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GCS (Pty) Ltd. Reg No: 2004/000765/07 Est. 1987
Offices: Durban Johannesburg Lusaka Ostrava Pretoria Windhoek
Directors: AC Johnstone (Managing) PF Labuschagne AWC Marais S Pilane
Non-Executive Director: B Wilson-Jones
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Environmental Authorisation Amendment Report
Proposed Repairs and Preventive Infrastructure
Upgrade to the Klein Jukskei Stabilisation Structure
South African National Blood Service (SANBS)
Constantia Kloof Campus, Gauteng
Report: Draft for Public Review
GDARD Ref No. GAUT: 006/15-16/E0011
Version – 1
June 2015
South African National Blood Service
GCS Project Number: 14-507
Client Reference: 01326
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14-507 June 2015 Page ii
ENVIRONMENTAL AUTHORISATION AMENDMENT REPORT
PROPOSED REPAIRS AND PREVENTIVE INFRASTRUCTURE UPGRADE TO THE KLEIN JUKSKEI STABILISATION STRUCTURE
SOUTH AFRICAN NATIONAL BLOOD SERVICE (SANBS) CONSTANTIA KLOOF CAMPUS, GAUTENG
Version – 1
June 2015
GDARD Ref No. GAUT: 006/15-16/E0011
South African National Blood Service
14-507
DOCUMENT ISSUE STATUS
Report Issue Draft for Public Review
GCS Reference Number GCS Ref – 14-507
Client Reference 01326
Title
Environmental Authorisation Amendment Report: Proposed
Repairs and Preventive Infrastructure Upgrade to the Klein
Jukskei Stabilisation Structure
Name Signature Date
Author Jonathan Mograbi
8 June 2015
Document Reviewer Jacques Harris
8 June 2015
Director Jacques Harris
8 June 2015
LEGAL NOTICE
This report or any proportion thereof and any associated documentation remain the property of GCS until the mandator effects payment of all fees and disbursements due to GCS in terms of the GCS Conditions of Contract and Project Acceptance Form. Notwithstanding the aforesaid, any reproduction, duplication, copying, adaptation, editing, change, disclosure, publication, distribution, incorporation, modification, lending, transfer, sending, delivering, serving or broadcasting must be authorised in writing by GCS.
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CONTENTS PAGE
CONTENTS PAGE ........................................................................................................................................... III
LIST OF FIGURES ............................................................................................................................................ III
LIST OF TABLES ............................................................................................................................................. III
LIST OF APPENDICES ..................................................................................................................................... III
1 INTRODUCTION ...................................................................................................................................... 1
1.1 BACKGROUND ............................................................................................................................................. 1
1.2 FLOOD DAMAGE .......................................................................................................................................... 1
1.3 ENVIRONMENTAL LEGAL REQUIREMENTS ......................................................................................................... 3
1.3.1 Review of Listed Activities Requiring Environmental Authorisation ............................................... 3
1.4 ENVIRONMENTAL AUTHORISATION AMENDMENT .............................................................................................. 3
1.4.1 Application for Amendment ............................................................................................................ 3
1.4.2 Amendment Report ......................................................................................................................... 3
1.4.3 Public Participation ......................................................................................................................... 3
1.4.4 Decision Making .............................................................................................................................. 4
2 DESCRIPTION OF THE PROPOSED PROJECT ............................................................................................. 7
2.1 OVERVIEW ................................................................................................................................................. 7
2.2 CONSTRUCTION METHOD .............................................................................................................................. 7
3 POTENTIAL IMPACTS AND MITIGATION ................................................................................................. 9
3.1 IMPACT ASSESSMENT ................................................................................................................................... 9
3.2 ADVANTAGES AND DISADVANTAGES OF THE PROJECT ......................................................................................... 9
3.2.1 Advantages of the Project ............................................................................................................... 9
3.2.2 Consequences of Not Going Ahead with the Project ...................................................................... 9
3.3 MITIGATION MEASURES ............................................................................................................................. 10
4 CONCLUSION ........................................................................................................................................ 16
LIST OF FIGURES
Figure 1 Local Setting of the Stabilisation Structure (Base map source: EcoAfrica, 2013 SANBS Basic Assessment Report) .................................................................................................. 2
Figure 2 Plans Showing the Approved Stabilisation Structure and Proposed Upgrade ................ 8
LIST OF TABLES
Table 1 Review of Relevant Listed Activities ............................................................... 5
Table 2 Impact Assessment Results .......................................................................... 11
Table 3 EMP Commitments Checklist and Pre-Project Audit Results .................................. 12
LIST OF APPENDICES
Appendix A Existing Environmental Authorisations ........................................................ A
Appendix B Record of Public Consultation .................................................................. B
Appendix C SANBS Risk Assessment and Photographic Record of Flood Damage ..................... C
Appendix D Professional Engineering Opinion .............................................................. D
Appendix E Schematic of Approved and Proposed Design ................................................ E
Appendix F Contractor Method Statement .................................................................. F
Appendix G High Level Specialist Ecological Assessment ................................................. G
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1 INTRODUCTION
1.1 Background
In order to protect its buildings from geotechnical instability associated with on-going erosion of a stretch
of the northern embankment of the Klein Jukskei River, the South African National Blood Service (SANBS)
recently installed a gabion embankment stabilisation structure (see Figure 1). In this regard, an
Environmental Authorisation (EA) in terms of the National Environmental Management Act (Act No. 107 of
1998 – NEMA) as amended, was obtained in November 2013. This authorisation was subsequently amended
to account for design changes in July 2014. Copies of the EA and amendment are included in Appendix A.
Construction of the structure was completed in December 2014.
In February 2015 a flash flood resulted in damage to the structure prompting the SANBS to amend the
existing EA to accommodate proposed repairs and preventive infrastructure upgrades. In this regard, GCS
(Pty) Ltd have been appointed in association with EcoAfrica Gauteng (Pty) Ltd as the independent
Environmental Assessment Practitioners (EAPs) to conduct the EA Amendment process.
1.2 Flood Damage
With reference to Figure 1 and the photographs below, the flash flood event of 16/17 February 2015
resulted in severe erosion and undercutting (up to 2.5 m in depth) along a stretch of approximately 30 m
of the stabilisation structure, below an installed weir and where an adjoining flood channel intersects the
river, as well as damaging the installed weir structure. This flood damage has resulted in the compromise
of the stabilisation structure and poses a threat to the SANBS Plasma Reserve building - the structure for
which the gabion stabilisation was originally installed to protect. Should the stabilisation structure fail
and the building be compromised, the supply of Blood Plasma products to the whole of South Africa’s blood
and medical services would be at risk. Please see the SANBS Internal Risk Assessment in Appendix C for
further detail. It is noted that the damage to the stabilisation structure was not an isolated incident
associated with the flood event of 16/17 February 2015: damage to the adjacent CADAC access road and
Constantia Blvd. embankment and bridge stabilisation structure is noted, as too are numerous news reports
of damage to private property, including collapsed boundary walls, washing away of vehicles, damage to
bridges and residents having to escape flooding houses through their ceilings. Photographs of other damage
are attached in Appendix C.
Area of river bed erosion and undercutting of the stabilisation structure
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Figure 1 Local Setting of the Stabilisation Structure (Base map source: EcoAfrica, 2013 SANBS Basic Assessment Report)
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1.3 Environmental Legal Requirements
1.3.1 Review of Listed Activities Requiring Environmental Authorisation
An Environmental Authorisation (Ref No. Gaut 002/12-13/E0144) was granted on 13 November 2013 and
amended on 22 July 2014, for the construction of the stabilisation structure as well as for additional
building activities within the SANBS Constantia Kloof Campus (see Appendix A for the existing EAs). The
Listed Activities approved by the above Environmental Authorisations relevant to the embankment
stabilisation portion of the overall project, as well as the equivalent 2014 Listed Activities are detailed in
Table 1 below.
Following review of the proposed repair and preventive upgrade measures against the existing
Environmental Authorisations, as well as against the equivalent 2014 amended Listing Notices (GN 983,
984 and 985), it is the view of GCS that the proposed project will not trigger any new Listed Activities not
already approved under the existing Environmental Authorisations.
1.4 Environmental Authorisation Amendment
Although no new listed activities are relevant to the project as detailed above, the proposed repairs and
preventive upgrades will result in an increase of structure’s approved footprint. In this regard, the current
approved footprint of the structure is 1 900 m2. A proposed increase of approximately 250 m2 will result,
increasing the new total footprint to 2 150 m2. In this regard, an amendment of the existing EA is required
under Chapter 5, Part 2: Amendments where a change in scope occurs, in terms of the Environmental
Impact Assessment Regulations (R.982 of 4 December 2014) promulgated under the NEMA. The EA
amendment process involves an application, an amendment report including public participation, and
decision making, as detailed hereunder.
1.4.1 Application for Amendment
In accordance with Section 31 of R.982, an application for amendment of the existing EA (Reference
Number GAUT 002/12-13/E0144) was submitted to the Gauteng Department of Agriculture and Rural
Development (GDARD) on 12 May 2015.
1.4.2 Amendment Report
This report has been complied in terms of the requirements of Section 32 of R982. In this regard, the
report includes the following:
• An assessment of all impacts relating to the proposed change (Section 3.1);
• Advantages and disadvantages associated with the proposed change (Sections 3.1 and 3.2);
• Measures to ensure avoidance, management and mitigation of impacts (Section 3.3); and
• Any changes to the Environmental Management Plan Report (Not applicable – see Section 3.3).
1.4.3 Public Participation
In addition, Section 32 of R.982 requires that the report be subjected to a public participation process,
whereby all registered interested and affected parties (IAPs) are made aware of the proposed development
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and EA amendment, and that all such parties are afforded the opportunity to review and comment on the
Amendment Report. In this regard, a database of all registered IAPs, a record of all comments received
and responses given and proof of correspondence is included in Appendix B. This report is hereby made
available for public review for a period of 30 calendar days.
1.4.4 Decision Making
Following the public review period, this report and the record of public participation will be updated and
the final Amendment Report submitted to the GDARD for consideration.
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Table 1 Review of Relevant Listed Activities
2010 LISTED ACTIVITIES APPROVED IN THE EXISTING EA’S EQUIVALENT ACTIVITY I.T.O. 2014 AMENDED LISTED ACTIVITIES
Listing Notice
Activity Number
Activity Description Listing Notice
Activity Number
Activity Description
R.544 of 18 June 2010
11(xi) The construction of: (xi) infrastructure or structures covering 50 square meters or more, where such construction occurs within a watercourse or within 32 meters of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line.
R.983 of 8 December 2014
12(xi) The development of- infrastructure or structures with a physical footprint of 100 square metres or more; where such development occurs- (a) within a watercourse; (b) in front of a development setback; or (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse- excluding (dd) where such development occurs within an urban area; (This is excluded as it is in an urban area)
18(i) The infilling or depositing of any material of more than 5 cubic meters into: (i) a watercourse; but excluding where such infilling, depositing; (a) is for maintenance purposes undertaken in accordance with a management plan agreed to by the relevant environmental authority; or (b) occurs behind the development setback line.
19(i) The infilling or depositing of any material of more than 5 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5 cubic metres from- (i) a watercourse;
40 (iv) The expansion of iv) infrastructure by more than 50 square meters, within a watercourse or within 32 meters of a watercourse, measured from the edge of a watercourse, but excluding where such expansion will occur behind the development setback line.
49(v) The expansion of – (v) infrastructure or structures where the physical footprint is expanded by 100 square metres or more; where such expansion or expansion and related operation occurs- (a) within a watercourse; (b) in front of a development setback; or (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse- Excluding (dd) where such expansion occurs within an urban area. (This is excluded as it is in an urban area)
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2010 LISTED ACTIVITIES APPROVED IN THE EXISTING EA’S EQUIVALENT ACTIVITY I.T.O. 2014 AMENDED LISTED ACTIVITIES
Listing Notice
Activity Number
Activity Description Listing Notice
Activity Number
Activity Description
R.546 of 18 June 2010
16(iv) The construction of: (iv) infrastructure covering 10 square metres or more (b) In Gauteng: v. Sites identified as irreplaceable or important in the Gauteng Conservation Plan iii. Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority;
R.985 of 8 December 2014
14(xii) The development of – (xii) infrastructure or structures with a physical footprint of 10 square metres or more; Where such development occurs – (a) within a watercourse; (b) in front of a development setback; or (c) if no development setback exists, within 32 metres of a watercourse, measured from the edge of a watercourse- (b) In Gauteng: iv. Sites identified as Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs) in the Gauteng Conservation Plan or in bioregional plans; vi. Sensitive areas identified in an environmental management framework adopted by relevant environmental authority;
24(d) The expansion of (d) infrastructure where the infrastructure will be expanded by 10 square metres or more (b) In Gauteng: v. Sites identified as irreplaceable or important in the Gauteng Conservation Plan
24(d) The expansion of (d) infrastructure where the infrastructure will be expanded by 10 square metres or more; where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line. (b) In Gauteng: iii. Sensitive areas as identified in an environmental management framework as contemplated in chapter 5 of the Act and as adopted by the competent authority; v. Sites identified as irreplaceable or important in the Gauteng Conservation Plan;
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2 DESCRIPTION OF THE PROPOSED PROJECT
2.1 Overview
In order to repair the damage to the stabilisation structure and prevent the failure of the stabilisation
structure and associated risk to the SANBS building, the measures listed below have been proposed by the
existing gabion installation contractor (MykaTrade) with input from a professional consulting engineer, Mr
Pieter de Coning - Pr Tech Eng of GCS(Appendix D):
• Repair and reinforcing of the weir;
• Re-establishing of an approximate 30 m stretch of eroded river bed and undercutting with a
secured and tied-in gabion structure;
• Tie-in of the gabion structure to the opposite bank to prevent erosion; and
• Repair of damage to the existing gabion structure.
Figure 2 below illustrates to the extent of the existing structure and proposed repair and preventive
measures, whilst detailed schematics of the approved and proposed design are provided in Appendix E.
2.2 Construction Method
In order to effect the proposed repair and preventive upgrade, the following construction method and
temporary supporting activities will be necessary:
• Pumping of water from upstream of the weir to downstream of the proposed work area in order
to allow for access and safe working conditions;
• Laydown of inert rock and gabion baskets for gabion installation;
• Hand excavation of sediment within the river bed working area to allow for anchoring of the
gabions to the river bed.
• Hand fitting and tying in of the gabion baskets;
• Mixing and use of small quantities of concrete;
• Hand repair/replacement of damaged gabions at the weir and foot of the existing stabilisation
structure; and
• Provision of a portable chemical toilet and waste collection for construction staff.
A detailed method statement for the proposed activities has been prepared by MykaTrade and is attached
in Appendix F.
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Figure 2 Plans Showing the Approved Stabilisation Structure and Proposed Upgrade
LEGEND
Existing Gabion Structure Proposed Extent of Repair Additional Structure Footprint
SANBS Constantia Kloof Campus
Klein Jukskei River
Un-named drainage channel
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3 POTENTIAL IMPACTS AND MITIGATION
3.1 Impact Assessment
The following potential impacts of the proposed project have been identified:
• General disturbance to biodiversity;
• Changes in hydrology and storm water management;
• Changes to the visual and urban landscape;
• Contaminants entering the watercourse and affecting downstream water users; and
• Potential adverse effects on the riverine environment and associated aquatic ecosystem.
The type of structure, materials and construction methods to be employed for the proposed project are
the same as those originally used for construction of the existing structure, and assessed in the approved
Basic Assessment Report (October 2013). A review of this original approved impact assessment against the
potential impacts of the proposed project listed above is provided in Table 2. Considering the above and
the results of impact assessment review, it is the finding of GCS that the impacts associated with the
proposed project are the same as those originally assessed and approved for the construction of the
structure.
3.2 Advantages and Disadvantages of the Project
The potential disadvantages of the project are discussed in terms of the potential negative impacts in
Section 3.1 above. Accordingly, this Section focusses on the advantages associated with the proposed
project as well as the potential consequences of not commencing with the proposed repairs and preventive
upgrade.
3.2.1 Advantages of the Project
As detailed in Table 2, the proposed project will serve the same advantages as included in the approved
Basic Assessment documentation. These include:
• Providing embankment protection and storm water management control;
• Ensuring the on-going operation of the SANBS and thus securing its associated benefits to the South
African medical sector; and
• Rehabilitation with indigenous vegetation and the inclusion of invasive plant species control in the
aftercare phase of the project.
3.2.2 Consequences of Not Going Ahead with the Project
Notwithstanding the above stated risk to the SANBS facility (see Appendix C for further detail), the
following risks are posed to the environment by the flood event if action is not taken as soon as possible:
• Collapse of the embankment and stabilisation structure could result in significant damming and
siltation of the river.
• Following such a collapse, the associated costs of remediation and rehabilitation of the river and
embankment would be far greater than the proposed emergency situation response measures. In
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this case, and despite the management of urban flood control infrastructure being under the
mandate of the Johannesburg Roads Agency, SANBS through the need to protect their facilities,
will cover the cost of the proposed emergency response measures.
• The possible collapse and subsequent damming of the river would result in further erosion and
damage to the river banks and property upstream of the site through increased water levels.
• The possible collapse and associated remediation and rehabilitation work, which would be far
more significant in scale and nature than the proposed response measures, would result in the
following related impacts:
- Significant disruption to downstream river flow.
- Negative impacts on downstream aquatic biota through changes in flow and water sediment
load, as well as the spread of alien invasive vegetation (see Appendix G for professional
ecology input in this regard).
- Increased sediment would exacerbate the already prominent issue of silting up of the
downstream dam and flood attenuation measures, particularly considering the filling station
located near to the dam, which if flooded could result in significant hydrocarbon
contamination.
3.3 Mitigation Measures
The mitigation measures contained in the existing, approved construction EMP have been summarised in
Table 3 below (with references to the relevant Section of the EMP document) in order to provide a pre-
project mitigation checklist against which the proposed repair and preventive upgrade has been audited
in preparation for the proposed activities. The finding of this process is that the current approved EMP
addresses the potential impacts of the proposed repairs and preventive upgrade, and that no changes to
the document are necessary.
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Table 2 Impact Assessment Results
APPROVED IMPACT ASSESSMENT (BASIC ASSESSMENT REPORT 2013) IMPACT ASSESSMENT FOR PORPOSED PROJECT
POTENTIAL IMPACTS: SIGNIFICANCE
RATING OF IMPACTS:
PROPOSED MITIGATION: SIGNIFICANCE
RATING OF IMPACTS AFTER MITIGATION:
RELEVANCE TO PROPOSED PROJECT
SIGNIFICANCE RATING OF IMPACTS AFTER MITIGATION:
Socio-economic: Impact at national and SADC regional level of keeping the CKloof facility operational.
Very High + Put embankment protection in place as rapidly as possible. Very High +
Continued operation of the SANBS facility.
Very High +
Socio-economic: Impact of bank collapse to the SANBS organization at the national keystone CKloof facility.
High + Put embankment protection in place as rapidly as possible. High +
Continued operation of the SANBS facility.
High +
Geo-physical: Impact of proposed upgrades structure on biodiversity.
Low to Medium -
Reduce pollution of watercourse during construction and operation to an absolute minimum, aiming to add zero pollution.
Low - General disturbance to biodiversity.
Low -
Geo-physical: Impact of proposed upgrades structure on hydrology and storm water management.
Medium -
Design and construct structure to add a minimum hydrological change to the current scenario and improve current storm water management.
Medium - Changes in hydrology and storm water management.
Medium -
Geo-physical: Impact of proposed upgrades structure on geological formations and sedimentation management.
Low +
Ensure that edges of the structure are well constructed in order to avoid future ‘nick points’ and erosion/collapse issues.
Low + Changes in hydrology and storm water management.
Low +
Geo-physical: Impact of proposed upgrades structure on groundwater supply.
Insignificant
Water to be used for specific purpose only, as polluted water already identified as a high risk and not fit for human consumption.
Insignificant N/A (refers to a borehole installation included in original Basic Assessment)
N/A
Visual: Impact of proposed upgrades on visual and urban landscape. Low -
Ensure the rehabilitation of open areas with indigenous vegetation, including shrubs and trees.
Low + Changes to the visual and urban landscape.
Low +
Biological: Possible impact of pollution to watercourse and downstream communities from hazardous materials handled on the site.
High -
Continue to ensure effective waste management aiming for zero spillage of hazardous materials; that carry a pollution threat to the river and downstream communities.
Low - Contaminants entering the watercourse and affecting downstream water users.
Low -
Biological: Possible impact on aquatic ecosystem and riverine environment.
Low to Medium -
Appropriate environmental management during construction and operational phases.
Low -
Potential adverse effects on the riverine environment and associated aquatic ecosystem.
Low -
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Table 3 EMP Commitments Checklist and Pre-Project Audit Results
APPROVED EMP COMMITMENT RELEVANCE TO
PROPOSED PROJECT
PRE-PROJECT FINDING/RECOMMENDATION
3 Environmental Monitoring and Control Guidelines
3.1 Environmental Control Officer
Appoint and Environmental Control Officer (ECO). Weekly site inspections to be conducted during construction. Monthly EMP performance reporting.
Yes SANBS Environmental Officer will include the project in her monitoring and control duties.
GCS has been appointed to conduct weekly site audits during construction and final close out audit upon completion. The project is expected to be completed within a month. A final close out audit report will be compiled by GCS.
3.2 Contractor responsibility and polluter pays principle
Environmental incidents or EMP infringements to be reported to the ECO.
Yes Channel of communications is established between contractor and ECO. Incidents or infringements will be captured in inspections and reports.
3.3 Environmental awareness
Site environmental awareness initiation with staff? Yes The same contractor that recently completed the installation of the structure will be used. Site environmental awareness initiation with staff was conducted during the installation. Staff are provided with on the job environmental awareness training in good environmental housekeeping. In addition, all work on site will be under fulltime supervision by the site foreman.
Environmental reference documents and do’s and don’ts are to be maintained on site.
Yes The contractor has a copy of the construction EMP, and posters of environmental do’s and don’ts are available to be erected at the site.
3.4 Penalties for non-compliance
Environmental penalty system in the construction contract. Yes The environmental penalties system proposed in the approved EMP was communicated to and accepted by the contractor during the construction of the existing structure. This will remain in place for the proposed project.
Applicable incidents, penalties and remediation. Yes The project has yet to commence. Any applicable incidents will be reported on, penalties applied and remediation implemented.
4 Environmental Management Objectives
4.1 Communications
A site instruction book is to be maintained on site. Yes A site instruction book was maintained during the construction of the existing structure. This book will be maintained during the proposed project.
Environmental control monitoring reports to be compiled and be available to authorities.
Yes The project is expected to be completed within a month. A final close out audit report will be compiled by GCS. Environmental monitoring reports were requested by the GDARD during the construction of the existing structure. These were provided to the relevant
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APPROVED EMP COMMITMENT RELEVANCE TO
PROPOSED PROJECT
PRE-PROJECT FINDING/RECOMMENDATION
GDARD case officer by the ECO. This practice will be carried across to the proposed project.
A method statement is to be complied by the construction contractor detailing how they will comply with the EMP.
Yes A method statement has been compiled by MykaTrade for the proposed project, and approved by the ECO.
Environmental auditing requested by authorities. Yes The project is expected to be completed within a month. A final close out audit report will be compiled by GCS. Environmental monitoring reports were requested by the GDARD during the construction of the existing structure. These were provided to the relevant GDARD case officer by the ECO. This practice will be carried across to the proposed project.
Record to be kept of all environmental documentation, including the EMP, method statements, site instruction book, incidents, site visits, etc.
Yes All environmental documentation will continue to be maintained by the contractor and be available on site for reference.
All stakeholders (incl. regulatory authorities) to be kept informed of project activities.
Yes All registered IAPs and regulatory authorities have been involved in the EA amendment process to date, and will remain informed of project developments.
4.2 Restriction of the activity footprint
Contractor’s camp to be suitable situated to the satisfaction of the ECO.
N/A Due to the nature, small scale and sort duration of the proposed project, a contractor’s camp will not be required.
Demarcation of high sensitivity / no-go areas with suitable markers. Access routes and storage areas to be identified and approved by the ECO.
Yes A site map showing the sensitive areas will be available on site. Working areas, access and storage areas have been agreed upon between the contractor and the ECO.
Controlled site access to be demarcated to avoid areas of sensitivity. Vehicles not impact on road surfaces beyond the site.
Yes The existing access route will be used. The site foreman will monitor vehicles for potential impacts on surrounding roads.
Working and storage areas to be demarcated. Yes Working areas, access and storage areas have been agreed upon between the contractor and the ECO.
Maintenance and service areas N/A No maintenance or servicing of equipment will take place on site.
Major earthworks with heavy machinery. N/A No major earthworks will be undertaken and no heavy machinery will be used. All activities will be conducted by hand.
4.3 Reduction of negative environmental impacts
Indigenous species not to be disturbed, unless upon approval by the ECO. Alien species to be removed.
Yes The proposed project will not involve the removal of any indigenous species. Alien species within the working area will be removed.
Chance find procedure for discovery of heritage resources must be followed.
N/A The proposed activities will take place in previously disturbed areas. No surface excavations are proposed.
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APPROVED EMP COMMITMENT RELEVANCE TO
PROPOSED PROJECT
PRE-PROJECT FINDING/RECOMMENDATION
Erosion controls to be implemented. N/A The proposed preventive upgrade is a means of erosion control. In addition, no earthworks are required for the proposed project.
Fuels and flammables to be stored in suitable areas, protected from the elements, outside of drainage lines and with spillage prevention and containment measures.
Yes Small quantities of fuel will be required for the proposed pumps. In this regard, fuel will be stored in sealed containers on suitable drip trays. Storage on site will be avoided as far as possible, with fuel being brought to site as required by the site foreman.
Hazardous construction materials. N/A Construction materials will comprise rocks and wire gabion baskets, as well as small quantities of cement.
Contractor to minimise waste and ensure appropriate collection storage and disposal. Adequate refuse facilities to be provided for staff.
Yes Small quantities domestic waste and rock and cement waste will be generated. These will be disposed at a municipal waste depot. Sealable bins for domestic waste will be provided. Left over construction materials will be removed for appropriate disposal at construction completion.
Recycling to be considered if significant waste is generated. N/A Recyclable waste generated will be insignificant.
Containment strategy to be in place for spillages of contaminating substances.
Yes Refuelling of pumps to take place using funnels and within a secondary containment. Spills of cement will be removed for appropriate disposal.
Appropriate use of machinery to include pollution prevention measures and to ensure that machinery is in proper working order.
Yes The pumps required will be located within secondary containment and the contractor will ensure they are in proper working order. Any leaking pumps will be removed from site for repair.
Cement mixing off site is preferred. Where not possible, demarcated area is to be used and spillage prevention implemented. Spills to be treated or removed for disposal.
Yes Due to the small quantities of cement required, ready mix will be used and mixed as required on site. Mixing will be conducted on tarpaulins or within wheelbarrows. Excess cement will be removed for appropriate disposal.
Empty cement bags may not be burnt, and must be stored away from the elements for disposal.
Yes Empty cement bags will be stored in bins and removed for appropriate disposal.
Care of existing services to ensure that third party access routes or services are not disrupted.
Yes No services are present in the proposed area of activity. The access route will remain obstructed.
Local labour to be used where possible. Yes The contractor has an existing workforce, however ad hoc labour may be required. In this regard a system of no papers – no work is applicable.
Dust control. N/A The proposed project will take place in a wet environment and no dust is expected. Project vehicles will be limited to staff and periodic delivery of material. No dust control measures are deemed necessary.
No fires are to be permitted within the construction site and firefighting equipment must be present.
Yes Fires will be prohibited. A fire extinguisher and buckets for use of river water will be available on site.
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APPROVED EMP COMMITMENT RELEVANCE TO
PROPOSED PROJECT
PRE-PROJECT FINDING/RECOMMENDATION
Suitable sanitary facilities (1 toilet per 15 staff) to be available and well maintained.
Yes Portable chemical toilets will be provided and serviced regularly by an appropriate service provider.
Blasting of rock to be conducted in consultation with the ECO. Blasting notices to be issued and flyrock protection to be implemented.
N/A No blasting is required.
Drilling to be conducted in consultation with the ECO. Yes The ECO will be informed of drilling activities, if necessary.
Environmentally friendly construction materials to be used where possible.
Yes No hazardous construction material will be used.
4.4 Rehabilitation of the construction site
Top material should be stripped from work sites and separately and securely stockpiled, in a manner that prevents contamination of the topsoil. The topsoil can later be used in rehabilitation
N/A No earthworks are proposed, therefore top soil stripping is not required.
Stabilisation of all areas disturbed during construction
Activities is required.
N/A No earthworks are proposed, therefore no destabilisation will occur.
Disturbed areas must be rehabilitated by the replacing of topsoil and planting of indigenous plant species. Invasive plant species will be controlled by removal and/or the use of eco-friendly herbicides. These areas will be monitored by the ECO for erosion and actions will be taken as necessary should erosion be observed.
Yes Following removal of materials at completion of construction, laydown areas will be ripped and monitored to ensure recovery of natural grasses. Invasive species will be removed during this period. This approach has been successful during the construction of the existing structure.
At completion, all structures, equipment, materials and facilities are to be removed to the satisfaction of the ECO.
Yes In addition to day site clean-ups as part of general house-keeping, all such items will be removed at completion and the close out audit will be performed by the ECO.
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4 CONCLUSION
In summation, the following findings are noted:
• No new listed activities in addition to those already approved are relevant to the proposed project;
• Whilst the structure footprint will increase, the proposed project activities do not differ from
those employed during the construction of the existing structure;
• The potential impacts of these activities have been assessed in the original approved assessment
documentation;
• The potential impacts of not going ahead with the proposed repairs and preventive upgrade
outweigh those of implementing the project;
• The mitigation measure necessary to ensure compliance and the prevention and mitigation of
potential impacts are included in the original approved construction EMP; and
• The proposed construction contractor is the same company that installed the existing structure
and has a history of compliance with the construction EMP, as documented in the construction
phase EMP compliance audit reports.
Accordingly, GCS do not foresee any circumstances associated with the proposed project that have not
been assessed or catered for in existing, approved impact management planning. This, together with a
proven track record of environmental compliance and the potential negative impacts of not going ahead
with the project, lead GCS to the conclusion that no further assessment is required and no fatal flaws to
the issuing of the Environmental Authorisation Amendment are present.
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Appendix A Existing Environmental Authorisations
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Appendix B Record of Public Consultation
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Appendix C SANBS Risk Assessment and Photographic Record of Flood Damage
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Appendix D Professional Engineering Opinion
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Appendix E Schematic of Approved and Proposed Design
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Appendix F Contractor Method Statement