report on final environmental management … - pongola/impact ph… · · 2014-02-1013 training...

Zitholele ConsultingReg. No. 2000/000392/07

PO Box 6002 Halfway House 1685South AfricaThandanani Park, Matuka CloseHalfway Gardens, MidrandTel + (27) 11 207 2060Fax + (27) 86 674 6121E-mail : [email protected]

Directors : S Pillay (Managing Director); N Rajasakran (Director); Dr RGM Heath (Director)

REPORT ON

Final Environmental ManagementProgramme (EMPr) for the proposed New

Golela Substation and two associated132kV turn-in lines from the existing Mkuze-Pongola 132kV Power line, KwaZulu Natal.

Report No : 12722 DEMPr v1

Submitted to:

Department of Environmental AffairsPrivate Bag X447

PRETORIA0001

DISTRIBUTION:

2 Copies - Department of Environmental Affairs

1 Copy - Zitholele Consulting (Pty) Ltd – Library

04 February 2014 12722

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ZITHOLELE CONSULTING

TABLE OF CONTENTS

SECTION PAGE

1 INTRODUCTION............................................................................................. 11.1 Background Information ........................................................................... 11.2 Project Details .......................................................................................... 1

2 ENVIRONMENTAL FEATURES OF STUDY AREA:..................................... 23 LEGAL FRAMEWORK.................................................................................... 54 ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) ....................... 55 CONTEXT AND OBJECTIVES OF THIS REPORT ...................................... 7

5.1 Objectives of the Environmental Management Programme..................... 75.2 Structure of this Document ....................................................................... 8

6 PROJECT LOCATION .................................................................................... 97 DESCRIPTION OF PROJECT COMPONENTS.......................................... 10

7.1 Construction Process for Substation and associated Power Lines........107.2 Operational Activities..............................................................................127.3 Decommissioning Activities ....................................................................12

8 SCOPE OF THE ENVIRONMENTAL MANAGEMENT PROGRAMME ..... 138.1 Integration of the Environmental Management Programme into the

Contract ..................................................................................................138.2 Specification structure and Application ..................................................138.3 Method statements .................................................................................13

9 SITE DOCUMENTATION AND RECORD KEEPING.................................. 1610 ENVIRONMENTAL AWARENESS TRAINING............................................ 1711 PROVISIONS FOR ADDRESSING NON-CONFORMANCE...................... 19

11.1 Environmental considerations in adjudication of tender.........................1912 ENVIRONMENTAL MANAGEMENT MEASURES FOR THE

PROJECT ...................................................................................................... 2012.1 Planning Phase ......................................................................................2012.2 Construction Phase ................................................................................2312.3 Operational Phase..................................................................................2812.4 Organizational Structure.........................................................................2812.5 Environmental Roles and Responsibilities .............................................29

13 TRAINING...................................................................................................... 3414 PROJECT COMPLIANCE REPORTING ..................................................... 34

14.1 Reporting Procedures and Documentation ............................................3414.2 Environmental Contact Person...............................................................3514.3 Emergency Numbers..............................................................................35

15 CONCLUSION............................................................................................... 35

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LIST OF FIGURES

Figure 1: Locality Map of the Study Area ............................................................................. 3

Figure 2: Land Cover Map of the study area........................................................................ 4

Figure 3 : Organisational structure for Environmental Reporting.......................................29

LIST OF TABLES

Table 1: Project Director Details........................................................................................... 6

Table 2 Impacts, Management/ Mitigation Measures during the Planning Phase .............21

Table 3: Impacts, Management/ Mitigation Measures during Construction Phase............23

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GLOSSARY OF TERMINOLOGY

Contractor means the main contractor as engaged by Eskom for the

construction of the subject infrastructure, including all Sub-

contractors and service provides appointed by the main

contractor of his own volition for the execution of parts of the

Works. “Contractor” also includes any other contractor

engaged by Eskom directly in connection with any part of the

construction, which is not a nominated sub-contractor to the

main contractor.

Environment1 (i) the land, water and atmosphere of the earth;

(ii) micro organisms, plant and animal life;

(iii) any part or combination of (i) and (ii) and the

interrelationships among and between them; and

(iv) the physical, chemical, aesthetic and cultural properties

and conditions of the foregoing that influence human health

and wellbeing.

EnvironmentalControl Officer

means a person who is responsible for the monitoring of the

implementation of the requirements of an EMPr on behalf of

the applicant.

EnvironmentalOfficer

means a person who is responsible for the implementation of

the requirements of an EMPr on behalf of the contractor.

EnvironmentalImpact Assessment(EIA)

means a study of the environmental consequences of a

proposed course of action.

Environmentalimpact

means an environmental change caused by some human act.

1 As defined in terms of the National Environmental Management Act No. 107 of 1998 (NEMA).

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Method Statement means setting out in detail how the management actions

contained in an EMPr will be implemented, in order to ensure

that the environmental objectives are achieved.

Public ParticipationProcess

means a process of involving the public in order to identify

needs, address concerns, in order to contribute to more

informed decision making relating to a proposed project,

programme or development.

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LIST OF ABBREVIATIONS

BA.........................................................................................................Basic Assessment

CH4 ..................................................................................................................... Methane

DME.......................................................................... Department of Minerals and Energy

DWA .................................................................................... Department of Water Affairs

EA.........................................................................................Environmental Authorisation

EIA .............................................................................Environmental Impact Assessment

EMPr ................................................................ Environmental Management Programme

ECO…………………….........................................................Environmental Control Officer

EO......................................................................................................Environmental Officer

DEA........... ..............................................................Department of Environmental Affairs

GNR..................................................................................Government Notice Regulation

I&AP .................................................................................. Interested and Affected Party

NEMA ................................ National Environmental Management Act (No. 107 of 1998)

NEM: AQA ...........National Environmental Management Air Quality Act (No 39 of 2004)

NEM:WA....................National Environmental Management Waste Act (No. 59 of 2008)

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1 INTRODUCTION

1.1 Background Information

Eskom Distribution KwaZulu-Natal Operating Unit (KZN OU) has been upgrading theelectricity infrastructure on the Makhathini Flats in northern KZN over the last 2 years.

A 132kV power line and substation is required to tee-off the existing Mkuze-Pongola 132kVpower line (also called Mkuze-Pongola line 1). This substation will need to be located in closeproximity to the intersection of the N2 with the road leading to the Golela border post withSwaziland. The substation will be required to accommodate the electrical load for theproposed developments within the vicinity of the border post.

The construction and operation of the substation and associated 132kV power lines is subjectto a Basic Assessment (BA) in terms of the National Environmental Management Act (Act 107of 1998), as amended. In fulfilment of this requirement, Eskom has appointed ZitholeleConsulting to undertake the necessary BA and compilation of associated documentation. ThisEMPr is a component of the independent environmental authorisation process carried out byZitholele Consulting for the purposes of authorisation of the substation and associated 132kVturn-in power lines

The BA process and supporting documentation (including this EMPr) is being carried outsimultaneously with the Pongola Candover 132kV second power line authorisation processand some of the tasks are carried out together.

1.2 Project Details

The proposed substation and associated power lines are a component of the electrificationinitiative for the greater Makhathini region, including the following key activities for whichauthorisation is being applied and for which this EMPr applies:

Location of a new 132/22kV substation approximately 1km north-east of the intersectionof the N2 with the Golela border post road; and

Location of two 500m wide, 15km long corridors for the construction of two 132 kV tee-offpower lines from the Mkuze-Pongola 132kV power line to provide supply to and from theproposed Golela Substation.

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The proposed Golela 132/22kV stepdown substation will have a footprint of approximately100m x 100m. The infrastructure within this footprint will include:

A perimeter fence to secure the substation for the safety of people and animals;

Terracing and foundations as required in line with the site and substation foundationrequirements;

Circuit breakers to facilitate disconnection under no-load conditions for safety, isolationand maintenance purposes;

Eight feeder bays for potential 5 x 22kV woodpole power lines to exit the substation.

The 132kV turn-in power line will consist of three conductors covered by a thinner shield wirecapable of distributing 132kV, connected by a series of pylons.

2 ENVIRONMENTAL FEATURES OF STUDY AREA:

The study area in which the Golela 132/22kV stepdown substation and 132kV turn-in powerlines will be located is approximately 20km east of Pongola. The substation will be situated inclose proximity to N2 intersection with the Golela border post road (R29). This proposedinfrastructure development falls within the uPhongolo Local Municipality and the ZululandDistrict Municipality. The predominant land uses in this area includes conservation withinNature Reserves, agriculture dominated by sugarcane, bananas and fruit orchards.

The topography of the region is undulating with extensive hillocks, rolling hills and high cliffs.The vegetation at the site is dominated by indigenous vegetation outside of the agriculturalland use. There are no significant identified cultural heritage sites associated with the Golelasubstation or 132kV turn-in lines.

There are several red data birds recorded for the area, predominantly vultures, eagles andstorks. These birds will be vulnerable to transmission lines rather than to the substationconstruction. However, the design of the taller infrastructure for the substation should includedevices to deter bird interaction with the electrical lines.

The site is associated with the Jozini Dam and is characterised by a variety of clay soils. Thesoils include Shortlands, Bonjeim and Wilowbrook melanic soils, as well as Rensburg andArcadia vertic soils. The Golela and Mkuze soil families are subgroups of the Bonheim soilform. The Pongola River is located approximately 4km to the south and to the west of theGolela substation site. There are various small tributaries in close association with thesubstation site.

Figure 1 provides a locality map of the study area and Figure 2 provides the land cover map.The Golela substation is demarcated by the yellow dot towards the north of the maps.

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Figure 1: Locality Map of the Study Area

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Figure 2: Land Cover Map of the study area

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3 LEGAL FRAMEWORK

An EMPr is guided by sound environmental management practices and is based on nationaland international best practices, and relevant legislation, policies and guidelines. Allstakeholders should note that obligations imposed by the EMPr are legally binding in terms ofenvironmental statutory legislation and in terms of the additional conditions to the generalconditions of contract that pertain to this project. In the event that any rights and obligationscontained in this document contradict those specified in the standard or project specificationsthen the latter shall prevail.

All legislation applicable to the development must be strictly enforced, and may including thefollowing:

The Constitution of the Republic of South Africa Act 108 of 1996, (Chapter 2: Bill of Rights,Section 24: Environmental right, Section 25: Rights in property);

National Environmental Management Act, 107 of 1998, as amended;

Environment Conservation Act, 73 of 1989;

National Environmental Management: Protected Areas Act, 57 of 2003;

National Environmental Management: Biodiversity Act, 10 of 2004;

National Forests Act, 43 of 1983;

The National Water Act, 36 of 1998;

Hazardous Substances Act, 15 of 1973;

National Heritage Resources Act, 25 of 1999;

Conservation of Agricultural Resources Act, 43 of 1983;

Occupational Health and Safety Act, 85 of 1993;

National Veld and Forest Fire Act, 101 of 1998;

Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 36 of 1947;

National Environmental Management: Waste Management Act, 59 of 2008;

Mineral and Petroleum Resources Development Act, 28 of 2002;

Health Act, 63 of 1977.

4 ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

In terms of the National Environmental Management Act ([NEMA] No 107 of 1998) andEnvironmental Impact Assessment (EIA) Regulations (Government Notice Regulation [GNR]543 to 546, June 2010) the proponent must appoint an Environmental Assessment Practitioner(EAP) to undertake an EIA/BA for listed activities regulated in terms of the aforementioned

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Act. In this regard, Eskom appointed Zitholele Consulting (Pty) Ltd. (Zitholele) to undertakethe BA for the proposed project, in accordance with the aforementioned regulations. As asupporting document to the BA, this EMPr strives to provide environmental managementrecommendations for the construction and operation of the Golela substation and associatedpower lines.

Zitholele is an empowerment company formed to provide specialist consulting servicesprimarily to the public sector in the fields of Water Engineering, Integrated Water ResourceManagement, Environmental and Waste Services, Communication (public participation andawareness creation) and Livelihoods and Economic Development. Zitholele Consulting hasno vested interest in the proposed project and hereby declares its independence as requiredby the EIA Regulations.

The details of the key individuals representing Zitholele, and acting as the EAP on this projectare given below.

Table 1: Project Director Details

Name: Warren Kok

Company Represented: Zitholele Consulting (Pty) Ltd.

Address: P O Box 6002, Halfway House, 1685

Telephone: 071 250 5371

Fax: 086 674 6121

E-mail: [email protected]

Warren Kok will be the designated Project Director on behalf of Zitholele. Warren will ensureregulatory compliance, quality assurance and overseeing the Technical Environmental Team.Warren holds a B.Hons degree in Geography and Environmental Management from RandAfrikaans University (2000) and a Higher Certificate in Project Management from Damelin. Heis a certified Environmental Assessment Practitioner (EAP) who is registered with EAPASA.Warren has in excess of 11 years’ experience in environmental consulting in South Africa. Hisexperience spans both the public and private sector. Warren has successfully undertakencountless integrated EIA processes that require integration of the MPRDA, NEM:WA, WULAand NEMA regulatory processes. Many of these projects are considered landmark projects inSouth Africa’s environmental mining sector and included several hazardous waste facilities.He is ideally skilled and experienced to manage this project to its conclusion.

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5 CONTEXT AND OBJECTIVES OF THIS REPORT

This Final EMPr has been drafted according to the findings of the impact assessment, and isincluded as an appendix to the BA Report (BAR) and submitted to the authorities for approvalalong with EA evaluation process. The Final EMPr is published as a standalone document forease of use.

5.1 Objectives of the Environmental Management Programme

Environmental management does not end with obtaining the required EA. Rather there is aneed to ensure that the remedial requirements identified during the environmental process areeffectively realised during project implementation, and this is where EMPrs have a key role toplay.

An EMPr, in the context of the EIA Regulations (2010), is a tool that takes a project from ahigh level consideration of issues down to detailed workable action plan that can beimplemented in a cohesive and controlled manner. An EMPr is defined as “an environmentalmanagement tool used to ensure that undue or reasonably avoidable adverse impacts of theconstruction phase of a project are prevented and that the positive benefits of the projects areenhanced”. Impacts range from those incurred during start up (site clearing, erection of theconstruction camp), and to those incurred during operation. Specifically, the objectives of thisEMPr can be articulated as follows:

To give effect to the construction related requirements;

To give effect to the environmental commitments to the various role players;

To ensure that these requirements / commitments are expressed in a manner that isaccessible to all parties and is binding upon those responsible for project implementation;

To ensure that sufficient resources are allocated to the project budget in order to give effectto the environmental requirements / commitments, and to ensure that the scale of EMPr-related interventions is consistent with the significance of identified impacts;

To provide a coherent and pragmatic framework for the implementation of therequirements, ranging from the roles and responsibilities of the key project participants tothe auditing and reporting of compliance;

To facilitate appropriate and proactive response to unforeseen events or changes inproject implementation that were not considered in the BA process; and

To ensure that the construction phase of the project does not result in undue or reasonablyavoidable adverse environmental impacts, and that any potential environmental benefitsare enhanced.

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5.2 Structure of this Document

This document has been divided into four parts, each addressing a different aspect of theEnvironmental Management Programme (EMPr).

Part A provides a brief introduction, details of the person who prepared the EMPr and his/ her expertise; and overview of the purpose and structure of this document;

Part B sets the context for the EMPr by providing an overview of the project, summarisingthe objectives of the EMPr, highlighting the scope of the EMPr and briefly emphasisingEskom’s environmental commitments;

Part C provides an overview of the structure and application of the environmentalmanagement plan and highlights the environmental considerations that should inform theconstruction and operation phases; and

Part D provides guidance in terms of the on-site implementation of the EMPr, highlightingthe organisation structure and various roles and responsibilities, emphasising theimportance of awareness training, summarising the requisite approach to monitoring andauditing and addressing the requirement for review and amendment of the environmentalspecifications.

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6 PROJECT LOCATION

The Golela Substation has two location alternatives. The preferred alternative is located 400mto the east of the N2 where it intersects with the Golela Border Post Road. This area isrelatively flat and the vegetation has experienced some degradation. The Alternative 2 locationis about 1.2km east of the N2 intersection with the Golela Border Post Road. This area iswithin a private game reserve and the site is well vegetated with indigenous species.

The two alternative sites for the Golela substation are located at the following co-ordinates:

Preferred Alternative 1 Alternative 2

Latitude (DDMMSS) 27°21’53.10’’ S 27°22’20.09’’ S

Longitude (DDMMSS) 31°49’25.64’’ E 31°49’12.83" E

The 132kV power lines have the following alternative corridors:

Alternative 1 (preferred) Western Corridor

South East

Starting point of the activity 27°25’13.64’’S 31° 48’38.04" E

Middle/Additional point of the activity 27°23’46.58" S 31° 49’02.36" E

End point of the activity 27° 22’09.57" S 31°49’18.58" E

Alternative 2 Eastern Corridor

South East

Starting point of the activity 27°24’47.33" S 31°50’19.98" E

Middle/Additional point of the activity 27°23’16.08" S 31°50’02.20" E

End point of the activity 27°22’09.57" S 31°49’02.36" E

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7 DESCRIPTION OF PROJECT COMPONENTS

Substation

The substation will have a footprint of about 100m x 100m. The substation will be fenced andwill include 8 feeder bays for the potential 5 x 22kV exit power lines from the substation.

Power Line Servitude

Each Turn-In 132 kV Power Line requires a servitude of 36 m wide. The proposed power linesfor this project will be built in parallel alignment.

Access Roads

Existing farm roads will be used to access the servitude for construction purposes. Amaintenance road of 5 m wide within the servitude will be retained post construction formaintenance of the power line during the operational phase.

Fencing, Gates and Access Control

The power line servitude will be fenced with a diamond mesh fence approximately 1,8 m heightto prevent unauthorised access for reasons of safety and security.

7.1 Construction Process for Substation and associated Power Lines

The power lines are constructed in the following steps:

1. Survey the route;2. Selection of the preferred conductors, towers, foundations;3. Final design of the line and the placement of towers;4. Issuing of tenders and awarding contract;5. Vegetation clearance and construction of access roads;6. Tower pegging;7. Construction of foundations;8. Assembly and erection of towers on site;9. Stringing of conductors;10. Rehabilitation of the disturbed area;11. Testing and commissioning.

The substation will require the following pre-construction activities:

Site selection;

Pre-Construction site work, including a detailed work plan;

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Site preparation.

The construction phase for the proposed project will include the following activities post-authorisation:

Vegetation clearance

All vegetation within the footprint of the sub-station should be cleared. This should be carriedout in a manner such that minimal soil erosion will result from the clearing of the site. Naturalfeatures shall be taken into consideration during design and where possible, these shall beprotected unless they will interfere with the operation for the substation. Where terracing isrequired, topsoil will be collected and retained for reuse in rehabilitation of areas not coveredby yard stone.

Construction Camp

A construction camp will be sited in area where least disturbance to potentially sensitiveenvironments will be caused. The construction will likely be sited with the construction campfor the Eskom CSP contractors.

Fencing

The substation site must be fenced for safety purposes. All Eskom gates must be fitted withlocks and kept locked at all times. Should fencing interfere with construction activities, thefencing should be deviated until the construction is complete.

Site Establishment

The site for construction of the sub-station should take place in accordance with the site plan.The site establishment will include the layout of the camp, management of ablution facilitiesas well as waste water management.

Concrete work

Concrete foundations are poured on site after site clearing. The substation framework,including support structures, will be placed on the concrete pads. Underground routes areexcavated to house the electric and communication lines between the control house and thesubstation yard.

Civil Construction

Once the concrete has dried and hardened the steel framework, comprising the towers andpoles, will be installed. The steel supports electric control equipment and the transmission

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lines that connect the substation to the grid. A control building will be constructed to housethe electric equipment. New transmission lines will be strung as described above.

The construction phase for the proposed project will take between 6 to 12 months.

7.2 Operational Activities

During the operational and maintenance phase of the project, Eskom requires access to theservitude and substation for maintenance activities. Maintenance activities are specialisedand are, therefore, carried out by Eskom employees.

Prior to commissioning of the substation and associated power lines an Operation PhaseEMPr will be compiled and submitted to the DEA for approval.

7.3 Decommissioning Activities

In terms of the decommissioning phase, the following are assumed:

The physical removal of the substation and power line infrastructure would entail thereversal of the construction process.

A rehabilitation programme would need to be agreed upon with the landowners (ifapplicable) before being implemented.

Materials generated by the decommissioning process will be disposed of according to theWaste Hierarchy i.e. wherever feasible; materials will be reused, then recycled and lastlydisposed of. Materials will be disposed of in a suitable manner, in a suitably licensedfacility.

All of the aforementioned decommissioning activities would be subject to a separateEnvironmental Authorisation process at the appropriate time.

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8 SCOPE OF THE ENVIRONMENTAL MANAGEMENT PROGRAMME

This EMPr is applicable to the construction phase of the project only. The EMPr must be readin conjunction with the BAR and EA issued for the project.

8.1 Integration of the Environmental Management Programme into the Contract

As mentioned in Section 2, this EMPr has been written in a form and language that isconsistent with the tender / contract documentation used for engineering contracts i.e. theEMPr takes the form of a set of environmental specifications that can integrate with the civil,mechanical and electrical tender / contract documentation. There are various advantages tothis approach:

The Contractor is made aware of the EMPr at the tender stage;

The Contractor is able to cost for compliance with the EMPr;

The EMPr is presented to the Contractor in the language and terminology with whichhe/she is familiar, and unnecessary duplication and contradiction is eliminated;

Inclusion of the EMPr within the contract ensures that the EMPr becomes a legally bindingdocument within a well-developed legal framework; and

The standardised form and structure of the environmental specifications ensures that withtime and each new contract, the Contractor becomes increasingly familiar with, and thusmore accepting of, the EMPr and implements it with the same diligence as any other setof specifications contained within the contract.

Ultimately, by measuring compliance against an explicit set of environmental controls that arewell located within a robust legal framework, the approach has been proven to enhancesuccess in the implementation and enforcement of the EMPr significantly.

8.2 Specification structure and Application

These specifications are not exclusive and could, within reason, be expanded on or amendedat any time during the contract by the Environmental Control Officer (ECO).

8.3 Method statements

Environmental practitioners are not specialists with regard to construction techniques.Therefore, so as not to hinder construction activities by stipulating elaborate, costly and/ orineffective mitigation measures, the environmental specification is underpinned by a series ofMethod Statements, within which the Contractor is required to outline how they propose tomitigate any identified environmental risks. For example, if the specification states that“cement contaminated water shall not be allowed to contaminate the soil or adjacent

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watercourse”, the Method Statement compiled by the Contractor would be required to outlinehow he or she intends to achieve this requirement.

In terms of the environmental specifications for the proposed substation and associated 132kv power lines, the Contractors must submit various written Method Statements to theEngineer and ECO as requested in the Specification.

For the purposes of the environmental specifications, a Method Statement is defined as “awritten submission by the Contractor to the Engineer in response to the Specification or arequest by the Engineer, setting out the materials, labour and method the Contractor proposesusing to carry out an activity, identified by the relevant specification or the Engineer whenrequesting the Method Statement, in such detail that the Engineer is enabled to assesswhether the Contractor's proposal is in accordance with the Specifications and/or will produceresults in accordance with the Specifications”.

The Method Statement must cover applicable details with regard to:

Retrofit (Construction) procedures,

Materials and equipment to be used,

Getting the equipment to and from site,

How the equipment/ material will be moved while on site (including crane operation),

How and where material will be stored,

Removal of construction related waste,

The containment (or action to be taken if containment is not possible) of leaks or spills ofany liquid or material that may occur,

Timing and location of activities,

Removal of fauna and flora;

Removal of bees on site;

Removal of snakes on site;

Compliance/ non-compliance with the Specifications, and

Any other information deemed necessary by the Engineer.

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The environmental specifications set very stringent requirements in terms of the provision ofMethod Statements and the commencement of the activities they cover:

Any Method Statement required by the Engineer/ECO or the specification must beproduced within the timeframes specified by the Engineer or the specification (typically twoweeks);

The Contractor may not commence the activity covered by the Method Statement until ithas been approved, except in the case of emergency activities and then only with theconsent of the Engineer;

The Engineer may require changes to a Method Statement if the proposal does not complywith the specification or if the proposed methodology carries an unreasonable risk ofexcessive damage to the environment;

Approved Method Statements must be readily available on the site and must becommunicated to all relevant personnel;

The Contractor is required to carry out the activities covered by the Method Statement inaccordance with the proposed approach; and

Approval of the Method Statement does not absolve the Contractor from their obligationsor responsibilities in terms of the Contract.

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9 SITE DOCUMENTATION AND RECORD KEEPING

The following documents must be kept on site:

Access negotiations and physical access plans;

Site instructions;

Pre-construction audit report;

Complaints register;

Records of all remediation / rehabilitation activities;

Copy of this EMPr;

Copy of the Environmental Authorisation;

Monthly compliance report;

Environmental training records;

Emergency response procedures.

The monthly compliance report should include:

Complaints received from affected parties and details of the actions taken;

Environmental incidents, spills of hazardous substances, etc.

Environmental damage which requires rehabilitation;

Damages of private property such as buildings or crops.

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10 ENVIRONMENTAL AWARENESS TRAINING

Training is required for all personnel involved in the proposed project. This includes allemployees working on the site including temporary labourers, contractors and subcontractors.

Training should cover:

The importance of the EMPr;

Specific details of the EMPr;

Employees role in compliance with the EMPr;

Environmental effects associated with the activities;

Training targeted at specific personnel for example operators of heavy machinery;

The environmental impacts, actual or potential, of their work activities;

The environmental benefits of improved personal performance;

Their roles and responsibilities in achieving conformance with the environmental policyand procedures;

Emergency preparedness and response requirements;

The potential consequences of departure from specified operating procedures;

The mitigation measures required to be implemented when carrying out their workactivities;

Environmental legal requirements and obligations;

Details regarding floral/faunal species of special concern and protected species, and theprocedures to be followed should these be encountered;

The impacts and consequences of poaching of animals or removal of indigenousvegetation;

The importance of not littering;

The importance of using supplied toilet facilities;

The need to use water sparingly;

Details of and encouragement to minimise the production of waste and re-use, recoverand recycle waste where possible.

Details regarding archaeological and/or historical sites which may be unearthed duringconstruction and the procedures to be followed should such be encountered.

Training should be conducted by a suitably qualified person and if necessary in more than onelanguage to ensure it is understood by all workers. Copies of the environmental training must

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be available on site in languages appropriate to the work force. Records of training sessionincluding attendance, nature of training and date of training should be kept to ensure all staffmembers have received the necessary training.

In addition to training, general environmental awareness must be fostered among the project’sworkforce to encourage the implementation of environmentally sound practices throughout itsduration. Environmental awareness and training is an important aspect of the implementationof the EMPr.

Environmental awareness could be fostered in the following manner:

Induction course for all workers on site, before commencing work on site.

Refresher courses as and when required.

Daily toolbox talks at the start of each day with all workers coming on site, where workersmight be alerted to particular environmental concerns associated with their tasks for thatday or the area/habitat in which they are working.

Courses must be given by suitably qualified personnel and in a language and mediumunderstood by workers/employees.

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11 PROVISIONS FOR ADDRESSING NON-CONFORMANCE

Ultimately, the key to construction phase is ensuring that the requirements of the EMPr areadequately and appropriately implemented on site. Accordingly, monitoring performance andaddressing non-compliance are key attributes of any environmental interventions. Part Daddresses the actual process for identifying and addressing non-compliance, whilst thissection provides an overview of the provision made for this in the environmental specification.

Broadly, the mechanisms for addressing non-compliance that are provided for in theenvironmental specifications and associated contract documentation can be divided into thefollowing categories:

Controlling performance via the certification of payments;

Requiring the Contractor to “make good”, at their own cost, any unjustifiable environmentaldegradation;

Implementing a system of penalties to dissuade environmentally risky behaviours; and

Removing environmentally non-compliant staff/ plant from site, or suspending part or all ofthe activities on site.

11.1 Environmental considerations in adjudication of tender

In terms of this EMPr, Eskom has an obligation to ensure compliance by various parties witha suite of environmental requirements related to the construction phase. To ensure that theseobligations continue to be fulfilling during the actual construction processes, it requires theEskom team to ensure that the appointed Contractors possess the requisite environmentalmanagement experience and expertise. Accordingly, it would be prudent for the Eskom teamto ensure that environmental considerations form part of the contractual process undertakenduring the appointment of contractors and consultants.

Key considerations in this regard would be as follows:

To request on appointment that the Contractor provide his environmental policy andindicate how this will influence the way the construction process is approached andmanaged on site. At the tender stage the Contractor would merely be asked to provide theoverarching environmental policy for the Company or Joint Venture;

To request as part of the tender process a list of the Contractor’s previous experience interms of the onsite implementation and management of environmental requirements;

To request as part of the tender process an indication of the proposed organisationalstructure for the Contract, and specifically for the Contractor to indicate which staff wouldbe acting in the capacity of Environmental Officer (EO) and which senior staff memberwould have overall responsibility for ensuring compliance by the Contractor with thespecified environmental requirements; and

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To confirm, upon receipt of the Tender, that the Contractor has made sufficient allowancein his Tender Price for meeting the various environmental requirements.

During the tender adjudication process for each Contract, each Contractor should be scoredin terms of the aforementioned considerations and allocated an environmental competencyscore. This score should form a key consideration in the final decision-making regarding theaward of the various contracts.

12 ENVIRONMENTAL MANAGEMENT MEASURES FOR THE PROJECT

The management measures documented in each of the sub-sections below have beencompiled using the following information:

Impact Assessment and mitigation measures documented in the BAR for the proposedsubstation and associated 132 kv lines;

Mitigation and management recommendations provided by the specialist studies.

In addition to the abovementioned information sources, the EMPr will be updated to includethe conditions documented in the Environmental Authorisation (EA) to be received uponapproval of the Basic Assessment (BA).

12.1 Planning Phase

To mitigate the negative environmental impacts, a number of measures would have to beaddressed in the design of the salvage during the planning phase. An inspection must becarried out on the design before commencement of the upgrade in order to ensure that themitigation measures have been incorporated in the design.

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Table 2 Impacts, Management/ Mitigation Measures during the Planning Phase

Planning PhaseEnvironmentalConsideration Mitigation Measures Responsible Party(ies)

Training andHealth and Safety

Eskom is to appoint an ECO Project Manager Introduce the ECO to the Project Team. Project Manager Training of the Contractor’s employees on the EMPr Elucidation of environmental monitoring protocol to the Project Team by the ECO.

ECO

All correspondence from ECO must be filed and kept on site. Project Manager and ECO Staff responsible for construction should be issued with the appropriate PPE and trained

in safe working procedures concerning the various processing action.Project Manager

ConstructionCamp/laydownarea

In consultation with the ECO, demarcate the suitable site identified for the laydown area.The site office as well as parking areas for construction vehicles should be confined todisturbed areas, away from drainage lines.

Contractor and the ECO

Chemical toilets must be provided at a ratio of at least one per 15 employees in terms ofablution facilities.

Chemical toilets must be serviced and emptied on a regular basis to avoid leaks andspillage.

Camp sites must be negotiated with the land owner. No fires or dumping of waste to take place at the camp sites. Landowners must be notified and negotiated with where construction camps may be

established on their property. Access procedures to privately owned land must be negotiated with the land owners. No chemical toilet may be within 100 m of a natural water body.

Project Manager,Contractor

Waste Identify suitable hazardous/general Waste Disposal Sites which will accept waste material

to be generated. Provide a plan for the collection, storage and transport of waste a recognized landfill site. All metal off-cuts and metal waste must be recycled.

Project Manager,Contractor

Social Local suppliers must be used, as far as possible; Local labour should be employed; No construction activities should be carried out prior to adjacent landowners being

notified;

Eskom and Contractor

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Planning PhaseEnvironmentalConsideration Mitigation Measures Responsible Party(ies)

Communicate in a cultural sensitive way the next phase of project; Communicate process in language of choice; A comment register for I&APs is to be lodged at the site office and surrounding

landowners and residence must be informed of its location and purpose.Designs Ensure that the retrofit is designed to fit inside the existing casing. EskomVehicles Ensure that all machinery on site is in a good working order;

All equipment and/or vehicles moved onto or off of the site are subject to legalrequirements as well as Eskom specifications for the transportation of such equipment;

All equipment and vehicles to the site must be clearly labelled as to their potential hazardsaccording to specifications;

All the required safety labelling on the containers and trucks should be in place.

Contractor

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12.2 Construction Phase

Table 3: Impacts, Management/ Mitigation Measures during Construction Phase

Construction PhaseEnvironmentalConsideration Mitigation Measures Responsible

Party(ies)Soil Salvage and stockpile topsoil (top 30 cm of the soil profile). This soil can be returned to the

construction area to encourage vegetation growth; Topsoil shall not be stored higher than 1.5 m; Demarcate the extent of the substation footprint to avoid unnecessary removal of vegetation

cover; Use existing access roads as far as possible; If a new road is constructed, ensure that Eskom erosion prevention guideline is followed; Adhere to tower construction specification TRMSCAAC1 Rev 3; Take land use into consideration when choosing pylon types, it is recommended that smaller

footprint pylons be used in cultivated areas; Take cognizance of soil types and land use when finalizing the substation footprint to avoid

clay soils and habitats or land uses of significance or sensitivity; Spread absorbent sand on areas where oil spills are likely to occur, such as the refuelling

area in the hard park; Oil-contaminated soils are to be removed to a contained storage area and bio-remediated or

disposed of at a licensed facility; Use berms to minimise erosion where vegetation is disturbed, including hard parks, plant

sites, borrow pit and office areas; If soils are excavated for the footing placement, ensure that the soil is utilised elsewhere for

rehabilitation/road building purposes; All cement mixing for the substation and/or power line towers must be carried out away from

sensitive habitats and surface water bodies and should be limited to areas that are effectivelybermed and lined; and

Ensure that soil is stockpiled in such a way as to prevent erosion from wind/storm water.

Contractor andECO.

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Party(ies)Air Quality Vehicles to be properly maintained to avoid unnecessary emissions.

The proposed construction operator should control on-site dust emissions by effectivemanagement and mitigation according to the existing procedures for the power lines.

Construction vehicles must travel at low speeds to reduce the effect of dust. Where necessary spraying of haul roads with water or dust suppressant must be carried out

to reduce dust generation.

Contractor

Fauna and Flora A walk through of the selected alignment as well as tower positions should be conducted by asuitable qualified botanist as well as zoologist in order to ascertain for the presence of anythreatened, protected, endemic or plant or animal species of special concern within or in closeproximity to the construction areas (tower supports) for the presence of any animal burrows(including spiders and scorpions), rocky outcrops, logs, stumps and other debris and relocateany affected animals to appropriate habitat away from the servitude or tower;

Protected trees within the servitude and the substation footprint will necessitate that appropriatepermits are applied for before these trees are damaged or removed;

General mitigation measures would include the avoidance of any physical damage to naturalvegetation on the periphery of the proposed servitude and the substation;

All alien vegetation clearing should be done according to the DWA approved methodology; Alien vegetation control should continue with follow up monitoring and removal programmes

should be initiated once construction is completed; No construction activity or disturbance to vegetation or habitat is to take place within 50m of a

delineated wetland or riparian zone; No hunting permitted by Eskom employees or contractors; No heavy machinery should impact on remnant patches of natural vegetation in association

with the substation and/or servitude; All construction areas should be demarcated prior to construction to ensure that the footprint

of impacts are limited; Adhere to Eskom vegetation management guideline; The ECO should identify any sensitive species or habitats along the servitude, particularly in

relation to large terrestrial species and notify the faunal specialist of these so that he canadvise on how best to handle these;

The construction of new access roads should be limited;

Contractor/ECO

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Party(ies) All vehicle and pedestrian movement should be restricted to the actual construction site and

servitude; Mark power lines with PVC spiral type Bird Flight Diverters to reduce mortality rates; Removal of plants along the power line servitude should be restricted to only those trees that

pose a risk to the power line; Sensitive alluvial vegetation should be avoided and construction restricted within 50m from

the edge of an endangered habitat; When the tallest substation infrastructure is to be erected, an avi-fauna specialist should be

contacted to ensure that the most effective anti-collision and anti-electrocution devices arebeing used on the substation and on turn-in lines.

Social Roads should be maintained or improved on. Have a trained first aid person on site. No squitter camps should be erected near construction camps. HIV/AIDS awareness training must form part of the induction of staff. Condoms must be freely available. Access to construction camps should be security controlled.

Eskom,Contractor

Aesthetics Sound housekeeping and waste management measures to be employed; The substation construction site should be maintained in an orderly and neat fashion; Light pollution must be minimized; Location of construction camp to be determined by ECO to minimise visual intrusion; Construction material to be stored in a neat and safe manner, in designated areas; Waste should be restricted to storage in specifically designated areas, and removed daily; Any complaints regarding the appearance of the construction site must be recorded and

addressed promptly; Ensure that all litter and pollution is cleared from the site (including remaining building rubble).

Contractor;

Noise All machinery to be maintained and fitted with equipment to reduce noise levels; Labourers to be provided with hearing protection (PPE); No loud music allowed from the construction camp or anywhere else within the work footprint; Construction working hours should be limited to 06:00 to 17:00 from Monday to Saturday with

no construction taking place on Sundays.

Contractor andEskom

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Party(ies)HeritageResources

Placement of infrastructure should avoid potential sites of high archaeological sensitivity suchas pans, rocky ridges and river beds;

Where bedrock is disturbed there should be paleontological monitoring in order to identify anypotential sensitive areas that may be exposed;

Any cultural, archaeological or paleontological sites that are identified during constructionshould be reported to SAHRA and investigated by a Heritage Resources expert;

On uncovering a possible grave or burial site, it is imperative that construction cease and aheritage specialist called onto the site;

The grave must be fenced off and SAHRA must be notified immediately.

Contractor,Eskom and ECO.

ConstructionMaterials

Construction material must be stored under a roof or inside a suitable container. The construction material must be mixed in designated areas, on impermeable surfaces. The

batching plant must be bonded to prevent storm water entry, and to contain dirty water. Material must be stored in a safe and neat manner. Site offices, parking areas for construction vehicles should be confined to disturbed areas. Mixing of concrete/cement must take place on impermeable surface, or where it is happening

on site on a plastic liner. All concrete spills must immediately be cleaned up. Oil spill kits must be available on site.

Contractor andECO

OccupationalHealth and Safety

All projects must be conducted in accordance with the Occupational Health and Safety Act(Act 85 of 1993).

The contact details of the Safety Officer/Representative should be provided to the ECO. Safety induction must be expanded to include environmental risks and mitigation measures.

Fire prevention: At least two staff members of the site contractor should be trained or be proficient in

firefighting and prevention, and at least one staff member should be on site at all times. Adequate firefighting equipment should be available on site at all times. The Contractor must take all the necessary precautions to protect the materials on site and to

avoid fires. No waste material may be burnt. Designated areas must be provided where smoking can occur in a controlled environment. A firebreak must be put around the construction camp.

Contractor

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Party(ies) Provide area with relevant warning signage (e.g. no smoking and open fires, fire

extinguisher).

Waste Littering on site and the surrounding areas is prohibited. Clearly marked litterbins must be provided on site. All bins must be cleaned of litter regularly. All general waste will be removed and disposed of at a registered Waste Disposal Site. The contractor must install and maintain mobile chemical toilets at work sites if existing

facilities are not available. Drip trays must be used under all machinery, including generators and vehicles.

Contractor

Sanitation Under no conditions may the surrounding areas be used for ablution purposes. Sufficientchemical toilets to be provided (if no existing facilities are available). Chemical toilets to beplaced at strategic points (with minimal visual impact).

Chemical toilets must be professionally serviced and emptied on a regular basis. Chemical toilets must be provided at a ratio of at least 1 toilet per 15 employees on site.

Contractor

Infrastructure,Vehicles and PlantEquipment

The equipment and plant to be used at for the power line construction must be suitable for theapplication and prevailing site conditions, of adequate rated capacity, in good workingcondition, and shall be so designed and constructed as to cause minimum environmentalpollution.

The plant, vehicles and equipment necessary for the operation shall be properly maintainedand the vehicles serviced at the required service intervals to ensure road worthiness.

All vehicles are inspected on a daily basis for roadworthiness.

Contractor

StakeholderLiaison

Access to the substation and servitude construction site must be negotiated with thelandowners.

Construction camp establishment on privately owned land must be negotiated with the landowner.

All gates to privately owned land must be closed and/or locked at all times to minimize thedisturbance to the land owner.

Land owners should be notified when Eskom staff will be active on their property and whenthat activity will cease. Any changes to these schedules should be communicated to the landowner.

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12.3 Operational Phase

Once construction of the power lines have been completed, the proposed operation is to beundertaken according to the existing operating procedure and associated procedures fortransmission lines by Eskom.

The Responsible Party from Eskom will monitor the activities of the operational team on siteto ensure all mitigatory measures are implemented and to prevent any additional impacts fromoccurring.

An annual Project Compliance Audit should be undertaken, which should focus on theadherence to the procedures.

12.4 Organizational Structure

The organisational structure identifies and defines the responsibilities and authority of thevarious role-players (individuals and organisations) involved in the project. All instructions andofficial communications regarding environmental matters shall follow the organisationalstructure shown in Figure 3 below.

The organisational structure reflected in Figure 3 has been developed to ensure that;

• There are clear channels of communication;

• There is an explicit organisational hierarchy for the integration project; and

• Potential conflicting or contradictory instructions are avoided.

In terms of the defined organisational structure reflected in the figure, all instructions that relateto environmental matters will be communicated to the Contractor via the Site supervisor. Theonly exception to this rule would be in an emergency (defined as a situation requiringimmediate action and where failure to intervene timeously would, in the reasonable opinion ofthe ECO, result in unacceptable environmental degradation), where instructions may be givendirectly to the Contractor .The detailed roles and responsibilities of the various role-playersidentified in the organisational structure are outlined in Section 11.

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12.5 Environmental Roles and Responsibilities

The key-role-players for the integration project are the DEA, Eskom (including theEnvironmental Control Officer) and the Contractor. The detailed roles and responsibilities ofeach of these organisations are outlined below.

Department of Environmental Affairs

As the competent environmental authority, the DEA has the responsibility to ensure that theproponent, viz. Eskom, complies with the conditions of the Environmental Authorisation for theFFP project (once received) as well as the requirements of the broader environmentallegislation, specifically the NEMA - National Environmental Management Act (No. 107 of1998). Compliance would be confirmed via the following mechanisms:

Receipt and review of the environmental reporting required in terms of the EA; and

Ad hoc and planned site inspection by the DEA Compliance and Enforcement

Eskom

As the Proponent, Eskom must ensure that the implementation of all components of the Golelasubstation and turn-in lines project complies with the requirements of the EnvironmentalAuthorisation (once received), this EMPr, as well as any obligations emanating from otherrelevant environmental legislation. Part of this obligation is being met by the development ofthe EMPr, its integration into the contract documentation, and the appointment of the ECO. Itmust be noted that Eskom cannot delegate out of this responsibility to adhere to theseenvironmental conditions for the project. Accordingly, Eskom retains various key roles and

Environmental ControlOfficer (ECO)

Eskom ContractManager

Eskom ProjectManager

Contractor EnvironmentalLiaison Officer

Figure 3 : Organisational structure for Environmental Reporting

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responsibilities during the construction of the substation and associated turn-in lineinfrastructure. These are outlined below.

The Eskom Project Manager must:

Be fully conversant with the BA reporting for the project, the conditions of theEnvironmental Authorisation (once received), the EMPr and all relevant environmentallegislation.

Ensure that all the specifications and, legal constraints pertaining to the project, specificallywith regards to environment management, are highlighted to Eskom and its Contractor(s)so that they are aware of these; and

Ensure that the environmental specifications are correctly implemented throughout theproject by means of site inspections and meetings. This will be documented as part of thesite meeting minutes.

Eskom’s Representative (≈ Eskom’s Construction Manager) must:

Be fully knowledgeable with the contents of the BA Reporting;

Be fully knowledgeable with the contents and conditions of the EnvironmentalAuthorisation;

Be fully knowledgeable with the contents of the EMPr, specifically as articulated into theenvironmental specifications attached to each Contract;

Be fully knowledgeable with the contents of all relevant environmental legislation andensure compliance with these;

Have overall responsibility of the environmental specifications and their properimplementation;

Ensure that regular audits are conducted to confirm compliance with the environmentalspecifications;

Ensure there is communication with the Eskom Project Manager or his delegate, the ECOand the relevant Site Engineers on matters concerning the environment;

Ensure that no actions are taken which will harm or may indirectly cause harm to theenvironment, and take steps to prevent pollution on the site.

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Environmental Control Officer

Eskom must appoint a suitable qualified ECO to monitor compliance with this EMPr,environmental legislation and the Environmental Authorisation (once received). To fulfil theserequirements, the ECO would need to have relevant on site experience. It should be noted,unless otherwise stated in the Environmental Authorisation, the ECO could be a Eskomemployee, as long as they have the requisite environmental training and experience.

The ECO will be responsible for monitoring, reviewing and verifying compliance by theContractor with the environmental specification. Accordingly, the ECO would be required to:

Be fully knowledgeable with the contents of the BA Reporting;

Be fully knowledgeable with the contents and conditions of the EnvironmentalAuthorisation;

Be fully knowledgeable with the contents of the EMPr, specifically as articulated into theenvironmental specifications attached to each Contract;

Be fully knowledgeable with the contents of all relevant environmental legislation andensure compliance with these;

Ensure that compliance with the conditions of the Environmental Authorisation andenvironmental specification are monitored and verified through regular and comprehensiveinspections of the site and surrounding areas, and that the results of these inspections arereduced to writing;

Ensure that if the environmental specifications are not followed then appropriate measuresare undertaken to address this; and

Report to the DEA every three months regarding compliance with the requirements of theEMPr, environmental legislation and the Environmental Authorisation (once received);

In meeting the aforementioned obligations, the ECO's specific duties would include thefollowing:

Assisting the Eskom Project Manager in ensuring necessary environmental authorizationsand permits have been obtained;

Confirming that activities on site comply with legislation;

Monitoring and verifying that the conditions of the Environmental Authorisation andenvironmental specifications are adhered to at all times and requiring the Contractor totake action if these are not followed;

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Monitoring and verifying that environmental impacts are kept to a minimum;

Giving a report back on the environmental issues at the monthly site meetings and othermeetings that may be called regarding environmental matters;

Inspecting the site and surrounding areas regularly with regard to compliance with theenvironmental specifications;

Ensuring that a register of complaints is kept by the Contractor and that all complaints areappropriately recorded and addressed;

Assisting the Engineer in certifying payment for items related to the environmentalspecification;

Approving any method statement required by the contractor;

Recommending the issuing of penalties for contraventions of the environmentalspecifications;

Advising on the removal of person(s) and/or equipment, not complying with thespecifications, from site;

Completing the requisite environmental reporting, which should include a daily site diaryentry, weekly audit checklists, a bi-monthly (viz. every second month) environmentalcompliance report;

Keeping a photographic record of progress on Site from an environmental perspective;and

Undertaking project and contractors audits.

As outlined previously, all instruction issued by the ECO would go through the Engineer’sRepresentative, who will then convey these to the Contractor.

Contractors

By virtue of the environmental obligations delegate to the Contractor through the ContractDocument, all contractors (including subcontractors and staff) and service providers appointedfor this project would be responsible for:

Ensuring adherence to the environmental specifications;

Ensuring that any instructions issued by the Engineer, on the advice of the ECO, areadhered to;

Ensuring that there must be communication tabled in the form of a report at each sitemeeting, which will document all incidents that have occurred during the period before thesite meeting;

Ensuring that a register is kept in the site office, which lists all the transgressions issuedby the ECO; and

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Undertaking subcontractor’s audits.

Ensure that all employees, including those of sub-contractors receive training before thecommencement of construction in order that they can constructively contribute towards thesuccessful implementation of the environmental requirements of the Contract.

The most important actions by the Contractor to ensure compliance with the environmentalrequirements, relates to the establishment of an adequate and appropriate organisationalstructure for ensuring the implementation and monitoring of the requisite environmentalcontrols.

The ECO's specific duties relate to the implementation of the environmental controls containedwithin the EMPr, and which are audited by the ECO. Accordingly, the EO’s duties include:

Ensuring that activities on site comply with legislation;

Monitoring and verifying that the environmental specifications are adhered to at all timesand taking action if the specifications are not followed;

In consultation with the engineers, develop any method statements required in this EMPr;

Monitoring and verifying that environmental impacts are kept to a minimum and takingaction to address any environmental degradation;

Proactively developing environmentally responsible solutions to problems, in consultationwith the EO where necessary;

Giving a report back on the environmental issues at the monthly site meetings and othermeetings that may be called regarding environmental matters;

Keeping records of all activities / incidents concerning the environment on site;

Inspecting the Site and surrounding areas regularly with regard to compliance with theenvironmental specifications;

Maintaining a register of complaints, ensuring that all complaints are appropriatelyrecorded and addressed and notifying the ECO of each complaint and how it was resolved;

Completing the requisite environmental reporting, namely a daily compliance checklist, arecord of staff induction and incidence reports, for submission to the ECO;

Keeping a photographic record of progress on Site from an environmental perspective;and

Undertaking subcontractor audits.

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13 TRAINING

The ECO shall be appropriately trained in environmental management and shall possessthe skills necessary to impart environmental management skills to all personnel involvedin the construction, of the proposed construction of the 132kV power lines;

Eskom, together with the Environmental and Safety Manager and the ECO, shall ensurethat the employees (including construction workers, engineers, and long-term employees)are adequately trained on the EMPr; and

All employees shall have an induction presentation on environmental awareness. Thecost, venue and logistics shall be for Eskom’s account.

Where possible, training must be conducted in the language of the employees. The inductionand training shall, as a minimum, include the following:

The importance of conformance with the EMPr, other environmental policies andprocedures;

The significant environmental impacts, actual or potential, related to their work activities;

The environmental benefits of improved personal performance;

Their roles and responsibilities in achieving conformance with the EMPr and otherenvironmental policies and procedures;

The potential consequences of departure from specified operating procedures; and

The mitigation measures required to be implemented when carrying out their workactivities.

14 PROJECT COMPLIANCE REPORTING

Regular monitoring of all the environmental management measures and components shall becarried out by Eskom and ECO to ensure that the provisions of this plan are adhered to.Ongoing and regular reporting of the progress of implementation of this Programme should bedone. Various points of compliance will be identified with regard to the various impacts thatthe construction will have on the environment.

Inspections and monitoring shall be carried out the implementation of the plan. Visualinspections on erosion and physical pollution shall be carried out on a regular basis.

14.1 Reporting Procedures and Documentation

Record keeping and monitoring of documentation is a vital part of compliance with theenvironmental management system, record-keeping procedures for the substation and 132kV power line construction has to be in order. Accurate records must be kept of all wasteexiting the construction site. Waste must be categorised by the number of loads, defined by

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mass, type and origin. Records must be kept on both a daily and a cumulative basis. One ora combination of the following systems could be used for record keeping:

An electronic, totally computerised, mass measuring device providing detailed records ofdaily, weekly and monthly transactions. This system should be used with the proposedweighbridge and computer system.

A mass measuring unit with hand capturing of data for manual or computerised collation.This would also be used as backup when the computer is out of action.

Details of waste category, quantities and origin will be obtained and recorded for all wastesaccepted by the Contractor’s access controller. A daily summary of the wastes accepted mustbe recorded by the Contractor in the Daily Diary in the Contractor’s site office.

14.2 Environmental Contact Person

To Be Confirmed

14.3 Emergency Numbers

Police: 10111 Ambulance 10177

Netcare 911 082 911 ER24 084 124

Emergency 107 Crimestop 08600 10 111

15 CONCLUSION

This EMPr offers environmental management actions to address potential environmental risks

associated with the construction of the Golela Substation and associated 132kV turn-in lines.

The effective implementation of the EMPr will provide appropriate environmental management

of the site for the duration of the construction phase.

ZITHOLELE CONSULTING (PTY) LTD

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