WATER USE LICENSE APPLICATION REPORT

Water Use License Application Report (WULAR) for the Proposed Thabametsi

Power Plant within the

Lephalale Municipality Submission: December ‘17

M2 ENVIRONMENTAL CONNECTIONS (PTY) LTD WULAR: THABAMETSI POWER COMPANY (PTY) LTD

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TITLE:

Water Use License Application Report (WULAR) for the proposed Thabametsi Power Plant on the farm

Onbelyk near Lephalale, Limpopo Province

CLIENT:

Applicant: Thabametsi Power Company (Pty) Ltd

Contact: Kazuaki Shibuya

Address: 2nd floor, Building 11B, Woodlands Office Park

, Western Service Road, Woodmead, Sandton, 2191

Tel number: (011) 568-1480

Mobile number: 063 688 5659

Fax number: (011) 802 0025

Email: [email protected]

REPORT NO:

WULA/TPP/201711/V6.1

AUTHOR:

Charné Appelman B Sc. Hons (Environmental Management & Geography)

REVIEW:

Johan Maré M.Sc. (Microbiology)

PriSci Nat (Registration Number 400092/91)

DATE:

November 2017

COPYRIGHT WARNING

This document is privileged and confidential in nature and unauthorised dissemination or copying

is prohibited. Thabametsi Power Company (Pty) Ltd claims protection of this information in terms

of the Promotion of Access to Information Act, 2002 (Act 2 of 2002) and without limiting this

claim, especially the protection afforded by Chapter 4.

mailto:[email protected]


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PROJECT:

Facilitation of the water use authorisation process for the proposed Thabametsi Power Plant,

Lephalale, Limpopo

LOCATION:

Farms Onbelyk, van der Waltspan and Graafwater, Limpopo Province

LICENSEE: Thabametsi Power Company (Pty) Ltd

REG NUMBER: 2016/193930/07

APPLICANT: Thabametsi Power Company (Pty) Ltd

TEL NUMBER: (011) 568-1480

DELEGATED PERSON: Kazuaki Shibuya

CONTACT DETAILS: 063 688 5659

FAX NUMBER: (011) 802 0025

PROJECT MANAGER: Ms. Jo-Anne Thomas

CONTACT DETAILS: Savannah Environmental (Pty) Ltd

Block 2

Woodlands Drive Office Park

Woodmead

2191

TEL NUMBER: 011 656 3237

MOBILE: 082 690 9105

EMAIL: [email protected]

CONSULTANT: M² Environmental Connections (Pty) Ltd

CONTACT: Mr. Johan Maré

CONTACT DETAILS: M² Environmental Connections (Pty) Ltd

P.O. Box 2047

Garsfontein East

0060

TEL: 012 004 0362

MOBILE: 083 389 6617

FAX NUMBER: 086 621 0292

EMAIL: [email protected]



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DOCUMENT CONTROL

AUTHOR:

This document was compiled by the following person:

Charné Appelman December 2017

_____________________ ________________________ ____________________

Name Signature Date

REVIEW (MENCO):

This document was reviewed and approved by the following person:

Johan Maré December 2017

_____________________ ________________________ ____________________

Name Signature Date

APPROVED (SAVANNAH ENVIRONMENTAL):

This document was approved by the following person:

Jo-Anne Thomas December 2017

_____________________ ________________________ ____________________

Name Signature Date

APPROVED (THABAMETSI POWER COMPANY (PTY) LTD):

This document was approved by the following person:

Kazuaki Shibuya December 2017

_____________________ ________________________ ____________________

Name Signature Date


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Application Checklist

General Required Information Official

Use

Description Applicable Submitted

Yes No Yes No

Proof of payment of license processing fee (Compulsory) √

Copy of Identity Document of Applicant (Compulsory) √

Copy of Company Registration Certificate (Compulsory) √

Copy of Trust Registration Certificate (Compulsory) √

Letter of Authorisation for Companies, Trusts or Legal Entities

Letter of Authority or Power of Attorney to Apply on behalf of

Applicant √

Copy of BBBEE Certificate

Letter of Consent if the Applicant is not the Property Owner

(Compulsory) √

Applicant Information Form: Individual (DW 756/769) √

Applicant Information Form: Water Service Provider (DW

757/770) √

Applicant Information Form: Company, Partnership,

Government (DW 758/771) √

Applicant Information Form: Water User Association (DW

759/772) √

Property Details Form (DW 901) √

Property Owner Details (DW 902) √

Permission to Occupy (PTO), Title Deed, Lease Agreement,

Community Resolution √

A description of the location of the activity, including (aa) the

21 digit Surveyor General code of each cadastral land parcel,

(bb) where available, the physical address or farm name, (cc)

where the required information in sub -regulation (aa) and (bb)

is not available, the coordinates of the boundary of the property

or properties

√

When providing coordinates, such coordinates must be provided

in degrees, minutes and seconds using the Hartebeesthoek94

WGS84 coordinate system.

√

A plan which locates the proposed activity or activities applied

for at an appropriate scale, or if it is-

(aa) a linear activity, a description and coordinates of the

corridor in which the proposed activity or activities is proposed;

or

(bb) on land where the property has not been defined, the

coordinates of the area within which the activity is proposed

√

Where applicable, proof of acceptance of an application for any

right or permit in terms of the Mineral and Petroleum Resources

Development Act, 2002 or environmental authorisation as per

regulation 7 must be provided

√


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Yes No Yes No

Section 21(a): Taking water from a resource √

Taking water from a water resource Form (DW 773) √

Pump Technical Data Form (DW 784) √

Canal Technical Data Form (DW 786) √

Irrigation Field and Crop Details (DW 787) √

Supplementary Info: Power Generation, Industrial or Mining

(DW 788)

√

Supplementary info: Domestic, Urban, Commercial or Industrial

(DW 789)

√

Soil Suitability Report (for irrigation from Dept. Agriculture) √

Section 21(b): Storing water

Storing water form (DW 762/774) √

Dam and Basin Technical Data Form (DW 789) √

Dam Classification Form (DW 793) (for dams >5m and >50,000

m3)

√

Dam Location Map √

Section 21(c) and (i): Impeding and Altering √

Impeding or diverting the flow of water in a watercourse form

(DW 763)

√

Altering the bed, banks, course or characteristics of a

watercourse (DW 789)

√

Supplementary Information for 21 (c)& (i) form (DW 775) √

Section 21(e): Engaging in controlled activity

Engaging in a controlled activity form (DW 765) √

Monitored Waste Discharge Details form (DW 904) √

Irrigation Field and Crop Details (DW 787) √

Section 21(f): Discharging waste or water containing

waste

√

Discharging waste or water containing waste into a water

resource through a pipe, canal, sewer or other conduit form

(DW 766)

√


Section 21(g): Disposing of waste in a manner that may

detrimentally impact on a water resource

√

Disposing of waste in a manner which may detrimentally impact

on a water resource form (DW 787)

√

Monitored Waste Discharge Details form (DW 904)

Details of Waste Management Facility form (DW 905) √

Section 21(h): Disposing in any manner of water

contains waste from or which has been heated in any

industrial or power generation process

Disposing in any manner of water which contains waste from,

or which has been heated in, any industrial or power generation

process form (DW 780)

√


Section 21(j): Removing, discharging or disposing of

water found underground if it is necessary for the

efficient continuation of an activity or for the safety of

people

√

Removing, discharging or disposing of water found underground

if it is necessary for the efficient continuation of an activity or

for the safety of people form (DW 780)

√


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Yes No Yes No

Section 21(k): Using water for recreational purposes √

Using water for recreational purposes form (DW 780) √

Official Use

Application submitted: ____________________ Complete

Incomplete

_____________________

Signature of Assessor


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Executive Summary

Thabametsi Power Company (Pty) Ltd is a proposed Independent Power Producer that is developing

a coal fired power plant situated near Lephalale, Limpopo under the Department of Energy's Coal

Baseload IPP Procurement Programme ("Project"). The Project entails the construction of a 630 MW

coal fired power plant on the farm Onbelyk 257 LQ located approximately 26 km north-west of

Lephalale. The Project will utilise Circulating Fluidised Bed technology that is dry-cooled in order to

facilitate a zero liquid effluent discharge plant. Dry-cooled technology is a pre-requisite for the

Department of Water and Sanitation due to the water scarcity currently experienced in the

catchment. The water supply for the Project will be sourced from Exxaro Coal (Pty) Ltd in terms of

a surrender of a portion of its existing water allocation which has been issued with a water use

license in terms of the Water Supply Agreement in respect of Phase 1 of the Mokolo and Crocodile

River (West) Water Augmentation Project.

The following water uses have been identified and are being applied for, to be licensed in

accordance with Section 40 of the National Water Act, 1998 (Act 36 of 1998), namely:

Section 21(a) Taking of water from a resource

Section 21(b) Storing of water

Section 21(c) Impeding or diverting the flow of water in a watercourse

Section 21(f) Discharge of water containing waste into a resource

Section 21(g) Disposing of waste which may detrimentally impact on a water resource

Section 21(i) Altering the bed, banks, course or characteristics of a watercourse

The applicant has appointed various specialists to conduct environmental investigations in support

of the Water Use License Application. The following Environmental Authorisation Processes has

been followed:

An Integrated Environmental Authorisation has been obtained from the Department of

Environmental Affairs (Ref: DEA/EIA/0001296/2012) (EA). The EA has been suspended

pending the consideration and decision by the Minister of Environmental Affairs, of, inter

alia, the Thabametsi Power Plant's climate change impacts.

An application for an air emissions license in terms of NEM: AQA has been undertaken

An application for a waste permit in terms of NEM:WA has been lodged for the operation of

the ash dam

For the WULA process:

Thabametsi Power Company (Pty) Ltd has undertaken the following Specialist

Investigations:

o Biodiversity Study

o Surface Water Study

o Wetland Delineation

o Geo-Hydrological Study

o Hydrological and Water Supply

After the Project was awarded preferred bidder status under the Coal Baseload IPP

Procurement Programme, the applicant has undertaken the following additional

Specialist Investigations:

o Civil Engineering Design Report


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o Storm Water Management Plan

o Construction Work Method Statement

The applicant has also committed to the following:

o Conduct a Section 25(2) application for the surrender of water

o Participate in MCWAP Phase 2 for future water supply

o Endorse full Public Participation Process

Conducted multiple feasibility studies complying with the requirements of the National

Environmental Management Act, 1998 (Act 107 of 1998) such as climate change study.

Based on the Environmental Impact Assessment conducted, the following impacts (without

mitigation) with a rating of moderate and higher have been identified.

Nature of Activity /

Impact

Extent Duration Magnitude Probability Significance

Alteration of drainage 2 4 6 3 36

Pipeline construction 3 2 8 4 52

Riparian and biodiversity 3 4 6 3 39

Surface water pollution 3 4 8 3 45

Groundwater pollution 3 4 8 3 45

Stormwater and spillage 3 4 6 3 39

Ash dump spillage 2 4 8 3 42

Coal stock yard and AMD 2 4 8 4 56

Catchment yield reduction 3 4 8 4 60

Residual impact 2 5 10 4 64

The Impact Assessment above ranges from moderate to high but could effectively be mitigated to a

low to moderate rating. The management measures are contained in the IWWMP and coupled with

a WUL the water resources within the catchment could be protected from unacceptable

degradation.

It is therefore recommended that the applicant should be issued with a Water Use License for the

identified water uses. The WUL should be issued for the maximum period as prescribed by the

DWS as the Thabametsi Power Plant is planned to be in operation for 30 years.


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Table of Contents

Page

1 BACKGROUND .......................................................................... 1 1.1 Applicant ........................................................................................ 1 1.2 Site and Regional Description ........................................................ 1

2 SUMMARY TECHNICAL INFORMATION ...................................... 4 2.1 Reports and Technical Information ................................................ 4 2.1.1 Biodiversity Study ......................................................................................... 4 2.1.2 Surface Water Study ...................................................................................... 4 2.1.3 Wetland Delineation ...................................................................................... 4 2.1.4 Geo-Hydrological Study .................................................................................. 5 2.1.5 Hydrological and Water Supply ....................................................................... 5 2.2 Project Description ......................................................................... 5 2.2.1 Power Plant Infrastructure .............................................................................. 6 2.2.2 Water Management Facilities .......................................................................... 6 2.3 Water Uses Applied For ................................................................ 10 2.3.1 Identified Water Uses .................................................................................. 10 2.3.2 Section 21(a) water uses ............................................................................. 11 2.3.3 Section 21(b) water uses ............................................................................. 12 2.3.4 Section 21(c) and (i) water uses ................................................................... 12 2.3.5 Section 21(f) water uses .............................................................................. 15 2.3.6 Section 21(g) water uses ............................................................................. 16 2.3.7 Water Demand Analysis ............................................................................... 16 2.3.8 Water Supply Analysis ................................................................................. 16 2.4 Impacts of Activities on Water Resource ...................................... 17 2.4.1 Surface Water ............................................................................................. 17 2.4.2 Groundwater .............................................................................................. 18 2.5 Proposed Mitigation Measures ..................................................... 18 2.5.1 Surface Water ............................................................................................. 18 2.5.2 Groundwater .............................................................................................. 19 2.5.3 Wetlands .................................................................................................... 21

3 ASPECTS TAKEN INTO CONSIDERATION ................................ 22 3.1 Departmental Correspondence ..................................................... 22 3.2 License Administration ................................................................. 23 3.3 Inputs from other Departmental Directorates .............................. 24 3.3.1 National Water Resource Planning ................................................................. 24 3.3.2 Abstraction and Storage ............................................................................... 24 3.3.3 Civil Design ................................................................................................ 25 3.3.4 Environment and Recreation ......................................................................... 26 3.4 Inputs from Stakeholders ............................................................ 26

4 SECTION 27 MOTIVATION ...................................................... 28 4.1 Existing lawful water uses ........................................................... 28 4.2 The need to redress past racial and gender discrimination .......... 28 4.3 Efficient and beneficial use of water in the public interest ........... 29 5.3.1 Taking of water ............................................................................................... 29 5.3.2 Altering the natural characteristics of the wetland areas ....................................... 29 5.3.3 Waste disposal ................................................................................................ 29 4.4 The socio-economic impact of the water use or uses if authorised29 4.5 The socio-economic impact of the failure to authorise the water use

..................................................................................................... 30 4.6 The catchment management strategy applicable to the resource . 31 4.7 The likely effect of the water use on water users ......................... 31 4.8 The class and the resource quality objectives of the water resource32


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4.9 Investments already made by the water user .............................. 32 4.10 The duration of water use ............................................................ 33 4.11 The strategic importance of the water use to be authorised ........ 34 4.11.1 Site specific ................................................................................................ 34 4.12 Enforcement and Management ..................................................... 34 4.12.1 Management Plans ...................................................................................... 34 4.12.2 Monitoring .................................................................................................. 34

5 CONCLUSIONS AND RECOMMENDATIONS .............................. 36

6 REFERENCES .......................................................................... 37


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List of Figures page

Figure 1-1: National Locality Map ..................................................................... 2 Figure 1-2: Regional Locality Map ..................................................................... 3 Figure 2-1: Infrastructure Layout Plan for Thabametsi IPP Power Plant ................. 7 Figure 2-2: Thabametsi IPP Power Plant coal and ash storage .............................. 8 Figure 2-3: Thabametsi IPP Power Plant water supply pipeline route ..................... 9 Figure 2-4: Section 21(a), (b), (c), (f), (g) and (i) Water Uses ........................... 13 Figure 2-5: Properties Related to Water Uses ................................................... 14 Figure 2-6: Wetlands within the project area ................................................... 15

List of Tables

Page

Table 2-1: Detailed information on water uses to be licensed, their location and description .................................................................................................. 11 Table 2-2: Mokolo Dam Yield Analysis ............................................................. 16 Table 2-3: Mokolo Dam Allocations ................................................................. 17 Table 2-4: Mitigation for surface water impacts ................................................ 18 Table 2-5: Mitigation measures for groundwater impacts ................................... 19 Table 3-1: Regulatory consultation process followed ......................................... 22 Table 3-2: Completed DW Forms .................................................................... 23 Table 4-1: Resource Quality Objectives for the receiving water resource ............. 32 Table 4-2: Details of the life activity of the Thabametsi Power Plant Project ......... 33


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List of Appendices

Appendix 1 Company Registration and Certified ID of applicant

Appendix 2 Title Deeds and Land Claim

Appendix 3 Contractual Agreement

Appendix 4 Section 25(2) Application

Appendix 5 Master Layout Plan

Appendix 6 BBEEE Certification

Appendix 7 DW Forms

Appendix 8 Proof of Payment

Appendix 9 RoD (Environmental Affairs)

Appendix 10 Integrated Water and Wastewater Management Plan

Appendix 11 EIA and EMP (soft copy only)

Appendix 12 Wetland Delineation Study

Appendix 13 Biodiversity Assessment

Appendix 14 Surface Water

Appendix 15 Geohydrological Assessment

Appendix 16 Construction Work Method Statement and Rehabilitation Plan

Appendix 17 Storm Water Management Plans

Appendix 18 Civil Engineering Designs

Appendix 19 Water Balance

Appendix 20 Hydrology and Water Supply

Appendix 21 Public Participation Report


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List of Abbreviations

AMD Acid Mine Drainage

BBBEE Broad Based Black Economic Empowerment

CER Centre for Environmental Rights

CMA Catchment Management Agency

CSY Coal Stock Yard

DWS Department of Water and Sanitation

EIA Environmental Impact Assessment

EISC Environmental Integrity and Sensitivity Class

ELA Earth Life Africa

ELU Existing Lawful Use

EMP Environmental Management Plan

GA General Authorisation

GN Government Notice

I&AP Interested and Affected Parties

IPP Independent Power Producer

IWULAR Integrated Water Use Licence Application Report

IWWMP Integrated Water and Wastewater Management Plan

MCWAP Mogol Crocodile Water Augmentation Project

NEM: AQA National Environmental Management: Air Quality Act, 2004 (Act 39 of 2004)

NEM: WA National Environmental Management: Waste Act, 2008 (Act 59 of 2008)

NERSA National Energy Regulator of South Africa

PCD Pollution Control Dam

PES Present Ecological Status

PPP Public Participation Process

RQO Resource Quality Objective

SWMP Stormwater Management Plan

TCTA Trans Caledon Tunnel Authority

WUL Water Use Licence

WMA Water Management Area

WWTW Waste Water Treatment Works

ZLED Zero Liquid Effluent Discharge Facility


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1 BACKGROUND

1.1 APPLICANT

Exxaro Coal Proprietary Limited (Exxaro) initiated during 2013 the environmental authorisation

process for the development of the Thabametsi Power Plant on the farm Onbelyk 257 LQ near the

town of Lephalale in the Limpopo Province. Exxaro initially selected Newshelf 1282 (Pty) Ltd as the

preferred Independent Power Producer (IPP) for the development of the power plant. During 2014

the applicant changed to Thabametsi Power Project (Pty) Ltd.

With the subsequent withdrawal of Thabametsi Power Project (Pty) Ltd during February 2015, the

Project was taken over by the Thabametsi Power Company (Pty) Ltd. The Department of Energy

awarded preferred bidder status under the Coal Baseload IPP Procurement Programme towards the

end of 2015 to the applicant. The Water Use License Application (WULA) was lodged with the

Limpopo-Northwest proto Catchment Management Area (CMA) situated in Polokwane in the name

of the applicant.

1.2 SITE AND REGIONAL DESCRIPTION

The Thabametsi Power Plant Project is situated approximately 29 km east south-east of Lephalale

and approximately 25 km south of the Stockpoort Border Post. The project area falls within the

jurisdiction of the Lephalale Local Municipality (LIM362) and the Waterberg District Municipality

(DC36).

Just south of the proposed project site the Grootgeluk Colliery as well as the Medupi and Matimba

Power Stations are located. Smaller settlements in close proximity include Marapong and

Steenbokpan to the south-west and south-east. Numerous small access roads occur to and from

the project site, however larger roads are only found closer to Lephalale. A railway line runs to the

south from the Grootgeluk Colliery just below the project site. The attached Figure 1-1 and

Figure 1-2 gives an indication of the regional locality of the study area.


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Figure 1-1: National Locality Map


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Figure 1-2: Regional Locality Map


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2 SUMMARY TECHNICAL INFORMATION

2.1 REPORTS AND TECHNICAL INFORMATION

As per requirement stated in Government Notice Regulation 267 promulgated on 24 March 2017

application for specific water uses are subject to the submission of specialist studies in support of

these water uses.

2.1.1 Biodiversity Study

The Biodiversity study was conducted during 2014 by Bathusi Environmental Consulting. The study

details all the biodiversity management action plans to be implemented as part of the Project

development. In terms of the WULA the biodiversity study contributed towards the Rehabilitation

Plan for the pipeline construction for those areas where the pipeline transects the protective buffer

zone of the delineated wetlands.

2.1.2 Surface Water Study

A surface water study was conducted by M2 Environmental Connections during June 2013. The

project site falls within quaternary drainage area A41J of the Mogol River that is part of the

Limpopo Water Management Area which is classified as phase 2 Freshwater Ecosystem Priority

Area. The study revealed that there are no surface water resources to be directly impacted by the

power plant development and that activities at the site during operational phase will contribute

towards moderate impacts on the catchment if mitigatory measures are not implemented. With

the implementation of appropriate mitigation and action plans surface water impacts are rated as

low to low moderate significance.

The only matter of concern is the availability of water supply to the area as the supply from the

Mogol Dam is considered to be over allocated. This will have a negative long-term impact on other

water users, specifically the agricultural sector.

2.1.3 Wetland Delineation

The baseline wetland delineation study was conducted during February 2014 by Digby Wells and

Associates. It was reported that the development may result in direct and indirect impacts on pans

and associated channels within the project area. The identified wetland units are stated as pans

linked to wooded drainage lines. The PES of the pans was given as Class C/B which the EIS states

as High. No pans are directly impacted by the development and the footprint will only transgress

the 500 m protective buffer zone of the delineated wetlands.

In addition a further wetland delineation study was conducted during 2017 by WSP South Africa

(Pty) Ltd to cater for any potential impacts on wetlands to be caused by the construction of a water

supply pipeline. It was confirmed that the wetlands are identified Depression Complexes that

consist of grouped HGM units that function as the same HGM unit due to similar land use impacts,

same vegetation type and similar impacts from runoff characteristics and water quality changes.


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Impact rating on the wetlands is stated as Moderate but could effectively mitigated to Low

significance.

2.1.4 Geo-Hydrological Study

A baseline groundwater impact study was conducted by Geo Pollution Technologies during February

2014 and subsequently been updated during July 2017 to align the groundwater modelling with the

final layout of the power plant footprint. The study revealed that the footprint of the development

overlay a minor aquifer with groundwater levels varying between 14.4 to 53.6 meters below

ground level.

Borehole LEP10 is to be negatively impacted by the development of the ash dump. Borehole LEP9

also has the potential to be impacted due to increased sulphate concentrations stemming from the

CSY. There is a long-term likelihood that boreholes LEP 13 and LEP 14 may be impacted in the

event that no liners are installed at the ash dump and coal stock pile. To prevent groundwater

contamination all pollution control facilities are designed with appropriate barrier systems as

contemplated in the Norm and Standards on Assessment of Waste for Landfill as specified in R635

of August 2013. Regular groundwater sampling will be introduced to monitor the establishment and

migration of a groundwater pollution plume.

2.1.5 Hydrological and Water Supply

UWP Consulting conducted a Water Supply Study during October 2015. The study revealed that the

safe yield of the Mokolo Dam will be exceeded in the nearby future. In addition the total installed

capacity of MCWAP-1 will defer water deficits for a few years but is rated as unsustainable in the

long-term. The deficit situation will be remedied when the MCWAP-2 project comes on line about

2020. There will be a deficit based on the high demand scenario around 2025 that could be

mitigated by abstracting water above the safe yield from the Mokolo Dam.

The water requirement for the 630 MW power plant is to be a water allocation of 720 000

m3/annum, and such amount is being made available to the applicant for purposes of the Project.

Water is currently available from the Mokolo Dam as part of the MCWAP Phase 1 project. The key

factor for the water supply to the Project revolves around the effective transfer of part of Exxaro's

current water license allocation to the applicant.

Water quality from both the Mokolo Dam and the Crocodile River (West) is considered suitable for

the Project, although the Mokolo Water quality is higher.

2.2 PROJECT DESCRIPTION

The Water Use License Application is for the proposed Thabametsi Power Plant in the Lephalale

area. As the Thabametsi Power Plant is currently still being designed, the infrastructure

requirements are considered conceptual. The infrastructure needed is outlined in Section 2.1 and

Figure 2-1 as well as Figure 2-2.


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2.2.1 Power Plant Infrastructure

The main infrastructure associated with the power plant includes the production units consisting of

boilers, furnaces turbines, generators and associated equipment. The footprint will also make

provision for an office complex, maintenance area, coal stock yard and ash dump. The following

treatment plants will be constructed and operated:

Waste Water Treatment Plant (Bio-Filter System)

Raw Water Treatment Plant

2.2.2 Water Management Facilities

Pollution control and water resource management activities and related infrastructure that will be

constructed include:

Pollution control dams (Ash Dump PCD, Coal Stockyard PCD & Waste Water Collection

Pond) as well as an Evaporation pond and Storm Water Pond;

Ash Dump;

Coal Stock Yard (CSY);

Stormwater drains as part of the SWMP;

Water pipeline for raw water supply from MCWAP 1; and

Waste Water Treatment Works.

The office infrastructure will be sufficient to cater for the number of employees at the Thabametsi

Power Plant. Security fencing and gate control will also be implemented for safety purposes. The

following infrastructure will be constructed in accordance with the civil engineering designs as

indicated in Figure 2-1 provided below.

Pollution Control Dam: All PCD’s to be constructed on the project site will be appropriately lined

that will provide containment service related to water management stemming from the ash dump

and all delineated dirty water areas.

Pipeline Water Supply and Conveyors: Two conveyors are proposed being the ash dump extendable

conveyor system as well as the conveyor system feeding the Strategic Coal Stockyard to store a

maximum of 750 000 tons of coal. The facility is further equipped with a pollution control sump and

pump station to recycle waste water runoff to one of the three PCD’s.

A water supply pipeline will be constructed from the tap-off point to the raw water reservoir (please

refer to Figure 2-3.

Waste Water Treatment Works: The Bio-filter Waste Water Plant is situated to the south of the bus

parking and access control area. The plant is designed to cater for a design capacity of 600 m3 per

day. The effluent will treated to standards as specified in GN 665 of 6 September 2013 and

disposed to the waste water collection pond. The treated waste water from the lined waste water

collection pond will be re-used and recycled as part of the power plant’s internal water circuit and

will not be discharged to the environment.


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Figure 2-1: Infrastructure Layout Plan for Thabametsi IPP Power Plant


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Figure 2-2: Thabametsi IPP Power Plant coal and ash storage


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Figure 2-3: Thabametsi IPP Power Plant water supply pipeline route

M2 ENVIRONMENTAL CONNECTIONS (PTY) LTD IWULAR: THABAMETSI POWER COMPANY (PTY) LTD

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2.3 WATER USES APPLIED FOR

2.3.1 Identified Water Uses

The following water uses have been identified and are being applied for, to be licensed in accordance

with Section 40 of the National Water Act, 1998 (Act 36 of 1998), namely:

Section 21 (a) – Taking of water from a resource;

Section 21 (b) – Storing of water;

Section 21 (c) – Impeding or diverting the flow of water in a watercourse;

Section 21 (f) – Discharge of water containing waste into a resource

Section 21 (g) – Disposing of waste which may detrimentally impact on a water resource;

Section 21 (i) - Altering the bed, banks, course or characteristics of a watercourse;

Further details on the water uses are provided in Table 2-1 and illustrated in Figure 2-4 with the

properties on which the water uses are to be exercised depicted in

Figure 2-5.


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Table 2-1: Detailed information on water uses to be licensed, their location and

description

Water Use Description Latitude Longitude Volume/

Dimension

Section 21(a) Taking water (WU1) 23°40'42.30"S 27°36'5.61"E 720,000 m3/a

Section 21(b) Storing water (WU2) 23°35'58.76"S 27°29'41.23"E 30,000 m3

Section 21(c), (i)

Pipeline water/wetland

crossing A at wetland

unit 4 (WU3)

Start

23°37'43.82"S

End

23°37'36.43"S

Start

27°33'38.41"E

End

27°33'37.61"E

230 m

Section 21(c), (i)


crossing B at wetland

unit 3 (WU4)

Start

23°37'10.64"S

End

23°36'36.46"S

Start

27°33'31.46"E

End

27°33'25.35"E

900 m

Section 21(c), (i)


crossing C at wetland

unit 2 (WU5)

Start

23°36'30.92"S

End

23°35'55.16"S

Start

27°31'27.15"E

End

27°30'19.79"E

1900 m

Section 21(c), (i)

Power plant

infrastructure within a

500 m protective buffer

zone of wetland cluster

(WU6)

Start

23°36'25.13"S

End

23°36'31.76"S

Start

27°29'44.22"E

End

27°29'70.13"E

1000 m

Section 21(g) Ash Dump PCD (WU7) 23°36'9.75"S 27°29'23.18"E 56,000 m3

Section 21(g) Coal Stockpile PCD

(WU8) 23°36'11.49"S 27°29'29.12"E 2,650 m3

Section 21(g) Evaporation pond

(WU9) 23°36'1.12"S 27°29'24.38"E 16,200 m3

Section 21(g) Waste Water Collection

Pond (WU10) 23°36'2.11"S 27°29'27.49"E 1,200 m3

Section 21(g) Storm Water Pond

(WU11) 23°36'4.35"S 27°29'28.68"E 13,600 m3

Section 21(g) Strategic Coal

Stockyard (WU12) 23°36'6.96"S 27°29'34.41"E 750,000 ton

Section 21(g) Ash Dump (WU13) 23°35'57.79"S 27°29'8.69"E

270 Ha

280 t/h

20, 848, 89

t/a

Section 21(f) WWTW Bio-filter plant

(WU14) 23°36'2.43"S 27°29'32.94"E 600 m3/day

Section 21(g) Dust Suppression

(WU15) 23°35'57.79"S 27°29'8.69"E 120,450 m3

2.3.2 Section 21(a) water uses

The need for a section 21(a) water use is debatable as this water use is to take place on Grootestryd

465 LQ, portion RE/3, out of an existing tap-off point as part of the volume of water surrendered by

Exxaro under its MCWAP-1 allocation under its water use licence in favour of the applicant.

A section 25(2) application process for the surrender of water has been followed.


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2.3.3 Section 21(b) water uses

In terms of Section 21(b) of the National Water Act (Act 36 of 1998), this water use entails the

storing of raw water for industrial use. The raw water is of potable quality and not seen as water

containing waste. A potable water treatment plant will purify the water for domestic use as well as

industrial use in the power plant as specific water qualities will be required in the power generation

process.

Potential impacts:

Section 21(b): There is no possible impact on the environment from storing water in a reservoir with

holding capacity of 30,000 m3. The dam wall of less than 3 meters ensures that the dam has no

safety risk.

2.3.4 Section 21(c) and (i) water uses

According to Government Gazette GN 1199 of 18 December 2009, a buffer zone of 500m should be

maintained around wetlands. It is however understood that the DWS expects this “regulated area” to

be applied horizontally as well as vertically. It is thus that the mine is applying for multiple section

21 (c) & (i) water uses as contemplated in Table 2-1 and Figure 2-4 with the supporting DW Forms

contained in Appendix 1 of this document.

The wetlands that are applied for in this WULAR were delineated by a Wetland Specialist from Digby

Wells and Associates and validated during a study performed by WSP SA (Pty) Ltd. Their study is

contained in the IWWMP and the finding is that the Eendrag Pan falls outside the footprint of the

Thabametsi Power Plant. There are however complex depression systems linked to wooded drainage

lines located within the 500 meter buffer zone which trigger a section 21 (c) and (i) water use.

Refer to Figure 2-6 for an illustration of the locality of NFEPA important wetlands.


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Figure 2-4: Section 21(a), (b), (c), (f), (g) and (i) Water Uses


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Figure 2-5: Properties Related to Water Uses


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Figure 2-6: Wetlands within the project area

Further water uses under this section include the pipeline crossings proposed for the operation of

the Thabametsi Power Plant. This pipeline crossing will be constructed as a best option to convey

raw water to the reservoir at the Thabametsi Power Plant and will follow existing linear

infrastructure to minimise further environmental impacts. This infrastructure can be seen in

Figure 2-1.

2.3.5 Section 21(f) water uses

Due to the intent of the applicant's requirement to commission a new WWTW and use this plant to

treat waste water, a Section 21(f) water use authorisation will be required. The water containing

waste will be recycled and used in the hydration of ash.

Potential impacts:

Should the water quality of the water being discharged be non-conformant to the stipulated RQO’s

to be determined by DWS, the ecosystem might moderately be impacted.

Project Site &

Ash Dump


16 | P a g e

2.3.6 Section 21(g) water uses

Power Generation is classified as Category A Environmental Risk Activity,1 meaning a license

will need to be obtained for the waste dump and or PCD’s constructed that may have the potential

to detrimentally impact on a water resource.

The Section 21 (g) water uses applicable to this application entail:

Ash Dump PCD;

Coal Stockyard PCD;

Waste Water Collection Pond;

An evaporation pond with capacity of 16,200 m3;

Storm water containment of 13,600 m3;

A coal stock yard with storage capacity of 750,000 tons

An ash dump with total storage capacity of 200 000 000 tons and operational life of 40

years. This facility is already authorised under NEM:WA.

All PCD’s are designed in accordance with GN 704 regulations and the designs make provision for a

HDPE liner to be implemented.

2.3.7 Water Demand Analysis

Information as contained in the Crocodile West Reconciliation Study (DWA, 2012) was used in pre-

feasibility phase of the Project. From the study it is evident that water requirements in the Greater

Lephalale area would exceed the safe water yield of the Mokolo Dam. It was also reported that the

total pumping capacity of MCWAP Phase 1 of 53.4 Mm3/annum will be exceeded by 2020. The

water demand for the area can be reduced with the implementation of MCWAP Phase 2.

2.3.8 Water Supply Analysis

The water supply to the project is completely dependent on the surrendering of 720,000 m3/a from

the Exxaro's allocation.

The Mokolo Dam Yield Analysis (DWA, 2008) has determined that the dam has gross capacity of

146 Mm3. The yield analysis results are stated in Table 2-2.

Table 2-2: Mokolo Dam Yield Analysis

Historic Firm Yield (HFY) Yield (Mm3/annum at indicted Recurrence Interval

Mm3/a RI (years) 1:200 (99.5%) 1:100 (99%) 1:50 (98%) 1:20 (95%)

38.7 1:224 39.1 44.6 50.7 66.8

Other sources investigated to augment water supply is groundwater abstraction where the

sustainable yield of 1.7 Mm3/annum could alleviate the water stress scenario. This could be

1 Government Gazette Notice: No 26187 (339) published 26 March 2004: Revision of General Authorisations in

terms of Section 39 of the National Water Act, 1998 (Act no. 36 of 1998)


17 | P a g e

increased to 7.2 Mm3/annum over a two year (short-term) abstraction period but the resource will

be subject to a recovery period of two years.

Based on the studies conducted by the Department of Water and Sanitation, water allocations from

the dam were 27.6 Mm3/a. Water was supplied to the industrial and municipal customers around

Lephalale through a 45 km pipeline from the dam terminating near Matimba Power Station. This

pipeline is owned by Exxaro and has a gross capacity of 14.7 million m3/a. Phase one of the

MCWAP was completed which entailed the laying of an additional pipeline from the Mokolo Dam to

Matimba Power Station. This was laid next to the Exxaro line apart from one small section. The new

pipeline has a capacity of 36.9 Mm3/a, thus a total gross pumping capacity of both pipelines of 53.4

Mm3/a.

Phase one consisted of an initial phase referred to as “debottlenecking”, where the capacity

of the existing gravity line from Wolvenfontein Reservoir to Rietspruitnek (15.9 km) was increased

by means of interconnections to the new pipeline (DWA, 2008, MCWAP, Feasibility Study, Main

Report). This was completed by October 2013 and increased the capacity from 14.7 M m3/a to 23.1

million Mm3/a (DWA, 2014). The allocations from the Mokolo Dam after completion of MCWAP

Phase 1 are indicated in

Table 2-3.

Table 2-3: Mokolo Dam Allocations

User Allocation (million m3/a)

Exxaro Current 5.6

Additional Phase 1 2.0

Sub-Total 7.6

Eskom Current Matimba Power Station 6.5

Medupi Additional Phase 1 8.0

Sub-Total 14.5

Others (Domestic) Lephalale and Marapong 7.2

Incidental Users 0.1

Sub-Total 7.3

Mogol Irrigation Board Irrigation 10.4

Natural Environment Provision for Ecological Reserve 4.0

TOTAL 43.8

2.4 IMPACTS OF ACTIVITIES ON WATER RESOURCE

2.4.1 Surface Water

Potential impacts:

Section 21(a): The impact of abstraction on water resources in the catchment is seen as high due

to scarcity of water. The water source is an existing allocation made to Exxaro Coal (Pty) Ltd.


18 | P a g e

Exxaro Coal (Pty) Ltd has agreed to surrender 720,000 m3 per annum of raw water to the applicant

for purposes of the Project. The water allocation to the Thabametsi Power Plant will not contribute

towards further water scarcity as this demand is already encapsulated in Exxaro's water use

license.

Should the PCD’s spill, the water quality within the Sandloop will become impaired. The risk for this

to happen is however low (as a Civil Engineer designed it with a 0.8m freeboard) and the

Thabametsi Power Plant will need to monitor the dam levels as well as water quality, especially as

the water will be used for dust suppression. Should such a spill occur, this incident must be

reported to DWS and corrective actions must be taken.

2.4.2 Groundwater

The fractured aquifer of the project site was classified as a minor aquifer as it is not a highly

productive aquifer. Using the Groundwater Decision Tool it was found that the aquifer has a

medium vulnerability and as a result it also has a medium level groundwater quality management

index. This indicates that a medium level of aquifer protection is required in the area of the

proposed Thabametsi Power Plant.

The main potential sources of this pollution are the ash dump and coal stockpile due to chemical

weathering by oxidation of the sulphide containing minerals (mostly pyrite) in these structures, as

well as other geochemical processes producing different contaminants. This is anticipated if no

liners are implemented below the stockpile and ash dump at the site, or if the liners are leaking.

Mitigatory measures in the form of liners could prevent groundwater contamination. A groundwater

monitoring program needs to be implemented.

2.5 PROPOSED MITIGATION MEASURES

2.5.1 Surface Water

The surface water environment will be protected in terms of the measures as contained in Table

2-4 below

Table 2-4: Mitigation for surface water impacts

Objective Action

To minimize the pollution of surface water and maximize the clean runoff from the area. This

policy will ensure the smallest possible detrimental impact on the surrounding surface

water catchment

A clean water cut-off trench (storm water diversion trench) had been installed on the

north-eastern side of the power station as well as around the CSY. This storm water diversion

trench was designed to cater for the runoff water from a 1:50 year 24-hour storm event with a

0.8m freeboard.

Any future infrastructure to be installed will be in accordance with the specifications as laid out in

Regulation 704 (4 June 1999) of the National Water Act, 1998 (Act 36 of 1998).

To ensure that the pollution control facilities are maintained on a regular basis

The power station manager will appoint a responsible person to ensure that the water

pollution control structures are constructed and


19 | P a g e

Objective Action operated in accordance with the approved

designs. These structures comply with Regulation 704 (4 June 1999) of the National Water Act,

1998 (Act 36 of 1998)

The water pollution control structures (berms, dirty water trenches, storm water diversion

trenches) will be inspected on a weekly basis for signs of erosion or blockages during the first

rainy season. Thereafter, inspections will occur at the advent of the subsequent rain seasons and

on a monthly basis during the rainy and dry

seasons. Any blockages or erosion will be cleared or repaired within 24 hours after discovery.

To ensure that the surface water runoff from the site complies with requirements of the National Water Act, 1998 (Act 36 of 1998).

A surface water-monitoring programme has been developed for implementation. Water quality

monitoring is a mandatory requirement

stipulated in the National Water Act, 1998 (Act 36 of 1998). Water samples will be taken on a monthly basis from the identified monitoring

points (i.e. upstream and downstream monitoring points) as well as from the pollution control dam and return water dams. The results generated at these points will be used to detect

any possible impact on surface water from the power station2.

Sampling will be performed according to recognized procedures and approved laboratory

analysing techniques will be followed. An

accredited laboratory will perform the hydrochemical analyses.

The contamination of other substances such as hydrocarbons will also be determined. A field

form will be designed for the use by the sampler.

Dam levels, signs of acid water formation, leaks, spills or any other relevant information will be

noted.

A water quality database had been set up for the site. Results from the monitoring will be

submitted to the Regional Director: DWS on a quarterly (three-monthly) basis in accordance with the requirements as specified in the water use licence. The results of the sampling will be compared to the South African Water Quality

Guidelines.

2.5.2 Groundwater

The water uses foreseen at the Thabametsi Power Plant will be managed well and managed in

accordance with the following principles to mitigate and control water uses and possible impacts

anticipated. A more detailed management plan is contained in the IWWMP. Water Resource

Management approach for impacts rate as “High” and are provided below (refer Table 2-5).

Table 2-5: Mitigation measures for groundwater impacts

Objective Action

2 The monitoring of surface water bodies may be omitted due to far distance from the resource


20 | P a g e

Objective Action

To reduce groundwater pollution and minimise the impact thereof on the aquifer and to ensure the sustainable use thereof for selected water

uses.

Trenches Cut-off trenches installed at the coal stockyard. This will assist in diverting the clean runoff away from the coal stockyard. Dirty runoff cascades to the Dam. The sub-surface of the section of

the current coal stock yard that is directly opposite the coal stockpiles was disturbed and

not compacted again at some stage during the earlier existence of the Thabametsi Power Plant. This implies that the integrity of the natural clay layer was compromised during this activity. It is assumed that that the ground water pollution as detected in borehole B8 emanates largely from

this area. In order to alleviate pollution of the ground water from this area the following

remedial activities were conducted: - A comprehensive needs analysis was

conducted to establish the exact surface area required for coal

storage.

- The rework and compaction of the Coal Stock Yard subsurface in line with the recommendation of the

geotechnical investigation. - Constructions of a suitably sized

facility complete with an effective clay membrane as per the Avon

Engineering recommendations. - Construction of coal stockyard, storm

water interception and reuse system (Coal Stockyard Dam) in accordance

with the requirements of GN 704 while taking cognisance of the

operating rule for the dam.

Boreholes Sixteen boreholes are to be used at the

Thabametsi Power Plant to monitor the possible

migration of polluted water to the ground water system. The sampling frequency for sampling

recommended by the specialist geohydrological investigation dated September 2012 is six monthly. This report further states the low

hydraulic conductivities and storage coefficients for the fractured aquifer. Records further showed

that blow-out yields of the existing boreholes were in the order of 0.025 litre per second. It is for this reason that Thabametsi Power Plant is not considering boreholes and the continuous

pumping of these holes in order to capture small masses of migrated salts through the creation of an inversion cone in the water table. There will

thus be no need to intercept and contain the groundwater plume by means of active

dewatering of the affected aquifer.

Clay membranes Migration of acidic products from the coal

handling and mill rejects (coal) disposal areas is a reality. A suitable clay membrane as described

in the civil engineering design report will mitigate pollution emanating from the coal

stockyard. Tracking the water quality of borehole LEP9 will give an indication of the efficacy of the


21 | P a g e

Objective Action

remedial activities. Disposal methods employed during the operation

of Thabametsi Power Plant may result in the leaching of acid rock drainage. The Thabametsi Power Plant ash generates sufficient alkalinity to

neutralise and eventually precipitate the acid leachates from the rehabilitated waste site.

Encapsulation of waste Wastes such as small volumes of organic

solvents emanating from the Laboratory and specialised equipment and part cleaning are

disposed of through a reputable hazardous waste contractor. Dirty oils and oily residues or sludge

are recycled through a reputable contractor. Medical and pharmaceutical wastes generated on

the site are disposed of through reputable

Medical Waste Disposal Contractors. There will

thus be no encapsulation of hazardous wastes at Thabametsi Power Plant.

The immobilisation of calcium sulphate in the ash through the precipitation as calcium sulphate

and ettringite could also be regarded as some form of encapsulation. The pozzalanic properties of the pulverised fuel ash (PFA) also allow for the

encapsulation of normal water borne pollutants

2.5.3 Wetlands

Moderate impacts are foreseen if wetland rehabilitation is not implemented. As stated in Table 16

of the Wetland Impact Report (WSP, 2017) the significance rating of the construction impacts are

“Low” implying that no mitigation is required. However during the Operational Phase of the Project

“Moderate” impacts could manifest in the area. The mitigatory measures stipulate that a

service/maintenance plan for the pipelines must be compiled, approved by the competent authority

and implemented. The plan must encompass procedures to minimise any impacts on the

surrounding environment such as vegetation removal and ground compaction. It must also outline

monitoring, emergency spill response and trenching procedures for any malfunctions. An approved

operational Stormwater Management Plan must be implemented to ensure only clean stormwater

enters the watercourses in a controlled manner.


22 | P a g e

3 ASPECTS TAKEN INTO CONSIDERATION

3.1 DEPARTMENTAL CORRESPONDENCE

The DWS Regional Office in the Limpopo Province was consulted as the relevant regulator dealing

with the Water Use License Application. In brief the application process could be summarised as

tabled below:

Table 3-1: Regulatory consultation process followed

Date Aspect Outcome

20 February 2015 Pre-feasibility meeting

Written notification and arrangement

for site visit. Meeting held at Mogol

Club and requirements for WULAR,

section 25(2) application and IWWMP

discussed as well as timeframe for

submission

20 May 2015 Regulatory authority meeting

Feedback on progress with IWWMP

and WULAR were reported as well as

the timelines for completing the

application process. In addition the

issuance of letters 1, 2 and 3 as per

Guidance Note was discussed. The

letters were required to be included

in the Bid Process

13 October 2015 Regulatory Authority Technical

Meeting: Polokwane

The draft IWWMP was presented to

the authorities covering section

21(a), (b), (c), (i), (f) and (g) water

uses. It was stated that the design

drawings are conceptual and will only

be finalised once the outcome of the

bid process is made known. The DWS

stated that the application will be on

hold until such time that they are

notified about the outcome of the Bid

Process.

18 October 2016 Regulatory Authority meeting

DWS notified that the applicant was

selected as the successful bidder and

that a Letter of submission of WULAR

is required by the Department of

Energy. The DWS responded that

application is still in pre-feasibility

phase and that the following actions

are required:

1. DW760 and supplementary 784

for the abstraction of water on a

borehole located on the farm

Transutu 257;

2. Supplementary form for Section

21 c and I water uses;

3. Signature on some of the DW763

application form;

4. Supplementary DW904 and 905


23 | P a g e

Date Aspect Outcome

forms with respect to waste

related water uses;

5. Signature on DW 901 and 902

forms for Onbelyk farm;

6. DW901 and 902 for Transutu 257

farm;

7. Title deed for Transutu 257 farm;

8. Comments by the Mokolo Water

Users Association for the Transfer

of water from Exxaro to the

applicant;

9. Comments by the land claims

commissioner with respect to

both the donating and receiving

property;

10. R114,00 water use

administration fee;

11. Construction Method

Statements;

12. A0 size Layout Master plan

which shows the proposed

activities with respect to the

water courses;

13. A0 size Signed Civil design

drawings done by a registered

professional;

14. Stormwater Management

Plan;

15. Exxaro’s updated water

balance which include the supply

to Thabametsi Power Plant

In order to adhere to the requirements as stipulated by the Regulatory Authority these aspects

were addressed and incorporated in the updated Water Use License Application Report (2017) for

further assessment, evaluation and issuance of the Water Use License in favour of the applicant.

3.2 LICENSE ADMINISTRATION

All completed and signed DW forms are attached in Appendix 7 of the WULAR. The following DW

forms with their specified supplementary forms are submitted in support of the WULA (refer Table

3-2).

Table 3-2: Completed DW Forms

WU DW Form Water Use Description Volume/

Dimension

- 755 All Water Use Registration

- 758 N/A Company Registration

1 760 Section 21(a) Taking water 720,000 m3/a

2 762 Section 21(b) Storing water 30,000 m3

3 763 768

Section 21(c), (i) Pipeline water crossing A at

wetland unit 4 230 m


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WU DW Form Water Use Description Volume/

Dimension

4 763

768 Section 21(c), (i)

Pipeline water crossing B at


5 763 768

Section 21(c), (i) Pipeline water crossing C at


6 763

768 Section 21(c), (i)

Power plant infrastructure

within a 500 m protective

buffer zone of wetland cluster

1000 m

7 767 Section 21(g) Ash Disposal PCD 56,000 m3

8 767 Section 21(g) Coal Stockpile PCD 2,650 m3

9 767 Section 21(g) Evaporation pond 16,200 m3

10 767 Section 21(g) Waste Water Collection Pond 1,200 m3

11 767 Section 21(g) Storm Water Pond 13,600 m3

12 767 Section 21(g) Strategic Coal Stockyard 750,000 ton

13 767 Section 21(g) Ash Dump 270 Ha

280 T/hr

14 766 Section 21(f) WWTW Bio-filter plant 600 m3/day

15 767 Section 21(g) Dust Suppression 120,450 m3

781 Supplementary Section 21(c) and (i) for

pipeline crossings

901 Property Appelvlakte 488

901 Property Gelykebult 450

901 Property Gelykebult 455

901 Property Graafwater 456_1

901 Property Graafwater 456_RE

901 Property Onbelyk 257

901 Property Vooruit 449

902 Property owner Exxaro

905 Supplementary Ash dump PCD

905 Supplementary Coal Stockpile PCD

905 Supplementary Evaporation pond

905 Supplementary Waste Water Collection Pond

905 Supplementary Storm Water Pond

905 Supplementary Strategic Coal Stockyard

905 Supplementary Ash dump

788 Water Use Sector Power Generation

3.3 INPUTS FROM OTHER DEPARTMENTAL DIRECTORATES

3.3.1 National Water Resource Planning

Several discussions were held with the Director: Option Analysis in an attempt to secure water

supply to the Thabametsi Power Plant. These discussions were attended by the TCTA that acts as

the Implementing Agent of the DWS. All requirements as specified had been considered as part of

the WULA.

3.3.2 Abstraction and Storage

Input from the Chief Engineer: Water Supply (Crocodile West and Marico) was obtained that has

recommended that the requirements of the Limpopo Regional Office must be followed. In terms of

this procedural statement the Regional Office has requested that the surrender of water must be

done in accordance with the requirements as contained in Section 25 of the National Water Act.


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3.3.3 Civil Design

The Directorate Civil Design oversees the evaluation of all water management facilities inclusive of

infrastructure, capacity of containment facilities, design specifications and storm water

management measures. A Civil Engineering Design Report must accompany the WULA detailing the

following:

Pipe River Crossings/Impeding Structures

Indicate in the engineering design report the following:

Nature of crossing, below on or above river bed;

If on or above river bed, analysis of effect of pipe on flow velocity and remedial effects on

possible erosion and ponding/flooding caused by the impeding pipe structure;

Construction method on perennial stream ensuring further damage to the watercourse is

minimised;

If the stream is diverted during construction, method used to divert the flow to minimise

the silt load on the stream;

For culverts/bridges, check storm event designed for and the freeboard allowed for;

For design events less than 1:100 year storm, what measures are taken to protect the

public and the risk of the structure being washed away

Storm water discharge into the watercourse/environment

What measures are taken to attenuate storm water;

Energy dissipation measures to minimise erosion at the discharge into the water course

environment

Clean and Dirty Water Dams/Stock Pile Facilities

Type of section 21(g) facilities;

Sizing of each facility with design calculations, 1:50 storm event and 0.8 m freeboard;

Safety risk of each impoundment (Dams more than 50,000 m3 and wall height more than 5

meters high);

Waste Classification Type (Norms and Standard, R 635 August 2013);

Barrier Layout Type (commensurate with Waste Classification Type)

o Design reports and drawings certified by a registered, professional civil engineer;

o Service life considerations quantified taking into account temperature effects on

containment barriers;

o Alternative elements of proven equivalent performance considered, such as the

replacement of:-

Granular filters or drains with geo-synthetic filters or drains;

Protective soil layers with geotextiles; or

Clay components with geo-membranes or geo-synthetic clay liners;

o All drainage layers that must contain drainage pipes of adequate size, spacing and

strength to ensure atmospheric pressure within the drainage application for the

service life of the facility;

o Alternative design layouts for slopes exceeding 1:3 (vertical: horizontal)

o Construction Quality Assurance (CQA);

o Geo-synthetic materials and compliance with relevant South African National

Standard specifications, or any prescribed management practice or standards which


26 | P a g e

ensure equivalent performance and consideration of the compatibility of liner

material with the waste stream

3.3.4 Environment and Recreation

The Sub-directorate: Environment and Recreation oversees the assessment and evaluation of all

section 21(c) and (i) water uses. The Thabametsi Power Plant triggers four section 21(c) and (i)

water uses due to the locality of the site within the protective buffer zone of delineated depression

(pan) wetlands. It is required that the WULA needs to be supported by specialist reports

(Wetland/Biodiversity) as well as Work Method Statement, Rehabilitation Plan and Plant Species

Plan. The plant species plan is inclusive of an Alien Invasive Control Program. It is further required

that all aspects related to the water use be indicated on a Master Layout where the water use is

related to the impacted receiving receptors.

3.4 INPUTS FROM STAKEHOLDERS

Savannah Environmental (Pty) Ltd as the appointed lead consultant has conducted a

comprehensive Public Participation Process. All details regarding the public participation process

followed is contained in the Environmental Impact Assessment Report as well as main concerns

summarised in the Integrated Water and Waste Management Plan.

During the pre-feasibility meeting held during February 2015 the DWS stated that it considered the

process followed satisfactory and that no additional consultation as depicted in Section 41(4) of the

National Water Act, 1998 (Act 36 of 1998) needs to be conducted. However, the applicant has

decided to voluntarily conduct public participation in terms of Section 41(4) of the NWA. A public

meeting was held on 31 October 2016 in Lephalale. In addition selected stakeholder meetings were

held with key role-players such as Exxaro, TCTA and Eskom to address concerns related to the

availability of water.

It is also noted that the Centre for Environmental Rights approached Menco during September

2014 to be registered on the stakeholders list. A list of names from the CER was made available to

whom feedback must be provided regarding the progress of the WULA. The CER was notified about

the status of the application and once the final IWWMP is updated it will be placed on the website

of Savannah Environmental for notification and further comment. The following stakeholders will

be notified in this regard:

Centre for Environmental Rights:

2. Robyn Hugo: [email protected]

3. Sylvia Kamanja: [email protected]

4. Ruth Kruger: [email protected]

5. Nicole Loser: [email protected]

6. Teboho Sebogodi: [email protected]

Earthlife Africa, Johannesburg Office

1. Dominique Doyle: [email protected]








27 | P a g e

2. Tristen Taylor: [email protected];

3. Makoma Lekalakala: [email protected]

The CER has objected to the WULA process lodged by the applicant and has requested that a

dedicated Public Participation Process be conducted for the WULA process. All the concerns and

comments as raised by the IAP’s are contained in the Public Participation Report included in this

application as APPENDIX 21.




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4 SECTION 27 MOTIVATION

4.1 EXISTING LAWFUL WATER USES

There’s currently no ELU for the property or activity. However, an Existing Lawful Use to be utilised

as a water source by the applicant is authorised to Exxaro. The DWS agreed that the WUL for

Exxaro would need to be amended to reflect water supply to the applicant and that the water

surrendered would need to be reflected as a Section 21(a) water use in a separate license for the

applicant. In terms of Section 25(1) of the NWA the temporary transfer of water from Exxaro to the

applicant is not feasible as this only applies to agricultural water allocation to be used for other

activities. Therefore, in terms of Section 25(2) of the NWA a permanent transfer of water needs to

be applied for whereby Exxaro surrenders part of their water allocation to favour the application by

the applicant. The section 25(2) application was submitted to the DWS during June 2015.

Subsequently the WUL of Exxaro have been replaced by a new amended water use license. In

order to ensure that the Section 25(2) application by the applicant is aligned with the amended

license, an updated application is submitted with the IWULAR for processing. The application is

contained in APPENDIX 4 of this report.

4.2 THE NEED TO REDRESS PAST RACIAL AND GENDER DISCRIMINATION

Thabametsi Power Company (Pty) Ltd is majority owned by South African investors comprising

affiliates of the Public Investment Corporation, Royal Bafokeng Holdings, KDI Holdings and

Tirisano. The Project has a total South African entity participation of 51% and its total ownership

by Black People is 30%.

Furthermore, Thabametsi Power Company (Pty) Ltd has made a number of economic development

commitments in terms of the Coal Baseload IPP Procurement Programme. These commitments

effectively ensure that there will be more jobs created than in any other single IPP project in South

Africa. The Project will also create a foundation for new, private baseload coal industrialization

initiatives in South Africa. Such skills development will enable South African citizens to service

South Africa and the region, as a result of these extensive local content commitments. The

manufacture of components and other supply chain items will have a positive economic impact on

the country. In support of the stimulus offered by this Project to local industry, approximately R820

million will be spent on developing new and growing the capacity of existing, suppliers to the local

coal and power industry. The applicant's detailed economic development plan seeks to address the

key needs identified in the area and the Limpopo Province in general.

The plan identifies the following key objectives and focus areas:

establishment of a local industry which is capable of constructing and operating a baseload

coal plant for the life thereof;

creation of 14 348 direct and indirect jobs over the life of the Project, across both

construction and operating periods, providing decent work in an area of high

unemployment;


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the focus of supplier development spend to create and support a number of Black

Industrialists in the supply chain;

a focus on a combination of broad-based, and women, as well as entrepreneurial Black

ownership in the Project (30%); and

the creation of an operating company, that will have the capacity to run this Project for 30

years.

4.3 EFFICIENT AND BENEFICIAL USE OF WATER IN THE PUBLIC INTEREST

5.3.1 Taking of water

Potable water will be obtained from the allocation made to Exxaro, as will water required for power

generation activities. This water will be treated by the applicant to the applicable standards for

utilisation within the Thabametsi Power Plant. The taking of water from the allocated MCWAP phase

1 has triggered several concerns related to sustainable water supply to the region.

5.3.2 Altering the natural characteristics of the wetland areas

Even though the applicant is planning to develop 500 hectares, none of the footprint of the

Thabametsi Power Plant will impact directly on the wetlands in the area. Indirect impacts are

foreseen due to invasion of the 500 m protective buffer zone.

5.3.3 Waste disposal

The seven section 21(g) applications for the disposal of waste in a manner that may be detrimental

to the environment are for the Pollution Control Dams, coal stock yard as well as dust suppression.

The PCD’s are lined and designed in accordance with GN 704 Regulations.

Furthermore, an application is made for a section 21(f) water use. This is for the

disposal/discharging of treated effluent from the Bio-filter System. The system will be designed to

adhere to GN 665 Limits. The water containing waste will be recycled in accordance with the ZLED

policy for the Thabametsi Power Plant. The WWTW effluent will be used in the hydration of ash for

disposal to the ash dump.

4.4 THE SOCIO-ECONOMIC IMPACT OF THE WATER USE OR USES IF AUTHORISED

The power generation activity will have a positive effect on the socio-economic context of the

region. The proposed Thabametsi Power Plant will create new employment opportunities, thus

positively impacting indirectly on dependents and the economic environment. Should the

application be successful, it will have a positive effect.

The main positive impacts are:


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Employment to a number of people during the construction and operational phases. The

numbers of jobs created are significant to the local and regional economy.

A large capital investment and foreign direct investment in the region.

Significant amounts paid to the government in the form of local, regional and national

taxes and levies.

Creation and support of service-sector jobs, the annual procurement of large quantities of

consumables and the outsourcing of service provision to local service providers.

The power generated will go towards Eskom’s power generation needs and therefore the

electricity output needed in South Africa

The positive impacts described above can be even further enhanced in the context of the

communities surrounding the project site. Further measures to enhance socio-economic

opportunities should focus on the promotion and development of small and medium enterprises in

the local communities, especially due to the short timeframe expected. Larger contracts should be

broken down into smaller more accessible contracts and local people should be employed where

possible.

The main potential negative impacts include the population influx into the area around a project

site and associated squatting is often associated with the chance of job opportunities. Well defined

employment/recruitment and housing policies will help negate the possibility of squatter

settlements and the associated problems. In addition, co-operation with the local police will help to

ensure that private property rights are protected on the project site and surrounding farmland.

4.5 THE SOCIO-ECONOMIC IMPACT OF THE FAILURE TO AUTHORISE THE WATER USE

If this Project does not proceed, the applicant will be prevented developing the Project as selected

by the Department of Energy under the Coal Caseload IPP Procurement Programme that was

implemented to meet the country's electricity demands in terms of the Government's Integrated

Resource Plan . The presence of the power generation activity, the employment of local persons

and the utilisation of local services will result in an increased income for local communities and

business and an increased tax base for traditional authorities and municipalities. These

opportunities will be lost should the project not proceed, and will have consequences on local,

regional and national scale.

Without the new proposed coal-fired power station in Lephalale, and alternative means of

generating an additional 630 MW capacity would be required to be sought from another power

generation source or a similar source in another area. However, as more than 50% of the

remaining coal reserves in the country are located in the Waterberg area, and optimal grid

connection opportunities are available, not developing the Project on the proposed site would see

such an opportunity being lost. At a local level, the level of unemployment will remain the same

and there will not be any transfer of skills to people in terms of the construction and operation of

the Thabametsi Power Plant.


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Without the implementation of this Project, this will not be achieved, and the greater power supply

in the country will be compromised in the near future. This has potentially significant negative

impacts on economic growth and social well-being. In addition, limitations on electricity supply may

impact quality coal for domestic purposes, collection of wood from natural areas, etc.

4.6 THE CATCHMENT MANAGEMENT STRATEGY APPLICABLE TO THE RESOURCE

According to DWAF (2004b) (also as specified in the National Water Act, Act 36 of 1998) the

delegation of water resource management from central government to catchment level will be

achieved by establishing Catchment Management Agencies (CMAs) at WMA level. Each CMA has

the responsibility to develop a Catchment Management Strategy (CMS) for the protection, use,

development, conservation, management and control of water resources within its WMA.

No Catchment Management Agency has been established yet for the Limpopo WMA and thus no

Catchment Management Strategy. However, establishment of such an agency for the Limpopo

Province is currently underway. Several other strategic documents have been compiled for the area

and include:

Department of Water Affairs and Forestry (DWAF), South Africa. 2004. National Water

Resources Strategy, 1st Ed. Pretoria

Department of Water Affairs (DWA), South Africa. 2013. National Water Resources

Strategy, 2nd Ed. Pretoria.

Department of Water Affairs (DWA), South Africa. 2010. Development of a Reconciliation

Strategy for all towns in the Northern Region, Waterberg District Municipality, Lephalale

Local Municipality. Report compiled by SRK Consulting. Pretoria.

4.7 THE LIKELY EFFECT OF THE WATER USE ON WATER USERS

Several surface water users dependent on water supply from the Mokolo Dam Water Scheme had

been identified within close proximity to the project site.

It is important to note that the applicant will receive its water supply from Exxaro. This volume of

water has already been allocated to Exxaro and will be surrendered by Exxaro to the applicant. No

additional water allocation is thus required for the proposed development and it is thus not

anticipated that any other surface water users will be directly affected by the authorization of the

Water Use License. It is however noted that several stakeholders (Eskom Matimba Power Station,

Mokolo Water Users Association, and Earthlife Africa) expressed their concerns regarding water

availability as Exxaro previously did not utilse the full allocation. The increased water demand from

the existing allocation will contribute towards increased stress on the available water resources.

During the operational phase, no groundwater abstraction is expected. Therefore, no groundwater

drawdown is expected from the Thabametsi Power Plant and the current status in this regard, will


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be maintained. However, a single privately owned borehole (LEP10) is likely to be destroyed during

the establishment of the ash dump, which can be considered to be an impact on groundwater

availability.

Mitigation measures as per this report will be implemented to limit the impact on groundwater and

surface water quantity and quality of the area.

4.8 THE CLASS AND THE RESOURCE QUALITY OBJECTIVES OF THE WATER RESOURCE

The project site is located on multiple catchments as delineated by the DWS. The site specific

indicators are given as:

Management area Crocodile Marico-Management Area

Drainage area: A42J/A42G

River name: Mokolo River

Management Unit: Mokolo Water Management Area

The Minister of Water and Sanitation is required to establish a classification system, and to

determine the class and resource quality objectives for all or part of the resources considered to be

significant. The quaternary drainage area A42J and A42G was given as a Class C (Moderately

Modified). The Resource Quality Objectives for the catchment is given in Table 4-1.

Table 4-1: Resource Quality Objectives for the receiving water resource

Variable RQO and Eco Specification for PES

MgSO4 (mg/l) 95th percentile must be ≤ 16 mg/l

Na2SO4 (mg/l) 95th percentile must be ≤ 20 mg/l

MgCl2 (mg/l) 95th percentile must be ≤ 15 mg/l

CaCl2 (mg/l) 95th percentile must be ≤ 21 mg/l

NaCl (mg/l) 95th percentile must be ≤ 45 mg/l

CaSO4 (mg/l) 95th percentile must be ≤ 351 mg/l

EC (mS/m) 95th percentile must be ≤ 30 mS/m

pH 5th and 95th percentiles must range from 6.5 to 8.0

DO (mg/l) 5th percentile of the data must be ≥ 7 mg/l

TIN 50th percentile must be ≤ 0.25 mg/l

PO4-P 50th percentile must be ≤0.015 mg/l

Chl-a 50th percentile must be ≤ 10 µg/l

4.9 INVESTMENTS ALREADY MADE BY THE WATER USER

The applicant has appointed various specialists to conduct environmental investigations in support

of the Environmental Impact Assessment and Water Use License Application.


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An Environmental Authorisation has been obtained from the Department of Environmental

Affairs (EA). The EA has been suspended pending the consideration and decision by the

Minister of, inter alia, the Thabametsi Power Plant's climate change impacts.

A Waste License has been obtained from the Department of Environmental Affairs;

EMP, EIA and associated specialist studies and impact assessments have been conducted;

Water samples have been taken to determine a reference condition which must be

maintained during operation of the Thabametsi Power Plant;

Civil Engineers have been contracted to design Pollution Control Facilities, Stormwater

Management, Layout plans as well as Water Balances;

The Water Use License Application is in process and will be submitted to the DWS for

evaluation and issuance.

4.10 THE DURATION OF WATER USE

The water uses associated for the Thabametsi Power Plant will be required for a time period of forty

(40) years. The Thabametsi Power Plant's capacity is 630 MW. The activity life description is

detailed in Table 4-2.

Table 4-2: Details of the life activity of the Thabametsi Power Plant Project

Component Description/Dimensions 3Electricity generating capacity 630 MW

Technology to be implemented in the power

generation process

Coal fired power station with Circulating

Fluidised Bed technology, dry cooled and zero

effluent discharge plant

Extend of the development

Thabametsi Power Plant consisting of

production units, boilers, furnaces, turbines,

generators, condensers, office, maintenance

and ash dam area – 50 hectare footprint;

Ash dam on footprint area of 500 hectares

with a life span of 40 years;

Coal Stock Yard of 100 hectares providing

coal for a 30 day period;

Raw water dam with storage capacity of

30,000 m3 on footprint of 2 hectare

4Ash Dam and associated infrastructure

Area of 500 hectares in extent;

Height up to 50 meters;

Storage volume of 200 million m3 of ash;

Overland ash conveyors at rate of 280

ton/hour;

Proposed to operate three PCD’s linked to

the rate of development of the ash dam;

Capacity of three PCD’s given as 33,000m3,

56,000 m3 and 75,000 m3 respectively;

3 Note that the applicant only intends to develop only one 630MW unit

4 Note that during the initial phase of the project only the PCD with storage capacity of 56,000m

3 will be build.


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Component Description/Dimensions

Stormwater management and evaporation

pond for storage of 16,200 m3 of stormwater

run-off

Expected life span of power station set at 40

years

Supporting services required for the duration of

the power station

Raw water supply at rate of 720,000

m3/annum for Phase 1;

Refuse material disposal to be removed by a

contractor for disposal at a licensed landfill

site;

Sanitation entails the construction of a

Waste Water Treatment Works with daily

throughput capacity of 600m3;

Potable water treatment plant with daily

treatment capacity of 4800m3

Pipeline for water supply

18 km in length with tie-in booster pump

station from tie-in point at Matimba Power

Station to Raw Water Storage Reservoir on

site

4.11 THE STRATEGIC IMPORTANCE OF THE WATER USE TO BE AUTHORISED

4.11.1 Site specific

The electricity demand in South Africa is placing increasing pressure on existing power generation

capacity. The National Integrated Resource Plan (IRP) developed by the Department of Energy has

identified the need for power generation from coal as part of the technology mix for power

generation in the country in the next 20 years. This power station is intended to be an IPP project

to alleviate pressure on Eskom’s base load power supply in the short to medium term through

independent power generation and the applicant was accordingly selected as a preferred bidder

under the Coal Baseload IPP Procurement Programme.

4.12 ENFORCEMENT AND MANAGEMENT

4.12.1 Management Plans

Enforcement and Management for the water resource and therefore the water uses that is required

for the Thabametsi Power Plant will be well managed by means of the IWWMP (to be updated

annually) and a complete EMP that had been drafted as part of the EIA process.

4.12.2 Monitoring

Water Management and Monitoring will be thorough and conducted as specified within the IWWMP

that is submitted along with this application. The proposed monitoring would suffice to assist with

the classification of the resources. There should however be a few additions such as:

Bio-Monitoring upstream and downstream of all drainage, riparian and wetland crossings

Wetland monitoring of wetlands to be conducted annually

Surface water monitoring at all waste streams including storm water once the Thabametsi

Power Plant becomes operational


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Groundwater monitoring (quality and depth) will be important to monitor the behaviour of

the groundwater resource

The applicant will be based on a SHEQ system that will seek continuous improvement and therefore

data and document control will be strictly implemented for purposes of management and early

detection in terms of water uses and possible anticipated impacts that was identified and discussed

within the Integrated Waste Water Management Plan (IWWMP) of this WUL application. Please

refer to the included IWWMP for more details on this matter.


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5 CONCLUSIONS AND RECOMMENDATIONS

From the attached appendices, and information contained in this application, the following

conclusion and recommendations are made.

Even though there are multiple impacts associated with power generation, the Thabametsi Power

Plant is situated within a developed area with several mining, power generation and industrial

developments. The following waste management hierarchy will be applied: reduce at source, re-

use, and re-cycle. Any waste generated will be disposed in an environmentally responsible manner.

From the geo-hydro study there are impacts identified for this operation. It is stated that there will

be moderate to high impacts stemming from the ash dump, coal stockpile and PCD areas. The

Thabametsi Power Plant has already obtained a waste license and adherence to the requirements

of the license will minimize the impacts on the aquifer in the area. Therefore, the impact of waste

is considered to be low with mitigation.

The depression wetland within the 500 m buffer zone of the study area is considered a low

significance in terms of national importance. The wetlands in the wider study area are considered

most sensitive with unique species composition and aquatic ecosystem functioning.

The lack of a sustainable raw water supply to the area is considered a high risk. The development

of Phase 2 of the MCWAP scheme will alleviate the future demand for water in the region. The

applicant has secured a raw water allocation (720,000 m3/a) under Phase 1 of MCWAP scheme

from Exxaro which is considered sufficient to allow for the continuation of the 630MW Plant.

It is therefore recommended that Thabametsi Power Company (Pty) Ltd should be issued a Water

Use License for the maximum period required for the Thabametsi Power Plant.


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6 REFERENCES

Department of Water Affairs and Forestry: Preliminary Determination of Reserve (RDM ref:

26/8/3/3/297)

Department of Water Affairs: National Water Resource Strategy, Second Edition (June 2013) Web:

http://www.dwa.gov.za/nwrs2013

Department of Water Affairs: National Water Resource Strategy, Second Edition (2013), Annexure

A: Perspectives per Water Management Area

Government Gazette Notice: No 26187 (339) published 26 March 2004: Revision of General

Authorisations in terms of Section 39 of the National Water Act, 1998 (Act no. 36 of 1998)


Appendix

Appendix 1:

Company Registration and ID


Appendix

APPENDIX 2:

Property Title Deeds


Appendix

APPENDIX 3:

Contractual Agreement


Appendix

APPENDIX 4:

Section 25(2) Application


Appendix

APPENDIX 5:

Master Layout Plan


Appendix

APPENDIX 6:

BBEE Certification


Appendix

APPENDIX 7:

DW FORMS


Appendix

APPENDIX 8:

Proof of Payment


Appendix

APPENDIX 9:

Record of Decision


Appendix

APPENDIX 10:

Integrated Water and Wastewater Management

Plan


Appendix

APPENDIX 11:

EIA and EMP


Appendix

APPENDIX 12:

Wetland Delineation Study


Appendix

APPENDIX 13:

Biodiversity Assessment


Appendix

APPENDIX 14:

Surface Water


Appendix

APPENDIX 15:

Geohydrological Assessment


Appendix

APPENDIX 16:

Work Method Statement and Rehabilitation


Appendix

APPENDIX 17:

Stormwater Management Plan


Appendix

APPENDIX 18:

Civil Engineering Design Report


Appendix

APPENDIX 19:

Water Balance


Appendix

APPENDIX 20:

Hydrology and Water Supply


Appendix

APPENDIX 21:

Public Participation

Documents

WATER USE LICENSE APPLICATION REPORT