Download - WATER USE LICENSE APPLICATION REPORT
Water Use License Application Report (WULAR) for the Proposed Thabametsi
Power Plant within the
Lephalale Municipality Submission: December ‘17
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TITLE:
Water Use License Application Report (WULAR) for the proposed Thabametsi Power Plant on the farm
Onbelyk near Lephalale, Limpopo Province
CLIENT:
Applicant: Thabametsi Power Company (Pty) Ltd
Contact: Kazuaki Shibuya
Address: 2nd floor, Building 11B, Woodlands Office Park
, Western Service Road, Woodmead, Sandton, 2191
Tel number: (011) 568-1480
Mobile number: 063 688 5659
Fax number: (011) 802 0025
Email: [email protected]
REPORT NO:
WULA/TPP/201711/V6.1
AUTHOR:
Charné Appelman B Sc. Hons (Environmental Management & Geography)
REVIEW:
Johan Maré M.Sc. (Microbiology)
PriSci Nat (Registration Number 400092/91)
DATE:
November 2017
COPYRIGHT WARNING
This document is privileged and confidential in nature and unauthorised dissemination or copying
is prohibited. Thabametsi Power Company (Pty) Ltd claims protection of this information in terms
of the Promotion of Access to Information Act, 2002 (Act 2 of 2002) and without limiting this
claim, especially the protection afforded by Chapter 4.
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PROJECT:
Facilitation of the water use authorisation process for the proposed Thabametsi Power Plant,
Lephalale, Limpopo
LOCATION:
Farms Onbelyk, van der Waltspan and Graafwater, Limpopo Province
LICENSEE: Thabametsi Power Company (Pty) Ltd
REG NUMBER: 2016/193930/07
APPLICANT: Thabametsi Power Company (Pty) Ltd
TEL NUMBER: (011) 568-1480
DELEGATED PERSON: Kazuaki Shibuya
CONTACT DETAILS: 063 688 5659
FAX NUMBER: (011) 802 0025
PROJECT MANAGER: Ms. Jo-Anne Thomas
CONTACT DETAILS: Savannah Environmental (Pty) Ltd
Block 2
Woodlands Drive Office Park
Woodmead
2191
TEL NUMBER: 011 656 3237
MOBILE: 082 690 9105
EMAIL: [email protected]
CONSULTANT: M² Environmental Connections (Pty) Ltd
CONTACT: Mr. Johan Maré
CONTACT DETAILS: M² Environmental Connections (Pty) Ltd
P.O. Box 2047
Garsfontein East
0060
TEL: 012 004 0362
MOBILE: 083 389 6617
FAX NUMBER: 086 621 0292
EMAIL: [email protected]
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DOCUMENT CONTROL
AUTHOR:
This document was compiled by the following person:
Charné Appelman December 2017
_____________________ ________________________ ____________________
Name Signature Date
REVIEW (MENCO):
This document was reviewed and approved by the following person:
Johan Maré December 2017
_____________________ ________________________ ____________________
Name Signature Date
APPROVED (SAVANNAH ENVIRONMENTAL):
This document was approved by the following person:
Jo-Anne Thomas December 2017
_____________________ ________________________ ____________________
Name Signature Date
APPROVED (THABAMETSI POWER COMPANY (PTY) LTD):
This document was approved by the following person:
Kazuaki Shibuya December 2017
_____________________ ________________________ ____________________
Name Signature Date
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Application Checklist
General Required Information Official
Use
Description Applicable Submitted
Yes No Yes No
Proof of payment of license processing fee (Compulsory) √
Copy of Identity Document of Applicant (Compulsory) √
Copy of Company Registration Certificate (Compulsory) √
Copy of Trust Registration Certificate (Compulsory) √
Letter of Authorisation for Companies, Trusts or Legal Entities
Letter of Authority or Power of Attorney to Apply on behalf of
Applicant √
Copy of BBBEE Certificate
Letter of Consent if the Applicant is not the Property Owner
(Compulsory) √
Applicant Information Form: Individual (DW 756/769) √
Applicant Information Form: Water Service Provider (DW
757/770) √
Applicant Information Form: Company, Partnership,
Government (DW 758/771) √
Applicant Information Form: Water User Association (DW
759/772) √
Property Details Form (DW 901) √
Property Owner Details (DW 902) √
Permission to Occupy (PTO), Title Deed, Lease Agreement,
Community Resolution √
A description of the location of the activity, including (aa) the
21 digit Surveyor General code of each cadastral land parcel,
(bb) where available, the physical address or farm name, (cc)
where the required information in sub -regulation (aa) and (bb)
is not available, the coordinates of the boundary of the property
or properties
√
When providing coordinates, such coordinates must be provided
in degrees, minutes and seconds using the Hartebeesthoek94
WGS84 coordinate system.
√
A plan which locates the proposed activity or activities applied
for at an appropriate scale, or if it is-
(aa) a linear activity, a description and coordinates of the
corridor in which the proposed activity or activities is proposed;
or
(bb) on land where the property has not been defined, the
coordinates of the area within which the activity is proposed
√
Where applicable, proof of acceptance of an application for any
right or permit in terms of the Mineral and Petroleum Resources
Development Act, 2002 or environmental authorisation as per
regulation 7 must be provided
√
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Description Applicable Submitted
Yes No Yes No
Section 21(a): Taking water from a resource √
Taking water from a water resource Form (DW 773) √
Pump Technical Data Form (DW 784) √
Canal Technical Data Form (DW 786) √
Irrigation Field and Crop Details (DW 787) √
Supplementary Info: Power Generation, Industrial or Mining
(DW 788)
√
Supplementary info: Domestic, Urban, Commercial or Industrial
(DW 789)
√
Soil Suitability Report (for irrigation from Dept. Agriculture) √
Section 21(b): Storing water
Storing water form (DW 762/774) √
Dam and Basin Technical Data Form (DW 789) √
Dam Classification Form (DW 793) (for dams >5m and >50,000
m3)
√
Dam Location Map √
Section 21(c) and (i): Impeding and Altering √
Impeding or diverting the flow of water in a watercourse form
(DW 763)
√
Altering the bed, banks, course or characteristics of a
watercourse (DW 789)
√
Supplementary Information for 21 (c)& (i) form (DW 775) √
Section 21(e): Engaging in controlled activity
Engaging in a controlled activity form (DW 765) √
Monitored Waste Discharge Details form (DW 904) √
Irrigation Field and Crop Details (DW 787) √
Section 21(f): Discharging waste or water containing
waste
√
Discharging waste or water containing waste into a water
resource through a pipe, canal, sewer or other conduit form
(DW 766)
√
Monitored Waste Discharge Details form (DW 903) √
Section 21(g): Disposing of waste in a manner that may
detrimentally impact on a water resource
√
Disposing of waste in a manner which may detrimentally impact
on a water resource form (DW 787)
√
Monitored Waste Discharge Details form (DW 904)
Details of Waste Management Facility form (DW 905) √
Section 21(h): Disposing in any manner of water
contains waste from or which has been heated in any
industrial or power generation process
Disposing in any manner of water which contains waste from,
or which has been heated in, any industrial or power generation
process form (DW 780)
√
Monitored Waste Discharge Details form (DW 903) √
Section 21(j): Removing, discharging or disposing of
water found underground if it is necessary for the
efficient continuation of an activity or for the safety of
people
√
Removing, discharging or disposing of water found underground
if it is necessary for the efficient continuation of an activity or
for the safety of people form (DW 780)
√
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Description Applicable Submitted
Yes No Yes No
Section 21(k): Using water for recreational purposes √
Using water for recreational purposes form (DW 780) √
Official Use
Application submitted: ____________________ Complete
Incomplete
_____________________
Signature of Assessor
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Executive Summary
Thabametsi Power Company (Pty) Ltd is a proposed Independent Power Producer that is developing
a coal fired power plant situated near Lephalale, Limpopo under the Department of Energy's Coal
Baseload IPP Procurement Programme ("Project"). The Project entails the construction of a 630 MW
coal fired power plant on the farm Onbelyk 257 LQ located approximately 26 km north-west of
Lephalale. The Project will utilise Circulating Fluidised Bed technology that is dry-cooled in order to
facilitate a zero liquid effluent discharge plant. Dry-cooled technology is a pre-requisite for the
Department of Water and Sanitation due to the water scarcity currently experienced in the
catchment. The water supply for the Project will be sourced from Exxaro Coal (Pty) Ltd in terms of
a surrender of a portion of its existing water allocation which has been issued with a water use
license in terms of the Water Supply Agreement in respect of Phase 1 of the Mokolo and Crocodile
River (West) Water Augmentation Project.
The following water uses have been identified and are being applied for, to be licensed in
accordance with Section 40 of the National Water Act, 1998 (Act 36 of 1998), namely:
Section 21(a) Taking of water from a resource
Section 21(b) Storing of water
Section 21(c) Impeding or diverting the flow of water in a watercourse
Section 21(f) Discharge of water containing waste into a resource
Section 21(g) Disposing of waste which may detrimentally impact on a water resource
Section 21(i) Altering the bed, banks, course or characteristics of a watercourse
The applicant has appointed various specialists to conduct environmental investigations in support
of the Water Use License Application. The following Environmental Authorisation Processes has
been followed:
An Integrated Environmental Authorisation has been obtained from the Department of
Environmental Affairs (Ref: DEA/EIA/0001296/2012) (EA). The EA has been suspended
pending the consideration and decision by the Minister of Environmental Affairs, of, inter
alia, the Thabametsi Power Plant's climate change impacts.
An application for an air emissions license in terms of NEM: AQA has been undertaken
An application for a waste permit in terms of NEM:WA has been lodged for the operation of
the ash dam
For the WULA process:
Thabametsi Power Company (Pty) Ltd has undertaken the following Specialist
Investigations:
o Biodiversity Study
o Surface Water Study
o Wetland Delineation
o Geo-Hydrological Study
o Hydrological and Water Supply
After the Project was awarded preferred bidder status under the Coal Baseload IPP
Procurement Programme, the applicant has undertaken the following additional
Specialist Investigations:
o Civil Engineering Design Report
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o Storm Water Management Plan
o Construction Work Method Statement
The applicant has also committed to the following:
o Conduct a Section 25(2) application for the surrender of water
o Participate in MCWAP Phase 2 for future water supply
o Endorse full Public Participation Process
Conducted multiple feasibility studies complying with the requirements of the National
Environmental Management Act, 1998 (Act 107 of 1998) such as climate change study.
Based on the Environmental Impact Assessment conducted, the following impacts (without
mitigation) with a rating of moderate and higher have been identified.
Nature of Activity /
Impact
Extent Duration Magnitude Probability Significance
Alteration of drainage 2 4 6 3 36
Pipeline construction 3 2 8 4 52
Riparian and biodiversity 3 4 6 3 39
Surface water pollution 3 4 8 3 45
Groundwater pollution 3 4 8 3 45
Stormwater and spillage 3 4 6 3 39
Ash dump spillage 2 4 8 3 42
Coal stock yard and AMD 2 4 8 4 56
Catchment yield reduction 3 4 8 4 60
Residual impact 2 5 10 4 64
The Impact Assessment above ranges from moderate to high but could effectively be mitigated to a
low to moderate rating. The management measures are contained in the IWWMP and coupled with
a WUL the water resources within the catchment could be protected from unacceptable
degradation.
It is therefore recommended that the applicant should be issued with a Water Use License for the
identified water uses. The WUL should be issued for the maximum period as prescribed by the
DWS as the Thabametsi Power Plant is planned to be in operation for 30 years.
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Table of Contents
Page
1 BACKGROUND .......................................................................... 1 1.1 Applicant ........................................................................................ 1 1.2 Site and Regional Description ........................................................ 1
2 SUMMARY TECHNICAL INFORMATION ...................................... 4 2.1 Reports and Technical Information ................................................ 4 2.1.1 Biodiversity Study ......................................................................................... 4 2.1.2 Surface Water Study ...................................................................................... 4 2.1.3 Wetland Delineation ...................................................................................... 4 2.1.4 Geo-Hydrological Study .................................................................................. 5 2.1.5 Hydrological and Water Supply ....................................................................... 5 2.2 Project Description ......................................................................... 5 2.2.1 Power Plant Infrastructure .............................................................................. 6 2.2.2 Water Management Facilities .......................................................................... 6 2.3 Water Uses Applied For ................................................................ 10 2.3.1 Identified Water Uses .................................................................................. 10 2.3.2 Section 21(a) water uses ............................................................................. 11 2.3.3 Section 21(b) water uses ............................................................................. 12 2.3.4 Section 21(c) and (i) water uses ................................................................... 12 2.3.5 Section 21(f) water uses .............................................................................. 15 2.3.6 Section 21(g) water uses ............................................................................. 16 2.3.7 Water Demand Analysis ............................................................................... 16 2.3.8 Water Supply Analysis ................................................................................. 16 2.4 Impacts of Activities on Water Resource ...................................... 17 2.4.1 Surface Water ............................................................................................. 17 2.4.2 Groundwater .............................................................................................. 18 2.5 Proposed Mitigation Measures ..................................................... 18 2.5.1 Surface Water ............................................................................................. 18 2.5.2 Groundwater .............................................................................................. 19 2.5.3 Wetlands .................................................................................................... 21
3 ASPECTS TAKEN INTO CONSIDERATION ................................ 22 3.1 Departmental Correspondence ..................................................... 22 3.2 License Administration ................................................................. 23 3.3 Inputs from other Departmental Directorates .............................. 24 3.3.1 National Water Resource Planning ................................................................. 24 3.3.2 Abstraction and Storage ............................................................................... 24 3.3.3 Civil Design ................................................................................................ 25 3.3.4 Environment and Recreation ......................................................................... 26 3.4 Inputs from Stakeholders ............................................................ 26
4 SECTION 27 MOTIVATION ...................................................... 28 4.1 Existing lawful water uses ........................................................... 28 4.2 The need to redress past racial and gender discrimination .......... 28 4.3 Efficient and beneficial use of water in the public interest ........... 29 5.3.1 Taking of water ............................................................................................... 29 5.3.2 Altering the natural characteristics of the wetland areas ....................................... 29 5.3.3 Waste disposal ................................................................................................ 29 4.4 The socio-economic impact of the water use or uses if authorised29 4.5 The socio-economic impact of the failure to authorise the water use
..................................................................................................... 30 4.6 The catchment management strategy applicable to the resource . 31 4.7 The likely effect of the water use on water users ......................... 31 4.8 The class and the resource quality objectives of the water resource32
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4.9 Investments already made by the water user .............................. 32 4.10 The duration of water use ............................................................ 33 4.11 The strategic importance of the water use to be authorised ........ 34 4.11.1 Site specific ................................................................................................ 34 4.12 Enforcement and Management ..................................................... 34 4.12.1 Management Plans ...................................................................................... 34 4.12.2 Monitoring .................................................................................................. 34
5 CONCLUSIONS AND RECOMMENDATIONS .............................. 36
6 REFERENCES .......................................................................... 37
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List of Figures page
Figure 1-1: National Locality Map ..................................................................... 2 Figure 1-2: Regional Locality Map ..................................................................... 3 Figure 2-1: Infrastructure Layout Plan for Thabametsi IPP Power Plant ................. 7 Figure 2-2: Thabametsi IPP Power Plant coal and ash storage .............................. 8 Figure 2-3: Thabametsi IPP Power Plant water supply pipeline route ..................... 9 Figure 2-4: Section 21(a), (b), (c), (f), (g) and (i) Water Uses ........................... 13 Figure 2-5: Properties Related to Water Uses ................................................... 14 Figure 2-6: Wetlands within the project area ................................................... 15
List of Tables
Page
Table 2-1: Detailed information on water uses to be licensed, their location and description .................................................................................................. 11 Table 2-2: Mokolo Dam Yield Analysis ............................................................. 16 Table 2-3: Mokolo Dam Allocations ................................................................. 17 Table 2-4: Mitigation for surface water impacts ................................................ 18 Table 2-5: Mitigation measures for groundwater impacts ................................... 19 Table 3-1: Regulatory consultation process followed ......................................... 22 Table 3-2: Completed DW Forms .................................................................... 23 Table 4-1: Resource Quality Objectives for the receiving water resource ............. 32 Table 4-2: Details of the life activity of the Thabametsi Power Plant Project ......... 33
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List of Appendices
Appendix 1 Company Registration and Certified ID of applicant
Appendix 2 Title Deeds and Land Claim
Appendix 3 Contractual Agreement
Appendix 4 Section 25(2) Application
Appendix 5 Master Layout Plan
Appendix 6 BBEEE Certification
Appendix 7 DW Forms
Appendix 8 Proof of Payment
Appendix 9 RoD (Environmental Affairs)
Appendix 10 Integrated Water and Wastewater Management Plan
Appendix 11 EIA and EMP (soft copy only)
Appendix 12 Wetland Delineation Study
Appendix 13 Biodiversity Assessment
Appendix 14 Surface Water
Appendix 15 Geohydrological Assessment
Appendix 16 Construction Work Method Statement and Rehabilitation Plan
Appendix 17 Storm Water Management Plans
Appendix 18 Civil Engineering Designs
Appendix 19 Water Balance
Appendix 20 Hydrology and Water Supply
Appendix 21 Public Participation Report
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List of Abbreviations
AMD Acid Mine Drainage
BBBEE Broad Based Black Economic Empowerment
CER Centre for Environmental Rights
CMA Catchment Management Agency
CSY Coal Stock Yard
DWS Department of Water and Sanitation
EIA Environmental Impact Assessment
EISC Environmental Integrity and Sensitivity Class
ELA Earth Life Africa
ELU Existing Lawful Use
EMP Environmental Management Plan
GA General Authorisation
GN Government Notice
I&AP Interested and Affected Parties
IPP Independent Power Producer
IWULAR Integrated Water Use Licence Application Report
IWWMP Integrated Water and Wastewater Management Plan
MCWAP Mogol Crocodile Water Augmentation Project
NEM: AQA National Environmental Management: Air Quality Act, 2004 (Act 39 of 2004)
NEM: WA National Environmental Management: Waste Act, 2008 (Act 59 of 2008)
NERSA National Energy Regulator of South Africa
PCD Pollution Control Dam
PES Present Ecological Status
PPP Public Participation Process
RQO Resource Quality Objective
SWMP Stormwater Management Plan
TCTA Trans Caledon Tunnel Authority
WUL Water Use Licence
WMA Water Management Area
WWTW Waste Water Treatment Works
ZLED Zero Liquid Effluent Discharge Facility
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1 BACKGROUND
1.1 APPLICANT
Exxaro Coal Proprietary Limited (Exxaro) initiated during 2013 the environmental authorisation
process for the development of the Thabametsi Power Plant on the farm Onbelyk 257 LQ near the
town of Lephalale in the Limpopo Province. Exxaro initially selected Newshelf 1282 (Pty) Ltd as the
preferred Independent Power Producer (IPP) for the development of the power plant. During 2014
the applicant changed to Thabametsi Power Project (Pty) Ltd.
With the subsequent withdrawal of Thabametsi Power Project (Pty) Ltd during February 2015, the
Project was taken over by the Thabametsi Power Company (Pty) Ltd. The Department of Energy
awarded preferred bidder status under the Coal Baseload IPP Procurement Programme towards the
end of 2015 to the applicant. The Water Use License Application (WULA) was lodged with the
Limpopo-Northwest proto Catchment Management Area (CMA) situated in Polokwane in the name
of the applicant.
1.2 SITE AND REGIONAL DESCRIPTION
The Thabametsi Power Plant Project is situated approximately 29 km east south-east of Lephalale
and approximately 25 km south of the Stockpoort Border Post. The project area falls within the
jurisdiction of the Lephalale Local Municipality (LIM362) and the Waterberg District Municipality
(DC36).
Just south of the proposed project site the Grootgeluk Colliery as well as the Medupi and Matimba
Power Stations are located. Smaller settlements in close proximity include Marapong and
Steenbokpan to the south-west and south-east. Numerous small access roads occur to and from
the project site, however larger roads are only found closer to Lephalale. A railway line runs to the
south from the Grootgeluk Colliery just below the project site. The attached Figure 1-1 and
Figure 1-2 gives an indication of the regional locality of the study area.
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Figure 1-1: National Locality Map
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Figure 1-2: Regional Locality Map
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2 SUMMARY TECHNICAL INFORMATION
2.1 REPORTS AND TECHNICAL INFORMATION
As per requirement stated in Government Notice Regulation 267 promulgated on 24 March 2017
application for specific water uses are subject to the submission of specialist studies in support of
these water uses.
2.1.1 Biodiversity Study
The Biodiversity study was conducted during 2014 by Bathusi Environmental Consulting. The study
details all the biodiversity management action plans to be implemented as part of the Project
development. In terms of the WULA the biodiversity study contributed towards the Rehabilitation
Plan for the pipeline construction for those areas where the pipeline transects the protective buffer
zone of the delineated wetlands.
2.1.2 Surface Water Study
A surface water study was conducted by M2 Environmental Connections during June 2013. The
project site falls within quaternary drainage area A41J of the Mogol River that is part of the
Limpopo Water Management Area which is classified as phase 2 Freshwater Ecosystem Priority
Area. The study revealed that there are no surface water resources to be directly impacted by the
power plant development and that activities at the site during operational phase will contribute
towards moderate impacts on the catchment if mitigatory measures are not implemented. With
the implementation of appropriate mitigation and action plans surface water impacts are rated as
low to low moderate significance.
The only matter of concern is the availability of water supply to the area as the supply from the
Mogol Dam is considered to be over allocated. This will have a negative long-term impact on other
water users, specifically the agricultural sector.
2.1.3 Wetland Delineation
The baseline wetland delineation study was conducted during February 2014 by Digby Wells and
Associates. It was reported that the development may result in direct and indirect impacts on pans
and associated channels within the project area. The identified wetland units are stated as pans
linked to wooded drainage lines. The PES of the pans was given as Class C/B which the EIS states
as High. No pans are directly impacted by the development and the footprint will only transgress
the 500 m protective buffer zone of the delineated wetlands.
In addition a further wetland delineation study was conducted during 2017 by WSP South Africa
(Pty) Ltd to cater for any potential impacts on wetlands to be caused by the construction of a water
supply pipeline. It was confirmed that the wetlands are identified Depression Complexes that
consist of grouped HGM units that function as the same HGM unit due to similar land use impacts,
same vegetation type and similar impacts from runoff characteristics and water quality changes.
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Impact rating on the wetlands is stated as Moderate but could effectively mitigated to Low
significance.
2.1.4 Geo-Hydrological Study
A baseline groundwater impact study was conducted by Geo Pollution Technologies during February
2014 and subsequently been updated during July 2017 to align the groundwater modelling with the
final layout of the power plant footprint. The study revealed that the footprint of the development
overlay a minor aquifer with groundwater levels varying between 14.4 to 53.6 meters below
ground level.
Borehole LEP10 is to be negatively impacted by the development of the ash dump. Borehole LEP9
also has the potential to be impacted due to increased sulphate concentrations stemming from the
CSY. There is a long-term likelihood that boreholes LEP 13 and LEP 14 may be impacted in the
event that no liners are installed at the ash dump and coal stock pile. To prevent groundwater
contamination all pollution control facilities are designed with appropriate barrier systems as
contemplated in the Norm and Standards on Assessment of Waste for Landfill as specified in R635
of August 2013. Regular groundwater sampling will be introduced to monitor the establishment and
migration of a groundwater pollution plume.
2.1.5 Hydrological and Water Supply
UWP Consulting conducted a Water Supply Study during October 2015. The study revealed that the
safe yield of the Mokolo Dam will be exceeded in the nearby future. In addition the total installed
capacity of MCWAP-1 will defer water deficits for a few years but is rated as unsustainable in the
long-term. The deficit situation will be remedied when the MCWAP-2 project comes on line about
2020. There will be a deficit based on the high demand scenario around 2025 that could be
mitigated by abstracting water above the safe yield from the Mokolo Dam.
The water requirement for the 630 MW power plant is to be a water allocation of 720 000
m3/annum, and such amount is being made available to the applicant for purposes of the Project.
Water is currently available from the Mokolo Dam as part of the MCWAP Phase 1 project. The key
factor for the water supply to the Project revolves around the effective transfer of part of Exxaro's
current water license allocation to the applicant.
Water quality from both the Mokolo Dam and the Crocodile River (West) is considered suitable for
the Project, although the Mokolo Water quality is higher.
2.2 PROJECT DESCRIPTION
The Water Use License Application is for the proposed Thabametsi Power Plant in the Lephalale
area. As the Thabametsi Power Plant is currently still being designed, the infrastructure
requirements are considered conceptual. The infrastructure needed is outlined in Section 2.1 and
Figure 2-1 as well as Figure 2-2.
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2.2.1 Power Plant Infrastructure
The main infrastructure associated with the power plant includes the production units consisting of
boilers, furnaces turbines, generators and associated equipment. The footprint will also make
provision for an office complex, maintenance area, coal stock yard and ash dump. The following
treatment plants will be constructed and operated:
Waste Water Treatment Plant (Bio-Filter System)
Raw Water Treatment Plant
2.2.2 Water Management Facilities
Pollution control and water resource management activities and related infrastructure that will be
constructed include:
Pollution control dams (Ash Dump PCD, Coal Stockyard PCD & Waste Water Collection
Pond) as well as an Evaporation pond and Storm Water Pond;
Ash Dump;
Coal Stock Yard (CSY);
Stormwater drains as part of the SWMP;
Water pipeline for raw water supply from MCWAP 1; and
Waste Water Treatment Works.
The office infrastructure will be sufficient to cater for the number of employees at the Thabametsi
Power Plant. Security fencing and gate control will also be implemented for safety purposes. The
following infrastructure will be constructed in accordance with the civil engineering designs as
indicated in Figure 2-1 provided below.
Pollution Control Dam: All PCD’s to be constructed on the project site will be appropriately lined
that will provide containment service related to water management stemming from the ash dump
and all delineated dirty water areas.
Pipeline Water Supply and Conveyors: Two conveyors are proposed being the ash dump extendable
conveyor system as well as the conveyor system feeding the Strategic Coal Stockyard to store a
maximum of 750 000 tons of coal. The facility is further equipped with a pollution control sump and
pump station to recycle waste water runoff to one of the three PCD’s.
A water supply pipeline will be constructed from the tap-off point to the raw water reservoir (please
refer to Figure 2-3.
Waste Water Treatment Works: The Bio-filter Waste Water Plant is situated to the south of the bus
parking and access control area. The plant is designed to cater for a design capacity of 600 m3 per
day. The effluent will treated to standards as specified in GN 665 of 6 September 2013 and
disposed to the waste water collection pond. The treated waste water from the lined waste water
collection pond will be re-used and recycled as part of the power plant’s internal water circuit and
will not be discharged to the environment.
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Figure 2-1: Infrastructure Layout Plan for Thabametsi IPP Power Plant
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Figure 2-2: Thabametsi IPP Power Plant coal and ash storage
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Figure 2-3: Thabametsi IPP Power Plant water supply pipeline route
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2.3 WATER USES APPLIED FOR
2.3.1 Identified Water Uses
The following water uses have been identified and are being applied for, to be licensed in accordance
with Section 40 of the National Water Act, 1998 (Act 36 of 1998), namely:
Section 21 (a) – Taking of water from a resource;
Section 21 (b) – Storing of water;
Section 21 (c) – Impeding or diverting the flow of water in a watercourse;
Section 21 (f) – Discharge of water containing waste into a resource
Section 21 (g) – Disposing of waste which may detrimentally impact on a water resource;
Section 21 (i) - Altering the bed, banks, course or characteristics of a watercourse;
Further details on the water uses are provided in Table 2-1 and illustrated in Figure 2-4 with the
properties on which the water uses are to be exercised depicted in
Figure 2-5.
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Table 2-1: Detailed information on water uses to be licensed, their location and
description
Water Use Description Latitude Longitude Volume/
Dimension
Section 21(a) Taking water (WU1) 23°40'42.30"S 27°36'5.61"E 720,000 m3/a
Section 21(b) Storing water (WU2) 23°35'58.76"S 27°29'41.23"E 30,000 m3
Section 21(c), (i)
Pipeline water/wetland
crossing A at wetland
unit 4 (WU3)
Start
23°37'43.82"S
End
23°37'36.43"S
Start
27°33'38.41"E
End
27°33'37.61"E
230 m
Section 21(c), (i)
Pipeline water/wetland
crossing B at wetland
unit 3 (WU4)
Start
23°37'10.64"S
End
23°36'36.46"S
Start
27°33'31.46"E
End
27°33'25.35"E
900 m
Section 21(c), (i)
Pipeline water/wetland
crossing C at wetland
unit 2 (WU5)
Start
23°36'30.92"S
End
23°35'55.16"S
Start
27°31'27.15"E
End
27°30'19.79"E
1900 m
Section 21(c), (i)
Power plant
infrastructure within a
500 m protective buffer
zone of wetland cluster
(WU6)
Start
23°36'25.13"S
End
23°36'31.76"S
Start
27°29'44.22"E
End
27°29'70.13"E
1000 m
Section 21(g) Ash Dump PCD (WU7) 23°36'9.75"S 27°29'23.18"E 56,000 m3
Section 21(g) Coal Stockpile PCD
(WU8) 23°36'11.49"S 27°29'29.12"E 2,650 m3
Section 21(g) Evaporation pond
(WU9) 23°36'1.12"S 27°29'24.38"E 16,200 m3
Section 21(g) Waste Water Collection
Pond (WU10) 23°36'2.11"S 27°29'27.49"E 1,200 m3
Section 21(g) Storm Water Pond
(WU11) 23°36'4.35"S 27°29'28.68"E 13,600 m3
Section 21(g) Strategic Coal
Stockyard (WU12) 23°36'6.96"S 27°29'34.41"E 750,000 ton
Section 21(g) Ash Dump (WU13) 23°35'57.79"S 27°29'8.69"E
270 Ha
280 t/h
20, 848, 89
t/a
Section 21(f) WWTW Bio-filter plant
(WU14) 23°36'2.43"S 27°29'32.94"E 600 m3/day
Section 21(g) Dust Suppression
(WU15) 23°35'57.79"S 27°29'8.69"E 120,450 m3
2.3.2 Section 21(a) water uses
The need for a section 21(a) water use is debatable as this water use is to take place on Grootestryd
465 LQ, portion RE/3, out of an existing tap-off point as part of the volume of water surrendered by
Exxaro under its MCWAP-1 allocation under its water use licence in favour of the applicant.
A section 25(2) application process for the surrender of water has been followed.
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2.3.3 Section 21(b) water uses
In terms of Section 21(b) of the National Water Act (Act 36 of 1998), this water use entails the
storing of raw water for industrial use. The raw water is of potable quality and not seen as water
containing waste. A potable water treatment plant will purify the water for domestic use as well as
industrial use in the power plant as specific water qualities will be required in the power generation
process.
Potential impacts:
Section 21(b): There is no possible impact on the environment from storing water in a reservoir with
holding capacity of 30,000 m3. The dam wall of less than 3 meters ensures that the dam has no
safety risk.
2.3.4 Section 21(c) and (i) water uses
According to Government Gazette GN 1199 of 18 December 2009, a buffer zone of 500m should be
maintained around wetlands. It is however understood that the DWS expects this “regulated area” to
be applied horizontally as well as vertically. It is thus that the mine is applying for multiple section
21 (c) & (i) water uses as contemplated in Table 2-1 and Figure 2-4 with the supporting DW Forms
contained in Appendix 1 of this document.
The wetlands that are applied for in this WULAR were delineated by a Wetland Specialist from Digby
Wells and Associates and validated during a study performed by WSP SA (Pty) Ltd. Their study is
contained in the IWWMP and the finding is that the Eendrag Pan falls outside the footprint of the
Thabametsi Power Plant. There are however complex depression systems linked to wooded drainage
lines located within the 500 meter buffer zone which trigger a section 21 (c) and (i) water use.
Refer to Figure 2-6 for an illustration of the locality of NFEPA important wetlands.
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Figure 2-4: Section 21(a), (b), (c), (f), (g) and (i) Water Uses
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Figure 2-5: Properties Related to Water Uses
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Figure 2-6: Wetlands within the project area
Further water uses under this section include the pipeline crossings proposed for the operation of
the Thabametsi Power Plant. This pipeline crossing will be constructed as a best option to convey
raw water to the reservoir at the Thabametsi Power Plant and will follow existing linear
infrastructure to minimise further environmental impacts. This infrastructure can be seen in
Figure 2-1.
2.3.5 Section 21(f) water uses
Due to the intent of the applicant's requirement to commission a new WWTW and use this plant to
treat waste water, a Section 21(f) water use authorisation will be required. The water containing
waste will be recycled and used in the hydration of ash.
Potential impacts:
Should the water quality of the water being discharged be non-conformant to the stipulated RQO’s
to be determined by DWS, the ecosystem might moderately be impacted.
Project Site &
Ash Dump
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2.3.6 Section 21(g) water uses
Power Generation is classified as Category A Environmental Risk Activity,1 meaning a license
will need to be obtained for the waste dump and or PCD’s constructed that may have the potential
to detrimentally impact on a water resource.
The Section 21 (g) water uses applicable to this application entail:
Ash Dump PCD;
Coal Stockyard PCD;
Waste Water Collection Pond;
An evaporation pond with capacity of 16,200 m3;
Storm water containment of 13,600 m3;
A coal stock yard with storage capacity of 750,000 tons
An ash dump with total storage capacity of 200 000 000 tons and operational life of 40
years. This facility is already authorised under NEM:WA.
All PCD’s are designed in accordance with GN 704 regulations and the designs make provision for a
HDPE liner to be implemented.
2.3.7 Water Demand Analysis
Information as contained in the Crocodile West Reconciliation Study (DWA, 2012) was used in pre-
feasibility phase of the Project. From the study it is evident that water requirements in the Greater
Lephalale area would exceed the safe water yield of the Mokolo Dam. It was also reported that the
total pumping capacity of MCWAP Phase 1 of 53.4 Mm3/annum will be exceeded by 2020. The
water demand for the area can be reduced with the implementation of MCWAP Phase 2.
2.3.8 Water Supply Analysis
The water supply to the project is completely dependent on the surrendering of 720,000 m3/a from
the Exxaro's allocation.
The Mokolo Dam Yield Analysis (DWA, 2008) has determined that the dam has gross capacity of
146 Mm3. The yield analysis results are stated in Table 2-2.
Table 2-2: Mokolo Dam Yield Analysis
Historic Firm Yield (HFY) Yield (Mm3/annum at indicted Recurrence Interval
Mm3/a RI (years) 1:200 (99.5%) 1:100 (99%) 1:50 (98%) 1:20 (95%)
38.7 1:224 39.1 44.6 50.7 66.8
Other sources investigated to augment water supply is groundwater abstraction where the
sustainable yield of 1.7 Mm3/annum could alleviate the water stress scenario. This could be
1 Government Gazette Notice: No 26187 (339) published 26 March 2004: Revision of General Authorisations in
terms of Section 39 of the National Water Act, 1998 (Act no. 36 of 1998)
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increased to 7.2 Mm3/annum over a two year (short-term) abstraction period but the resource will
be subject to a recovery period of two years.
Based on the studies conducted by the Department of Water and Sanitation, water allocations from
the dam were 27.6 Mm3/a. Water was supplied to the industrial and municipal customers around
Lephalale through a 45 km pipeline from the dam terminating near Matimba Power Station. This
pipeline is owned by Exxaro and has a gross capacity of 14.7 million m3/a. Phase one of the
MCWAP was completed which entailed the laying of an additional pipeline from the Mokolo Dam to
Matimba Power Station. This was laid next to the Exxaro line apart from one small section. The new
pipeline has a capacity of 36.9 Mm3/a, thus a total gross pumping capacity of both pipelines of 53.4
Mm3/a.
Phase one consisted of an initial phase referred to as “debottlenecking”, where the capacity
of the existing gravity line from Wolvenfontein Reservoir to Rietspruitnek (15.9 km) was increased
by means of interconnections to the new pipeline (DWA, 2008, MCWAP, Feasibility Study, Main
Report). This was completed by October 2013 and increased the capacity from 14.7 M m3/a to 23.1
million Mm3/a (DWA, 2014). The allocations from the Mokolo Dam after completion of MCWAP
Phase 1 are indicated in
Table 2-3.
Table 2-3: Mokolo Dam Allocations
User Allocation (million m3/a)
Exxaro Current 5.6
Additional Phase 1 2.0
Sub-Total 7.6
Eskom Current Matimba Power Station 6.5
Medupi Additional Phase 1 8.0
Sub-Total 14.5
Others (Domestic) Lephalale and Marapong 7.2
Incidental Users 0.1
Sub-Total 7.3
Mogol Irrigation Board Irrigation 10.4
Natural Environment Provision for Ecological Reserve 4.0
TOTAL 43.8
2.4 IMPACTS OF ACTIVITIES ON WATER RESOURCE
2.4.1 Surface Water
Potential impacts:
Section 21(a): The impact of abstraction on water resources in the catchment is seen as high due
to scarcity of water. The water source is an existing allocation made to Exxaro Coal (Pty) Ltd.
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Exxaro Coal (Pty) Ltd has agreed to surrender 720,000 m3 per annum of raw water to the applicant
for purposes of the Project. The water allocation to the Thabametsi Power Plant will not contribute
towards further water scarcity as this demand is already encapsulated in Exxaro's water use
license.
Should the PCD’s spill, the water quality within the Sandloop will become impaired. The risk for this
to happen is however low (as a Civil Engineer designed it with a 0.8m freeboard) and the
Thabametsi Power Plant will need to monitor the dam levels as well as water quality, especially as
the water will be used for dust suppression. Should such a spill occur, this incident must be
reported to DWS and corrective actions must be taken.
2.4.2 Groundwater
The fractured aquifer of the project site was classified as a minor aquifer as it is not a highly
productive aquifer. Using the Groundwater Decision Tool it was found that the aquifer has a
medium vulnerability and as a result it also has a medium level groundwater quality management
index. This indicates that a medium level of aquifer protection is required in the area of the
proposed Thabametsi Power Plant.
The main potential sources of this pollution are the ash dump and coal stockpile due to chemical
weathering by oxidation of the sulphide containing minerals (mostly pyrite) in these structures, as
well as other geochemical processes producing different contaminants. This is anticipated if no
liners are implemented below the stockpile and ash dump at the site, or if the liners are leaking.
Mitigatory measures in the form of liners could prevent groundwater contamination. A groundwater
monitoring program needs to be implemented.
2.5 PROPOSED MITIGATION MEASURES
2.5.1 Surface Water
The surface water environment will be protected in terms of the measures as contained in Table
2-4 below
Table 2-4: Mitigation for surface water impacts
Objective Action
To minimize the pollution of surface water and maximize the clean runoff from the area. This
policy will ensure the smallest possible detrimental impact on the surrounding surface
water catchment
A clean water cut-off trench (storm water diversion trench) had been installed on the
north-eastern side of the power station as well as around the CSY. This storm water diversion
trench was designed to cater for the runoff water from a 1:50 year 24-hour storm event with a
0.8m freeboard.
Any future infrastructure to be installed will be in accordance with the specifications as laid out in
Regulation 704 (4 June 1999) of the National Water Act, 1998 (Act 36 of 1998).
To ensure that the pollution control facilities are maintained on a regular basis
The power station manager will appoint a responsible person to ensure that the water
pollution control structures are constructed and
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Objective Action operated in accordance with the approved
designs. These structures comply with Regulation 704 (4 June 1999) of the National Water Act,
1998 (Act 36 of 1998)
The water pollution control structures (berms, dirty water trenches, storm water diversion
trenches) will be inspected on a weekly basis for signs of erosion or blockages during the first
rainy season. Thereafter, inspections will occur at the advent of the subsequent rain seasons and
on a monthly basis during the rainy and dry
seasons. Any blockages or erosion will be cleared or repaired within 24 hours after discovery.
To ensure that the surface water runoff from the site complies with requirements of the National Water Act, 1998 (Act 36 of 1998).
A surface water-monitoring programme has been developed for implementation. Water quality
monitoring is a mandatory requirement
stipulated in the National Water Act, 1998 (Act 36 of 1998). Water samples will be taken on a monthly basis from the identified monitoring
points (i.e. upstream and downstream monitoring points) as well as from the pollution control dam and return water dams. The results generated at these points will be used to detect
any possible impact on surface water from the power station2.
Sampling will be performed according to recognized procedures and approved laboratory
analysing techniques will be followed. An
accredited laboratory will perform the hydrochemical analyses.
The contamination of other substances such as hydrocarbons will also be determined. A field
form will be designed for the use by the sampler.
Dam levels, signs of acid water formation, leaks, spills or any other relevant information will be
noted.
A water quality database had been set up for the site. Results from the monitoring will be
submitted to the Regional Director: DWS on a quarterly (three-monthly) basis in accordance with the requirements as specified in the water use licence. The results of the sampling will be compared to the South African Water Quality
Guidelines.
2.5.2 Groundwater
The water uses foreseen at the Thabametsi Power Plant will be managed well and managed in
accordance with the following principles to mitigate and control water uses and possible impacts
anticipated. A more detailed management plan is contained in the IWWMP. Water Resource
Management approach for impacts rate as “High” and are provided below (refer Table 2-5).
Table 2-5: Mitigation measures for groundwater impacts
Objective Action
2 The monitoring of surface water bodies may be omitted due to far distance from the resource
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Objective Action
To reduce groundwater pollution and minimise the impact thereof on the aquifer and to ensure the sustainable use thereof for selected water
uses.
Trenches Cut-off trenches installed at the coal stockyard. This will assist in diverting the clean runoff away from the coal stockyard. Dirty runoff cascades to the Dam. The sub-surface of the section of
the current coal stock yard that is directly opposite the coal stockpiles was disturbed and
not compacted again at some stage during the earlier existence of the Thabametsi Power Plant. This implies that the integrity of the natural clay layer was compromised during this activity. It is assumed that that the ground water pollution as detected in borehole B8 emanates largely from
this area. In order to alleviate pollution of the ground water from this area the following
remedial activities were conducted: - A comprehensive needs analysis was
conducted to establish the exact surface area required for coal
storage.
- The rework and compaction of the Coal Stock Yard subsurface in line with the recommendation of the
geotechnical investigation. - Constructions of a suitably sized
facility complete with an effective clay membrane as per the Avon
Engineering recommendations. - Construction of coal stockyard, storm
water interception and reuse system (Coal Stockyard Dam) in accordance
with the requirements of GN 704 while taking cognisance of the
operating rule for the dam.
Boreholes Sixteen boreholes are to be used at the
Thabametsi Power Plant to monitor the possible
migration of polluted water to the ground water system. The sampling frequency for sampling
recommended by the specialist geohydrological investigation dated September 2012 is six monthly. This report further states the low
hydraulic conductivities and storage coefficients for the fractured aquifer. Records further showed
that blow-out yields of the existing boreholes were in the order of 0.025 litre per second. It is for this reason that Thabametsi Power Plant is not considering boreholes and the continuous
pumping of these holes in order to capture small masses of migrated salts through the creation of an inversion cone in the water table. There will
thus be no need to intercept and contain the groundwater plume by means of active
dewatering of the affected aquifer.
Clay membranes Migration of acidic products from the coal
handling and mill rejects (coal) disposal areas is a reality. A suitable clay membrane as described
in the civil engineering design report will mitigate pollution emanating from the coal
stockyard. Tracking the water quality of borehole LEP9 will give an indication of the efficacy of the
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Objective Action
remedial activities. Disposal methods employed during the operation
of Thabametsi Power Plant may result in the leaching of acid rock drainage. The Thabametsi Power Plant ash generates sufficient alkalinity to
neutralise and eventually precipitate the acid leachates from the rehabilitated waste site.
Encapsulation of waste Wastes such as small volumes of organic
solvents emanating from the Laboratory and specialised equipment and part cleaning are
disposed of through a reputable hazardous waste contractor. Dirty oils and oily residues or sludge
are recycled through a reputable contractor. Medical and pharmaceutical wastes generated on
the site are disposed of through reputable
Medical Waste Disposal Contractors. There will
thus be no encapsulation of hazardous wastes at Thabametsi Power Plant.
The immobilisation of calcium sulphate in the ash through the precipitation as calcium sulphate
and ettringite could also be regarded as some form of encapsulation. The pozzalanic properties of the pulverised fuel ash (PFA) also allow for the
encapsulation of normal water borne pollutants
2.5.3 Wetlands
Moderate impacts are foreseen if wetland rehabilitation is not implemented. As stated in Table 16
of the Wetland Impact Report (WSP, 2017) the significance rating of the construction impacts are
“Low” implying that no mitigation is required. However during the Operational Phase of the Project
“Moderate” impacts could manifest in the area. The mitigatory measures stipulate that a
service/maintenance plan for the pipelines must be compiled, approved by the competent authority
and implemented. The plan must encompass procedures to minimise any impacts on the
surrounding environment such as vegetation removal and ground compaction. It must also outline
monitoring, emergency spill response and trenching procedures for any malfunctions. An approved
operational Stormwater Management Plan must be implemented to ensure only clean stormwater
enters the watercourses in a controlled manner.
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3 ASPECTS TAKEN INTO CONSIDERATION
3.1 DEPARTMENTAL CORRESPONDENCE
The DWS Regional Office in the Limpopo Province was consulted as the relevant regulator dealing
with the Water Use License Application. In brief the application process could be summarised as
tabled below:
Table 3-1: Regulatory consultation process followed
Date Aspect Outcome
20 February 2015 Pre-feasibility meeting
Written notification and arrangement
for site visit. Meeting held at Mogol
Club and requirements for WULAR,
section 25(2) application and IWWMP
discussed as well as timeframe for
submission
20 May 2015 Regulatory authority meeting
Feedback on progress with IWWMP
and WULAR were reported as well as
the timelines for completing the
application process. In addition the
issuance of letters 1, 2 and 3 as per
Guidance Note was discussed. The
letters were required to be included
in the Bid Process
13 October 2015 Regulatory Authority Technical
Meeting: Polokwane
The draft IWWMP was presented to
the authorities covering section
21(a), (b), (c), (i), (f) and (g) water
uses. It was stated that the design
drawings are conceptual and will only
be finalised once the outcome of the
bid process is made known. The DWS
stated that the application will be on
hold until such time that they are
notified about the outcome of the Bid
Process.
18 October 2016 Regulatory Authority meeting
DWS notified that the applicant was
selected as the successful bidder and
that a Letter of submission of WULAR
is required by the Department of
Energy. The DWS responded that
application is still in pre-feasibility
phase and that the following actions
are required:
1. DW760 and supplementary 784
for the abstraction of water on a
borehole located on the farm
Transutu 257;
2. Supplementary form for Section
21 c and I water uses;
3. Signature on some of the DW763
application form;
4. Supplementary DW904 and 905
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Date Aspect Outcome
forms with respect to waste
related water uses;
5. Signature on DW 901 and 902
forms for Onbelyk farm;
6. DW901 and 902 for Transutu 257
farm;
7. Title deed for Transutu 257 farm;
8. Comments by the Mokolo Water
Users Association for the Transfer
of water from Exxaro to the
applicant;
9. Comments by the land claims
commissioner with respect to
both the donating and receiving
property;
10. R114,00 water use
administration fee;
11. Construction Method
Statements;
12. A0 size Layout Master plan
which shows the proposed
activities with respect to the
water courses;
13. A0 size Signed Civil design
drawings done by a registered
professional;
14. Stormwater Management
Plan;
15. Exxaro’s updated water
balance which include the supply
to Thabametsi Power Plant
In order to adhere to the requirements as stipulated by the Regulatory Authority these aspects
were addressed and incorporated in the updated Water Use License Application Report (2017) for
further assessment, evaluation and issuance of the Water Use License in favour of the applicant.
3.2 LICENSE ADMINISTRATION
All completed and signed DW forms are attached in Appendix 7 of the WULAR. The following DW
forms with their specified supplementary forms are submitted in support of the WULA (refer Table
3-2).
Table 3-2: Completed DW Forms
WU DW Form Water Use Description Volume/
Dimension
- 755 All Water Use Registration
- 758 N/A Company Registration
1 760 Section 21(a) Taking water 720,000 m3/a
2 762 Section 21(b) Storing water 30,000 m3
3 763 768
Section 21(c), (i) Pipeline water crossing A at
wetland unit 4 230 m
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WU DW Form Water Use Description Volume/
Dimension
4 763
768 Section 21(c), (i)
Pipeline water crossing B at
wetland unit 3 900 m
5 763 768
Section 21(c), (i) Pipeline water crossing C at
wetland unit 2 1900 m
6 763
768 Section 21(c), (i)
Power plant infrastructure
within a 500 m protective
buffer zone of wetland cluster
1000 m
7 767 Section 21(g) Ash Disposal PCD 56,000 m3
8 767 Section 21(g) Coal Stockpile PCD 2,650 m3
9 767 Section 21(g) Evaporation pond 16,200 m3
10 767 Section 21(g) Waste Water Collection Pond 1,200 m3
11 767 Section 21(g) Storm Water Pond 13,600 m3
12 767 Section 21(g) Strategic Coal Stockyard 750,000 ton
13 767 Section 21(g) Ash Dump 270 Ha
280 T/hr
14 766 Section 21(f) WWTW Bio-filter plant 600 m3/day
15 767 Section 21(g) Dust Suppression 120,450 m3
781 Supplementary Section 21(c) and (i) for
pipeline crossings
901 Property Appelvlakte 488
901 Property Gelykebult 450
901 Property Gelykebult 455
901 Property Graafwater 456_1
901 Property Graafwater 456_RE
901 Property Onbelyk 257
901 Property Vooruit 449
902 Property owner Exxaro
905 Supplementary Ash dump PCD
905 Supplementary Coal Stockpile PCD
905 Supplementary Evaporation pond
905 Supplementary Waste Water Collection Pond
905 Supplementary Storm Water Pond
905 Supplementary Strategic Coal Stockyard
905 Supplementary Ash dump
788 Water Use Sector Power Generation
3.3 INPUTS FROM OTHER DEPARTMENTAL DIRECTORATES
3.3.1 National Water Resource Planning
Several discussions were held with the Director: Option Analysis in an attempt to secure water
supply to the Thabametsi Power Plant. These discussions were attended by the TCTA that acts as
the Implementing Agent of the DWS. All requirements as specified had been considered as part of
the WULA.
3.3.2 Abstraction and Storage
Input from the Chief Engineer: Water Supply (Crocodile West and Marico) was obtained that has
recommended that the requirements of the Limpopo Regional Office must be followed. In terms of
this procedural statement the Regional Office has requested that the surrender of water must be
done in accordance with the requirements as contained in Section 25 of the National Water Act.
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3.3.3 Civil Design
The Directorate Civil Design oversees the evaluation of all water management facilities inclusive of
infrastructure, capacity of containment facilities, design specifications and storm water
management measures. A Civil Engineering Design Report must accompany the WULA detailing the
following:
Pipe River Crossings/Impeding Structures
Indicate in the engineering design report the following:
Nature of crossing, below on or above river bed;
If on or above river bed, analysis of effect of pipe on flow velocity and remedial effects on
possible erosion and ponding/flooding caused by the impeding pipe structure;
Construction method on perennial stream ensuring further damage to the watercourse is
minimised;
If the stream is diverted during construction, method used to divert the flow to minimise
the silt load on the stream;
For culverts/bridges, check storm event designed for and the freeboard allowed for;
For design events less than 1:100 year storm, what measures are taken to protect the
public and the risk of the structure being washed away
Storm water discharge into the watercourse/environment
What measures are taken to attenuate storm water;
Energy dissipation measures to minimise erosion at the discharge into the water course
environment
Clean and Dirty Water Dams/Stock Pile Facilities
Type of section 21(g) facilities;
Sizing of each facility with design calculations, 1:50 storm event and 0.8 m freeboard;
Safety risk of each impoundment (Dams more than 50,000 m3 and wall height more than 5
meters high);
Waste Classification Type (Norms and Standard, R 635 August 2013);
Barrier Layout Type (commensurate with Waste Classification Type)
o Design reports and drawings certified by a registered, professional civil engineer;
o Service life considerations quantified taking into account temperature effects on
containment barriers;
o Alternative elements of proven equivalent performance considered, such as the
replacement of:-
Granular filters or drains with geo-synthetic filters or drains;
Protective soil layers with geotextiles; or
Clay components with geo-membranes or geo-synthetic clay liners;
o All drainage layers that must contain drainage pipes of adequate size, spacing and
strength to ensure atmospheric pressure within the drainage application for the
service life of the facility;
o Alternative design layouts for slopes exceeding 1:3 (vertical: horizontal)
o Construction Quality Assurance (CQA);
o Geo-synthetic materials and compliance with relevant South African National
Standard specifications, or any prescribed management practice or standards which
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ensure equivalent performance and consideration of the compatibility of liner
material with the waste stream
3.3.4 Environment and Recreation
The Sub-directorate: Environment and Recreation oversees the assessment and evaluation of all
section 21(c) and (i) water uses. The Thabametsi Power Plant triggers four section 21(c) and (i)
water uses due to the locality of the site within the protective buffer zone of delineated depression
(pan) wetlands. It is required that the WULA needs to be supported by specialist reports
(Wetland/Biodiversity) as well as Work Method Statement, Rehabilitation Plan and Plant Species
Plan. The plant species plan is inclusive of an Alien Invasive Control Program. It is further required
that all aspects related to the water use be indicated on a Master Layout where the water use is
related to the impacted receiving receptors.
3.4 INPUTS FROM STAKEHOLDERS
Savannah Environmental (Pty) Ltd as the appointed lead consultant has conducted a
comprehensive Public Participation Process. All details regarding the public participation process
followed is contained in the Environmental Impact Assessment Report as well as main concerns
summarised in the Integrated Water and Waste Management Plan.
During the pre-feasibility meeting held during February 2015 the DWS stated that it considered the
process followed satisfactory and that no additional consultation as depicted in Section 41(4) of the
National Water Act, 1998 (Act 36 of 1998) needs to be conducted. However, the applicant has
decided to voluntarily conduct public participation in terms of Section 41(4) of the NWA. A public
meeting was held on 31 October 2016 in Lephalale. In addition selected stakeholder meetings were
held with key role-players such as Exxaro, TCTA and Eskom to address concerns related to the
availability of water.
It is also noted that the Centre for Environmental Rights approached Menco during September
2014 to be registered on the stakeholders list. A list of names from the CER was made available to
whom feedback must be provided regarding the progress of the WULA. The CER was notified about
the status of the application and once the final IWWMP is updated it will be placed on the website
of Savannah Environmental for notification and further comment. The following stakeholders will
be notified in this regard:
Centre for Environmental Rights:
2. Robyn Hugo: [email protected]
3. Sylvia Kamanja: [email protected]
4. Ruth Kruger: [email protected]
5. Nicole Loser: [email protected]
6. Teboho Sebogodi: [email protected]
Earthlife Africa, Johannesburg Office
1. Dominique Doyle: [email protected]
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2. Tristen Taylor: [email protected];
3. Makoma Lekalakala: [email protected]
The CER has objected to the WULA process lodged by the applicant and has requested that a
dedicated Public Participation Process be conducted for the WULA process. All the concerns and
comments as raised by the IAP’s are contained in the Public Participation Report included in this
application as APPENDIX 21.
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4 SECTION 27 MOTIVATION
4.1 EXISTING LAWFUL WATER USES
There’s currently no ELU for the property or activity. However, an Existing Lawful Use to be utilised
as a water source by the applicant is authorised to Exxaro. The DWS agreed that the WUL for
Exxaro would need to be amended to reflect water supply to the applicant and that the water
surrendered would need to be reflected as a Section 21(a) water use in a separate license for the
applicant. In terms of Section 25(1) of the NWA the temporary transfer of water from Exxaro to the
applicant is not feasible as this only applies to agricultural water allocation to be used for other
activities. Therefore, in terms of Section 25(2) of the NWA a permanent transfer of water needs to
be applied for whereby Exxaro surrenders part of their water allocation to favour the application by
the applicant. The section 25(2) application was submitted to the DWS during June 2015.
Subsequently the WUL of Exxaro have been replaced by a new amended water use license. In
order to ensure that the Section 25(2) application by the applicant is aligned with the amended
license, an updated application is submitted with the IWULAR for processing. The application is
contained in APPENDIX 4 of this report.
4.2 THE NEED TO REDRESS PAST RACIAL AND GENDER DISCRIMINATION
Thabametsi Power Company (Pty) Ltd is majority owned by South African investors comprising
affiliates of the Public Investment Corporation, Royal Bafokeng Holdings, KDI Holdings and
Tirisano. The Project has a total South African entity participation of 51% and its total ownership
by Black People is 30%.
Furthermore, Thabametsi Power Company (Pty) Ltd has made a number of economic development
commitments in terms of the Coal Baseload IPP Procurement Programme. These commitments
effectively ensure that there will be more jobs created than in any other single IPP project in South
Africa. The Project will also create a foundation for new, private baseload coal industrialization
initiatives in South Africa. Such skills development will enable South African citizens to service
South Africa and the region, as a result of these extensive local content commitments. The
manufacture of components and other supply chain items will have a positive economic impact on
the country. In support of the stimulus offered by this Project to local industry, approximately R820
million will be spent on developing new and growing the capacity of existing, suppliers to the local
coal and power industry. The applicant's detailed economic development plan seeks to address the
key needs identified in the area and the Limpopo Province in general.
The plan identifies the following key objectives and focus areas:
establishment of a local industry which is capable of constructing and operating a baseload
coal plant for the life thereof;
creation of 14 348 direct and indirect jobs over the life of the Project, across both
construction and operating periods, providing decent work in an area of high
unemployment;
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the focus of supplier development spend to create and support a number of Black
Industrialists in the supply chain;
a focus on a combination of broad-based, and women, as well as entrepreneurial Black
ownership in the Project (30%); and
the creation of an operating company, that will have the capacity to run this Project for 30
years.
4.3 EFFICIENT AND BENEFICIAL USE OF WATER IN THE PUBLIC INTEREST
5.3.1 Taking of water
Potable water will be obtained from the allocation made to Exxaro, as will water required for power
generation activities. This water will be treated by the applicant to the applicable standards for
utilisation within the Thabametsi Power Plant. The taking of water from the allocated MCWAP phase
1 has triggered several concerns related to sustainable water supply to the region.
5.3.2 Altering the natural characteristics of the wetland areas
Even though the applicant is planning to develop 500 hectares, none of the footprint of the
Thabametsi Power Plant will impact directly on the wetlands in the area. Indirect impacts are
foreseen due to invasion of the 500 m protective buffer zone.
5.3.3 Waste disposal
The seven section 21(g) applications for the disposal of waste in a manner that may be detrimental
to the environment are for the Pollution Control Dams, coal stock yard as well as dust suppression.
The PCD’s are lined and designed in accordance with GN 704 Regulations.
Furthermore, an application is made for a section 21(f) water use. This is for the
disposal/discharging of treated effluent from the Bio-filter System. The system will be designed to
adhere to GN 665 Limits. The water containing waste will be recycled in accordance with the ZLED
policy for the Thabametsi Power Plant. The WWTW effluent will be used in the hydration of ash for
disposal to the ash dump.
4.4 THE SOCIO-ECONOMIC IMPACT OF THE WATER USE OR USES IF AUTHORISED
The power generation activity will have a positive effect on the socio-economic context of the
region. The proposed Thabametsi Power Plant will create new employment opportunities, thus
positively impacting indirectly on dependents and the economic environment. Should the
application be successful, it will have a positive effect.
The main positive impacts are:
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Employment to a number of people during the construction and operational phases. The
numbers of jobs created are significant to the local and regional economy.
A large capital investment and foreign direct investment in the region.
Significant amounts paid to the government in the form of local, regional and national
taxes and levies.
Creation and support of service-sector jobs, the annual procurement of large quantities of
consumables and the outsourcing of service provision to local service providers.
The power generated will go towards Eskom’s power generation needs and therefore the
electricity output needed in South Africa
The positive impacts described above can be even further enhanced in the context of the
communities surrounding the project site. Further measures to enhance socio-economic
opportunities should focus on the promotion and development of small and medium enterprises in
the local communities, especially due to the short timeframe expected. Larger contracts should be
broken down into smaller more accessible contracts and local people should be employed where
possible.
The main potential negative impacts include the population influx into the area around a project
site and associated squatting is often associated with the chance of job opportunities. Well defined
employment/recruitment and housing policies will help negate the possibility of squatter
settlements and the associated problems. In addition, co-operation with the local police will help to
ensure that private property rights are protected on the project site and surrounding farmland.
4.5 THE SOCIO-ECONOMIC IMPACT OF THE FAILURE TO AUTHORISE THE WATER USE
If this Project does not proceed, the applicant will be prevented developing the Project as selected
by the Department of Energy under the Coal Caseload IPP Procurement Programme that was
implemented to meet the country's electricity demands in terms of the Government's Integrated
Resource Plan . The presence of the power generation activity, the employment of local persons
and the utilisation of local services will result in an increased income for local communities and
business and an increased tax base for traditional authorities and municipalities. These
opportunities will be lost should the project not proceed, and will have consequences on local,
regional and national scale.
Without the new proposed coal-fired power station in Lephalale, and alternative means of
generating an additional 630 MW capacity would be required to be sought from another power
generation source or a similar source in another area. However, as more than 50% of the
remaining coal reserves in the country are located in the Waterberg area, and optimal grid
connection opportunities are available, not developing the Project on the proposed site would see
such an opportunity being lost. At a local level, the level of unemployment will remain the same
and there will not be any transfer of skills to people in terms of the construction and operation of
the Thabametsi Power Plant.
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Without the implementation of this Project, this will not be achieved, and the greater power supply
in the country will be compromised in the near future. This has potentially significant negative
impacts on economic growth and social well-being. In addition, limitations on electricity supply may
impact quality coal for domestic purposes, collection of wood from natural areas, etc.
4.6 THE CATCHMENT MANAGEMENT STRATEGY APPLICABLE TO THE RESOURCE
According to DWAF (2004b) (also as specified in the National Water Act, Act 36 of 1998) the
delegation of water resource management from central government to catchment level will be
achieved by establishing Catchment Management Agencies (CMAs) at WMA level. Each CMA has
the responsibility to develop a Catchment Management Strategy (CMS) for the protection, use,
development, conservation, management and control of water resources within its WMA.
No Catchment Management Agency has been established yet for the Limpopo WMA and thus no
Catchment Management Strategy. However, establishment of such an agency for the Limpopo
Province is currently underway. Several other strategic documents have been compiled for the area
and include:
Department of Water Affairs and Forestry (DWAF), South Africa. 2004. National Water
Resources Strategy, 1st Ed. Pretoria
Department of Water Affairs (DWA), South Africa. 2013. National Water Resources
Strategy, 2nd Ed. Pretoria.
Department of Water Affairs (DWA), South Africa. 2010. Development of a Reconciliation
Strategy for all towns in the Northern Region, Waterberg District Municipality, Lephalale
Local Municipality. Report compiled by SRK Consulting. Pretoria.
4.7 THE LIKELY EFFECT OF THE WATER USE ON WATER USERS
Several surface water users dependent on water supply from the Mokolo Dam Water Scheme had
been identified within close proximity to the project site.
It is important to note that the applicant will receive its water supply from Exxaro. This volume of
water has already been allocated to Exxaro and will be surrendered by Exxaro to the applicant. No
additional water allocation is thus required for the proposed development and it is thus not
anticipated that any other surface water users will be directly affected by the authorization of the
Water Use License. It is however noted that several stakeholders (Eskom Matimba Power Station,
Mokolo Water Users Association, and Earthlife Africa) expressed their concerns regarding water
availability as Exxaro previously did not utilse the full allocation. The increased water demand from
the existing allocation will contribute towards increased stress on the available water resources.
During the operational phase, no groundwater abstraction is expected. Therefore, no groundwater
drawdown is expected from the Thabametsi Power Plant and the current status in this regard, will
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be maintained. However, a single privately owned borehole (LEP10) is likely to be destroyed during
the establishment of the ash dump, which can be considered to be an impact on groundwater
availability.
Mitigation measures as per this report will be implemented to limit the impact on groundwater and
surface water quantity and quality of the area.
4.8 THE CLASS AND THE RESOURCE QUALITY OBJECTIVES OF THE WATER RESOURCE
The project site is located on multiple catchments as delineated by the DWS. The site specific
indicators are given as:
Management area Crocodile Marico-Management Area
Drainage area: A42J/A42G
River name: Mokolo River
Management Unit: Mokolo Water Management Area
The Minister of Water and Sanitation is required to establish a classification system, and to
determine the class and resource quality objectives for all or part of the resources considered to be
significant. The quaternary drainage area A42J and A42G was given as a Class C (Moderately
Modified). The Resource Quality Objectives for the catchment is given in Table 4-1.
Table 4-1: Resource Quality Objectives for the receiving water resource
Variable RQO and Eco Specification for PES
MgSO4 (mg/l) 95th percentile must be ≤ 16 mg/l
Na2SO4 (mg/l) 95th percentile must be ≤ 20 mg/l
MgCl2 (mg/l) 95th percentile must be ≤ 15 mg/l
CaCl2 (mg/l) 95th percentile must be ≤ 21 mg/l
NaCl (mg/l) 95th percentile must be ≤ 45 mg/l
CaSO4 (mg/l) 95th percentile must be ≤ 351 mg/l
EC (mS/m) 95th percentile must be ≤ 30 mS/m
pH 5th and 95th percentiles must range from 6.5 to 8.0
DO (mg/l) 5th percentile of the data must be ≥ 7 mg/l
TIN 50th percentile must be ≤ 0.25 mg/l
PO4-P 50th percentile must be ≤0.015 mg/l
Chl-a 50th percentile must be ≤ 10 µg/l
4.9 INVESTMENTS ALREADY MADE BY THE WATER USER
The applicant has appointed various specialists to conduct environmental investigations in support
of the Environmental Impact Assessment and Water Use License Application.
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An Environmental Authorisation has been obtained from the Department of Environmental
Affairs (EA). The EA has been suspended pending the consideration and decision by the
Minister of, inter alia, the Thabametsi Power Plant's climate change impacts.
A Waste License has been obtained from the Department of Environmental Affairs;
EMP, EIA and associated specialist studies and impact assessments have been conducted;
Water samples have been taken to determine a reference condition which must be
maintained during operation of the Thabametsi Power Plant;
Civil Engineers have been contracted to design Pollution Control Facilities, Stormwater
Management, Layout plans as well as Water Balances;
The Water Use License Application is in process and will be submitted to the DWS for
evaluation and issuance.
4.10 THE DURATION OF WATER USE
The water uses associated for the Thabametsi Power Plant will be required for a time period of forty
(40) years. The Thabametsi Power Plant's capacity is 630 MW. The activity life description is
detailed in Table 4-2.
Table 4-2: Details of the life activity of the Thabametsi Power Plant Project
Component Description/Dimensions 3Electricity generating capacity 630 MW
Technology to be implemented in the power
generation process
Coal fired power station with Circulating
Fluidised Bed technology, dry cooled and zero
effluent discharge plant
Extend of the development
Thabametsi Power Plant consisting of
production units, boilers, furnaces, turbines,
generators, condensers, office, maintenance
and ash dam area – 50 hectare footprint;
Ash dam on footprint area of 500 hectares
with a life span of 40 years;
Coal Stock Yard of 100 hectares providing
coal for a 30 day period;
Raw water dam with storage capacity of
30,000 m3 on footprint of 2 hectare
4Ash Dam and associated infrastructure
Area of 500 hectares in extent;
Height up to 50 meters;
Storage volume of 200 million m3 of ash;
Overland ash conveyors at rate of 280
ton/hour;
Proposed to operate three PCD’s linked to
the rate of development of the ash dam;
Capacity of three PCD’s given as 33,000m3,
56,000 m3 and 75,000 m3 respectively;
3 Note that the applicant only intends to develop only one 630MW unit
4 Note that during the initial phase of the project only the PCD with storage capacity of 56,000m
3 will be build.
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Component Description/Dimensions
Stormwater management and evaporation
pond for storage of 16,200 m3 of stormwater
run-off
Expected life span of power station set at 40
years
Supporting services required for the duration of
the power station
Raw water supply at rate of 720,000
m3/annum for Phase 1;
Refuse material disposal to be removed by a
contractor for disposal at a licensed landfill
site;
Sanitation entails the construction of a
Waste Water Treatment Works with daily
throughput capacity of 600m3;
Potable water treatment plant with daily
treatment capacity of 4800m3
Pipeline for water supply
18 km in length with tie-in booster pump
station from tie-in point at Matimba Power
Station to Raw Water Storage Reservoir on
site
4.11 THE STRATEGIC IMPORTANCE OF THE WATER USE TO BE AUTHORISED
4.11.1 Site specific
The electricity demand in South Africa is placing increasing pressure on existing power generation
capacity. The National Integrated Resource Plan (IRP) developed by the Department of Energy has
identified the need for power generation from coal as part of the technology mix for power
generation in the country in the next 20 years. This power station is intended to be an IPP project
to alleviate pressure on Eskom’s base load power supply in the short to medium term through
independent power generation and the applicant was accordingly selected as a preferred bidder
under the Coal Baseload IPP Procurement Programme.
4.12 ENFORCEMENT AND MANAGEMENT
4.12.1 Management Plans
Enforcement and Management for the water resource and therefore the water uses that is required
for the Thabametsi Power Plant will be well managed by means of the IWWMP (to be updated
annually) and a complete EMP that had been drafted as part of the EIA process.
4.12.2 Monitoring
Water Management and Monitoring will be thorough and conducted as specified within the IWWMP
that is submitted along with this application. The proposed monitoring would suffice to assist with
the classification of the resources. There should however be a few additions such as:
Bio-Monitoring upstream and downstream of all drainage, riparian and wetland crossings
Wetland monitoring of wetlands to be conducted annually
Surface water monitoring at all waste streams including storm water once the Thabametsi
Power Plant becomes operational
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Groundwater monitoring (quality and depth) will be important to monitor the behaviour of
the groundwater resource
The applicant will be based on a SHEQ system that will seek continuous improvement and therefore
data and document control will be strictly implemented for purposes of management and early
detection in terms of water uses and possible anticipated impacts that was identified and discussed
within the Integrated Waste Water Management Plan (IWWMP) of this WUL application. Please
refer to the included IWWMP for more details on this matter.
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5 CONCLUSIONS AND RECOMMENDATIONS
From the attached appendices, and information contained in this application, the following
conclusion and recommendations are made.
Even though there are multiple impacts associated with power generation, the Thabametsi Power
Plant is situated within a developed area with several mining, power generation and industrial
developments. The following waste management hierarchy will be applied: reduce at source, re-
use, and re-cycle. Any waste generated will be disposed in an environmentally responsible manner.
From the geo-hydro study there are impacts identified for this operation. It is stated that there will
be moderate to high impacts stemming from the ash dump, coal stockpile and PCD areas. The
Thabametsi Power Plant has already obtained a waste license and adherence to the requirements
of the license will minimize the impacts on the aquifer in the area. Therefore, the impact of waste
is considered to be low with mitigation.
The depression wetland within the 500 m buffer zone of the study area is considered a low
significance in terms of national importance. The wetlands in the wider study area are considered
most sensitive with unique species composition and aquatic ecosystem functioning.
The lack of a sustainable raw water supply to the area is considered a high risk. The development
of Phase 2 of the MCWAP scheme will alleviate the future demand for water in the region. The
applicant has secured a raw water allocation (720,000 m3/a) under Phase 1 of MCWAP scheme
from Exxaro which is considered sufficient to allow for the continuation of the 630MW Plant.
It is therefore recommended that Thabametsi Power Company (Pty) Ltd should be issued a Water
Use License for the maximum period required for the Thabametsi Power Plant.
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6 REFERENCES
Department of Water Affairs and Forestry: Preliminary Determination of Reserve (RDM ref:
26/8/3/3/297)
Department of Water Affairs: National Water Resource Strategy, Second Edition (June 2013) Web:
http://www.dwa.gov.za/nwrs2013
Department of Water Affairs: National Water Resource Strategy, Second Edition (2013), Annexure
A: Perspectives per Water Management Area
Government Gazette Notice: No 26187 (339) published 26 March 2004: Revision of General
Authorisations in terms of Section 39 of the National Water Act, 1998 (Act no. 36 of 1998)
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Appendix
Appendix 1:
Company Registration and ID
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Appendix
APPENDIX 2:
Property Title Deeds
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Appendix
APPENDIX 3:
Contractual Agreement
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Appendix
APPENDIX 4:
Section 25(2) Application
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Appendix
APPENDIX 5:
Master Layout Plan
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Appendix
APPENDIX 6:
BBEE Certification
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Appendix
APPENDIX 7:
DW FORMS
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Appendix
APPENDIX 8:
Proof of Payment
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Appendix
APPENDIX 9:
Record of Decision
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Appendix
APPENDIX 10:
Integrated Water and Wastewater Management
Plan
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Appendix
APPENDIX 11:
EIA and EMP
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Appendix
APPENDIX 12:
Wetland Delineation Study
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Appendix
APPENDIX 13:
Biodiversity Assessment
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Appendix
APPENDIX 14:
Surface Water
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Appendix
APPENDIX 15:
Geohydrological Assessment
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Appendix
APPENDIX 16:
Work Method Statement and Rehabilitation
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Appendix
APPENDIX 17:
Stormwater Management Plan
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Appendix
APPENDIX 18:
Civil Engineering Design Report
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Appendix
APPENDIX 19:
Water Balance
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Appendix
APPENDIX 20:
Hydrology and Water Supply
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Appendix
APPENDIX 21:
Public Participation