.05 Total chromium mg/l Cr <0.5 Hexavalent chromium mg/l Cr 0.05 Copper mg/l Cu <1.0 Lead mg/l Pb <0.1 Manganese mg/l Mn <0.4 Zinc mg/l Zn <5.0 Mercury mg/l Hg <0.02 Residual chlorine mg/l CP 0.1 Free and saline ammonia mg/l N 10,0 Arsenic mg/l As 0.5 Phenolic compounds mg/l phenol 0.1 Cyanides mg/l Cn 0.5 Sulphides mg/l S 1,0 Selenium mg/l Se 0.05 Soap, oil and grease mg/l <2.5 Dissolved solids * * The values for each of these should be determined in specific circumstances and dealt with as such Other constituents Dissolved oxygen Shall be less than 75 % saturation

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METOLONG WATER TREATMENT WORKS

Constituent (Otieno Unit Value Comment 1997) Typical (faecal) Coli Effluent shall not contain any typical coli per 100 millilitres Oxygen absorbed 10 mg/l (while performed at 27 °C using acceptable methods) Suspended solids mg/l <25

Waste water generated from operations must comply with the general limit of the South African Effluent Discharge Standards

SUBSTANCE/PARAMETER GENERAL LIMIT Faecal Coliforms (per 100 mℓ) 1 000 Chemical Oxygen Demand (mg/ℓ) 75 (i) pH 5,5-9,5 Nitrate/Nitrite as Nitrogen (mg/ℓ) 15 Chlorine as Free Chlorine (mg/ℓ 0,25 Suspended Solids (mg/ℓl) 25 Electrical Conductivity (mS/m) 70 mS/m above intake to a maximum of 150 mS/m Ortho-Phosphate as phosphorous (mg/ℓ) 10 Fluoride (mg/ℓ) 1 Soap, oil or grease (mg/ℓ) 2,5 Dissolved Arsenic (mg/ℓ) 0,02 Dissolved Cadmium (mg/ℓ) 0,005 Dissolved Chromium (VI) (mg/ℓ) 0,05 Dissolved Copper (mg/ℓ) 0,01 Dissolved Cyanide (mg/ℓ) 0,02 Dissolved Iron (mg/ℓ) 0,3 Dissolved Lead (mg/l) 0,01 Dissolved Manganese (mg/ℓ) 0,1 Mercury and its compounds (mg/ℓ) 0,005

Dissolved Selenium (mg/ℓ) 0,02 Dissolved Zinc (mg/ℓ) 0,1 Boron (mg/ℓ) 1

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METOLONG WATER TREATMENT WORKS

APPENDIX G MSDS for Chemicals to be used at the WTW

January 2010 Report No. 12280-9299-2 148

MATERIAL SAFETY DATA SHEET

d. HYDROCHLORIC ACID PAGE 1 OF 12 Reg. No. 67/02258/06 MURIATIC ACID MSDS 010/R2

Reg. No. 2001/01917/0709 HCl 2003-07-04

NCP CHLORCHEM (Pty) Ltd EMERGENCY TELEPHONE No.: +27 11 976 2115 Cnr Allandale Road & Chloor Road, Chloorkop TELEPHONE No.: +27 11 921 3111 KEMPTON PARK FAX No: +27 11 976 3305 P O Box 150, KEMPTON PARK 1620 SOUTH AFRICA

1. PRODUCT IDENTIFICATION

TRADE NAME Hydrochloric acid CHEMICAL FAMILY Inorganic Acid CHEMICAL NAME Hydrochloric Acid SYNONYMS Aqueous hydrogen chloride Hydrogen chloride Muriatic acid Spirits of salt CHEMICAL ABSTRACTS No. 7647-01-0 NIOSH No. MW 4025000 HAZCHEM CODE 2R UN No. 1789

2. COMPOSITION

HAZARDOUS COMPONENTS Hydrochloric acid (HCl) is commercially available as a solution of up to 38% hydrogen chloride (m/m) dissolved in water.

EEC CLASSIFICATION [C;Xi] Corrosive; Irritant.

RISK PHRASES R34: Causes burns. R36/37/38: Irritating to eyes and respiratory system and skin.

SAFETY PHRASES S1/2: Keep locked up and out of reach of children. S26: In case of contact with eyes, rinse with plenty of water, seek medical advice. S28: After contact with skin, wash immediately with plenty of water. S45: In case of accident or if you feel unwell, seek medical advice immediately, show label where possible.

EU COMMENTS :

Concentration greater than or equal to 25%: Corrosive. Causes burns. Irritating to the respiratory system. [C;R34-37]. Concentration less than 25% and greater than or equal to 10%: Irritant. Irritating to eyes, and respiratory system and skin. [Xi, R36/37/38].

The product label must indicate the percentage concentration of the solution.

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 2 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

3. HAZARD IDENTIFICATION

MAIN HAZARDS

Threshold limit values (TLVs) / American Conference of Governmental Industrial Hygienists (ACGIH) / 2002*

Ceiling Exposure Limit (TLV-C) : 5 ppm (7.5 mg/m3)

(*Notice of intended change: The reduction of the TLV-C to 2 ppm , 3mg/m3 )

CHEMICAL HAZARDS

Hydrochloric acid may react explosively with potassium permanganate (1*,2*) or sodium, and contact of fuming hydrochloric acid with tetraselenium tetranitride is also explosive. Passing hydrogen chloride into alcoholic hydrogen cyanide in preparation of alkyliminoformate chlorides proceeds explosively (3*), and other hazard-free methods are available (4*). An extremely exothermic decomposition reaction may occur with 1,1-difluoroethylene particularly at high vessel loadings (5*).

Rubidium acetylide ignites in contact with hydrochloric acid, and caesium acetylide ignites in contact with gaseous hydrogen chloride or concentrated hydrochloric acid. Hydrogen chloride also ignites in contact with fluorine, and concentrated aqueous solutions produce flame. Aluminium-titanium alloys ignite or incandesce on heating in hydrogen chloride. Hexalithium disilicide incandesces in concentrated hydrochloric acid, and silanes (which ignite) are evolved with the dilute acid.

Filling a glass drying tap on a hydrochloric acid storage tank with silica gel instead of calcium sulphate resulted in fracturing of the tap (6*), and the accidental addition of concentrated hydrochloric acid to a tank of sulphuric acid caused the tank to burst violently (7*). The safe dehydration of hydrochloric acid which releases a lot of gas (8*) avoids the possibility of layer formation in an unstirred flask (9*).

BIOLOGICAL HAZARDS

Hydrochloric acid and high concentrations of the gas are highly corrosive to the skin and mucous membranes. Considerable variation in species sensitivity to hydrochloric acid exists (11*). The health effects of occupational exposure have reviewed (10-12*).

HEALTH EFFECTS - EYES

Low concentrations of vapour or mist (10-35 ppm) can be immediately irritating, causing redness.(2) Concentrated vapour, mist or splashed liquid can cause severe irritation, burns and permanent blindness.(4)

HEALTH EFFECTS - SKIN

Hydrochloric acid liquid can cause skin burns, and may produce keloid and retractile scarring (29*). Facial burns may result in serious and disfiguring scars. Frequent contact with the dilute acid may cause dermatitis (14*). and photosensitisation may result from industrial contact.

HEALTH EFFECTS - INGESTION

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 3 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

Hydrochloric acid solutions can cause corrosive burns to mouth, throat, oesophagus and stomach. Symptoms may include difficulty in swallowing, intense thirst, nausea, vomiting, diarrhoea and in severe cases, collapse and death. Small amounts of acid which enter the lungs during ingestion or vomiting (aspiration) can cause serious lung injury and death.

HEALTH EFFECTS - INHALATION

The major effects of acute exposure to hydrogen chloride are usually limited to the upper respiratory tract and are severe enough to lead to prompt withdrawal (13*). Exposure to the gas causes cough, burning of the throat and choking feeling, inflammation and ulceration of the nose, throat and larynx (14*). Exposure to higher concentrations, as may occur if a worker is prevented from escaping, may cause laryngeal spasm, and oedema of the lungs and vocal cords (15*).

Prolonged or repeated exposure may cause dental discolouration and erosion (15* - 17*). Pulmonary function changes in naive but not chronically exposed workers suggests acclimatisation occurs (18*). Gastritis and chronic bronchitis have also been reported in exposed workers (19*).

In humans, exposure to 50 - 100 ppm for 1 hour is barely tolerable, 35 ppm for a short while causes throat irritation, and 10 ppm was tolerable (20*), although immediate irritation has been reported at concentrations over 5 ppm (21*). Bleeding nose and gums, ulceration of nasal and oral mucosa, and painful shaving due to tender facial skin was reported in workers exposed to mists from heated metal pickling solutions (22*).

In animal studies reported effects of exposure to high concentration of hydrogen chloride include damage to the lungs and blood vessels, lung collapse, and lesions of the liver and other organs(23*), coughing, wheezing, frothing, slowing of movement, increased respiratory rate, and death due to respiratory tract effects (24*). Repeated exposure to low concentrations of the gas (34 ppm) had no immediate toxic effects and produced no morphological changes (23*). Exposure to 100 ppm, 6 hours/day for 50 days caused slight unrest and irritation of the nose and eyes in several species (25*), while repeated exposure at higher concentrations caused weight loss (23*). Lesions in the nasal cavity of mice has also been reported (26*).

Inhalation of weak hydrochloric acid into the bronchi of rabbits caused inflammatory processes like those occurring in "flu or due to chemical weapons (27*). Differing responses to irritant gases such as hydrogen chloride between rodents and nonhuman primates suggest that the former may be an inadequate model for evaluating the toxicity of irritant gases to humans (28*).

ADDITIONAL MEDICAL INFORMATION

CARCINOGENICITY

No carcinogenic response was noted in inhalation experiments with rats (31*). Mortality rate from lung cancer was found to be significantly alleviated in workers exposed to sulphuric and hydrochloric acid mists during steel- pickling operations (32*).

MUTAGENICITY

No information is available concerning the mutagenicity of hydrochloric acid.

TERATOGENICITY AND EMBRYOTOXICITY

No human information is available. Insufficient information is available to evaluate an animal report.

REPRODUCTIVE HAZARDS

No information is available concerning the reproductive hazards of hydrochloric acid

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 4 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

4. FIRST AID MEASURES

PRODUCT IN EYE

Immediately flush the contaminated eye(s) with gently flowing water for at least 30 minutes, holding the eyelid(s) open. Neutral saline solution may be used as soon as it is available. DO NOT INTERRUPT FLUSHING. If necessary, keep emergency vehicle waiting. Take care not to rinse contaminated water into the non-affected eye. If irritation persists, repeat flushing. Transport victim to hospital as soon as possible.

PRODUCT ON SKIN

Remove contaminated clothing immediately, drench the contaminated area with running water for at least 30 minutes. Do not interrupt flushing. If necessary, keep emergency vehicle waiting. Transport victim to hospital as soon as possible. Completely decontaminate clothing, shoes and leather goods before re-use or discard.

PRODUCT INGESTED

Never give anything by mouth if victim is rapidly losing consciousness, or is unconscious or convulsing. Have victim rinse mouth thoroughly with water. DO NOT INDUCE VOMITING. Have victim drink 240 to 300 ml of water. If milk is available, it may be administered AFTER the water has been given. If vomiting occurs naturally, have victim lean forward to reduce risk of aspiration. Repeat administration of water. Transport victim to hospital as soon as possible.

PRODUCT INHALED

Take proper precautions to ensure your own safety before attempting rescue; e.g., wear appropriate protective equipment, use the "buddy" system. Remove source of contamination or move victim to fresh air. If unconscious, do not give anything to drink, give artificial ventilation and chest compression or place in the recovery position as necessary. If conscious make the casualty lie or sit down quietly, give medical oxygen if available. Lung congestion may occur - a conscious casualty with breathing difficulties should be placed in a sitting position. Immediately transport victim to an emergency medical facility. Symptoms may be delayed up to 48 hours after exposure.

FIRST AID COMMENTS

Consult a physician and/or the nearest Poison Control Centre for all exposures except minor instances of inhalation or skin contact. All first aid procedures should be periodically reviewed by a physician familiar with the material and its conditions of use in the workplace.

5. FIRE FIGHTING MEASURES

EXTINGUISHING MEDIA

Hydrochloric acid is not combustible. Use extinguishing agents compatible with acid and appropriate for the burning material. Use water spray to cool containers involved in a fire to prevent rupture.(14) Use water spray or fog to reduce or direct vapours. Do not direct water spray at source of leak.(14)

SPECIAL HAZARDS

Contact with common metals produces hydrogen gas which may form explosive mixtures in air.(14)

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 5 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

PROTECTIVE CLOTHING

Gas-tight chemical safety goggles or face shield. Impervious gloves, coveralls, boots, and/or other resistant protective clothing to prevent all possible skin contact. Neoprene, Viton and butyl rubber are suitable materials for protective clothing. An impervious acid-resistant full-body encapsulating suit and respiratory protection may be required. See section 8.

6. ACCIDENTAL RELEASE MEASURES

PERSONAL PRECAUTIONS

Restrict access to area until completion of clean-up. Ensure clean-up is conducted by fully-trained personnel only. Wear adequate personal protective equipment:- Gas-tight chemical safety goggles or face shield. Impervious gloves, coveralls, boots, and/or other resistant protective clothing to prevent all possible skin contact. Neoprene, Viton and butyl rubber are suitable materials for protective clothing. An impervious acid-resistant full-body encapsulating suit and respiratory protection may be required. See section 8.

Ventilate area.

ENVIRONMENTAL PRECAUTIONS

Keep now neutralised material out of sewers, storm drains, surface waters and soil. Notify government occupational health and safety and environmental authorities.

CLEAN-UP METHODS

Small spills

Contain and soak up spill with absorbent material which does not react with spilled chemical. Put material in suitable, covered, labelled containers. Neutralise spill area with lime or soda ash and flush area with water. Do not get water inside containers. Contaminated absorbent material may pose the same hazards as the spilled product.

Large spills

Avoid contact with spilled material. Keep upwind and out of low areas. Avoid inhaling vapour. Prevent material from entering sewers, waterways or confined spaces. Stop or reduce leak if it can be done without risk. Recover spilled HCl if feasible. Contain spill with earth, sand, or absorbent material which does not react with spilled material. Collect material in suitable, covered, labelled containers. Dispose of contaminated product and materials used in cleaning in a manner approved for this chemical. After removal, neutralise spill area with lime or soda ash and flush spill area with water to an approved sewer. Water fog or spray may be necessary to knock down vapours. Contact fire and emergency services and supplier for additional advice.

7. HANDLING AND STORAGE

SUITABLE MATERIALS

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 6 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

Rubber-lined steel, Haveg, Hastelby and tantalum, are the most commonly used corrosion-resistant materials of construction. Rubber, glass, plastic and ceramic ware are also resistant to corrosion.

UNSUITABLE MATERIALS

Very corrosive to metals.

HANDLING PRECAUTIONS

Prevent release of vapour or mist into the workplace air. Always ensure adequate ventilation in handling areas. When diluting or preparing solutions, slowly add acid to water to avoid boiling or splattering. Use the smallest possible amounts in designated areas with adequate ventilation, Have emergency equipment (for fires, spills, leaks, etc.) readily available. Label containers. keep containers closed when not in use. Empty containers may contain residues which are hazardous. For detailed handling for tank cars and trucks see reference 16.

STORAGE PRECAUTIONS

Store in a cool, dry, well-ventilated area, out of direct sunlight and away from heat sources. Drums should be vented when received and then at least weekly to relieve internal pressure (14). Store away from incompatible materials such as oxidising materials, reducing materials, strong bases. Use corrosion -resistant structural materials and lighting and ventilation systems in the storage area. Floors should not allow liquids to penetrate. Wood and other organic/combustible materials should not be used on floors, structural materials and ventilation systems in the storage area. Use containers which are securely labelled and protected from damage. Use the type of container recommended by the chemical manufacturer or supplier. Storage tanks should be above ground and surrounded with dikes capable of holding the entire contents. Limit the quantity of material in storage. Restrict access to the storage area. Post warning signs where appropriate. Keep storage area separate from populated work areas. Inspect periodically for deficiencies such as damage or leaks.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION

OCCUPATIONAL EXPOSURE STANDARDS

HSE No data available MAK 7 mg/m3 ACGIH 7.5 mg/m3 (2002 Notice of intended change: The reduction of the TLV-C to 2 ppm , 3mg/m3 )

UK EXPOSURE LIMITS Long -term (8 hr. TWA value) 7 mg/m3 Short-term (10 min TWA value) 7 mg/m3

ENGINEERING CONTROL MEASURES

Engineering methods to control hazardous conditions are preferred. Methods include mechanical ventilation (dilution and local exhaust), process or personnel enclosure, control of process conditions, and process modification (e.g. substitution of less hazardous material). Administrative controls and personal protective equipment may also be required. Because of the high potential hazard associated with this substance. stringent control measures such as enclosure or isolation are recommended when dealing with large quantities. Use corrosion-resistant ventilation systems separate from other exhaust ventilation systems. Exhaust directly to the outside. Local exhaust ventilation is usually required. Consider down-draft general exhaust ventilation in potential high concentration areas such as unloading stations, cylinder, drum or carboy filling stations, treatment vats, and waste disposal

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 7 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

areas (16). Cleaning of contaminated exhaust air before release to the outdoors is usually necessary. Supply sufficient replacement air to make up for air removed by exhaust systems. Engineering designs are reviewed in reference 16.

PERSONAL PROTECTION - RESPIRATORY

NIOSH RECOMMENDATIONS FOR HYDROGEN CHLORIDE (GAS) CONCENTRATIONS IN AIR (11):

UP TO 50 PPM: SAR; or SCBA; or chemical cartridge respirator with cartridge(s) to protect against hydrogen chloride.

UP TO 100 PPM: SAR operated in a continuous flow mode; or full-face piece SCBA; or full-face piece SAR; or gas mask with canister to protect against hydrogen chloride; or full-face piece chemical cartridge respirator with cartridge(s) to protect against hydrogen chloride; or powered air-purifying respirator with cartridge(s) to protect against hydrogen chloride.

ABBREVIATIONS:

SAR = supplied-air respirator; SCBA = self-contained breathing apparatus.

PERSONAL PROTECTION - HAND

Neoprene, Viton or butyl rubber gloves.

PERSONAL PROTECTION - EYE

Gas-tight chemical safety goggles. A face shield may also be necessary.

PERSONAL PROTECTION - SKIN

Impervious gloves, coveralls, boots, and/or other resistant protective clothing to prevent all possible skin contact. Neoprene, Viton and butyl rubber are suitable materials for protective clothing. An impervious acid-resistant full-body encapsulating suit and respiratory protection may be required in some operations. Have a safety shower/eye-wash fountain readily available in the immediate work area.

RESISTANCE OF MATERIALS FOR PROTECTIVE CLOTHING

Guidelines for hydrochloric acid (12) :-

VERY GOOD: Neoprene, nitrile blended polyvinyl chloride (PVC)

GOOD: Chlorinated polyethylene, Viton coated neoprene, natural rubber, nitrile, Viton, Saranex, butyl coated neoprene, chlorobutyl, polycarbonate, neoprene blended PVC, styrene-butadiene rubber (SBR)

FAIR/POOR: PVC, polyurethane, neoprene blended SBR, SBR coated neoprene.

9. PHYSICAL AND CHEMICAL PROPERTIES

APPEARANCE Concentrated hydrochloric acid is a colourless or slightly yellow, fuming liquid. ODOUR A pungent, choking odour. pH 1.1 (0.1 N solution); strongly acidic (10)

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 8 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

BOILING POINT/RANGE 108.6°C; forms constant boiling mixture at 20% HCl (10) MELTING POINT/RANGE -35°C (35% HCl) (10) FLASH POINT Not applicable FLAMMABILITY Not applicable AUTOFLAMMABILITY Not applicable EXPLOSIVE PROPERTIES None OXIDISING PROPERTIES None VAPOUR PRESSURE 100 mm Hg (13.3 kPa) at 20°C (35% HCl) (10) SPECIFIC GRAVITY 1.18 (35% HCl) SOLUBILITY - WATER Soluble in all proportions.(10) SOLUBILITY - SOLVENT Very soluble in alcohols; soluble in ether and benzene; insoluble in hydrocarbons (6) VISCOSITY 2 centipoise (2 mPa.s) at 25°C VAPOUR DENSITY 1.268 (air = 1) (8)

10. STABILITY AND REACTIVITY

STABILITY Stable.

HAZARDOUS POLYMERIZATION

HCl itself does not polymerize. Reaction of HCl with some incompatible materials can cause polymerization.

STABILITY AND REACTIVITY COMMENTS

Large amounts of heat can be released when concentrated HCl is mixed with water or with organic solvents

CONDITIONS TO AVOID

CORROSIVITY TO METALS

Very corrosive to most metals.

INCOMPATIBLE MATERIALS

MATERIALS TO AVOID:

METALS - can react generating flammable hydrogen gas.

BASES (e.g. sodium hydroxide, amines) - react violently generating heat and pressure.

ALDEHYDES, EPOXIDES - HCl may cause violent polymerization, generating heat and pressure.

REDUCING AGENTS - reaction may produce heat, fire and flammable hydrogen gas.

OXIDIZING AGENTS - may react generating heat and toxic or corrosive chloride gases.

EXPLOSIVES - contact may generate heat which could cause detonation.

ACETYLIDES, BORIDES, CARBIDES, SILICIDES - may react producing flammable gas (e.g., acetylene).

CYANIDES, SULFIDES - may react to release toxic gas (HCN or H2S).

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 9 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

PHOSPHIDE - may react to release toxic, flammable phosphine gas. See reference 10 for further information.

HAZARDOUS DECOMPOSITION PRODUCTS

HCl is thermally stable up to temperatures of about 1500°C (2730°F).(15) At higher temperatures it breaks down to form hydrogen and chlorine.(6)

11. TOXICOLOGICAL INFORMATION

No human information is available. Insufficient information is available to evaluate an animal report.

ACUTE TOXICITY

Hydrochloric acid and high concentrations of the gas are highly corrosive to the skin and mucous membranes

SKIN AND EYE CONTACT

Low concentrations of vapour or mist (10-35 ppm) can be immediately irritating, causing redness.(2) Concentrated vapour, mist or splashed liquid can cause severe irritation, burns and permanent blindness.(4)

Hydrochloric acid liquid can cause skin burns, and may produce keloid and retractile scarring (29*). Facial burns may result in serious and disfiguring scars

SUB-CHRONIC TOXICITY

Frequent contact with the dilute acid may cause dermatitis (14*). and photosensitisation may result from industrial contact.

CARCINOGENICITY

No carcinogenic response was noted in inhalation experiments with rats (31*). Mortality rate from lung cancer was found to be significantly alleviated in workers exposed to sulphuric and hydrochloric acid mists during steel- pickling operations (32*).

MUTAGENICITY

No information is available concerning the mutagenicity of hydrochloric acid.

REPRODUCTIVE TOXICITY

No information is available concerning the reproductive hazards of hydrochloric acid.

12. ECOLOGICAL INFORMATION

AQUATIC TOXICITY - FISH Dangerous to aquatic life in high concentrations. Notify local Health and Pollution Control authorities AQUATIC TOXICITY - DAPHNIA No data available. AQUATIC TOXICITY - ALGAE No data available. BIODEGRADABILITY Not relevant. BIO-ACCUMULATION None.

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 10 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

MOBILITY No data available GERMAN WGK No data available

13. DISPOSAL CONSIDERATIONS

DISPOSAL METHODS

This material is highly corrosive. Comply with State and Local regulations on disposal. Store material for disposal as indicated in Storage Conditions. Waste treatment procedures must only be performed by trained, experienced personnel using appropriate protective equipment in approved treatment facilities. Disposal of neutralized waste by secure landfill may be acceptable. Small quantities: Contaminated materials may be cautiously added to water and slowly neutralized with sodium or calcium carbonate. Caution: Neutralizing an acid spill will produce heat of reaction and vapours. The resulting neutralized solids may be treated as normal waste.(13)

DISPOSAL OF PACKAGING

Empty containers may contain dangerous residues and are subject to proper waste disposal. Always obey hazard warnings.

14. TRANSPORT INFORMATION

UN No. 1789 SUBSTANCE IDENTITY No. ADR/RID CLASS 8 ADR/RID ITEM No. Not available ADR/RID HAZARD IDENTITY No. 80 IMDG - SHIPPING NAME Hydrochloric acid. IMDG - CLASS 8 IMDG - PACKAGING GROUP II IMDG - MARINE POLLUTANT 9.2 Substance hazardous to the environment. IMDG - EMS No. IMDG - MFAG TABLE No. 8183 IATA - SHIPPING NAME Hydrochloric acid IATA - CLASS 8 IATA - SUBSIDIARY RISK(S) Corrosive ADNR - CLASS Not available UK - DESCRIPTION Not available UK - EMERGENCY ACTION CODE Not available UK - CLASSIFICATION Not available TREMCARD No.

15. REGULATORY INFORMATION

EEC CLASSIFICATION [C;Xi] Corrosive; Irritant.

RISK PHRASES R34: Causes burns. R36/37/38: Irritating to eyes and respiratory system and skin.

SAFETY PHRASES S1/2: Keep locked up and out of reach of children.

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 11 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

S26: In case of contact with eyes, rinse with plenty of water, seek medical advice. S28: After contact with skin, wash immediately with plenty of water. S45: In case of accident or if you feel unwell, seek medical advice immediately, show label where possible.

EU COMMENTS :

Concentration greater than or equal to 25%: Corrosive. Causes burns. Irritating to the respiratory system. [C;R34-37]. Concentration less than 25% and greater than or equal to 10%: Irritant. Irritating to eyes, and respiratory system and skin. [Xi, R36/37/38].

The product label must indicate the percentage concentration of the solution.

NATIONAL LEGISLATION Hazardous Substances Act 15 of 1973 and Regulations, Occupational Health and Safety Act 85 of 1993 and Regulations.

16. OTHER INFORMATION

CAS No. 7647-01-0 EINECS No. 231-595-7 EEC ANNEX 1 No. Not available MITI No. Not available FDA LIST No. Not available LISTING - TOSCA Not available LISTING - ACOIN Not available

APPENDIX

MSDS PREPARATION DATE 1993-01-29 MSDS SERIAL No. H002.MS1 COMPILED BY D D LIEBENBERG

MSDS REVISION DATE 2003-07-04 REVISED BY D D LIEBENBERG MSDS SERIAL No. MSDS 010/R2

APPROVED BY VIC VAN ZYL – MANUFACTURING DIRECTOR DATE OF APPROVAL 2004-02-16

SOURCES OF INFORMATION

MATERIAL SAFETY DATA SHEET HYDROCHLORIC ACID PAGE 12 OF 12 MURIATIC ACID MSDS 010/R2 HCl 2003-07-04

1. Cheminfo Record Number: 13. and references contained therein. Numbers in parenthesis ( ) refer to this article.

2. Chemical Safety Data Sheets, Volume 3, Corrosives and Irritants. Published by the Royal Society of Chemistry, Information Services. Numbers in parenthesis ( *) refer to this article.

EXCLUSION OF LIABILITY

“All information and instructions provided in this Material Safety Data Sheet (“MSDS”) in respect of the substance is given solely in terms of the provisions of the Occupational Health and Safety Act No 85 of 1993 and Regulations (“the Act”), is based on scientific and technical knowledge as at the date indicated on this MSDS, and is presented in good faith to be correct.

The information and instructions provided in this MSDS apply only to the substance in its present form and not to any formulation or mix, in which event it is the sole responsibility of the user of the substance as formulated and/or mixed to investigate and establish any danger which may arise out of its use, wherever such user may be situated.

It is the sole responsibility of the person in receipt of this MSDS, wherever such recipient may be situated, to ensure that the information provided is communicated to and understood by any person who may come in contact with the substance in any place and in any manner whatsoever. If such recipient produces formulations or mixes using the substance, then it is such recipient’s sole responsibility to comply with the provisions of the Act in respect of the provision of the necessary MSDS, or to comply with any other applicable legislation.”

Material Safety Data Sheet

Shell Automotive Gasoil (South Africa) Infosafe ACK64 Version 1.1 DRAFT 2005/11/01 Status DRAFT No. ZA/eng/C No. Date

1. IDENTIFICATION OF THE SUBSTANCE/PREPARATION AND COMPANY/UNDERTAKING

Product Name V – Power Diesel, Diesel Extra, Diesel

Product Type/Use Automotive gas oil. Fuel for on-road diesel-powered engines.

Company Name Shell SA Marketing (Pty) Ltd

Address Twickenham, The Campus 57 Sloane Street Epson Downs Bryanston 2021 REPUBLIC OF SOUTH AFRICA

Emergency Tel. 011 608 3300 Netcare Poison Centre 0800 333 444

Telephone/Fax Number Tel: +27 11 996 7000 Fax: +27 11 996 7777

Other Names Not Available

2. COMPOSITION/INFORMATION ON INGREDIENTS

Preparation Description Complex mixture of hydrocarbons consisting of paraffins, cycloparaffins, aromatic and olefinic hydrocarbons with carbon numbers predominantly in the C9 to C25 range. May contain catalytically cracked oils in which polycyclic aromatic compounds, mainly 3-ring but some 4- to 6-ring species, are present. May also contain several additives at <0.1% v/v each. Dyes and markers can be used to indicate tax status and prevent fraud. May contain cetane improver (Ethyl Hexyl Nitrate) at <0.2% v/v.

Dangerous R Components / Name CAS EINECS Proportion Hazard Phrase Constituents

Fuels, diesel 68334- 269- 0-100 % Xn, N R65, 30-5 822-7 R40, R66, R51/53 Fuels, diesel, no.2 68476- 270- 0-100 % Xn, N R65, 34-6 676-1 R40, R66, R51/53

Other Information See Section 16 'Other Information' for full text of each relevant Risk Phrase.

3. HAZARDS IDENTIFICATION

Human Health Hazards Harmful, may cause lung damage if swallowed. Limited evidence of a carcinogenic effect. Aspiration into the lungs may cause chemical pneumonitis which can be fatal. Prolonged or repeated exposure to skin may give rise to dermatitis. Under conditions of poor personal hygiene, excessive exposure may lead to irritation, oil acne and folliculitis and development of warty growths which may subsequently become malignant.

Safety Hazards Not classified as flammable, but will burn. May ignite on surfaces at temperatures above auto- ignition temperature. Vapour in the headspace of tanks and containers may ignite and explode at temperatures exceeding auto-ignition temperature, where vapour concentrations are within the flammability range.

Environmental Hazards Toxic to aquatic organisms. May cause long term adverse effects in the aquatic environment.

Other Information This product is intended for use as a fuel in a closed system. If used for any other purpose, in open systems or as a spray, ignition and exposure risks will increase and a careful risk assessment should be carried out.

4. FIRST AID MEASURES

Symptoms and Effects Not expected to give rise to an acute hazard under normal conditions of use. Aspiration into the lungs may occur directly or following ingestion. This may cause chemical pneumonitis which may be fatal. If ingested may lead to irritation of the mouth, irritation of the throat, irritation of the digestive tract, and vomiting. Splashes into the eye may cause irritation.

Inhalation Remove to fresh air. If breathing but unconscious, place in the recovery position. If breathing has stopped, apply artificial respiration. If heartbeat absent, give external cardiac compression. Monitor breathing and pulse. Seek urgent medical advice.

Skin Wash skin with water using soap if a vailable. Contaminated clothing must be removed as soon as possible. It must be laundered before reuse. When using high pressure equipment, injection of product under the skin can occur. If high pressure injuries occur, the casualty should be sent immediately to a hospital. Do not wait for symptoms to develop.

Eye Flush eye with copious quantities of water. If persistent irritation occurs, obtain medical attention.

Ingestion DO NOT INDUCE VOMITING. Protect airway if vomiting begins. Give nothing by mouth. If breathing but unconscious, place in recovery position. If breathing has stopped, apply artificial respiration. OBTAIN MEDICAL ATTENTION IMMEDIATELY.

Advice to Doctor Treat symptomatically. In cases of ingestion, consider gastric lavage. Gastric l avage must only be undertaken after cuffed endotracheal intubation in view of the risk of aspiration. Administration of carbon for medicinal use (carbo medicinalis) may reduce absorption from the digestive tract. In cases of chemical pneumonitis, antibiotic and corticosteroid therapy should be considered, but only under expert guidance and with special care facilities. High pressure injection injuries require prompt surgical intervention and possibly steroid therapy, to minimise tissue damage and loss of function.

5. FIRE FIGHTING MEASURES

Specific Hazards Combustion is likely to give rise to a complex mixture of airborne solid and liquid particulates (smoke), and gases, including carbon monoxide, oxides of sulphur, and unidentified organic and inorganic compounds. Flammable vapours may be present even at temperatures below the flash point.

Extinguishing Media Foam, fine water spray and dry chemical powder. Carbon dioxide, Clean Agents (e.g. Inergen, Argonite etc.), sand or earth may be used for small fires only.

Unsuitable Extinguishing Media Do not use water in a jet.

Protective Equipment Proper protective equipment must be worn, this should include breathing apparatus when approaching a fire in a confined space.

Other Information Keep adjacent drums and tanks cool by spraying with water from a safe location. If possible remove them from the danger zone. If adequate cooling cannot be achieved, the area needs to be evacuated, and further fire fighting and cooling attempts should be carr ied out from safe location.

6. ACCIDENTAL RELEASE MEASURES

Personal Precautions Remove all possible sources of ignition in the surrounding area. Evacuate all personnel. Do not breathe fumes, vapour. Do not operate electrical equipment. Avoid contact with skin, eyes, clothing. Ventilate contaminated area thoroughly. Wear chemical resistant knee length safety boots and PVC jacket and trousers. Wear safety glasses or full face shield if splashes are likely to occur.

Environmental Precautions Prevent from spreading or entering into drains and surface waters (e.g. lakes, ponds, ditches, rivers and streams) by using sand, earth, or other appropriate non-combustible barriers. Inform local authorities if impacts cannot be prevented.

Clean-up Methods - Small Spillages To minimize soil and groundwater contamination, absorb liquid with sand earth or other recommended sorbant material, as soon as possible. Sweep up and remove to a suitable, clearly marked container for disposal in accordance with local regulations. Do not disperse using water.

Clean-up Methods - Large Spillages Prevent from spreading by making a barrier with sand, earth or other containment material. Reclaim liquid directly or in an absorbent. Dispose of as for small spills.

Maritime Spillages Maritime spillages should be dealt with using a Shipboard Oil Pollution Emergency Plan (SOPEP), as required by MARPOL Annex 1 Regulation 26.

Other Information Local authorities should be advised if significant spillages cannot be contained. Observe all relevant local regulations.

7. HANDLING AND STORAGE

Exposures in Normal Use Maintenance and fuelling activities - Avoid inhalation of vapours and contact with skin when emptying containers.

Handling Avoid naked flames. The vapour is heavier than air, spreads along the ground and distant ignition is possible. When using do not eat, drink or smoke. Never siphon by mouth. Only use in well-ventilated areas. Take precautionary measures against static discharges. Ensure all equipment is properly earthed. If using pressurised equipment, take extra care to avoid injection under the skin. Use local exhaust ventilation if there is risk of inhalation of vapours, mists or aerosols. Avoid prolonged or repeated contact with skin. When handling product in drums, safety footwear should be worn and proper handling equipment should be used. Prevent spillages. Cloth, paper and other materials that are used to absorb spills present a fire hazard. Avoid their accumulation by disposing of them safely and immediately. In addition to any specific recommendations given for controls of risks to health, safety and the environment, an assessment of risks must be made to help determine controls appropriate to local circumstances.

Storage This product must never be stored in buildings occupied by people. Drums and small containers should be stored in well-ventilated areas, flameproof cabinets or stores. Keep container tightly closed in a dry, well-ventilated place away from direct sunlight and other sources of heat or ignition. Keep in a bunded area with a sealed (low permeability) floor, to provide containment against spillage. Stack drums to a height not exceeding 3 metres without the use of racking. Locate tanks away from heat and other sources of ignition. Seek specialist advice for the design, construction and operation of bulk storage facilities.

Storage Temperatures Ambient.

Product Transfer Electrostatic charges may be generated during pumping. Ensure electrical continuity by bonding all equipment. Avoid splash filling. Wait 2 minutes after tank filling (for tanks such as those on road tanker vehicles) before opening hatches or manholes. Wait 30 minutes after tank filling (for large storage tanks) before opening hatches or manholes. Contamination resulting from product transfer may give rise to light hydrocarbon vapour in the headspace of tanks that have previously contained gasoline. This vapour may explode if there is a source of ignition. Partly filled containers present a greater hazard than those that are full, therefore handling, transfer and sampling activities need special care.

Tank Cleaning Cleaning, inspection and maintenance of storage tanks is a specialist operation that requires the implementation of strict procedures and precautions. These include issuing of work permits, gas-freeing of tanks, using a manned harness, lifelines, and wearing air-supplied breathing apparatus. Prior to entry and whilst cleaning is underway, the atmosphere within the tank must be monitored using an oxygen meter and explosimeter. Additional precautions are required where the tank may previously have contained leaded gasoline.

Recommended Materials For containers or container linings, use mild steel or stainless steel. Aluminium may also be used for applications where it does not present an unnecessary fire hazard. Examples of suitable materials are: high density polyethylene (HDPE), polypropylene (PP), and Viton (FKM), which have been specifically tested for compatibility with this product. For container linings, use amine-adduct cured epoxy paint. For seals and gaskets use: graphite, PTFE, Viton A, Viton B.

Unsuitable Materials Synthetic materials such as plastics and fibreglass may be unsuitable for containers or container linings depending on the material specification and intended use. Examples of materials to avoid are: natural rubber (NR), nitrile rubber (NBR), ethylene propylene rubber (EPDM), polymethyl methacrylate (PMMA), polystyrene, polyvinyl chloride (PVC), polyisobutylene. However, some may be suitable for glove materials.

Other Information Ensure that all local and international regulations regarding handling and storage facilities are followed.

8. EXPOSURE CONTROLS, PERSONAL PROTECTION

Exposure Limits

Exposure Exposure Substance Regulations Units Notes Duration Limit

Fuels, diesel ACGIH TWA 100 mg/m3

Fuels, diesel, no.2 ACGIH TWA 100 mg/m3

ACGIH ACGIH Threshold Limit Values.

Exposure Controls The level of personal protection and the types of controls necessary will vary depending on exposure conditions. Select controls based on a risk assessment of local circumstances. Use sealed systems as far as possible. Use local, intrinsically safe, exhaust ventilation if there is a risk of inhalation of vapours, mists, or aerosols. Provide eye washes and showers for emergency use.

Respiratory Protection Care should be taken to keep exposures below applicable occupational exposure limits. If this cannot be achieved, use of a respirator fitted with an organic vapour cartridge combined with a particulate pre-filter should be considered. Where air-filtering respirators are unsuitable (e.g. where airborne concentrations are high, there is a confined space or a risk of oxygen deficiency) use appropriate positive pressure breathing apparatus.

Hand Protection Select gloves tested to a relevant standard (e.g. Europe EN374, US F739). When prolonged or frequent repeated contact occurs, Nitrile, Neoprene or PVC gloves may be suitable. (Breakthrough time of > 240 minutes ). Breakthrough times for gloves vary depending on, e.g. chemical resistance, material thickness, frequency and duration of contact. Selection should also take into account other usage requirements, e.g. dexterity, heat resistance, other chemical substances handled. Always seek advice from glove suppliers. Contaminated gloves should be replaced. Personal hygiene is a key element of effective hand care. Gloves must only be worn on clean hands. After using gloves, hands should be washed and dried thoroughly. Application of a non-perfumed moisturizer is recommended.

Eye Protection Wear safety glasses or full face shield if splashes are likely to occur.

Body Protection Minimise all forms of skin contact. In the event of risk from splashing wear e.g. Nitril e, PVC, or neoprene rubber apron. Wear safety shoes or boots which are chemical and petroleum distillate resistant.

Environmental Exposure Controls Minimise release to the environment. An environmental assessment must be made to ensure compliance with local environmental legislation.

Exposure Measurement Methods Monitoring of the concentration of substances in the breathing zone of workers or in the general workplace may be required to confirm compliance with an Occupational Exposure Limit and adequacy of exposure controls. For some substances biological monitoring may also be appropriate. Information on suitable methods is available on request.

9. PHYSICAL AND CHEMICAL PROPERTIES

Colour pale straw/yellow.

Physical State Liquid.

Odour Characteristic of normal diesel. pH Value Data not available.

Vapour Pressure <0.1 kPa at 20ºC.

Initial Boiling Point circa 170ºC.

Final Boiling Point circa 390ºC.

Sulphur Levels Less than 50 ppm Solubility in Water Negligible.

Density 820 to 845 kg/m3 at 15°C.

Flash Point >55ºC (Method: PMCC).

Flammable Limits - Upper 6%(V/V) maximum.

Flammable Limits - Lower 1%(V/V) minimum.

Auto-Ignition Temperature >220ºC.

Kinematic Viscosity 2 to 5 mm2/s at 40°C.

Vapour Density (Air=1) Greater than 5.

Partition co-efficient, n-octanol/water log Pow 3 to 6.

Other Information Sulphur contents: V- Power Diesel: <0.005% wt Diesel Extra, Diesel: <0.05%wt

10. STABILITY AND REACTIVITY

Stability Stable under normal use conditions.

Conditions to Avoid Heat, flames and sparks.

Materials to Avoid Strong oxidizing agents e.g. chlorates and ammonium nitrate.

Hazardous Decomposition Products Hazardous decomposition products are not expected to form during normal storage.

11. TOXICOLOGICAL INFORMATION

Basis for Assessment Fuels are typically made from blending several refinery streams. Toxicological studies have been carried out on a variety of hydrocarbon blends and streams but not those containing additives. Information given is based on a knowledge of the components and the toxicology of similar products.

Acute Toxicity - Oral LD50 > 5000 mg/kg. Ingestion may lead to vomiting and aspiration into the lungs, this may result in chemical pneumonitis, which may be fatal.

Acute Toxicity - Dermal LD50 > 2000 mg/kg.

Acute Toxicity - Inhalation LC50 expected to be >5mg/l.

Eye Irritation Slightly irritating.

Skin Irritation Slightly irritating.

Respiratory Irritation Expected to be slightly irritating.

Skin Sensitisation Not a skin sensitizer.

Carcinogenicity Dermal application to mice causes skin tumours.

Mutagenicity In-vitro mutagenicity studies show that mutagenic activity is related to 4-6 ring polycyclic aromatic content.

Reproductive Toxicity Not a developmental toxicant.

Human Effects Prolonged/repeated contact may cause defatting of the skin which can lead to dermatitis and may make the skin more susceptible to irritation and penetration by other materials. Under conditions of poor personal hygiene, excessive exposure may lead to irritation, oil acne and foliculitis and development of warty growths which may subsequently become malignant.

Other Information High pressure injection of product into the skin may lead to local necrosis if the product is not surgically removed.

12. ECOLOGICAL INFORMATION

Basis for Assessment Fuels are typically made from blending several refinery streams. Ecotoxicological studies have been carried out on a variety of hydrocarbon blends and streams but not those containing additives. Information given is based on a knowledge of the components and the ecotoxicology of similar products.

Mobility Floats on water. Contains volatile components. Partly evaporates from water or soil surfaces, but a significant proportion will remain after one day. If it enters soil, it will adsorb to soil particles and will not be mobile. Large volumes may penetrate soil and could contaminate groundwater.

Persistence / Degradability Hovedbestanddelene er naturlig bionedbrytbare over tid (inherently biodegradable). Persists under anaerobic conditions. The volatile components oxidise rapidly by photochemical reactions in air.

Bioaccumulation Contains components which may have the potential to bioaccumulate. May cause tainting of fish and shellfish.

Ecotoxicity Poorly soluble mixture. Product is classified as toxic to aquatic organisms, LL/EL50 1 -10 mg/l. (LL/EL50 expressed as the nominal amount of product required to prepare aqueous test extract). Films formed on water may affect oxygen transfer and damage organisms.

13. DISPOSAL CONSIDERATIONS

Waste Disposal Waste arising from a spillage or tank cleaning should be disposed of in accordance with prevailing regulations, preferably to a recognised collector or contractor. The competence of the collector or contractor to deal satisfactorily with this type of product should be established beforehand. Do not dispose into the environment, in drains or in water courses. Do not dispose of tank water bottoms by allowing them to drain into the ground. This will result in soil and groundwater contamination.

Product Disposal As for waste disposal.

Container Disposal Recycle or dispose of in accordance with the legislation in force with a recognised collector or contractor. Do not pollute the soil, water or environment with the waste product.

14. TRANSPORT INFORMATION

ADR/RID UN Number 1202

ADR/RID Class 3

ADR/RID Packing Group III

ADR/RID Proper Shipping Name GAS OIL

IMDG UN No 1202

IMDG Hazard Class 3

IMDG Packing Group III

IMDG Proper Shipping Name GAS OIL

UN Number (Air Transport, IATA) 1202

IATA Hazard Class 3

IATA Packing Group III

IATA Proper Shipping Name GAS OIL

Other Information Not a Marine Pollutant under IMDG. MARPOL rules apply for bulk shipments by sea.

15. REGULATORY INFORMATION

EC Symbols Xn N

Indication of danger Harmful. Dangerous for the Environment.

EC Risk Phrase R40 Limited evidence of a carcinogenic effect. R65 Harmful: may cause lung damage if swallowed. R66 Repeated exposure may cause skin dryness and cracking. R51/53 Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment.

EC Safety Phrase S2 Keep out of reach of children. S29 Do not empty into drains. S61 Avoid release to the environment. Refer to special instructions/safety data sheet. S62 If swallowed, do not induce vomiting; seek medical advice immediately and show this container or label. S36/37 Wear suitable protective clothing and gloves.

Packaging & Labelling Contains fuels, diesel.

16. OTHER INFORMATION

SDS Distribution This document contains important information to ensure the safe storage, handling and use of this product. The information in this document should be brought to the attention of the person in your organisation responsible for advising on safety matters.

References 67/548/EEC - Dangerous Substances Directive, subsequent amendments and adaptations. 1999/45/EC - Dangerous Preparations Directive, subsequent amendments and adaptations. 91/155/EEC - Safety Data Sheet Directive and 2nd amendment 2001/58/EC. Concawe Report 01/53 - Classification and Labelling of Petroleum Substances according to the EU Dangerous Substances Directive. Concawe Report 01/54 - Environmental Classification of Petroleum Substances - Summary Data and Rationale. Concawe Report 01/97 - Petroleum Products - First Aid Emergency and Medical Advice. Concawe Report 00/56 - Revised Preparations - Summary Data and Rationale. CENELEC CLC/TR 50404 Electrostatics - Code of Practise for the Avoidance of Hazards Due to Static Electricity. United Nations - Recommendations on the Transport of Dangerous Goods, Model Regulations. Vol 1 & 2 . International Air Transport Association - Dangerous Goods Regulations. International Maritime Organisation - International Maritime Dangerous Goods Code. Vol 1 & 2. European Model Code of Safe Practice in the Storage and Handling of Petroleum Products. Associated Octel Company UK - Leaded Gasoline Tank Cleaning and Disposal of Sludge (Booklet OIP/5 (5/99)). Concawe Product Dossier 95/107 - Gas Oils. Restrictions This product must not be used in applications other than those recommended without first seeking the advice of the supplier. This product is not to be used as a solvent or cleaning agent, for lighting or brightening fires, or as a skin cleanser.

List of R Phrases in Section 2 R40 Limited evidence of a carcinogenic effect. R65 Harmful: may cause lung damage if swallowed. R66 Repeated exposure may cause skin dryness and cracking. R51/53 Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment.

Further Information This information is based on our current knowledge and is intended to describe the product for the purposes of health, safety and environmental requirements only. It does not constitute a guarantee for any specific property of the product.

End of SDS

MATERIAL SAFETY DATA SHEET

Sudflockl 3456

INTERNATIONAL STANDARD MATERIAL SAFETY DATA SHEET FOR CHEMICAL PRODUCTS WHICH CONFORMS TO ISO 11014-1 1994

SECTION 1. IDENTIFICATION OF THE SUBSTANCE/PREPARATION

Name : Sudfloc 3456 Code : MSDS ref. : 641 B /005 In emergency contact: Süd-Chemie Water & Process Technologies at (27) 11 929-5800/929-5940 Head Office: No.1 Horn Street, Chloorkop Ext. 1 Gauteng Province, RSA Tremcard : ►

SECTION 2. COMPOSITION/INFORMATION ON INGREDIENTS

Substance/Preparation: Preparation Common Name: Nil Synonyms: Nil HAZARDOUS COMPONENTS CAS. No. COMPONENT RANGE % CONTENT

------No hazardous components

SECTION 3. HAZARDS IDENTIFICATION

Listing as per SABS 0265: 1999 KEY

Inhalation : 0 – Normal material GHS: No listing 4 : Very toxic. Skin : 0 – Normal material GHS: No listing 3 : Toxic. 2 : Harmful. Ingestion : 0 – Normal material GHS: No listing 1 : Slight risk. Environmental : 0 – Normal material GHS: No listing 0 : Normal material.

SECTION 4. FIRST AID MEASURES

Inhalation : Move patient to fresh air. Administer oxygen if necessary. Obtain medical attention without delay. Skin : Immediately wash affected area. If necessary obtain medical attention. Eyes : Immediately flush with water. Seek medical attention. Ingestion : Obtain medical attention if necessary. - SECTION 5. FIRE FIGHTING MEASURES

This product is neither flammable nor explosive. Where drums of this product are involved in a fire, regular foam, water or carbon dioxide/dry chemical may be used to cool them off until the fire is extinguished. As with any fire involving chemicals a self-contained breathing apparatus and full face-shield, operated under positive pressure, should be used. Contain and collect water. Do not discharge to drains or sewers.

File name: SUDFLOC 3456 Issue number: 005 Revision date and by whom: MARCH 2008 – G.MAHLARE Page1 of 3

SECTION 6. ACCIDENTAL RELEASE MEASURES

Personal : Persons not wearing protective equipment should be excluded from the area. Environmental : Prevent run-off to sewers, streams or other bodies of water.

SECTION 7. HANDLING AND STORAGE

Handling : Follow all relevant precautions. Ventilation : General room ventilation is expected to be satisfactory. Storage : Store separately from any reactive substances.

SECTION 8. EXPOSURE CONTROLS/PERSONAL

Inhalation : In case of insufficient ventilation, use suitable respiratory protection. Skin : Use barrier cream and impervious gloves. Wear suitable overall. Eyes : Use face shield or goggles. Avoid direct contact. Ingestion : Observe the rules of hygiene. Wash before eating or drinking. Appropriate hand protection and protective clothing must always be used.

FLAMMABILITY NFPA LISTINGS HEALTH HAZARD 0

0 0 Most Hazardous: Nil REACTIVITY SPECIFIC HAZARD

SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES

Chemical Class : Liquid Description : Preparation. Boil. Pt : 75-100ºC Flash pt.: N/A Auto Ignition Temp : N/A Explosive Prop. : N/A Sol. in water: Complete pH : 4.0-4.40 pH Units Decomposition Temp : N/A

SECTION 10. STABILITY AND REACTIVITY

Stable under normal conditions : Yes Will react with oxidizers : No Reaction with water : Soluble Decomposition Products : None Conditions to avoid : None

SECTION 11. TOXICOLOGICAL INFORMATION. MAJOR TOXICOLOGICAL COMPONENT

Acute Toxicity (Formulation) LD 50 : 10266 + mg/kg. Sensitisation : Yes Inhalation – Ceiling – TWA : 5.2 mg/m3 Skin : Rabbit : LC 50 Ingestion (Formulation MTC) : 10266 + mg/kg.

SECTION 12. ECOLOGICAL INFORMATION. MAJOR TOXICOLOGICAL COMPONENT

Mobility : Bio-Accumlation : Degradability :

Ecotoxicity Limited information.

LC 50 : 3.9mg/l Daphnia magna (48hr) LC 50 : 133 mg/l Mosquito fish (96hr) LC 50 : 0.075 mg/l Trout (96 hr) LC 50 : 3.6 mg/l Fundus Heteroc litus (96 hr)

SECTION 13. DISPOSAL INFORMATION

Use reputable waste disposal contractors. Exercise caution in disposal of used containers.

File name: SUDFLOC 3456 Issue number: 005 Revision date and by whom: MARCH 2008 – G.MAHLARE Page2 of 3

SECTION 14. TRANSPORT INFORMATION

NOT REGULATED -- Non Hazardous.

Cas No. : UN No. : Class : Sub Risk : EMS No. : IMDG Code : MFAG Table : Pack Group : Marine Pollutant : Label : Flash Point : N/A Not Regulated by D.O.T.

SECTION 15. REGULATORY INFORMATION

R: 38 : Irritating to skin. S: 24 : Avoid contact with skin R: 36 : Irritating to eyes. S: 25 : Avoid Contact with eyes S: 39 : Wear eye/face protection

SECTION 16. OTHER INFORMATION

Any discomfort experienced, seek medical advice. All chemical products may be hazardous, therefore wear protective equipment and do not reuse container for any purpose whatsoever.

Refer Emergency Response Handbook – Nil.

The information, provided in this Safety Data Sheet, is to the best of our knowledge, correct as of the date of publication. The information is designed only as a guide for safe handling, use, storage, transportation, disposal and release.

If serious risk is incurred please contact : Poisons Emergency Control Phone: RSA 082911.

File name: SUDFLOC 3456 Issue number: 005 Revision date and by whom: MARCH 2008 – G.MAHLARE Page3 of 3

MATERIAL SAFETY DATA SHEET

Sudflockl 3TL

INTERNATIONAL STANDARD MATERIAL SAFETY DATA SHEET FOR CHEMICAL PRODUCTS WHICH CONFORMS TO ISO 11014-1 1994

SECTION 1. IDENTIFICATION OF THE SUBSTANCE/PREPARATION

Name : Sudfloc TL Code : 0265 / GHS MSDS ref. : 678 A/006 In emergency contact: Süd-Chemie Water & Process Technologies at (27) 11 929-5800/929-5940 Head Office: No.1 Horn Street, Chloorkop Ext. 1 Gauteng Province, RSA Tremcard : ►

SECTION 2. COMPOSITION/INFORMATION ON INGREDIENTS

Substance/Preparation: Preparation Common Name: Nil Synonyms: Nil HAZARDOUS COMPONENTS CAS. No. COMPONENT RANGE % CONTENT

26062793 Poly(diallyldimethylammonium chloride) 24%

SECTION 3. HAZARDS IDENTIFICATION

Listing as per SABS 0265: 1999 KEY

Inhalation : 0 – Normal material GHS: No listing 4 : Very toxic. Skin : 0 – Normal material GHS: No listing 3 : Toxic. 2 : Harmful. Ingestion : 0 – Normal material GHS: No listing 1 : Slight risk. Environmental : 0 – Normal material GHS: No listing 0 : Normal material.

SECTION 4. FIRST AID MEASURES

Inhalation : Move patient to fresh air. Administer oxygen if necessary. Obtain medical attention without delay. Skin : Immediately wash affected area. If necessary obtain medical attention. Eyes : Immediately flush with water. Seek medical attention. Ingestion : Non hazardous, if necessary obtain medical attention.

SECTION 5. FIRE FIGHTING MEASURES

This product is neither flammable nor explosive. Where drums of this product are involved in a fire, regular foam, water or carbon dioxide/dry chemical may be used to cool them off until the fire is extinguished. Contain and collect water. Do not discharge to drains or sewers.

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SECTION 6. ACCIDENTAL RELEASE MEASURES

Personal : Persons not wearing protective equipment should be excluded from the area. Environmental : Prevent run-off to sewers, streams or other bodies of water.

SECTION 7. HANDLING AND STORAGE

Handling : Follow all relevant precautions. Ventilation : General room ventilation is expected to be satisfactory. Storage : Store separately from any reactive substances.

SECTION 8. EXPOSURE CONTROLS/PERSONAL

Inhalation : In case of insufficient ventilation, use suitable respiratory protection. Skin : Use barrier cream and impervious gloves. Wear suitable overall. Eyes : Use face shield or goggles. Avoid direct contact. Ingestion : Observe the rules of hygiene. Wash before eating or drinking. Appropriate hand protection and protective clothing must always be used.

FLAMMABILITY HEALTH HAZARD 0 NFPA LISTINGS 0 0 REACTIVITY Most Hazardous: Nil

SPECIFIC HAZARD

SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES

Chemical Class : Liquid Description : Preparation. Boil. Pt : 96 C Flash pt.: N/A Auto ignition Temp : N/A Explosive Prop. : N/A Sol. in water : Complete pH : 2.0 – 4.0 pH units. Decomposition Temp: 100+ C

SECTION 10. STABILITY AND REACTIVITY Stable under normal conditions : Yes Will react with oxidizers : Yes Reaction with water : Soluble Decomposition Products : Noxious fumes. Conditions to avoid : Strong oxidants. SECTION 11. TOXICOLOGICAL INFORMATION. MAJOR TOXICOLOGICAL COMPONENT

Acute Toxicity (Formulation) LD 50 : Greater than 20000 mg/kg GHS: No listing. Sensitisation : Yes Inhalation – Ceiling – TWA : No data ppm GHS: No listing. Skin : Rabbit : LC 50 : Irritant Ingestion (Formulation MTC) : Greater than 20000 mg/kg GHS: No listing.

SECTION 12. ECOLOGICAL INFORMATION. MAJOR TOXICOLOGICAL COMPONENT

Relatively non toxic Mobility : Bio-Accumulation: Ecotoxicity GHS: No listing. LC 50 : mg/l (50 hrs.) Daphnia Magna LC 50 : mg/l (96 hrs.) Mosquito fish LC 50 : mg/l (96 hrs.) Salmo Gairdneri

SECTION 13. DISPOSAL INFORMATION

Use reputable waste disposal contractors. Exercise caution in disposal of used containers.

SECTION 14. TRANSPORT INFORMATION Not Classified as Hazardous for Transport

Cas No. : 26062793 UN No. : Class : Sub Risk : EMS No. : IMDG Code : MFAG Table : Pack Group : Marine Pollutant : Label : Flash Point :

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SECTION 15. REGULATORY INFORMATION

Non Hazardous

SECTION 16. OTHER INFORMATION

Any discomfort, always seek medical advice. All chemical products may be hazardous, therefore wear protective equipment and do not reuse container for any purpose whatsoever.

Refer Emergency Response Handbook – Nil

The information, provided in this Safety Data Sheet, is to the best of our knowledge, correct as of the date of publication. The information is designed only as a guide for safe handling, use, storage, transportation, disposal and release.

If serious risk is incurred please contact : Poisons Emergency Control Phone: RSA 082911.

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APPENDIX H Drinking Water Standards: SANS 241 (2006) Edition 6.1 and WHO 2006

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Potable water quality guidelines are being developed for Lesotho. These guidelines are likely to be similar to those developed for South Africa. The treated water produced by the Works shall comply with a Class I water as defined in the South African National Standard for Drinking Water SANS 241:2006 Edition 6.1 or the World Health Organisation (WHO) Guidelines whichever is the most stringent. Determinants and their limit values are shown in the Table below.

Determinant Unit SANS 241: 2006 WHO

Class I Class II Class II Guidelines (Recommended (Maximum Maximum 2006 allowed for consumption operational limit) limited period) period

Colour (aesthetic) mg/ℓ Pt <20 20 – 50 No limit

Conductivity at 25°C (aesthetic) mS/m <150 150 – 370 7 years

Dissolved solids (aesthetic) mg/ℓ <1 000 1 000 – 2 400 7 years

Odour (aesthetic) TON <5 5 – 10 No limit pH value @ 25ºC Units 5.0 – 9.5 4.0 – 10.0 No limit (aesthetic/operational)

Taste (aesthetic) FTN <5 5 – 10 No limit

Turbidity (aesthetic/operational/ NTU <1 1 – 5 No limit indirect health)

Ammonia (operational) mgN/ℓ <1 1.0 – 2.0 No limit

Calcium (aesthetic/operational) mgCa/ℓ <150 150 – 300 7 years

Chloride (aesthetic) mgCl/ℓ <200 200 – 600 7 years <250

Fluoride (health) mgF/ℓ <1 1.0 – 1.5 1 year <1.5

Magnesium (aesthetic/health) mgMg/ℓ <70 70 – 100 7 years

Nitrate + nitrite (health) mgN/ℓ <10 10 – 20 7 years <50

Potassium (operational/health) mgK/ℓ <50 50 – 100 7 years

Sodium (aesthetic/health) mgNa/ℓ <200 200 – 400 7 years

Sulphate (health) mgSO4/ℓ <400 400 – 600 7 years

Zinc (aesthetic/health) mgZn/ℓ <5 5.0 – 10 1 year <3

Aluminium (health) μgAl/ℓ <300 300 – 500 1 year

Antimony (health) μgSb/ℓ <10 10 – 50 1 year

Arsenic (health) μgAs/ℓ <10 10 – 50 1 year <10

Cadmium (health) μgCd/ℓ <5 5 – 10 6 months <3

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Determinant Unit SANS 241: 2006 WHO

Class I Class II Class II Guidelines (Recommended (Maximum Maximum 2006 allowed for consumption operational limit) limited period) period

Total Chromium (health) μgCr/ℓ <100 100 – 500 3 months

Cobalt (health) μgCo/ℓ <500 500 – 1 000 1 year <50

Copper (health) μgCu/ℓ <1 000 1 000 – 2 000 1 year <2000

Cyanide (health) μgCN/ℓ <50 50 – 70 1 week

Iron (aesthetic/operational) μgFe/ℓ <200 200 – 2 000 7 years <300

Lead (health) μgPb/ℓ <20 20 – 50 3 months <10

Manganese (aesthetic) μgMn/ℓ <100 100 – 1 000 7 years

Mercury (health) μgHg/ℓ <1 1 – 5 3 months

Nickel (health) μgNi/ℓ <150 150 – 350 1 year <290

Selenium (health) μgSe/ℓ <20 20 – 50 1 year

Vanadium (health) μgV/ℓ <200 200 – 500 1 year

Dissolved organic carbon (health) mgC/ℓ <10 10 – 20 3 months

Total trihalomethanes (health) μg/ℓ <200 200 – 300 10 years

Phenols (aesthetic/health) μg/ℓ <10 10 – 70 No limit

Microbiological safety requirements are given in Table below. Where a microbiological test result exceeds the value given for 1% of samples, an unacceptable risk to health is implied.

1 2 3 4 5 Determinant Unit Allowable compliance contribution 95% of samples, 4% of samples, 1% of samples, min. max. max. Upper Limits E.colib or Count/100 mℓ Not detected Not detected 1 Thermo tolerant (faecal) Count/100 mℓ Not detected 1 10 coliform bacteriac a The allowable compliance contribution shall be at least 95% to the limits indicated in column 3, with a maximum of 4% and 1%, respectively, to the limits indicated in column 4 and column 5. The objective of disinfection should, nevertheless, be to attain 100% compliance to the limits indicated in column 3. b Definitive, preferred indicator of faecal pollution.

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1 2 3 4 5 Determinant Unit Allowable compliance contribution 95% of samples, 4% of samples, 1% of samples, min. max. max. Upper Limits c Indicator of unacceptable microbial water quality could be tested instead of E. coli but is not the preferred indicator of faecal pollution. Also provides information on treatment efficiency and after growth in distribution networks.

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APPENDIX I Species List of Plants in the WTW (Summer 2009)

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Scientific Name Common Name Sotho Name Uses Ajuga ophrydis Bugle plant senyarela Medicinal Albuca setosa Ornamental, medicinal Aloe striatula mohalakane, seholobe Hedge Anacampseros Haaskos filamentosa Andropogon eucomis Grazing Aptosimum procumbens Arctotis arctotoides putsoa-pululu Medicinal *Argemone ochroleuca Mexican poppy Weed Argyrolobium cf. velutinum Aristida adscenscionis Annual bristle grass Lefielo, mohlolohadi Grazing Aristida diffusa Iron grass Bohlanya ba dipere, grazing, brooms lefielo Aristida junciformis Ngongoni bristlegrass phuthadikgoba, lefielo grazing, brooms Artemisia afra Wormwood lengana Medicinal Athrixia angustissima phefshoane-e-nyenyane tea, medicinal Asclepias multicaulis Doily cartwheel lekhoaphela Food Asparagus khopa, sesilatsane Medicinal, ornamental ramosissimus Aster bakerianus phoa Medicinal, ornamental Berkheya cirsiifolia mohata-o-mosoeu * Bidens pilosa Blackjack Ornamental Brachiaria serrata Signal grass Lefokodi Medicinal, grazing Cheilanthes Four-pinnate lip fern lehorometso, lepata- quadripinnata maoa * Cirsium vulgare Scottish thistle Commelina africana Yellow Commelina khopo, khotsoana Medicinal Convolvulus sagittatus Crabbea acaulis Pig's Ears serelile Medicinal, ornamental Cymbopogon Turpentine grass moshanyana-oa- Grazing marginatus marallaneng Cymbopogon plurinodis Turpentine grass moshanyana-oa- Medicinal, grazing marallaneng Cynodon dactylon Couch grass, kweek Mohlwa Medicinal, erosion control, grazing Cynoglossum hispidum Hound's tongue bohomenyana Medicinal Cyperus rupestris Russet rock sedge taoane, taoanenyana Medicinal

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Scientific Name Common Name Sotho Name Uses * stramonium Thorn apple Medicinal Delosperma sp. Digitaria ternata Blackseed finger moeane, moqopshwe Grazing grass Diospyros austro- Firesticks piperekisi-tsa-makhoaba Medicinal, grazing africana Ehrharta erecta Eleusine corocana Goose grass diangwetsi, modia Medicinal, food ngwetsi Elionurus muticus Silky grass Hloko, hlooko Medicinal, grazing Enneapogon scoparius Eragrostis capensis Heartseed love grass Barwa, barwana grazing Eragrostis curvula Weeping love grass Moseeka, moseka Grazing Eragrostis chloromelas Curly leaf Moseeka, moseka Grazing Eragrostis racemosa Narrow heart love Barwa, barwana Grazing & soil stabilisation grass Euphorbia striata Milkweed mohlatsisa Felicia filifolia Fine-leaved Felicia leholo, sehalahala firewood Felicia muricata Bloublommetjie koelehane, mokhoto Medicinal Gazania krebsiana Common Gazania shoeshoe, tsikitlane Medicinal, ornamental Gerbera ambigua Botterblom moarubetso, tsebe-ea- Medicinal, ornamental pela Gerbera piloselloides Swartteebossie moarubetso, tsebe-ea- Medicinal, ornamental pela Haplocarpha scaposa Tonteldoosbossie khutsana, lengoaka Medicinal, ornamental Harpochloa falx Caterpillar grass bohole, lefokolodi, grazing lekhasi Helichrysum Hottentot's tea mohlomela-tsie, Medicinal, food odoratissimum Helichrysum pilosellum phefo-ea-setlolo, tooane Medicinal Helichrysum rugulosum boleba, boleba-ba-liliba, Medicinal leboko Helictotrichon Small oats grass litsi-ba-palumo, Grazing turgidulum seboeane Hermannia depressa Rooi-opslag Seletjane Medicinal (sore eyes) Hermannia coccocarpa moederkappie Seletjane Medicinal Hermannia geniculata Homeria pallida Tulp Teele Hyparrhenia hirta Common thatch grass Leqokwana Construction & grazing

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Scientific Name Common Name Sotho Name Uses Hyparrhenia tamba Blue thatch grass Construction & grazing *Hypochaeris radiata Hairy wild lettuce Imperata cylindrica Cottonwool grass Mohlabalerumo, tlhorumo Medicinal, erosion control Jamesbrittenia Cape saffron phiri-ea-hlaha-e- aurantiaca nyenyane Kalanchoe thyrsiflora White Lady serelile Medicinal and ornamental Leucosidea sericea Ouhout cheche Construction, firewood Linum thunbergii Wild flax bohlokoana Medicinal Lobelia sp. Lotononis laxa musa-pelo--oa-matlapa- o-monyenyane Lotononis listii Maytenus acuminata Silky bark tšikane Medicinal, construction *Meliolotus indica Melolobium obcordatum Lethokho, seakha Medicinal Microchloa caffra Pincushion grass Jwang ba matlapa Grazing Mohria vestita (=Mohria Scented fern lehorometso, Medicinal, ornamental caffrorum var. vestita) mahorometso Nemesia caerulea Nemesia Nidorella undulata mokotelo-o-moholo *Oenothera indecora Small evening primrose Oenothera stricta *Oenothera rosea Rose evening moopeli-o-mofubelu Weed primrose *Oxalis corniculata Creeping sorrel Food *Papaver acueleatum Poppy sehlohlo Weed in lands Paspalum dilatatum Common paspalum bohlwa Grazing Pellaea calomelanos Blue rock fern lehorometso, lepata- Medicinal, protective charm maoa *Pennisetum Kikuyu kikoejoe Grazing clandestinum *Physalis viscosa Sticky gooseberry Pinus sp. Pine tree Construction, firewood Pollichia campestris Waxberrry *Populus canescens Poplar popoliri Firewood, construciton Psammotropha bohomana, senama Medicinal mucronata

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Scientific Name Common Name Sotho Name Uses Raphionacme hirsuta Medicinal Rhamnus prinoides Glossy leaf Mofifi medicinal, firewood Rhynchosia adenoids Medicinal Rhynchosia totta Yellow carpet bean sebalibetloa Medicinal, food Roripa nudiuscula papasane Food Rubus rigidus White bramble monokotsoai-oa-bana food Salvia runcinata wildesalie Mosisili Medicinal Scabiosa columbaria Wild Scabious Selomi Medicinal, ornamental Searsia dentata (=Rhus Nana-berry kolitšana Food, ornamental dentata) Searsia divaricata Rusty-leaved currant kolitšana food, firewood (=Rhus divaricata) Searsia pyroides Common wild currant kolitšana, leroana Medicinal (=Rhus pyroides) Sebaea sedoides Sebaea Medicinal Sebaea natalensis Medicinal Selago densiflora Ornamental Selago galpinii Selago tšitoanenyana, Ornamental tšitoanyane Senecio asperulus Senecio moferefe, makhona- Medicinal tsohle Senecio coronatus Woolly grassland lehlomane Food, medicinal Senecio Setaria sphacelata Golden timothy grass Grazing undulata Gunpowder plant lithotoana, molokoloko Medicinal *Solanum nigrum Sonchus sp. Stachys aethiopica African Stachys bokhatha, bolao-ba- Medicinal and ornamental litaola Stoebe vulgaris Zigzag Bush Sehalahala Sutera floribunda Kerriebos boluma Ornamental Tagetes minuta Khaki weed Medicinal Tephrosia sp. (? Medicinal marginella) Themeda triandra Red grass Seboku, setjhaba Fodder Thesium costatum bohoho Medicinal Trichoneura Tumble grass joang-ba-tsela grazing (young) grandiglumis Tristachya leucothrix Hairy trident grass letswalle, motswalle Climax grass, grazing

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Scientific Name Common Name Sotho Name Uses Verbena bonariensis Verbena Vernonia hirsuta Quilted-leaved hlele-hlele, sechee Medicinal, ornamental Vernonia Vernonia natalensis Silver Vernonia ileleva Medicinal, ornamental Veronica anagallis- Food aquatica Wahlenbergia krebsii Fairy Bell-flower moopetsane, tenane Pot herb Walafrida densiflora *Xanthium strumarium shoba Medicinal Xysmalobium Milkwort leshokoa, poho-tšehla Medicinal undulatum Bold = protected species * = Alien/weedy species

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APPENDIX J Extracts from ‘FIDIC policy on HIV-AIDS in the construction sector’

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AIDS in the Construction Sector

In the Introduction to the Draft Specification for HIV-AIDS Awareness, the Construction Industry Development Board of South Africa (Reference 2), says:

“Research indicates that the South African construction industry has the third highest incidence of HIV/Aids in South Africa. The construction sector has a predominantly migratory labour force, making it a prime contributor to the spread of HIV/Aids. Labour camps are a breading ground for the spread of HIV/Aids and Sexually Transmitted Diseases (STDs), this being compounded by the situation where migrant workers on contract generally avoid or are ignorant of the consequences of casual sexual relationships.

The prevalence of subcontracting, the emergence of many small contractors and the tendency toward labour-only subcontracting increased the complexity of developing an effective HIV/Aids strategy that targets the full spectrum of those employed in construction. This level of complexity places a special responsibility on clients, the professions and industry leaders.

The construction sector has the potential to play an important role in the country’s inter-sectoral approach to coping with the epidemic. The sector also provides entry-level local jobs, which may be crucial to the survival of youth-headed households and extended families in areas hard hit by the epidemic. Construction sites can accordingly provide a convenient location for HIV/Aids programmes to both construction workers and rural communities.”

FIDIC and FIDIC Members have a corporate social responsibility, and FIDIC recognises that Member Firms can make a significant difference, because they have already done so in a number of countries. For these reasons, FIDIC has developed this Policy on HIV-AIDS in the Construction Sector.

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1 FIDIC POLICY ON HIV-AIDS IN THE CONSTRUCTION SECTOR

FIDIC recommends that FIDIC Member Firms should at all times use their influence, position and strengths to reduce the impact of HIV-AIDS on their own employees and those of Contractors, and their families, and for the wider community particularly at or related to construction sites on which the Member Firm is engaged. The responses of FIDIC Firms in showing Leadership and Advocacy will normally comprise the following five strategies recommended for implementation in engineering and construction works contracts (Ref 3):

Five strategies to be implemented in engineering and construction works contracts:

1. Raising awareness about HIV/AIDS - Facilitate increased understanding about the disease, through dissemination of information and by generating discussion. 2. Ensuring that construction workers have access to condoms. 3. HIV counselling, testing and referral services. 4. Sexually Transmitted Infection (STI) diagnosis and treatment. 5. Monitoring of outcomes.

These strategies are designed to build an HIV resilient workforce as well as communities associated with the workforce, i.e., communities that are able to draw on its own capacity to prevent further transmission of HIV, minimise the impact of the HIV/AIDS epidemic, and talk about HIV/AIDS.

The objectives of these strategies are to:

 Reduce the risk of transfer of the HIV virus between and among construction workers and the local community;  Raise awareness amongst construction workers and the local community of the risk of infection with the HIV virus;  Promote early diagnosis; and  Assist affected individuals to access care and counselling.

2 HIV-AIDS CLAUSES FOR INCLUSION IN CONTRACT DOCUMENTS FIDIC has prepared HIV-AIDS Clauses aimed at meeting the above objectives and recommends that these Clauses be included in Construction Contracts wherever there is the slightest risk of HIV-AIDS infection relating to the construction site or activities. It is recommended that the following sub-clause be added to Clause 6, Staff and Labour, of the Conditions Particular Application of the FIDIC Conditions of Contract for Construction (Ref 4).

EXAMPLE SUB-CLAUSE HIV-AIDS Prevention The Contractor shall conduct an HIV-AIDS awareness programme via an Approved Service Provider, and shall undertake such other measures as are specified in this Contract to reduce the risk of the transfer of the HIV virus between and among the Contractors

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Employees and the local community, to promote early diagnosis and to assist affected individuals.

HIV-AIDS Technical Clauses are provided in Annexure 1. These are drafted for use with the FIDIC Standard Conditions of Contract (Ref 4), as clauses within the Contract Technical Specification, although the Clauses could be adapted to any form of Contract.

In drafting these Clauses, FIDIC has drawn upon the publications of CIDB (Ref. 2) and ILO (Ref. 3). The intent of these Clauses is that the measures specified to be undertaken by the Contractor are to be measured and priced in the tender Bill of Quantities, and subsequently paid for on completion or progressively as measurable (pay) items in accordance with the General Conditions (Clause 12 of the FIDIC Condition of Contract, 1999).

Annexure 2 contains suggested Bill of Quantities items which match the provision of the recommended HIV- AIDS Clauses in the Specification (these items are taken from Ref 2).

3 WIDER USE OF FIDIC HIV/AIDS CLAUSES The FIDIC HIV/AIDS Clauses (Annexure 1) have been drafted specifically for use with FIDIC Standard Contracts, drawing upon the sources referenced in References 2 and 3. However, FIDIC suggests that the Clauses may be adapted for wider use, including:

 With other forms of contract;  In designing anti-HIV/AIDS strategies in other applications such as other industries and community awareness generally;  Specifically in campaigns within the offices of Member Firms operating in AIDS- prevalent situations.

4 MONITORING FIDIC Member Firms working either as an employer or when acting as Project Managers or Site Supervisors, are in a position to monitor the take up and effectiveness of anti-HIV/AIDS measures, and FIDIC recommends that they do so. Examples of indicators to be monitored would include:

 HIV related absences amongst staff;  Frequency of attendance at training seminars;  Take up of condom use;  Understanding of the anti-HIV/AIDS messages amongst staff.

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FIDIC HIV/AIDS POLICY - ANNEXURE 1: TECHNICAL SPECIFICATION

HIV-AIDS CLAUSE FOR INCLUSION IN THE FIDIC CONSTRUCTION CONTRACT 1.1 For the purpose of this Clause:

“an Approved Service Provider” means a person or entity approved by the national HIV/AIDS Authority to provide the HIV Awareness Programme;

“the Contractor’s Personnel” or “Construction Workers” means, without prejudice to any other definition contained in the Contract, all personnel, who are under the Contractor’s control and on the Site in connection with the Contract, including any workers who are under the control of any person or entity to whom the contractor has sub-contracted any of this obligations under the Contract other than those responsibilities set out in this Clause;

“the HIV Awareness Programme” means an HIV awareness programme [as set out in the Project documentation /in compliance with the HIV Awareness Programme curriculum and guidelines published by UNAIDS and available on its website www.hiv-development.org or on request];

“the Local Community” means the communities local to the Site most likely to have contact with the Contractor’s Personnel and, in particular, sex workers in those communities;

“National Aids Authority” small mean the authority in the country where the Site is located designated by the relevant national government to have responsibility for preventing and/or combating HIV/AIDS;

“UNAIDS” shall means [the agency of the United Nations of that name or the United Nations Regional Task Force on mobile population and HIV vulnerability].

Abbreviations

STI: Sexually transmitted infection HIV: Human Immunodeficiency Virus AIDS: Acquired Immune Deficiency Syndrome

1.2 It shall be a requirement of the Contract that the Contractor:

1.2.1 sub-contracts with an Approved Service Provider to provide an HIV Awareness Programme to the Contractor’s Personnel and the Local Community as soon as practicable after the Contractor’s Personnel arrive at the Site but in any case within two weeks after the Contractor’s Personnel arrive at Site and to repeat the HIV Awareness Programme at intervals not exceeding four months;

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1.2.2 gives any representative of the Approved Service Provider, the Employer and the National HIV/AIDS Authority all reasonable access to the Site in connection with the HIV Awareness Programme;

1.2.3 if the National Aids Authority has not provided the names of available Approved Service Providers within two weeks after being asked the contractor may select its own service provider after consultation with the appropriate UNAIDS office;

1.2.4 instructs the Contractor’s Personnel to attend the HIV Awareness Programme in the course of their employment and during their normal working hours or any period of overtime provided for in the relevant employment contracts and uses all reasonable endeavours to ensure this instruction is followed;

1.2.5 provides suitable space for delivery of the HIV Awareness Programme and does nothing to dissuade the Contractor’s Personnel from attending the HIV Awareness Programme;

1.2.6 as soon as practicable, notifies the National HIV/AIDS Authority of its sub- contract with an Approved Service Provider to facilitate the National HIV/AIDS Authority’s audit of Approved Service Providers; and

1.2.7 gives all reasonable co-operation to the National HIV/AIDS Authority if it exercises its right to audit the provision by the Approved Service Provider of the HIV Awareness Programme.

1.2.8 make condoms complying with the requirements of ISO 4074 available to all contractor’s employees at readily accessible points on the site, suitably protected from the elements, for the duration of the contract;

1.2.9 either place and maintain HIV/AIDS awareness posters of size of not less than A1 in areas which are highly trafficked by construction workers, or provide construction workers with a pamphlet, in languages largely understood by construction workers, which reinforce the outcomes of the HIV Awareness Programme stated in 1.2.1;

1.2.10 encourage voluntary HIV/STI testing;

1.2.11 provide information concerning counselling, support and care of those that are infected services.

1.3 The outcomes of the HIV Awareness Programme shall as a minimum, result in contractors personnel exposed to such a programme being able to:

a) communicate the existence of problems of HIV and be able to outline the consequences of transmission of HIV to or from the local community;

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b) recall and communicate the mode of HIV transmission and preventative measures including the proper use of the condom.

1.4 Reporting

1.4.1 The contractor shall prepare and attach to his claims for payment a brief report which outlines how the actions taken by the contractor in the period for which payment is claimed satisfy the requirements and a schedule which lists the names, identify numbers, trade / occupation and name of employer of all construction workers exposed to the programme.

1.4.2 The employer’s representative shall certify the report and schedule described in 1.4.1 whenever a claim for payment is issued to the employer.

1.5 Where a clinic is provided on behalf of the Contractor on site, the Contractor shall ensure that such clinic provides to the Contractor’s Personnel, on request and without charge:

1.5.1 Counselling and advice on AIDS in compliance with UNAIDS guidelines; and

1.5.2 Condoms that comply with either the current ISO standard or WHO/UNAIDS Specification and Guidelines for Condoms 1998 or any more recent equivalent publication.

1.6 The Contractor shall be entitled to be reimbursed by the Employer for any payments made under a sub-contract made on either cost incurred for the purpose of Sub-Clause [1.2] in accordance with the relevant provisions in the Contract, and in particular, for the amounts included in the Bill of Quantities;.

1.7 Where the Contract does not provide for reimbursement of named costs, the amount paid by the Contractor t the Approved Service Provider shall be added to any lump sum to be paid by the Employer to the Contractor under the Contract and, before such lump sum is paid, the Contractor shall provide to the Employer evidence of:

1.7.1 payment of the amount claimed to the Approved Service Provider; and

1.7.2 provision of the HIV Awareness Programme (e.g., a Compliance certificate issued by the Approved Service Provider – refer Annexure 3).

1.8 Where the Contractor sub-contracts any of its obligations under the Clause of the Contract it shall require any sub-contractor to comply with sub-clauses (1.2.2 to 1.2.11) of the Contract as if it were the Contractor.

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FIDIC HIV/AIDS POLICY - ANNEXURE 2: PRICING DATA

FIDIC recommends that the HIV/AIDS awareness requirements contained in the Standard Clauses should be identified as a separate item / activity and be included in the bills of quantities or in activity schedules as a single item or a group of items.

Example:

ITEM DESCRIPTION UNIT RATE AMOUNT

1. Conduct HIV /AIDS Awareness Programme on Site for Contractors personnel inclusive of all direct and indirect costs.

2. Provide and maintain condom dispenser.

3. Provide and maintain HIV/AIDS awareness posters.

4. Provide information regarding the voluntary testing of construction workers and counselling, support and care.

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FIDIC HIV/AIDS POLICY - ANNEXURE 3: COMPLIANCE REPORT

Contract number: ………………

Payment Claim number: ………………… Period covered by payment claim: ………………

1. Distribution of condoms (brief describe where and how condoms are distributed)

2. Posters / pamphlets (brief describe where posters were placed / how pamphlets were distributed)

3. Voluntary HIV/STI testing (brief describe the actions taken/information provided to promote testing)

4. Counselling, support and care (summarise information provided)

6. Schedule of construction workers exposed to the HIV awareness programme

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Name Identify number Trade / occupation Name of employer

I hereby declare the above to be a true reflection of actions taken to ensure compliance with the specification.

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