CHAPTER 6:

IMPACTS ON WASTE PLANNING AND

MANAGEMENT

Second Order Draft for Stakeholder Comment

Integrating Author: Suzan Oelofse

Contributing Authors: Johan Schoonraad

Corresponding Authors: Dave Baldwin

Peer Reviewers: Carin Bosman, Ray Gosine, Eddie Hannekom, Dave Yoxtheimer

Page 6-1

CONTENTS

CHAPTER 6: IMPACTS ON WASTE PLANNING AND MANAGEMENT 6-4

6.1 Introduction and scope 6-4

6.1.1 What is meant by this topic? 6-5

6.1.2 Overview of international experience 6-6

6.1.2.1 Minimisation, reuse and recycling of produced water 6-8

6.1.2.2 Treatment 6-10

6.1.2.3 Disposal 6-14

6.1.2.4 Beneficial reuse 6-15

6.2 Special features of the Karoo in relation to waste 6-15

6.3 Relevant legislation, regulation and practice 6-17

6.3.1 Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) 6-17

6.3.2 National Environmental Management Act, 1998 (Act 107 of 1998) 6-19

6.3.3 National Environmental Management: Waste Act, 2008 (Act 56 of 2008) 6-20

6.3.4 National Water Act, 1998 (Act 36 of 1998) 6-21

6.3.5 National Nuclear Regulator Act, 1999 (Act 47 of 1999) 6-23

6.3.6 National Road Traffic Act, 1996 (Act 93 of 1996) 6-23

6.3.7 Disaster Management Act, 2002 (Act 57 of 2002) 6-24

6.4 Key potential impacts and their mitigation 6-24

6.4.1 On-site storage 6-25

6.4.2 Liquid Waste Treatment 6-26

6.4.3 Off-site management and disposal 6-26

6.4.4 Deep well injection 6-27

6.4.5 Surface water discharge 6-27

6.4.6 Land application 6-28

6.4.7 Spills 6-28

6.4.8 Residuals management 6-28

6.5 Risk assessment 6-29

6.5.1 How risk is measured 6-29

6.5.2 Limits of acceptable change 6-29

6.5.3 Risk Matrix 6-29

6.5.4 Best practice guidelines and monitoring requirements 6-30

6.5.4.1 Best Practice Guideline No H4: Water Treatment 6-31

6.5.4.2 Guidelines for the Utilisation and Disposal of Wastewater Sludge 6-31

Page 6-2

6.5.4.3 National Norms and Standards for Assessment of Waste for Landfill

Disposal 6-31

6.5.4.4 Norms and Standards for Disposal of Waste to Landfill 6-32

6.5.4.5 National Norms and Standards for Storage of Waste 6-32

6.5.4.6 Minimum Requirements for Monitoring of Water Quality at Waste

Management Facilities 6-32

6.6 Topics on which information is inadequate for decision-making 6-37

6.7 References 6-37

6.8 Addendum A6: Tabulated detailed information 6-41

Tables

Table 6.1: Produced water minimization technologies (Veil, 2015). 6-8

Table 6.2: Examples of water reuse and recycle management options and some of the specific uses

(Veil, 2015). 6-9

Table 6.3: Treatment technologies designed to remove salts and other inorganic compounds from

produced water (Veil, 2015). 6-11

Table 6.4: Treatment technologies designed to remove oil and grease and other organics from produced

water water (Veil, 2015). 6-12

Table 6.5: Water disposal methods (Veil, 2015). 6-15

Table 6.6: Risk Matrix. 6-29

Table 6.7: Monitoring requirements for general and hazardous waste disposal facilities and sewage

sludge 6-35

Figures

Figure 6.1: Map of the study area showing waste facilities for general landfills and Waste Water

Treatment Works 6-16

Figure 6.2: Water use categories as defined by the Pricing Strategy (RSA, 2015). 6-23

Figure 6.3: A schematic presentation of these monitoring systems (DWAF, 1998b). 6-33

Figure 6.4: Minimum Requirements (DWAF, 1998b) also provide guidance on borehole design 6-36

Page 6-3

Executive Summary 1

This chapter focus on the management aspects of solid and liquid waste generated during 2

shale gas development (SGD) by identifying the 3

potential impacts and mitigation measures required 4

to reduce the risks posed by waste to the 5

environment and communities. 6

Waste must be managed in an integrated way in-line 7

with the waste management hierarchy and the 8

principles for integrated waste management in 9

South Africa. The emphasis here is to minimise 10

waste arisings, promote the use of non-hazardous 11

chemicals, reuse and recycling and minimise the 12

impact of waste on water, the environment and 13

communities. 14

Schedule 3 of the Waste Amendment Act, 2014 15

classifies waste from gas exploration and development as hazardous waste. It is likely that 16

most of the waste generated will be classified as Type 1 hazardous waste requiring disposal at 17

a Class A or H:H landfill. Municipal landfill sites in the study area do not meet the design 18

requirements to accept Type 1 hazardous waste. The closest commercial facilities to the 19

study area that are duly authorised to accept Type 1 hazardous waste is Aloes in Port 20

Elizabeth and Vissershok in Cape Town. 21

Limited capacity and skills of municipalities in the study area is a serious issue for municipal 22

waste management and requires intervention to deal with any additional loads of domestic or 23

other general waste streams. 24

Available waste water infrastructure in the study area is under pressure and requires urgent 25

intervention. The technologies and capacity at these already stressed facilities are not 26

sufficient or appropriate to treat wastewater from SGD. 27

The current, constantly changing, waste management legislation will not be able to deal with 28

waste from shale gas exploration and production operations effectively despite the 29

promulgation of the Regulations for Petroleum Exploration and Production, 2015 which 30

amongst other, prescribe: an impermeable site underlay to prevent environmental 31

contamination; disclosure of the content of drilling fluids through material safety data sheets 32

and disclosure of the chemical composition of the fracking fluids; above-ground storage tanks 33

for fracturing fluids, flowback and produced water; and prohibition of underground disposal, 34

including the use of re-injection disposal wells for waste water and drilling muds and the 35

prohibition of certain listed substances from being used in the fracking process.36

Page 6-4

CHAPTER 6: IMPACTS ON WASTE PLANNING AND 1

MANAGEMENT 2

6.1 Introduction and scope 3

The management of waste is an integral 4

part of responsible oil and gas 5

exploration and production activities but 6

can be especially challenging in areas 7

where supporting infrastructure or 8

regulatory frameworks are not well 9

developed (OGP, 2009). 10

11

Waste is defined in South African law in 12

both the National Water Act, 1998 and in 13

the National Environmental 14

Management: Waste Act, 2008. The two 15

definitions differ in that the Water Act 16

defines waste based on its potential to pollute the water resource (RSA, 1998) while the Waste Act 17

defines waste as any substance, material or object that is unwanted, rejected, abandoned, discarded or 18

disposed of, or that is intended or required to be disposed of, irrespective of whether or not such 19

substance material or object can be reused, recycled or recovered (RSA, 2008 as amended). When 20

considering waste in the context of this study, both definitions will apply. 21

22

Waste must be managed in-line with the waste management hierarchy and the principles for 23

integrated waste management in South Africa. The emphasis here is to minimise waste arisings, 24

promote reuse and recycling, and minimise the impact of waste on water, the environment and 25

communities. All waste must be separated at source in-line with the requirements of the Waste Act, 26

2008 to maximise opportunities for reuse and recycling, and treatment efficiencies. 27

28

The onshore production of gas, which is the topic of this study, includes various phases in which 29

hazardous, non-hazardous waste and waste water can be generated. Typical waste streams would 30

include construction and demolition waste, drill cuttings and drilling muds, and flowback (Amec, 31

2013). Much of the waste generated by hydraulic fracturing will be Type 1 hazardous waste in terms 32

clause 7(3) of the National Norms and Standards for the Assessment of Waste for Landfill Disposal, 33

2013 (RSA, 2013a): 34

Principles for Integrated Waste Management in

South Africa (DEAT, 2000)

Sustainable Development

Access to Information

Precautionary

Duty of Care

Preventative

Polluter Pays

Best Practicable Environmental Option (BPEO)

Cooperative Governance

Integrated Environmental Management

Environmental Justice

Participatory

Equitable access to environmental resources

Page 6-5

“If a particular chemical substance in a waste is not listed with corresponding 1

LCT and TCT limits in section 6 of these Norms and Standards, and the waste 2

has been classified as hazardous in terms of regulation 4(2) of the Regulations 3

based on the health or environmental hazard characteristics of the particular 4

element or chemical substance, the following applies 5

(a) the waste is considered to be Type 1 Waste;” 6

7

Inappropriate treatment and management of these wastes and spills of fracking fluids has the potential 8

to threaten human health and safety and impact negatively on water resources and the environment 9

(Kiboub, 2011; OGP, 2009). Hydraulic fracturing uses a large number of chemicals, including some 10

known hazardous substances (e.g., the foaming agent 2-butoxyethanol), and brings many potentially 11

dangerous compounds to the surface, such as hydrocarbons, varying amounts of BTEX (benzene, 12

toluene, ethylbenzene, xylenes) compounds, brine, and other naturally occurring geological 13

components (e.g., arsenic, radionuclides) (Council of Canadian Academies, 2014; Zhang et al., 2016). 14

This section of the report will therefore assess all waste and waste water streams generated as a result 15

of shale gas development (SGD), and the potential risks associated with the various waste and waste 16

water management options. It will also propose mitigation measures to protect human health and the 17

environment against the effects caused by spills and the collection, transport, treatment, storage and 18

disposal of waste and waste water. 19

6.1.1 What is meant by this topic? 20

Hydraulic fracturing and the production of natural gas from fracked wells yield wastes that must be 21

managed responsibly to avoid potential harm to the 22

environment and human health. The waste waters generated 23

are known as “flowback” and “produced water” and both 24

may contain potentially harmful pollutants including salts, 25

organic hydrocarbons (oils and grease), inorganic and 26

organic additives and naturally occurring radioactive 27

materials (NORM) (also see Chapter 5 for a description of 28

the groundwater quality). Contaminated run-off also needs to 29

be contained and treated as waste water. The solid wastes 30

produced are mostly drill cuttings (mud) or sludges from 31

waste water treatment. Impacts of spills during off-site 32

transport of waste water or waste may result from accidents, 33

Key definitions and abbreviations

“Flowback” refers to fracturing fluid

injected into a gas well that returns to

the surface when drilling pressure is

released

“Produced water” refers to all waste-

water emerging from the well after

production begins, much of which is

salty water contained within the shale

formation.

Source: Hammer and Van Briesen, 2012

Page 6-6

from inadequate management or training, and from illicit dumping. Domestic solid waste associated 1

with worker deployment to the area and opportunistic migrants looking for employment and other 2

economic opportunities are also considered. 3

4

Issues not covered in this chapter are non-water related impacts of waste water management (with 5

limited exceptions). Such impacts include air emissions from trucks used to haul waste water and 6

waste (refer to chapter 3), noise and traffic impacts from those trucks (refer to chapters 16 and 18), 7

soil contamination and land disturbance impact from the construction of waste water management 8

facilities (refer to chapters 5 and 7). 9

10

Assumptions: Operators/prospectors must fully disclose the composition of the fracturing fluid 11

additives, consistent with the provisions of the Regulations for Petroleum Exploration and Production, 12

2015, as this will determine the treatment options required to ensure correct treatment and proper 13

management of this waste stream. The waste stream has been pre-defined as hazardous waste in 14

Schedule 3 of the Waste Amendment Act, 2014 (RSA, 2014). 15

6.1.2 Overview of international experience 16

Disposal of drilling and fracturing wastes, as well as spills of fracturing fluids and waste, poses a 17

number of potential environmental and health risks. Surface spills of fracturing fluid may pose a 18

greater contamination risk than hydraulic fracturing itself (Grout and Grimshaw, 2012). Released 19

materials include fuels, drilling mud and cuttings, and chemicals (particularly for hydraulic 20

fracturing). Hydraulic fracturing chemicals in concentrated form (before mixing) at the surface 21

present a more significant risk above ground than as a result of injection in the deep subsurface (Grout 22

and Grimshaw, 2012). Leaks and spills associated with SGD may occur at the drill pad or during 23

transport of chemicals and waste materials. Sources at the wellsite include the drill rig and other 24

operating equipment, storage tanks, impoundments or pits, and leaks or blowouts at the wellhead. The 25

primary risk of uncontrolled releases is generally to surface water and groundwater resources (Grout 26

and Grimshaw, 2012). 27

28

Many of the waste streams generated by hydraulic fracturing are the same as or similar to those of 29

conventional oil and gas production (Grout and Grimshaw, 2012). The flowback and produced water 30

generated by hydraulic fracturing may pose a serious risk to the surrounding environment and public 31

health because this wastewater usually contains many toxic chemicals and high levels of total 32

dissolved solids (TDS) (Zhang et al., 2016). The composition of waste waters changes over the 33

lifetime of the well with produced water increasing in salinity in the latter stages of shale gas 34

extraction (Koppelman et al., 2012). The management of these wastes may be the greatest challenge 35

Page 6-7

of shale gas regulation by the responsible authorities (Grout and Grimshaw, 2012). The US 1

Environmental Protection Agency reported groundwater contamination in Pavillion, Wyoming as a 2

direct result of improper operational practices associated with hydraulic fracturing waste management 3

(DiGiulio et al., 2011). “Detection of high concentrations of benzene, xylenes, gasoline range 4

organics, diesel range organics, and total purgeable hydrocarbons in ground water samples from 5

shallow monitoring wells near pits indicates that pits are a source of shallow ground water 6

contamination in the area of investigation. Pits were used for disposal of drilling cuttings, flowback, 7

and produced water” (DiGiulio et al., 2011:33). 8

9

According to Grout and Grimshaw (2012) regulations for waste storage primarily address temporary 10

pits and tanks for drilling fluid and cuttings and flowback and produced water. These regulations 11

typically include requirements for pit liners, freeboard (excess volumetric capacity), and closure, all 12

of which have the objective of preventing soil and water contamination. Some states in the US are 13

adopting provisions which require that drilling and fracturing waste must be stored in tanks rather 14

than pits to reduce the potential impacts on the environment (Grout and Grimshaw, 2012). Open 15

storage ponds are not allowed in the UK (Koppelman et al., 2012) or in South Africa (RSA, 2015a). 16

17

According to Hammer and Van Briesen (2012) there are five basic management options for 18

contaminated waste water from shale gas extraction as illustrated in the graphic. These are: 19

1) Minimisation of produced water generation 20

2) Recycling and reuse within operations 21

3) Treatment 22

4) Disposal 23

5) Beneficial reuse outside the operations 24

Page 6-8

1

6.1.2.1 Minimisation, reuse and recycling of produced water 2

Water use and waste water minimisation technologies are still being developed and the effect they 3

will have on long-term produced water quantities is uncertain (Hammer and Van Briesen, 2012). 4

Challenges to reuse may include removing constituents that could affect well performance (salts, 5

suspended solids, microorganisms and scale forming chemicals) and adjusting the stimulation 6

chemistry with chemical additives that work in saltier waters (Hammer and Van Briesen, 2012). 7

8

Minimising the volume of produced water that is generated to the surface is a way to simplify water 9

management options and costs. To achieve produced water minimization, processes are modified, 10

technologies adapted or products are substituted so that less water is generated (Veil, 2015). 11

12

Produced water minimization technologies are summarized in the table below (Veil, 2015). 13

Table 6.1: Produced water minimization technologies (Veil, 2015). 14

Approach Technology Pros Cons

Reduce the volume

of water entering

the wells

Mechanical blocking

devices (e.g., packers,

plugs, good cement

jobs)

These should be used in

new construction. They

can be added later on to fix

some problems.

May not be easy to fix pre-

existing problems.

Water shut-off

chemicals (e.g.,

Can be very effective in

selected instances,

Need the right type of

formation in order to achieve

Page 6-9

Approach Technology Pros Cons

polymer gels) primarily in sandstone and

limestone formations.

cost-effective results.

Reduce the volume

of water managed

at the surface by

remote separation

Dual completion wells

(downhole water sink)

Can be very effective in

selected instances.

Limited prior use. Makes wells

more complex.

Downhole oil/water

separation

May be a good future

technology.

Earlier trials were inconsistent

and the technology went out of

favour. New designs and good

candidate wells are needed to

bring back this technology.

1

The opportunity for reuse and recycling is greater during the flowback period than during the 2

production phase. Produced water generated during the lifetime of the well can be collected and 3

repurposed for operations at other wells, but this requires transport to new well pads which may be 4

more costly than transport to disposal or treatment locations. Logistics and economics therefore 5

control the reuse opportunity (Hammer and Van Briesen, 2012). Reinjection for enhanced recovery is 6

a fairly common practice in the USA and elsewhere (Veil, 2015). In general, increased emphasis is 7

being placed on requirements for waste water reduction through reuse and recycling of hydraulic 8

fracturing fluids (Grout and Grimshaw, 2012). Desalination technologies are being developed to 9

control salinity and support reuse of waste waters (Koppelman et al., 2012). Examples of water reuse 10

and recycle management options and some of the specific uses are shown in the table below (Veil, 11

2015). 12

Table 6.2: Examples of water reuse and recycle management options and some of the specific uses (Veil, 13 2015). 14

Management

Option Specific Use Pros Cons

Reinjection for

enhanced

recovery

Water flood;

steam flood

Common use of produced

water for onshore

conventional formations.

Usually has low cost.

Need to ensure chemical

compatibility with receiving

formation

Injection for

future water use

Aquifer storage

and recovery

Can augment public water

supplies.

Need to ensure that water meets

drinking water standards before

injecting it into a shallow aquifer.

May encounter public opposition.

Oil and gas companies may not

choose this option due to fear of

future liability.

Injection for

hydrological

purposes

Subsidence

control

Can help solve a local

problem (e.g., Wilmington

Oil Field, Long Beach, CA).

Need to ensure chemical

compatibility with receiving

formation.

Agricultural use Irrigation;

subsurface drip

Can be a great benefit to arid

areas.

May need to treat the water before

applying it to the soil or add soil

Page 6-10

Management

Option Specific Use Pros Cons

irrigation supplements. May need to choose

salt-tolerant plant species.

Livestock and

wildlife watering

Can provide a source of

water for animals.

Need to ensure that water is clean

enough to avoid illness or other

impacts to animals.

Managed/construc

ted wetlands

Provides a “natural” form of

treatment. Creates a good

habitat for wildlife.

Large space requirements. Needs

extensive oversight and

management. Typically limited to

water with low to moderate salinity.

Industrial use Oil and gas

industry

applications (e.g.,

drilling fluids,

frac fluids)

Can substitute for fresh

water supplies in making

new drilling or stimulation

fluids.

May need treatment in order to meet

operational specifications.

Power plants May be able to supplement

cooling water sources

Will require treatment. The large

volumes needed result in collection

and transportation costs.

Other (e.g.,

vehicle wash, fire-

fighting, dust

control on gravel

roads; road de-

icing)

Can be a good supplemental

water supply in arid areas.

Will need storage facilities and

possibly treatment. Concerns about

water quality impacts from runoff

after application or inappropriate

application.

Treat to

drinking water

quality

Use for drinking

water and other

domestic uses

Can help supply water to

communities in arid areas.

Cost to treat may be high. Need

good quality control. May encounter

public opposition and face concern

over liability.

It may be more cost-effective and

energy-conserving to treat other

water sources like saline

groundwater rather than treating

produced water.

1

Pre-treatment could take place onsite, but this is currently very expensive (Koppelman et al., 2012). 2

Off-site reuse of untreated produced water is rare due to the high concentration of salts and the scaling 3

potential (Hammer and Van Briesen, 2012). 4

6.1.2.2 Treatment 5

Prior to disposing of or reusing water from fracking operations, different treatment processes and 6

technologies may be required (Veil, 2015). The quality requirement for the final disposition of the 7

water will determine the type and extent of treatment required. For example, if water is discharged, 8

the parameter of greatest concern can be related to either the organic content or the salt content to 9

meet the resource quality objectives. Treatment technologies designed to remove salts and other 10

inorganic compounds from produced water are listed in the Table below (Veil, 2015). 11

Page 6-11

Table 6.3: Treatment technologies designed to remove salts and other inorganic compounds from produced 1 water (Veil, 2015). 2

Technology Subcategory Pros Cons

pH adjustment,

flocculation, and

clarification

N/A This is a common

pretreatment step to remove

metals. The cost is modest.

This process removes metals

but does not treat chlorides or

TDS. The process generates

sludge that requires disposal.

Membrane processes Microfiltration,

ultrafiltration, and

nanofiltration

They are good pretreatment

steps for more advanced

processes like RO. They

operate at lower pressure and

lower cost than RO.

These levels of filtration cannot

remove most salinity.

Potential for membrane fouling.

Sensitivity to fluctuating water

quality.

Reverse osmosis

(RO)

RO can remove salinity (up to

about 40,000 mg/L TDS).

Requires pretreatment and

regular membrane cleaning. Not

suitable for high-salinity water.

Potential for membrane fouling.

Sensitivity to fluctuating water

quality. Moderate to high

energy usage and cost.

Other (e.g.,

electrodialysis,

forward osmosis)

May offer future treatment

opportunities.

Have not been used extensively

in full-scale oil field treatment

systems yet.

Potential for membrane fouling.

Sensitivity to fluctuating water

quality.

Thermal Treatment Distillation Can process high-salinity

waters like flowback.

Generate very clean water

(can be reused).

High energy usage and cost.

Generates concentrated brine

stream that requires separate

disposal. Potential for scaling.

May require remineralization

before release or beneficial

reuse.

Evaporation/

Crystallization

Can treat to a zero liquid

discharge standard.

High energy usage and cost.

Limited usage in oil field

applications. Potential for

scaling. Challenges in disposing

of salt residue.

Ion exchange N/A Successfully treats low to

medium salinity water (e.g.,

Powder River Basin).

Large acid usage. Resins can

foul. Challenges in disposing of

rinse water and spent media

(resin). Also ineffective on high

salinity produced waters.

Capacitive

deionization

N/A Low energy cost. Limited to treating low salinity

waters. Limited usage in oil

field applications.

3

Treatment technologies designed to remove oil and grease and other organics from produced water 4

are listed in the Table below (Veil, 2015). 5

Page 6-12

Table 6.4: Treatment technologies designed to remove oil and grease and other organics from produced water 1 water (Veil, 2015). 2

Technology Subcategory Pros Cons

Physical separation Advanced separators

(e.g., inclined plate,

corrugated plate)

Provide enhanced oil

capture compared to

basic oil/water separators

Work well for free oil,

but not as effective on

dispersed and soluble oil.

Performance can be

improved by adding

flocculants.

Hydrocyclone No moving parts results

in good reliability.

Separates free oil very

well.

Does not work well on

dispersed and soluble oil.

Filtration Different types of filter

media and filter

operations provide a

good range of oil and

grease removal.

Requires regular back-

flushing. Does not treat

most soluble oil.

Centrifuge Provides good separation

of free and dispersed oil.

More expensive than

other technologies in this

group.

Coalescence N/A Collects small oil

droplets and forms larger

droplets that can be more

easily removed by the

other technologies.

Limited value for

dispersed or soluble oil.

Flotation Dissolved air flotation,

induced gas flotation

Removes free and

dispersed oil.

Does not remove soluble

oil.

Combined physical and

extraction processes

Compact separators and

other units.

Can treat to very low oil

and grease levels.

Not used currently in

U.S. because its low

level of oil and grease is

not needed to meet U.S.

regulatory standards.

Solvent extraction Macro-porous polymer

extraction

Can treat to very low oil

and grease levels.

Not used currently in

U.S. because its low

level of oil and grease is

not needed to meet U.S.

regulatory standards.

Probably is very costly.

Adsorption Organoclay, activated

carbon, zeolites,

specialized polymers,

swelling glass.

Does a good job at

removing oil and grease.

Used primarily for

polishing.

Most types of media

cannot be reused or

regenerated – results in

large volume of solid

waste.

Oxidation Advanced processes

using combinations of

ozonation, cavitation,

and electrochemical

decomposition

Creates nearly sterile

brine

Has high energy input.

Limited use to date.

3

Page 6-13

Veil (2015) reports that new produced water technologies and products are being introduced to the 1

marketplace each month; the technologies listed in the Tables are major technology categories that 2

were in use in 2014. 3

4

Treatment is the most complex management option and can be done on- or off-site and in conjunction 5

with recycling, reuse, discharge and disposal. On-site treatment is designed for reuse only and will 6

incorporate the minimum treatment technology required for reuse without compromising the 7

chemistry of the hydraulic fracturing makeup water (Hammer and Van Briesen, 2012). 8

9

Desalination is possible, but is rarely necessary to produce water suitable for reuse in fracking 10

operations (Hammer and Van Briesen, 2012). Biofouling of membranes by organic material has 11

historically been responsible for the largest number of failures in reverse osmosis desalination 12

processes. Thus, effective pretreatment of oilfield-produced brines is necessary to prevent biofouling 13

and scaling of reverse osmosis membranes (Lee et al., 2002). 14

15

Treatment is predominantly done off-site and therefore requires transport of the waste water (Hammer 16

and Van Briesen, 2012). Off-site options and decisions are more complex and will require initial 17

analysis of the water to determine its fate. Regardless of its ultimate fate, preliminary treatment is 18

likely to be required (Hammer and Van Briesen, 2012). 19

20

The main contaminants to be removed during treatment are: 1) salts, including metals, 2) organic 21

hydrocarbons (sometimes referred to as oil and grease), 3) inorganic and organic additives, and 4) 22

naturally occurring radio-active materials (NORM). The treatment technology to employ can only be 23

determined through complete chemical analysis of the water. Significant concern has been raised 24

regarding the nature of the additives, with 29 identified as of particular concern for human health and 25

13 identified as probable or known human carcinogens (Hammer and Van Briesen, 2012). Among the 26

most notable are 2-butoxyethanol (2BE), naphthalene, benzene and polyacrylamide. A list of the 27

chemicals of concern present in fracking fluids is provided in Table 1 in the Addendum. 28

29

In the US, there are calls for operators to disclose fully the composition of the fracturing fluid 30

additives and it is already a requirement in the UK (DiGiulio et al, 2011; Koppelman et al., 2012) and 31

included in South African regulations (RSA, 2015a). 32

33

Shale gas operators in the US are known to have sent waste water to publicly owned treatment works 34

for treatment (Hammer and Van Briesen, 2012), but this practice has become controversial and has 35

been banned in some states, while other states require pre-treatment before discharge into publicly 36

owned treatment works (Grout and Grimshaw, 2012). In July 2011, 15 treatment facilities were 37

Page 6-14

exempted from compliance with the regulations, meaning that they were allowed to discharge treated 1

waste water with concentrations exceeding the TDS and chlorides limits. Nine of these facilities were 2

publicly owned waste water treatment plants. An alternative is treatment of produced water at 3

dedicated brine or industrial waste water facilities (Hammer and Van Briesen, 2012). The USEPA 4

has indicated that waste water treatment standards will be developed for shale gas waste water (Grout 5

and Grimshaw, 2012). 6

7

Treated water may be discharged, shipped back to the well site for reuse or diverted for beneficial 8

reuse or resource extraction, depending on the final quality (Hammer and Van Briesen, 2012). 9

6.1.2.3 Disposal 10

Direct disposal above ground or to soils in the near surface environment, on- or off-site was routine in 11

the early part of the 20th century, and the use of on-site unlined ponds and nearby off-site land 12

applications were common disposal practices (Hammer and van Briesel, 2012). These practices are 13

no longer used due to salt contamination in soils and aquifers. Produced water in the USA is often 14

disposed via underground injection into disposal wells (Hammer and Van Briesen, 2012; Shaffer et 15

al., 2013). A small fraction of produced waste is reportedly discharged to surface water, managed by 16

evaporation ponds, or beneficially reused outside the industry (Shaffer et al, 2013). Some states are 17

re-evaluating the practice of on-site land disposal of waste (Grout and Grimshaw, 2012). Field 18

evaluations on a subset of impoundments and pits used for waste and wastewater storage in the 19

Marcellus Shale development, found several construction and maintenance deficiencies related to the 20

containment systems and transport pipelines (Ziemkiewicz et al., 2014). 21

22

In some shale gas areas, operators manage waste at a centralised waste disposal facility that accepts 23

waste from multiple well sites (Koppelman et al., 2012; Grout and Grimshaw, 2012). These facilities 24

may be subject to general state requirements such as best management practices to protect human 25

health and the environment or to specific requirements such as an operating plan, water well 26

monitoring and storm water diversion (Grout and Grimshaw, 2012). Water disposal methods (Veil, 27

2015) are listed in the Table below. 28

29

Page 6-15

Table 6.5: Water disposal methods (Veil, 2015). 1

Technology Pros Cons

Discharge Very common for offshore

facilities. Offers moderate cost and

acceptable environmental impact,

where permitted.

Not approved for most onshore

wells. Where allowed, requires

treatment unless the water is high

quality, such as some CBM

effluent. Different treatment

requirements for discharges into

different types of water bodies.

Underground injection (other than

for enhanced recovery)

Very common onshore practice.

Tends to have low cost. EPA and

state agencies recognize this as a

safe, widely used, proven, and

effective method for disposing of

produced water.

Requires presence of an

underground formation with

suitable porosity, permeability, and

storage capacity. May require

treatment to ensure that injectate

does not plug formation. A small

subset of disposal wells has been

linked to felt earthquake activity –

this is an active area of research.

Transportation costs can be

significant.

Evaporation In arid climates, takes advantage

of natural conditions of humidity,

sun, and wind.

Not practicable in humid climates.

May create air quality and salt

deposition problems.

Offsite Commercial disposal Companies providing services to

oil and gas community by

accepting and disposing water for

a fee. Removes water treatment

burden from the operator.

Requires infrastructure (disposal

facilities and transportation

network to move water to disposal

site). Can be costly. Potential for

Superfund liability.

6.1.2.4 Beneficial reuse 2

The beneficial reuse of oil and gas brines has a long history in the USA. For low-TDS water 3

beneficial reuse options include livestock watering, aquaculture and hydroponic vegetable culture, 4

irrigation of crops, washing of equipment and fire control. None of these opportunities exist for waste 5

water from highly saline formations like the Marcellus Shale. The unique mixture of chemicals in 6

treated hydraulic fracturing waste water, has not yet been studied with respect to its uptake into crops 7

(Shariq, 2013). However, according to Shariq (2013) arsenic, one of the known toxic inorganic 8

constituents in the wastewater, has been shown to bio-accumulate throughout rice plants, and organic 9

hydrocarbons have also been identified in wheat plants grown in contaminated soil. 10

11

6.2 Special features of the Karoo in relation to waste 12

There are currently no specialized hazardous waste disposal or treatment facilities in the Karoo. The 13

spatial distribution of waste water treatment and solid waste disposal facilities in the study area is 14

illustrated in the map below. Eden District Municipality is in the process of building a Class B 15

Page 6-16

regional waste disposal site with a hazardous waste cell that will be able to accept Type 2 hazardous 1

waste from 2017. The hazardous waste generated by hydraulic fracturing is likely to be Type 1 2

hazardous waste which will not be allowed at the new Eden regional waste disposal facility. All Type 3

1 hazardous waste will therefore have to be trucked to a suitably designed and authorized hazardous 4

waste disposal site in Port Elizabeth or Cape Town. Although the PetroSA landfill in Mossel Bay is 5

also licensed to accept Type 1 hazardous waste, it is not a commercial facility and therefore would 6

require the consent of the permit holder and the relevant authorities to be used for disposal of waste 7

from fracking activities. Construction of a new on-site or centralized disposal facility could be 8

considered for large scale development and production subject to a full EIA and approval of a 9

disposal site licence under the Waste Act (Act 56 of 2008). 10

11

12

Figure 6.1: Map of the study area showing waste facilities for general landfills and Waste Water Treatment 13 Works 14

15

Facilities for the disposal of domestic solid waste, generated by workers deployed to the study area 16

and opportunistic migrants, are limited to small and communal disposal sites (Table 2 in Addendum). 17

As at 2007, only twelve sites were estimated to have 15 years or more airspace remaining (DEAT, 18

2007), the other sites are likely to be filled up by now. Recycling initiatives in the Karoo are limited 19

due to relative low volumes and large transport distances to markets for recyclables. 20

21

Waste water infrastructure in the study area is limited to municipal owned treatment works (see 22

Table 3 in Addendum). The majority of these facilities is placed under regulatory surveillance or 23

Page 6-17

requires immediate interventions (DWS, 2014). The ‘risk’ associated with municipal waste water 1

treatment facilities relates to design capacity (including the hydraulic loading into the receiving water 2

body), operational flow (exceeding, on or below capacity), and number of non-compliance trends in 3

terms of effluent quality (discharged into the receiving environment) and compliance or non-4

compliance in terms of technical skills (DWS, 2014). Waste water generated by shale gas exploration 5

and development will therefore have to be transported (trucked or piped) to suitable facilities further 6

afield or on-site treatment facilities will have to be established. The volumes during the exploration 7

phase (Phase 1) will be too small for pipelines and therefore transportation by truck will be the only 8

option. During exploitation (Phase 2) the ideal would be to have local (possibly mobile) waste water 9

treatment facilities to minimize fluid transport movement and distances in line with clause 117(a) of 10

the Petroleum Exploration and Production Regulations (RSA, 2015a). 11

6.3 Relevant legislation, regulation and practice 12

Applicable legislation to shale gas exploration and development in South Africa has been 13

promulgated by the Department of Mineral Resources, Department of Water and Sanitation and the 14

Department of Environmental Affairs. The Department of Mineral Resources is responsible for the 15

sustainable development of South Africa’s mineral and petroleum resources within the framework of 16

national environmental policy, norms and standards while promoting economic and social 17

development (RSA, 2002). The Department of Environmental Affairs is the lead agent for the 18

protection of the environment (RSA, 1998a) and waste management (RSA, 2008) while the 19

Department of Water Affairs is the public trustee of the nation’s water sources (RSA, 1998). 20

6.3.1 Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) 21

The objective of the Mineral Resources and Petroleum Development Act, 2002 (Act 28 of 2002) is 22

amongst other to “give effect to section 24 of the Constitution by ensuring that the nation’s mineral 23

and petroleum resources are developed in an orderly and ecologically sustainable manner while 24

promoting justifiable social and economic development” (RSA, 2002). 25

26

Page 6-18

Regulation 466 for Petroleum Exploration and 1

Production (RSA, 2015a) requires, amongst other, the 2

following measures to prevent environmental contamination 3

from SGD: 4

Clause 91 Suitably designed impermeable site5

underlay systems and site drainage 6

arrangements. 7

Clause 109 Drilling fluids must be declared 8

through material safety data sheets. 9

Clause 112(8) (g) Proppants must be tagged with 10

radioactive isotopes so that proppant can be 11

analysed to locate where different stages of 12

the proppant went and to locate fractures at 13

depth. 14

Clause 112(8) (h) Chemical tracers must be added to 15

improve the understanding of fracture fluid 16

loss and flowback. 17

Clause 113 Hydraulic fracturing fluid disclosure 18

including prohibition of substances listed in 19

schedule 1. 20

Clause 115 Fracturing fluids management through a risk management plan. 21

Clause 116 Management of flowback and produced fluids through an approved waste 22

management plan. 23

Clause 117 An approved fluid transportation plan, planning to minimize fluid transport 24

movements and distances. 25

Clause 118 Fluid storage: at the well site and centralized storage for potential reuse prior to 26

disposal, hydraulic fracturing additives, hydraulic fracturing fluids, flowback and 27

produced water must be stored in above-ground tanks with lined bund walls. 28

Clause 123(3) Re-use of hydraulic fracturing fluids and produced water from operation on site or 29

from neighbouring operations must be considered to reduce competition with 30

freshwater uses. 31

Clause 124(1) Waste must be disposed of in accordance with applicable legislation. 32

Clause 124(2) Waste containing radioactive materials must be managed in accordance with 33

National Radioactive Waste Disposal Institute Act, 2008 (Act 53 of 2008). 34

Clause 124(3) Liquid waste must be disposed of at an approved waste treatment facility in 35

accordance with relevant legislation and disposal of liquid waste at domestic waste 36

Chemical Components of concern

listed in Schedule 1:

Methanol (Methyl), Ethylene glycol

(1,2-), Diesel, Naphthalene, Xylene,

Hydrogen chloride, toluene,

Ethylbenzene, Diethanolamine (2,2-

iminodiethanol) Formaldehyde,

Sulphuric acid, Thoreau, Benzyl

chloride, Cumene, Nitrilotriacetic acid,

Dimethyl formamide, phenol, Benzene,

Di (2-), Acrylamide, Hydrogen

fluoride, Phthalic anhydride,

Acetaldehyde, Acetophenone, Copper,

Ethylene oxide, Lead, Propylene oxide,

p-Xylene, 1-Methylnaphtalenel, 2-

Butanone, Aniline, 2-Methylphenol, 3-

Methylphenol, 4-Methylphenol,

Acetonitrile, Thiophene, Pyrrole, 2-

Methylnaphthalene, Benzidine,

Isophorone, Chloroethane, 2-

pyrrolidone, Vinyl chloride,

Bromomethane, Acetone, 2-Hexanone

Page 6-19

water treatment facilities must only take place after prior consultation with the 1

department responsible for water affairs. 2

Clause 124(4) Disposal to underground, including the use of re-injection disposal wells, is3

prohibited. 4

Clause 124(5) Discharge of hydraulic fracturing fluids, hydraulic fracturing flowback, and produced 5

water into surface water course is prohibited. 6

Clause 124(6) Annular disposal of drill cuttings or fluids is prohibited. 7

Clause 124(7) Drill cuttings and waste mud must be temporarily stored in above-ground tanks. 8

Clause 124(8) Solid waste generated during operations must be categorized and disposed of 9

accordingly at a licensed landfill site or treatment facility. 10

Clause 125 A waste management plan must be prepared and approved as part of the application 11

for Environmental Authorisation. 12

6.3.2 National Environmental Management Act, 1998 (Act 107 of 1998) 13

This act sets out the fundamental principles that apply to environmental decision making. The core 14

environmental principle is the promotion of ecologically sustainable development. Principles 15

referring to waste and pollution include: 16

That pollution and degradation of the environment are avoided or where they cannot be 17

altogether avoided, are minimised and remedied 18

That waste is avoided, or where it cannot be altogether avoided, minimized and re-used or 19

recycled where possible and otherwise disposed of in a responsible manner 20

Decisions must be taken in m open and transparent manner, and access to information must 21

be provided in accordance with the law 22

The cost of remedying pollution, environmental degradation and consequent adverse health 23

effects and of preventing, controlling or minimizing further pollution, environmental damage 24

or adverse health effects must be paid for by those responsible for harming the environment 25

26

Waste management activities that have, or are likely to have, a detrimental effect on the environment 27

as listed in Regulation 921 of 29 November 2013 (RSA, 2013c) are subject to the Environmental 28

Impact Assessment Regulations made under section 24(5) of the National Environmental 29

Management Act, 1998 as part of a waste management licence application under the National 30

Environmental Management: Waste Act, 2008. 31

32

Relevant regulations under NEMA: 33

Environmental Impact Assessment Regulations (Regulation 982 of 4 December 2014) 34

Page 6-20

Regulations pertaining to the financial provisions for prospecting, exploration, mining or 1

production operations (Regulation 1147 of 29 November 2015). 2

6.3.3 National Environmental Management: Waste Act, 2008 (Act 56 of 2008) 3

South Africa has an integrated pollution and waste management policy that is driven by a vision of 4

environmentally sustainable economic development by amongst other, preventing and minimising, 5

controlling and remediating pollution and waste to protect the environment from degradation (DEAT, 6

2000). Waste management in South Africa is informed by the waste management hierarchy which 7

outlines waste management options covering the lifecycle of waste, in descending order of priority: 8

waste avoidance (prevention and minimization), reuse and recycling, recovery, waste treatment and 9

disposal as last resort (DEA, 2012). 10

11

Waste legislation in South Africa is emerging and constantly changing. The National Environmental 12

Management: Waste Act, 2008 (NEMWA) is the first law in South Africa dedicated to waste and a 13

number of new strategies and regulations under this act are currently under development. 14

15

Waste management activities that may require a licence in terms of NEMWA are listed in Regulation 16

921 of 29 November 2013 (RSA, 2013c) and Regulation 633 of 24 July 2015 (RSA, 2015b). These 17

activities include: 18

Storage of general waste in lagoons and storage of hazardous waste in lagoons excluding 19

storage of effluent, waste water or sewage 20

Recycling or recovery of waste 21

Treatment of waste 22

Disposal of waste 23

Construction, expansion or decommissioning of facilities and associated structures and 24

infrastructure 25

Establishment or reclamation of a residue stockpile or residue deposit resulting from activities 26

which require a prospecting right or mining permit in terms of the Mineral and Petroleum 27

Resources Development Act, 2002 (Act 28 of 2002) 28

29

Depending on the size, handling capacity and the type of waste to be managed at the facility, a basic 30

assessment or full environmental impact assessment set out in the Environmental Impact Assessment 31

regulations under Section 24(5) of the National Environmental Management Act, 1998 (Act 107 of 32

1998) will be required as part of the licence application process. 33

34

Applicable regulations under NEMWA include: 35

Page 6-21

Waste Information regulations (Regulation 625 of 13 Aug 2012) 1

Waste Classification and Management Regulations (Regulation 634 of 23 Aug 2013) 2

National Norms and Standards for the Assessment of Waste for Landfill Disposal (Regulation 3

635 of 23 Aug 2013) 4

National Norms and Standards for Disposal of Waste to Landfill (Regulation 636 of 23 Aug 5

2013) 6

List of Waste Management Activities that have or are likely to have a detrimental impact on 7

the Environment (GN 921 of 29 Nov 2013) 8

National Norms and Standards for Storage of Waste (GN 926 of 29 Nov 2013) 9

Regulations regarding the planning and management of residue stockpiles and residue 10

deposits from a prospecting, mining, exploration or production operation (Regulation 632 of 11

24 July 2015) 12

Amendments to the list of waste management activities that have or are likely to have a 13

detrimental effect on the environment (Regulation 633 of 24 July 2015). 14

15

NEMWA and its regulations will not be able to 16

adequately deal with the waste from SGD. Site specific 17

waste management licences are required for each waste 18

activity requiring a licence. Multiple storage and 19

treatment facilities will potentially attract the need for 20

multiple licence applications each with a requirement 21

for an EIA at scoping or full assessment level which will 22

add cost and time delays in obtaining authorisations. 23

Waste classification regulation stipulate that waste must 24

be kept separate for purposes of classification, and must 25

be “re-classified within 30 days of modification to the 26

process or activity that generated the waste, changes in 27

raw materials or other inputs, or any other variation of 28

relevant factors” (RSA, 2013). 29

6.3.4 National Water Act, 1998 (Act 36 of 1998) 30

The National Water Act, 1998 (NWA), provides 31

regulatory and market based instruments to manage the 32

impacts on water quality. These instruments include 33

licensing of water uses (NWA, Section 21), including 34

disposal of waste, which may impact on water resources 35

National Water Act, 1998,

Section 21 Waste Discharge related

water use

Engaging in a controlled activity

(where the controlled activity

relates to waste discharge

activities)

Discharging waste or water

containing waste into a water

resource

Disposing of waste in a manner

which may detrimentally impact

on a water resource

Disposing in any manner of water

which contains waste from, or

which has been heated in, any

industrial or power generation

process

Altering the bed, banks, course or

characteristics of a water course

(where such activities have

impacts on the water quality of the

water course)

Removing, discharging or

disposing of water found

underground if it is necessary

Page 6-22

and waste discharge charges in line with the “polluter pays” principle (DWA, 2009). 1

2

Water used in excess of the limits specified in Schedule 1 and General Authorisation notices will 3

require a water use licence. The Minister may however dispense with the requirement for a licence 4

under the NWA (Section 22(3)) by issuing a Record of Decision which is then incorporated in the 5

waste licence issued under NEMWA. 6

7

Several water uses can be covered by one integrated water use licence. The integrated water use 8

licence will prescribe conditions for the management, monitoring and reporting relating to the water 9

use. An integrated water and waste management plan is a typical requirement of a water use licence. 10

11

The Pricing Strategy as amended (RSA, 2015) provides for six water use categories including 12

fracking (as illustrated below) to represent the user groups and to allow for clearly targeted charges. 13

Charges will be calculated based on the volume of the wastewater discharged from a point source, and 14

on the degree of management activity required for non-point source registered users. Cost allocations 15

will be based on: 16

Point source discharge – management effort for point discharges, attracting all waste 17

discharge related costs 18

Waste disposal to facilities/land – management effort for waste disposal to land, attracting all 19

waste discharge related activity costs 20

Irrigation of land with water containing waste – Management effort for irrigated effluent, 21

attracting all waste discharge related activity costs. 22

23

24

Page 6-23

Figure 6.2: Water use categories as defined by the Pricing Strategy (RSA, 2015). 1 2

Relevant regulations under NWA: 3

Regulations on the use of water for mining and related activities aimed at the protection of 4

water resources (Regulation 77 of 12 February 2010). 5

6.3.5 National Nuclear Regulator Act, 1999 (Act 47 of 1999) 6

NORM waste will be regulated under this act. The National Nuclear Regulator document RD-004 7

Requirements Document on the Management of Radioactive waste associated with waste products 8

from facilities handling NORM (2007) describes how NORM waste must be managed. 9

6.3.6 National Road Traffic Act, 1996 (Act 93 of 1996) 10

Vehicles transporting dangerous goods (including hazardous waste) must adhere to SANS 10228 in 11

terms of identification and classification of goods and display the relevant signage. 12

In terms of Section 76 of the National Road Traffic Act, 1996 the following standards are deemed to 13

be regulations: 14

15

SANS 10228: Identifies and classifies each of the listed dangerous goods and substances and set out 16

information including the United Nations Number, the correct shipping name, hazard class assigned 17

and other information pertinent to the substance. 18

19

SANS 10229: Contains information on acceptable packaging for dangerous goods and substances and 20

also include requirements for the testing of packaging and the correct marking and labelling of 21

packages. 22

23

SANS 10230: Includes statutory vehicle inspection requirements for all vehicles conveying dangerous 24

goods. This code stipulates the safety aspects of both the vehicle and the goods containment. 25

Minimum inspection requirements by both in-house and outside agencies are listed. 26

27

SANS 10231: This code of practice prescribes the operation rules and procedures for transporting 28

Dangerous Goods and Hazardous Materials. It also includes the prescribed responsibilities of the 29

owner/operator of the dangerous goods vehicle. It outlines the information required and who will have 30

to supply information for the safe conveyance of dangerous goods. The requirements for the drafting 31

and formulating of an operational agreement are also specified. This code also requires the 32

owner/operator or vehicle to be registered as dangerous goods carrier. It is also prescribed that the 33

Page 6-24

owner operator has available adequate insurance cover for civil liability as well as pollution and 1

environmental rehabilitation cover in the event of an incident. 2

3

SANS 10232-1: 2007: This code includes details of new placarding requirements for vehicles 4

transporting dangerous goods and the individual or substance exempt quantities and the compatibility 5

requirements of mixed loads. Part 3 of this code contains information on the Emergency Response 6

Guides to be used in case of an incident or accident. 7

6.3.7 Disaster Management Act, 2002 (Act 57 of 2002) 8

This act provides for an integrated and coordinated disaster management policy that focuses on 9

preventing or reducing the risk of disasters (natural or human induced) mitigating the severity of 10

disasters, emergency preparedness, rapid and effective response to disasters and post-disaster 11

recovery. 12

6.4 Key potential impacts and their mitigation 13

Waste-generating pathways and handling options, include inter alia drilling fluids, drilling muds, 14

fracturing fluids, lubricating oils and greases, contaminated land (spills on-site), domestic waste, 15

sewage, construction waste etc. The expected volumes of waste generated during the different 16

scenarios for SGD in the Karoo is summarized in Chapter 1. Composition of the waste is important in 17

terms of classification and management of the waste - it is likely that most of the waste will be Type 1 18

hazardous waste. Disclosure of the hydraulic fracturing fluids in terms of chemical and concentration 19

by mass, as provided for in Clause 113 of Regulation 466 (RSA, 2015a) will assist in the accurate 20

classification of the waste. Prohibition of certain chemicals, as listed in Schedule 1 of Regulation 466 21

(RSA, 2015a), will limit the toxicity of the waste and thereby also the potential risk to the 22

environment and human health. The National Nuclear Regulator (NNR) is an important player for 23

low-level radio-active waste. 24

25

Municipalities will not be able to cope with additional waste loads (municipal solid waste and waste 26

water) at their facilities (landfill and sewage plants) (refer to Table 2 and 3 of the Addendum) due to 27

limited capacity and technical expertise in municipalities. Similarly, technical knowledge on the 28

specialized waste streams from SGD will need to be developed at national and provincial government 29

level to ensure informed decision making and enforcement of legislation. 30

31

Literature findings suggest that surface spills and leakages from holding ponds, tank battery systems 32

and transport of chemicals and waste materials are important routes of potential ground and surface 33

Page 6-25

water contamination from hydraulic fracturing activities (Grout and Grimshaw, 2012; Gross et al., 1

2013; Ziemkiewicz et al., 2014). Sources of spills at the wellsite include the drill rig and other 2

operating equipment, storage tanks, impoundments or pits, and leaks or blowouts at the wellhead 3

(Grout and Grimshaw, 2012). Leaks or spills may also occur during transportation (by truck or 4

pipeline) of materials and wastes to and from the well pad. The primary risk of uncontrolled releases 5

is generally to surface and groundwater resources (Grout and Grimshaw, 2012). Mitigation measures 6

to prevent pollution from spills include impermeable site underlay (Clause 91 Regulation 466) and 7

lined bund walls around storage tanks (Clause 118(3) Regulation 466) (RSA, 2015a). Constituents of 8

particular concern include benzene, toluene, ethylbenzene and xylene which, at sufficient doses, have 9

been associated with adverse human health effects (Osborn et al., 2011) and arsenic (Grout and 10

Grimshaw, 2012). These constituents of concerns have all been banned from being allowed as 11

additives to fracturing fluids (Schedule 1, Regulation 466) (RSA, 2015a). 12

13

Three important characteristics of an incident will determine the severity of its consequences – 14

volume, degree of containment and characteristics of the material (wastewater or waste) (Grout and 15

Grimshaw, 2012). It is therefore important to provide secondary containment for areas of fuel and 16

fracturing fluid chemicals storage, loading and unloading areas, and other key operational areas 17

(Grout and Grimshaw, 2012) including waste and waste water storage, treatment and disposal sites. 18

Such containment areas are already prescribed in Clause 118(3) of Regulation 466 (RSA, 2015a). 19

6.4.1 On-site storage 20

Maximising recycling and reuse of flowback water will reduce the amount chemicals and need for 21

clean water, but may increase the volume of waste and waste water to be stored on-site and may 22

increase the potential impacts. The mitigation measures to implement will include barrier and 23

containment systems such as impermeable site linings, bunding and using non-hazardous chemicals 24

where possible (Koppelman et al., 2012). All these measures are already prescribed in Regulation 25

466 (RSA, 2015a). Minimising design, construction and maintenance problems associated with: out-26

slope berm stability, uncontrolled groundwater seepage, geomembrane liner puncture, and tear 27

potential from improper site preparation and maintenance (Ziemkiewicz et al., 2014). In this regard, 28

Regulation 466 already prescribes above-ground storage tanks for all liquids, liquid waste, drill 29

cuttings and waste mud (RSA, 2015a). Secondary containment is a best management practice where 30

the tank sits within a tray-like structure with raised sides or berms such that materials released during 31

a tank rupture would be contained (Hammer and Van Briesen, 2012). Clause 118 of Regulation 466 32

stipulate a containment capacity to hold the volume of the largest container stored on-site plus 10% to 33

allow for precipitation, unless the container is equipped with individual secondary containment (RSA, 34

2015a). 35

Page 6-26

6.4.2 Liquid Waste Treatment 1

Liquid waste must be disposed of at an approved waste treatment facility in accordance with relevant 2

legislation (RSA, 2015a). The designated treatment works must have capacity to accept the load and 3

volume of waste water to be treated and must be duly authorized to receive the waste water from 4

fracking operations. Technologies must be appropriate for the quality of the waste water received and 5

it must be able to produce the required discharge quality. Waste water treatment technology choice 6

must be based on the degree and surety of removal of constituents required. Pre-treatment may also 7

be required depending on the treatment technology selected and the objectives to be met (DWAF, 8

2007). 9

10

It is expected that treatment of liquid waste could potentially be dealt with by modular, on-site, 11

containerized treatment facilities which are commercially available. Disposal of liquid waste at 12

domestic waste water treatment facilities must only take place after prior consultation with and 13

approval by the department responsible for water affairs (RSA, 2015a). 14

6.4.3 Off-site management and disposal 15

The current off-site disposal options for Type 1 hazardous wastes are limited to two licensed 16

commercial hazardous waste treatment facilities in Port Elizabeth and Cape Town and possibly the 17

private PetroSA hazardous waste landfill in Mossel Bay, provided that the relevant authorities and 18

landfill owner approve. Municipal wastewater treatment works in the study area do not have the 19

capacity or required technologies to treat the waste water from this process. It is therefore likely that 20

the waste water will also have to be trucked to a suitable off-site facility for treatment. Key potential 21

impacts from off-site management and disposal relates to the transport of the waste and waste water 22

by road or pipelines. Construction and maintenance deficiencies related to transport pipelines, or road 23

accidents if the waste or waste water is transported off site by road need to be mitigated (Ziemkiewicz 24

et al., 2014). Mitigation measures relating to pipelines will include proper design, construction and 25

placement of liquid transfer piping (Ziemkiewicz et al., 2014). It is also imperative that inadequate 26

capacity, treatment technologies and human resources at municipal treatment and disposal facilities be 27

addressed to ensure that additional loads of municipal solid waste and sewage can be handled 28

appropriately. 29

30

Whether to have central processing facilities or have those in conjunction with well pads, is a decision 31

that needs to be taken for each specific development, based on minimizing the overall negative impact 32

from the development (DNV, 2013). A centralised waste disposal facility for Type 1 hazardous waste 33

may be considered for full scale SGD. Site selection for establishing a disposal facility will involve 34

elimination of areas with associated fatal flaws, identification of candidate sites, based on site 35

Page 6-27

selection criteria, ranking of candidate sites and carrying out a feasibility study on the best option 1

(DWAF, 1998a). Site selection criteria include: 2

Economic criteria 3

Environmental criteria 4

Public acceptance criteria 5

6

Establishment and authorization of such a facility will require a full EIA, and meeting the design 7

requirements as outlined in the Norms and Standards for disposal of waste to landfill (Regulation 636 8

of 23 August 2013). 9

10

Processing facilities for solid waste and waste water must be designed and constructed to meet the 11

following criteria (DNV, 2013): 12

Design and construction will be in compliance with applicable standards 13

Design and construction will be to achieve effective utility according to anticipated life-time 14

and future development prospects 15

Processing facilities should as far as reasonably practicable be placed in the terrain in such a 16

way that any impact on vulnerable areas is minimized 17

Shall have area space and load bearing capacity to cater for processing systems and 18

equipment 19

Shall have appropriate spill control measured in place 20

6.4.4 Deep well injection 21

Deep well injection is a common disposal option in the USA, but due to the South African geology 22

and legal framework, it is not an option in South Africa. Regulation 466 for Petroleum Exploration 23

and Production (Clause 124(4)) prohibits disposal to underground, including the use of re-injection 24

disposal wells (RSA, 2015a). 25

6.4.5 Surface water discharge 26

Discharge of hydraulic fracturing fluids, hydraulic fracturing flowback, and produced water into a 27

water source is prohibited in terms of Clause 124(5) of Regulation 466 (RSA, 2015a). Treated 28

surplus water not recycled back into the operations may be discharged into surface water resources 29

provided that it meets quantity and quality limits stated in the applicable water use licence. There is a 30

risk of pollution of surface and ground water sources if the water quality does not meet the required 31

discharge standards. Residuals that are likely to be released to surface water include TDS and the 32

monovalent ions sodium, chloride, and bromide (Hammer and Van Briesen, 2012). Mitigation 33

Page 6-28

measures to ensure meeting water quality requirements will include alternative use options for the 1

waste water, treatment to prescribed standards, as specified in General Authorisations or applicable 2

licence, before discharge (this may require some form of pre-treatment as well) and regular 3

maintenance of treatment works. Regular water quality testing of effluent before discharge and 4

regular downstream water quality monitoring will also be required. Development of norms and 5

standards specific for discharge of treated shale gas flowback and produced water in the Karoo may 6

be required to ensure equal and adequate protection of all the water resources and associated 7

ecosystems in the study area. 8

6.4.6 Land application 9

Application of produced water to roads for dust control has several potential negative impacts 10

including: surface and groundwater deterioration, soil contamination, toxicity to soil and water biota, 11

toxicity to humans during and after application, air pollution from volatile dust suppressant 12

components, accumulation in soils, changes in hydrologic characteristics of soil, and impacts on 13

native flora and fauna populations (Hammer and Van Briesen, 2012). Areas with shallow ground 14

water resources may also be at risk of pollution if the quality of the water used in land application is 15

not sufficient. Mitigation of these negative impacts will be to treat the water to acceptable standards 16

before land application and continued monitoring. Norms and standards for land application of waste 17

water from SGD may be required to ensure adequate protection of the water resource and ecosystems 18

from potential impacts associated with land application of waste water. 19

6.4.7 Spills 20

The impact of spills of fracturing fluids (or waste water) onsite can be mitigated using established best 21

practices such as installing impermeable site linings, bunding and using non-hazardous chemicals 22

where possible (Koppelman et al., 2012). These requirements are already included in Regulation 466 23

of 3 June 2015. The impacts of spills resulting from transport incidents can be mitigated by 24

prescribing transport routes, limiting the transport distance as far as possible as envisaged by 25

Regulation 466 of 3 June 2015 and having spill response units on stand-by in the study area. 26

6.4.8 Residuals management 27

Regardless of the treatment options selected, residuals – the concentrated brines and solids containing 28

the chemicals removed from the produced water, and sludge – will be treated as a waste. Since 29

chemicals present in the residual wastes are present at higher concentrations than in the original 30

produced waters, careful management is essential. Solids and sludges generated in treatment plants 31

for produced water should be disposed of in landfills with adequate protection against the formation 32

Page 6-29

of subsequent brines in the leachate. The only mitigation measure for this waste will be to dispose of 1

the waste at a duly authorized landfill site, designed, constructed and operated in line with the 2

National Norms and Standards for disposal of waste to landfill. 3

6.5 Risk assessment 4

6.5.1 How risk is measured 5

Assessment of risk associated with waste and potential impacts on human health and the environment 6

must take into account all properties that are related to exposure within the environment (DWAF, 7

1998), such as: 8

Biodegradability 9

Persistence 10

Bioaccumulation 11

Chronic toxicity 12

Concentration 13

Production volume 14

High dispersion 15

Leakage to the environment 16

Risks associated with disposal of waste water sludges relate to sludge stability, disposal site design 17

and location, the constituents in the sludge and their hazardousness, possible groundwater pollution, 18

pollution of surface run-off as well as valuable land surface area taken up by surface disposal 19

(DWAF, 2007). 20

6.5.2 Limits of acceptable change 21

All waste water is treated to required standards to optimize reuse opportunities (on and off-site) 22

towards minimizing the requirement for fresh water resource use. Excess water that cannot be reused 23

is treated to a suitable quality for release back into a water resource without impacting negatively on 24

the receiving environment. 25

26

All waste generated as a result of SGD is managed in line with the waste management hierarchy and 27

the principles of integrated waste management to ensure sustainable development with due regard for 28

environmental protection. 29

6.5.3 Risk Matrix 30

Table 6.6: Risk Matrix. 31

Page 6-30

Impact Locatio

n

Scenari

o

Without mitigation With mitigation

Consequenc

e

Likelihoo

d

Risk Consequenc

e

Likelihoo

d

Ris

k

Exposure

to

hazardous

waste

(Sludge,

mud, drill

cuttings,

flowback

and

produced

water)

Near

disposal

or

spillage

site

Scen 0 Moderate Not likely Low

Risk

Slight but

noticeable

Not likely Very

low

risk

Scen 1 Substantial Very likely Moderat

e risk

Moderate Very likely Low

risk

Scen 2 Severe Very likely High risk Moderate Very likely Low

risk

Scen 3 Severe Very likely High risk Moderate Very likely Low

risk

Exposure

to

domestic

waste

Municipal

landfill

Scen 0 Moderate Likely Low risk Slight but

noticeable

Likely Very

low

risk

Scen 1 Moderate Likely Low risk Slight but

noticeable

Likely Very

low

risk

Scen 2 Moderate Very likely Low risk Slight but

noticeable

Very likely Very

low

risk

Scen 3 Severe Very likely High risk Moderate Very likely Low

risk

Additiona

l sewage

load at

already

stressed

WWTW

Municipal

WWTW

Scen 0 Moderate Very likely Moderat

e risk

Moderate Very likely Low

risk

Scen 1 Substantial Very likely Moderat

e risk

Moderate Very likely Low

risk

Scen 2 Severe Very likely High risk Moderate Very likely Low

risk

Scen 3 Severe Very likely High risk Moderate Very likely Low

risk

1

Risk associated with the transport of the waste and waste water is assessed in the Chapter 18. 2

6.5.4 Best practice guidelines and monitoring requirements 3

According to the Council of Canadian Academies (2014) appropriate environmental monitoring 4

approaches for the anticipated level of SGD have not yet been identified. Monitoring programs will 5

have to be adapted to advances in technologies and to the location, scale, and pace of the SGD. 6

Best practice guidelines of relevance to this study include: 7

Best practice guideline No H4: Water Treatment (DWAF, 2007) and 8

Guidelines for the utilization and disposal of wastewater sludge: 9

National Norms and Standards for the Assessment of Waste for Landfill Disposal (Regulation 10

635 of 23 Aug 2013) 11

National Norms and Standards for Disposal of Waste to Landfill (Regulation 636 of 23 Aug 12

2013) 13

National Norms and Standards for Storage of Waste (GN926 of 29 Nov 2013) 14

Page 6-31

Minimum Requirements for the Monitoring of Water Quality at Waste Management 1

Facilities. (DWAF, 1998b) 2

6.5.4.1 Best Practice Guideline No H4: Water Treatment 3

These guidelines (DWAF, 2007) outline a water treatment plant evaluation and selection process to 4

assist decision makers in selecting an appropriate technology for their specific requirements. It 5

describes in a fair amount of detail the differences between different treatment technologies including 6

benefits and constraints of each technology option. The guidelines also touch on the characteristics of 7

residue streams and provide some guidance on possible disposal options for the residue streams. 8

Costs associated with the disposal of residues/sludges include disposal costs (based on volume and 9

nature) and transportation cost (transportation distance to disposal site). 10

6.5.4.2 Guidelines for the Utilisation and Disposal of Wastewater Sludge 11

The development of the sludge guidelines (Herselman and Snyman, 2007) was commissioned by the 12

Water Research Commission to encourage the beneficial use of wastewater sludge. It is however 13

recognized that beneficial use of waste water sludge is not always feasible. A separate Guideline 14

Volume dealing with each of the management options were therefore developed as follows: 15

Volume 1: Selection of management options 16

Volume 2: Requirements for the agricultural use of sludge 17

Volume 3: Requirements for the on-site and off-site disposal of sludge 18

Volume 4: Requirements for the beneficial use of sludge 19

Volume 5: Requirements for thermal sludge management practices and for commercial 20

products containing sludge 21

22

The quality and classification of the sludge is the determining factor in selecting the best management 23

option. 24

6.5.4.3 National Norms and Standards for Assessment of Waste for Landfill Disposal 25

The assessment of waste for the purpose of disposal to landfill requires a full chemical analysis of the 26

waste and laboratory analysis to determine the total concentrations (TC) and leachable concentrations 27

(LC) of the elements and chemical substances contained in the waste (RSA, 2013a) . The TC and LC 28

limits must then be compared to the threshold limits specified in the norms and standards to determine 29

the type of waste. All analyses must be done at accredited laboratories. 30

Page 6-32

6.5.4.4 Norms and Standards for Disposal of Waste to Landfill 1

The norms and standards for disposal of waste provides for four different classes of landfills based on 2

their containment barrier designs parameters. Waste acceptance criteria for landfill is based on the 3

Type of waste and the class of landfill as outlined in Clause 4 of Regulation 636 (RSA, 2013b). 4

6.5.4.5 National Norms and Standards for Storage of Waste 5

These standards apply to any person who store general or hazardous waste in a waste storage facility 6

irrespective of whether a waste management licence is required or not. Waste storage facilities must 7

be registered with the competent authority. Location of hazardous waste storage facilities must be 8

within an industrial demarcated zone or must have a buffer zone of at least 100 meter unless there is a 9

prescribed buffer zone by the relevant municipality and must be located in areas accessible to 10

emergency response personnel and equipment (RSA, 2013d). 11

12

Liquid waste storage areas must have firm, impermeable, chemical resistant floors and a roof. Liquid 13

waste containers that are not stored under a roof must be coated to prevent direct sunlight and rain 14

from getting into contact with the waste. There are also requirements for liquid storage areas to be 15

surrounded by an interception trench with a sump and a secondary containment system (i.e. bund, drip 16

tray) (RSA, 2013d). 17

18

Hazardous waste storage facilities must have impermeable and chemical resistant floors (RSA, 19

2013d). 20

21

These norms and standards also prescribe access control and notices as well as operational 22

requirements. There are also prescribed minimum requirements for above ground waste storage tanks 23

(Clause 11) (RSA, 2013d). 24

6.5.4.6 Minimum Requirements for Monitoring of Water Quality at Waste Management 25

Facilities 26

Acknowledging the uniqueness of the South African groundwater systems, the Minimum 27

Requirements were developed to ensure coordinated and meaningful water quality monitoring by 28

applying the principle of best available technology, not entailing excessive cost (DWAF, 1998b). It is 29

a minimum requirement that a risk assessment, to determine the risk of water becoming polluted, be 30

performed at all waste sites before the installation of a monitoring system. This serves to ensure that 31

the design of the monitoring system is adequate and the risk assessment methodology to follow is 32

prescribed in the report (DWAF, 1998b). 33

Page 6-33

1

According to DWAF (1998b) the main purpose of a monitoring system is to: 2

Provide reliable data on the quality and chemical composition of the groundwater 3

Detect and quantify the presence and seriousness of any polluting substances in the ground 4

water at the earliest stage possible 5

Detect possible release or impending release of contaminants from the waste facility 6

Provide a rationale comparison between the predicted and actual flow and solute transport 7

rates 8

Provide and ongoing and reliable performance record for the design and control systems fro 9

effectively controlling pollution 10

11

To achieve the above objectives it may necessary to employ two separate monitoring systems in cases 12

where the generation of hazardous leachate may be a problem. The two monitoring systems are: 13

Early warning monitoring systems 14

Regional monitoring systems. 15

16

A schematic presentation (DWAF, 1998b) of these monitoring systems is shown below 17

18

Figure 6.3: A schematic presentation of these monitoring systems (DWAF, 1998b). 19 20

Minimum monitoring requirements at various types of waste management facilities provided does not 21

include above-ground storage facilities as are required for SGD. It does however include monitoring 22

Page 6-34

requirements for general and hazardous waste disposal facilities and sewage sludge as indicated 1

below. 2

3

Page 6-35

Table 6.7: Monitoring requirements for general and hazardous waste disposal facilities and sewage sludge 1

2

3

The Minimum Requirements (DWAF, 1998b) also provide guidance on borehole design as illustrated 4

below. 5

Page 6-36

1

2

Figure 6.4: Minimum Requirements (DWAF, 1998b) also provide guidance on borehole design 3 4

5

Data required from monitoring

boreholes (DWAF, 1998b):

Geological log

Water intersections (depth and

quantity

Construction information

(depth of hole and casing,

borehole diameter, method

drilled, date drilled)

Use of water, if not solely for

monitoring: Frequency of

abstraction; abstraction rate;

and whether other water

sources are readily available.

Water quality

Page 6-37

6.6 Topics on which information is inadequate for decision-making 1

Suitable sites for waste water treatment and on-site disposal of waste must be identified should SGD 2

go ahead. Detail on the composition of the wastes will be required to inform site selection, design 3

requirements of these facilities as well as the technology choices to consider. 4

5

6.7 References 6

Amec, 2013. Strategic Environmental Assessment for futher onshore oil and gas licensing: 7

Environmental Report. Department of Energy and Climate Change, United Kingdom. 8

Broderick J, Wood R, Gilbert P, Sharmina M and Anderson K. 2011 Shale gas: an updated 9

assessment of environmental and climate impacts. A report commissioned by The Co-operative 10

and undertaken by researchers at the Tyndall Centre, Univeristy of Manchester. 11

Council of Canadian Academies, 2014. Environmental Impacts of Shale Gas Extraction in Canada. 12

Ottawa (ON): The Expert Panel on Harnessing Science and Technology to Understand the 13

Environmental Impacts of Shale Gas Extraction, Council of Canadian Academies. 14

DEAT, 2000. White Paper on Integrated Pollution and Waste Management for South Africa: A policy 15

on Pollution Prevention, Waste Minimisation, Impact Management and Remediation. 16

Department of Environmental Affairs and Tourism, Pretoria. 17

DEAT, 2007. Disposal site census report of unauthorised disposal sites in South Africa. Department 18

of Environmental Affairs and Tourism, Pretoria. 19

DEA, 2012. National Waste Management Strategy. GN 344 Government Gazette 35306 of 4 May 20

2012. 21

DiGiulio DC, Wilkin RT, Miller C and Oberley G. 2011. Draft: Investigation of ground water 22

contamination near Pavillion, Wyoming, US. Environmental Protection Agency: Oklahoma. 23

DNV (Det Norske Veritas AS) 2013. Risk Management of Shale Gas Development and Operations. 24

Recommended Practice DNV-RP-U301 January 2013. 25

DWA, 2009. Water for Growth and Development Framework. Available online at 26

https://www.dwa.gov.za/wfgd/documents/wfgdv6nov21.pdf 27

DWAF, 1998. Waste Management Series. Minimum Requirements for the Handling, Classification 28

and Disposal of hazardous waste. Department of Water Affairs and Forestry, Pretoria. 29

Page 6-38

DWAF, 1998a. Waste Management Series. Minimum Requirements for Waste Disposal by Landfill. 1

Department of Water Affairs and Forestry, Pretoria. 2

DWAF, 1998b. Waste Management Series. Minimum Requirements for Water Monitoring at Waste 3

Management Facilities. Department of Water Affairs and Forestry, Pretoria 4

DWAF, 2007. Best Practice Guideline No. H4: Water Treatment. Department of Water Affairs and 5

Forestry, Pretoria. 6

DWS 2014. 2014 Green Drop Progress Report. Department of Water and Sanitation, Pretoria. 7

Gross SA, Avens HJ, Banducci AM, Sahmel J, Panko JM and Tvermoes BE. 2013. Analysis of BTEX 8

groundwater concertations from surface spills associated with hydraulic fracturing operations. 9

Journal of the Air and Waste Management Association 63:424-432. 10

Grout CG and Grimshaw TW, 2012. Fact-based regulation for environmental protection in shale gas 11

development. Energy Institute, University of Texas: Austin. 12

Hammer R and Van Briesen J. 2012. In Fracking’s Wake: New rules are needed to protect our health 13

and environment from contaminated waste water. NRDC Document, May 2012 D:12-05-A. 14

Herselman JE and Snyman HG, 2007. Guidelines for the Utilisation and Disposal of Wastewater 15

Sludge. Water Research Commission, Pretoria. 16

Kiboub, FZ. 2011. Oil and gas production waste: Case study, best available technologies and shared 17

lessons. Norwegian University of Science and Technology, Trondheim. 18

Koppelman B, Walker A and Woods E. 2012. Shale gas extraction in the UK: A review of hydraulic 19

fracturing. The Royal Society and the Royal Academy of Engineering, 2012. 20

Lee R, Seright, Hightower M, Sattler A, Cather M, McPherson B, Wrotenbery L, Martin A and 21

Whitworth M. 2002. Strategies for Produced water handling in New Mexico. 22

OGP 2009. Guidelines for waste management with special focus on areas with limited infrastructure. 23

Report No 413 rev 1.1 September 2008 (updated March 2009) International Association of Oil 24

and Gas Producers, United Kingdon. 25

Osborn, S. G., Vengosh, A., Warner, N. R., & Jackson, R. B. 2011a. Methane contamination of 26

drinking water accompanying gas-well drilling and hydraulic fracturing. Proceedings of the 27

National Academy of Sciences of the United States of America, 108(20), 8172–8176. 28

http://doi.org/10.1073/pnas.1109270108 29

Page 6-39

RSA, 1998. National Water Act, 1998 (Act 36 of 1998). Government Gazatte 19182, Notice 1091 of 1

26 August 1998. 2

RSA, 1998a. National Environmental Management Act, 1998 (Act 107 of 1998). Government Gazette 3

19519, Notice 1540 of 27 November 1998. 4

RSA, 2002. Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002). Government 5

Gazette 23922, Notice 448 of 10 October 2002. 6

RSA, 2008. National Environmental Management: Waste Act, 2008. (Act 56 of 2008) Government 7

Gazette 32000, Notice 278 of 10 March 2009. 8

RSA, 2013. Waste Classification and Management Regulations. Government Gazette 36784, 9

Regulation 634 of 23 August 2013. 10

RSA, 2013a. National Norms and Standards for the assessment of waste for landfill disposal. 11

Government Gazette 36784, Regulation 635 of 23 August 2013. 12

RSA, 2013b. National Norms and Standards for disposal of waste to landfill. Government Gazette 13

36784 Regulation 636 of 23 August 2016. 14

RSA, 2013c. List of Waste management Activities that have or are likely to have a detrimental effect 15

on the environment. Government Gazette 37083, Regulation 921 of 29 November 2013. 16

RSA, 2013d. National Norms and Standards for the Storage of Waste. Government Gazette 37088 17

Regulation 926 of 29 November 2013. 18

RSA, 2014. National Environmental Management: Waste Amendment Act, 2014 (Act 26 of 2014) 19

Government Gazette 37714, Notice 449 of 2 June 2014. 20

RSA, 2015. Revision of the pricing strategy for water use charges in terms of section 56(1) of the 21

National Water Act, 1998. Government Gazette 39411, Notice 1154 of 13 November 2015. 22

RSA, 2015a. Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002): 23

Regulations for Petroleum Exploration and Production. Government Gazette 38855, Regulation 24

466 of 3 June 2015. 25

RSA, 2015b. Amendments to the List of Waste Management Activities that have, or are likely to 26

have, a Detrimental Impact on the Environment. Government Gazette 39020, Regulation 633 of 27

24 July 2015. 28

Page 6-40

Shaffer DL, Chavez LHA, Ben-Sasson M, Castrillon SR-V, Yip, NY and Elimelech M. 2013. 1

Desalination and reuse of high-salinity shale gas produced water: Drivers, Technologies, and 2

future directions Environmental Science and Technology 47: 9569-9583. 3

Shariq L. 2013. Uncertainties associated with the reuse of treated hydraulic fracturing wastewater for 4

crop irrigation. Environmental Science and technology 47:2435-2436. 5

Veil J. 2015. U.S. Produced water volumes management practices in 2012. Prepared for the Ground 6

Water Protection Council, April 2015. 7

Zhang X, Sun AY and Duncan IJ. 2016. Shale gas wastewater management under uncertainty. 8

Journal of Environmental Management 165: 188-198. 9

Ziemkiewicz PF, Quaranta JD, Darnell A and Wise R. 2014. Exposure pathways related to shale gas 10

development and procedures for reducing environmental and public risk. Journal of Natural 11

Gas Science and Engineering 16: 77-84. 12

13

Page 6-41

6.8 Addendum A6: Tabulated detailed information 1

Table 1: Chemical components of concern present in fracturing fluids (Hammer and Van Briesen, 2012) 2

3 4

Page 6-42

Table 2: Chemical constituents used in Fracking Fluids (Broderick et al., 2011) 1

2

3

Page 6-43

1

2

Page 6-44

1

2

Page 6-45

Table 3: List of operational municipal waste disposal sites in the study area (DEAT, 2007). 1

Province Municipality Landfill site Class Airspace estimate 2007 (years)

Eastern Cape Lukhanji Queenstown GCB- 25

Baviaans Willowmore GSB+ 10

Blue Crane Route Cookhouse GSB- 3

Pearston GCB- 6

Somerset East GMB-

Camdeboo Nieu-Bethesda (Jakkalshoek) GCB- 10

Aberdeen GCB- 30

Gariep Burgersdorp GCB- 15-20

Tsolwana Tarkastad GSB- 4

Britstown GCB- 10

Hanover GCB- 20

Emalahleni Dordrecht GCB+ 5-10

Indwe GCB+ 5

Northern Cape Hantam Nieuwoudtville GCB- 20

Middelpos GCB- 10

Kareeberg Vosburg GCB- 20

Vanwyksvlei GCB- 20

Karoo Hoogland Williston GCB- 10

Sutherland GCB- 8

Ubuntu Loxton GCB- 15

Richmond GCB- 15

Umsobomvu Norvalspont GCB- 20

Western Cape Beaufort West Merweville GCB- 10

Nelspoort GCB- 30

Laingsburg Laingsburg GSB-

Prince Albert Klaarstroom GCB- 20

Prince Albert Road GCB- 6

Leeu Gamka GCB- 8

2

3

Page 6-46

Table 4: The number of wastewater treatment plants per municipality in the study area and technologies 1 employed 2

Province Municipality No of WWTW Technologies in use Cumulative Risk

Rating (DWS, 2014)

Eastern Cape Lukhanji 2 Activated sludge

Drying beds

Oxidation ponds

Anaerobic digestion

Biological filters

Maturation ponds

Sedimentation

Chlorination

High

Baviaans 3 Drying beds

Oxidation ponds

Chlorination

High

Blue Crane Route 3 Oxidation ponds High

Camdeboo 3 Activated sludge

Drying beds

Oxidation ponds

Chlorination

Medium

Gariep 4 Activated sludge

Drying beds

Oxidation ponds

Maturation ponds

Sedimentation

Chlorination

Medium

Maletswai 2 Activated sludge

Drying beds

Maturation ponds

Chlorination

Medium

Sundays River Valley 4 Activated sludge

Drying beds

Oxidation ponds

Chlorination

High

Tsolwana 2 Oxidation ponds

Maturation ponds

Chlorination

High

Ngqushwa 2 Activated sludge

Drying beds

Belt press dewatering

Sedimentation

Chlorination

Filtration

Medium

Nkonkobe 3 Activated sludge

Drying beds

Maturation ponds

Sedimentation

Chlorination

Medium

Page 6-47

Province Municipality No of WWTW Technologies in use Cumulative Risk

Rating (DWS, 2014)

Emalahleni 2 Oxidation ponds

Maturation ponds

High

Inkwanca 2 Activated sludge

Oxidation ponds

Maturation ponds

Chlorination

High

Inxuba Yethemba 2 Activated sludge

Drying beds

Oxidation ponds

Anaerobic digestion

Biological filters

Chlorination

High

Nxuba 2 Activated sludge

Drying beds

Oxidation

Maturation ponds

Chlorination

Medium

Ikwezi 2 Oxidation ponds

Maturation ponds

High

Makana 3 Activated sludge

Oxidation ponds

Anaerobic digestion

Biological filters

Sedimentation

Chlorination

High

Northern Cape Hantam 5 Oxidation ponds

Anaerobic ponds

Maturation ponds

Low

Kareeberg 3 Drying beds

Oxidation ponds

Medium

Karoo Hoogland 3 Oxidation ponds

Chlorination

High

Emthanjeni 3 Activated sludge

Drying beds

Oxidation ponds

Maturation ponds

Low

Ubuntu 3 Activated sludge

Drying beds

Oxidation ponds

Chlorination

Medium

Umsobomvu 3 Activated sludge

Oxidation ponds

Anaerobic digestion

Maturation ponds

High

Western Cape Beaufort West 4 Activated sludge

Drying beds

Oxidation ponds

Biological filters

Low

Page 6-48

Province Municipality No of WWTW Technologies in use Cumulative Risk

Rating (DWS, 2014)

Witzenberg 4 Activated sludge

Oxidation ponds

Low

Laingsburg 1 Oxidation ponds High

Prince Albert 3 Aerated lagoons

Oxidation ponds

Anaerobic digestion

High

Breede Valley

4 Activated sludge

Drying beds

Anaerobic digestion

Biological nutrient removal

Biological filters

Maturation ponds

Sedimentation

Medium

1