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Basic Assessment Environmental Impact Assessment Report: Proposed Wastewater Treatment Facility and Associated Infrastructure, Including Irrigation and Discharge into a Watercourse of Treated Effluent from the WWTW and Storage of Treated Effluent, Remainder of Farm No. 695 and the Remainder of Portion 12 of the Farm Rietfontein No. 175, Bonnievale, Western Cape Province

30 July 2019

PO Box 30134, Tokai, 7966 Telephone: 021 712 5060, Fax: 021 712 5061

Email: [email protected]

BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) – October 2017 Page 1 of 143

BASIC ASSESSMENT REPORT

BASIC ASSESSMENT REPORT

IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107

OF 1998) AND ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2014 (AS

AMENDED)

October 2017

PROJECT TITLE

Proposed Wastewater Treatment Facility and Associated Infrastructure, Remainder of Farm No. 695, Parmalat, Bonnievale, Western Cape Province.

16th July 2019

REPORT TYPE CATEGORY REPORT REFERENCE NUMBER DATE OF REPORT Pre-Application Basic Assessment Report (if

applicable)1 SEC Reference Number: 019026 16th July 2019

Draft Basic Assessment Report2 Final Basic Assessment Report3 or, if applicable

Revised Basic Assessment Report4 (strikethrough

what is not applicable)

Notes:

1. In terms of Regulation 40(3) potential or registered interested and affected parties, including the Competent Authority,

may be provided with an opportunity to comment on the Basic Assessment Report prior to submission of the application

but must again be provided an opportunity to comment on such reports once an application has been submitted to the

Competent Authority. The Basic Assessment Report released for comment prior to submission of the application is referred

to as the “Pre-Application Basic Assessment Report”. The Basic Assessment Report made available for comment after

submission of the application is referred to as the “Draft Basic Assessment Report”. The Basic Assessment Report together

with all the comments received on the report which is submitted to the Competent Authority for decision-making is referred

to as the “Final Basic Assessment Report”.

2. In terms of Regulation 19(1)(b) if significant changes have been made or significant new information has been added to

the Draft Basic Assessment Report , which changes or information was not contained in the Draft Basic Assessment Report

consulted on during the initial public participation process, then a Final Basic Assessment Report will not be submitted, but

rather a “Revised Basic Assessment Report”, which must be subjected to another public participation process of at least

30 days, must be submitted to the Competent Authority together with all the comments received.


DEPARTMENTAL REFERENCE NUMBER(S)

Pre-application reference number:

File reference number (EIA):

NEAS reference number (EIA):

File reference number (Waste):

NEAS reference number (Waste):

File reference number (Air Quality):

NEAS reference number (Air Quality):

File reference number (Other):

NEAS reference number (Other):


CONTENT AND GENERAL REQUIREMENTS

Note that:

1. The content of the Department’s Circular EADP 0028/2014 (dated 9 December 2014) on the “One Environmental

Management System” and the Environmental Impact Assessment (“EIA”) Regulations, 2014 (as amended), any subsequent

Circulars, and guidelines must be taken into account when completing this Basic Assessment Report Form.

2. This Basic Assessment Report is the standard report format which, in terms of Regulation 16(3) of the EIA Regulations, 2014

(as amended) must be used in all instances when preparing a Basic Assessment Report for Basic Assessment applications

for an environmental authorisation in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998)

(“NEMA”)and the EIA Regulations, 2014 (as amended) and/or a waste management licence in terms of the National

Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (“NEM:WA”), and/or an atmospheric emission licence

in terms of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (“NEM:AQA”) when the

Western Cape Government: Environmental Affairs and Development Planning (“DEA&DP”) is the Competent

Authority/Licensing Authority.

3. This report form is current as of October 2017. It is the responsibility of the Applicant/ Environmental Assessment Practitioner

(“EAP”) to ascertain whether subsequent versions of the report form have been released by the Department. Visit the

Department’s website at http://www.westerncape.gov.za/eadp to check for the latest version of this checklist.

4. The required information must be typed within the spaces provided in the form. The size of the spaces provided is not

necessarily indicative of the amount of information to be provided. The tables may be expanded where necessary.

5. The use of “not applicable” in the report must be done with circumspection. All applicable sections of this report form must

be completed. Where “not applicable” is used, this may result in the refusal of the application.

6. While the different sections of the report form only provide space for provision of information related to one alternative, if

more than one feasible and reasonable alternative is considered, the relevant section must be copied and completed for

each alternative.

7. Unless protected by law, all information contained in, and attached to this report, will become public information on

receipt by the competent authority. If information is not submitted with this report due to such information being protected

by law, the applicant and/or EAP must declare such non-disclosure and provide the reasons for believing that the

information is protected.

8. Unless otherwise indicated by the Department, one hard copy and one electronic copy of this report must be submitted

to the Department at the postal address given below or by delivery thereof to the Registry Office of the Department.

Reasonable access to copies of this report must be provided to the relevant Organs of State for consultation purposes,

which may, if so indicated by the Department, include providing a printed copy to a specific Organ of State.

9. This Report must be submitted to the Department and the contact details for doing so are provided below.

10. Where this Department is also identified as the Licencing Authority to decide applications under NEM:WA or NEM:AQA, the

submission of the Report must also be made as follows, for-

• Waste management licence applications, this report must also (i.e., another hard copy and electronic copy) be

submitted for the attention of the Department’s Waste Management Directorate (tel: 021-483-2756 and fax: 021-483-

4425) at the same postal address as the Cape Town Office.

• Atmospheric emissions licence applications, this report must also be (i.e., another hard copy and electronic copy)

submitted for the attention of the Licensing Authority or this Department’s Air Quality Management Directorate (tel:

021 483 2798 and fax: 021 483 3254) at the same postal address as the Cape Town Office.

DEPARTMENTAL DETAILS

CAPE TOWN OFFICE GEORGE REGIONAL OFFICE

REGION 1 (City of Cape Town & West Coast District)

REGION 2 (Cape Winelands District & Overberg District)

REGION 3 (Central Karoo District & Eden District)

Department of Environmental Affairs

and Development Planning

Attention: Directorate: Development

Management (Region 1)

Private Bag X 9086

Cape Town,

8000

Registry Office

1st Floor Utilitas Building

1 Dorp Street,

Cape Town

Queries should be directed to the

Directorate: Development

Management (Region 1) at:

Tel.: (021) 483-5829

Fax: (021) 483-4372





Private Bag X 9086

Cape Town,

8000

Registry Office

1st Floor Utilitas Building

1 Dorp Street,

Cape Town




Tel.: (021) 483-5842

Fax: (021) 483-3633





Private Bag X 6509

George,

6530

Registry Office

4th Floor, York Park Building

93 York Street

George




Tel.: (044) 805-8600

Fax: (044) 805 8650

http://www.westerncape.gov.za/


TABLE OF CONTENTS:

Section Page(s)

Section A: Project Information 27

Section B: Description of the Receiving Environment 45

Section C: Public Participation 65

Section D: Need and Desirability 67

Section E: Details of all the Alternatives considered 74

Section F: Environmental Aspects Associated with the Alternatives 83

Section G: Impact Assessment, Impact Avoidance, Management, Mitigation

and Monitoring Measures 91

Section H: Recommendations of the EAP 136

Section I: Appendices 138

Section J: Declarations 139

APPENDICES:

APPENDIX Attached

Appendix A: Locality Map (s) X

Appendix B:

Layout Plan & WWTW Process Flow X

B1: Layout of Three Options & Associated Infrastructure X

B2: Detailed Site Layout Plan for WWTW Design X

B3: Elevations and Sections for WWTW X

B4: WWTW Process Flow Diagram X

B5: Concept Design of Emergency Detention Pond Pending

B6: Concept Design of Discharge Outlet into Breede River Pending

B7: Conceptual Stormwater Management Design Pending

Appendix C: Photographs X

Appendix D:

Biodiversity Overlay Map(s) X

D1: Critical Biodiversity & Ecological Support Areas X

D2: Freshwater Ecosystems Likely to be Impacted Upon X

D3: NFEPA, Non-Perennial Rivers & Wetlands X

Appendix E:

Existing Approvals / Licenses X

E1: Copy of comment from HWC

E2: Existing Water Use License (effluent storage & irrigate)

X

X

Appendix F:

Public Participation Information: X

Appendix F1: Register of Interested & Affected Parties X

Appendix F2: Site Notice & Proof of Placement X Proof

Pending

Appendix F3: Newspaper Advertisements & Proof of

Placements

X Proof

Pending


Appendix F4: Proof of Notification Pending

Appendix F5: All Comments Received Pending

Appendix F6: Comments & Responses Table Pending

Appendix G:

Specialist Report(s) X

Appendix G1: Freshwater Impact Assessment X

Appendix G2: Botanical Impact Assessment X

Appendix G3: Geo-hydrological Impact Assessment X

Appendix G4: Heritage Notice of Intent to Develop

Appendix H: Environmental Management Plan X

Appendix I: CV of EAP X

ACRONYMS USED IN THIS BASIC ASSESSMENT REPORT AND APPENDICES:

BAR Basic Assessment Report

CBA Critical Biodiversity Area

DEA National Department of Environmental Affairs

DEA&DP Western Cape Government: Environmental Affairs and Development

Planning

DWS National Department of Water and Sanitation

EIA Environmental Impact Assessment

EMPr Environmental Management Programme

ESA Ecological Support Area

GA General Authorisation

HWC Heritage Western Cape

I&APs Interested and Affected Parties

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

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

2004)

NEM:ICMA National Environmental Management: Integrated Coastal Management Act,

2008 (Act No. 24 of 2008)

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

NHRA National Heritage Resources Act, 1999 (Act No. 25 of 1999)

PPP Public Participation Process

WULA Water Use License Application


DETAILS OF THE APPLICANT

Applicant / Organisation /

Organ of State: Parmalat SA (Pty) Ltd

Contact person: Connie Fagan (Head of Risk: Africa Region)

Postal address:

Parmalat SA (Pty) Ltd Strand Road Stellenbosch

Telephone: 021 809 1400 Postal Code: 7600

Cellular: 083 386 6105 Fax: 021 886 6939

E-mail: [email protected]

DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (“EAP”)

Name of the EAP organisation: Sillito Environmental Consulting (SEC)

Person who compiled this

Report: Lauren Elston

EAP Reg. No.: N/A Contact Person (if not author): Lauren Elston

Postal address:

P.O. Box 30134 Tokai Cape Town

Telephone: 021 712 5060 Postal Code: 7966

Cellular: 071 992 2341 Fax: 021 712 5061

E-mail: [email protected]

EAP Qualifications:

Bachelor of Science (Honours) Degree: Environmental Management; and Bachelor of Science Degree: Environmental & Geographical Science and Oceanography & Atmospheric Sciences.

Please provide details of the lead EAP, including details on the expertise of the lead EAP responsible for the Basic Assessment

process. Also attach his/her Curriculum Vitae to this BAR.

Lauren has a Bachelor of Science Honours Degree in Environmental Management obtained from UNISA (cum laude) and a Bachelor of Science Degree (Environmental & Geographical Science, Atmospheric Science and Oceanography) obtained from UCT in 2005. She has more than 12 years of local and international practical experience in the environmental impact assessment, management consulting and climate science fields of expertise. Lauren has compiled numerous Environmental Impact Assessment Reports in the past 12 years and she has worked in the private environmental consulting field as well as in the public sector as an environmental case officer for DEA & DP in 2007. Lauren is a member of the South African Affiliate of the International Association for Impact Assessment (IAIAsa). Lauren is also a member of the National Association of Clean Air (NACA). Please see CV attached in Appendix I.

mailto:[email protected]



EXECUTIVE SUMMARY OF THE BASIC ASSESSMENT REPORT:

1. Introduction & Background

Parmalat SA (Pty) Ltd has a dairy product and cheese factory located in Bonnievale (see Appendix A Site

Location Map). The facility employs hundreds of people in the community. The facility produces liquid industrial

wastewater from the cheese making process that is currently partially treated at the factory before being

pumped approximately 5.2km south to a 180 000m3 capacity effluent storage dam. The partially treated effluent

is used to irrigate approximately 45ha of kikuyu grass adjacent to the effluent storage dam.

The Parmalat SA Bonnievale facility historically generated between 1 200m3 to 1 300m3 effluent / day (prior to

2017). In 2017, a decision was taken to relocate the “Simonsberg” plant in Stellenbosch to Bonnievale and a

smaller part to Ladismith. The relocation was motivated by economies of scale and less transport costs of

primary and secondary by products. The feta production plant, white mould production plant and processed

cheese production plant were moved to Bonnievale and blue mould cheese production was moved to Ladismith.

This resulted in more processing equipment in Bonnievale and subsequently more cleaning activities and hence

the considerable increase in effluent wastewater generated.

On the 17th May 2011 Parmalat SA was issued with a Water Use License (see Appendix E2 to irrigate with

partially treated wastewater and to store wastewater in an effluent retention dam. Parmalat SA confirmed that

they were also issued with an Environmental Authorisation for the construction of the effluent storage dam. The

EA cannot however at this stage be found on record. We are engaging t-with the DEA & DP to obtain the EA

for the large dam that was built in 2011.

There however challenges with the existing Water Use License and Parmalat’s current ability to meet the

conditions of the Water use License (WULA). Parmalat are irrigating more than that allowed for in the license

and the wastewater quality is exceeding the required water quality limits. This has resulted in localised odours,

waterlogged soil and vegetation loss, further reducing the ability of the grass to absorb the water. Impacts to

the freshwater environment have also taken place and are currently taking place as wastewater has been / is

being discharged to the Breede River that exceeds the General Limit Values1.

The effluent storage dam is currently at almost full capacity (the dam wall is 10m in height). Please note that in

addition to the effluent, the storage dam also receives natural stormwater runoff. Irrigation of effluent from the

dam is not always possible if the soils are waterlogged during rainy periods. Given the poor quality of the effluent

in the storage dam (dam capacity of 180 000m3), should the dam wall collapse or effluent overflow into the

watercourse as a result of exceeding the storage capacity, this would significantly impact on the downstream

watercourses. Parmalat therefore urgently need to implement short and long-term measures to reduce existing

and potential future impacts to the environment, most importantly the freshwater environment, and the social

environment (employees of the factory and adjacent landowners / community).

With regards to a short-term solution to reduce the existing impacts and to avoid potential future risk, the

following measures have been implemented by Parmalat SA:

• “water sprayers” have been installed at the dam with the purpose of spraying effluent from the dam into the

atmosphere for increased evaporation;

• “roll-on” lawn (Kikuyu grass) has been applied within the areas in the existing 45ha irrigation area where

lawn has died, with the aim of absorbing effluent;

• Expansion of the existing 45ha irrigation area by an additional 2 X 16ha has taken place. Two additional

irrigation areas have been identified (2 X 16ha). The addition 32ha area is already being irrigated (since

May / June 2019). An emergency General Authorisation Water Use License Application is being submitted

1 General Limit Values are wastewater discharge limits allocated to substances within the wastewater which are set out in

the National Water Act (NWA). They have been formulated by the Department of Water Affairs and it is assumed that

should the limits specified not be exceeded then significant impacts to people’s health, well-being and the freshwater

environment will not take place as they were formulated for this purpose.


to the BGCMA in this regard and close consultation has taken place with the BGCMA with the aim of

receiving a GA for the two irrigation expansion areas shortly.

• Parmalat SA are discharging a portion of the untreated effluent (“cows’ water”) to the river (approximately

300 000 litres per day). This activity should cease due to the poor quality of the effluent causing water

pollution impacts. Discharge into the river should only take place once the WWTW is in operation and the

water quality has been treated to General Limit Values;

With regard to a long-term solution to improve on the water quality of the effluent, a Wastewater Treatment

Works (WWTW) is proposed to treat the industrial effluent generated from the dairy factory to General Limit

Values in order to not only irrigate the treated effluent at an improved water quality but to also discharge treated

effluent to the Breede River. This will relieve pressure of the 45ha irrigation area and the effluent storage dam.

During winter months, when irrigation is not possible, effluent can then be discharged into the river at an

acceptable quality.

The BGCMA has advised that due to the flaws in the existing WULA (45ha irrigation area and wastewater

storage facility) that an entirely new WULA must be submitted for the current 45ha irrigation area (already

licensed), existing effluent storage dam (already licensed), seepage and balancing ponds near the large effluent

dam, a new emergency effluent storage dam proposed at the factory, the crossing of watercourses for the road

and pipeline infrastructure associated with the WWTW as well as the proposed discharge of treated effluent to

the river.

Sillito Environmental Consulting (SEC) has therefore been appointed to undertake an Integrated WULA & Basic

Assessment EIA Process for the proposed WWTW and associated infrastructure with the aim of receiving an

Environmental Authorisation for the WWTW and associated infrastructure in terms of the 2014 EIA Regulations,

as amended, published under the National Environmental Management Act (NEMA), and a Water Use License

for the water use activities mentioned above in terms of Section 21 of the National Water Act.

2. Project Location

The WWTW and most of the associated infrastructure (roads and pipelines) associated with the Option 2 site

location (the preferred option being put forward for authorisation) is located on the Remainder of Farm No. 695,

Swellendam. A portion of the proposed access road and pipeline infrastructure, adjacent to the R317, is located

on the Remainder of Portion 26 of the Farm Bosjesmansdrift No. 174. It is also proposed to cross the R317

Provincial Road with the pipeline infrastructure. The site (Farm no 695) is owned by Parmalat SA (Pty) Ltd. The

site is located just outside the town of Bonnievale adjacent to the R317 Provincial road. The site for the WWTW

is opposite the Parmalat Factory on the other side of the R317. Figure 1 below shows the location of the

proposed WWTW. Figure 2 below shows an overview of the study area that was the subject of the Freshwater

Impact Assessment. It shows the location of the three options for the WWTW that have been assessed, the

existing and new irrigation areas and the location of the existing effluent storage dam.

The location of the existing effluent storage dam and existing 45ha irrigation area, proposed to be utilized for

the storage of treated wastewater from the WWTW prior to irrigation on the same site currently being irrigated,

is on the remainder of Portion 12 of the Farm Rietfontein No 175.


Figure 1: The location of the proposed Wastewater Treatment Works (Option 2 is preferred, Option 1 & 3 have

also been assessed).

Figure 2: Overview map of the study area that was the subject of the Freshwater Impact Assessment. It shows

the location of the Parmalat factory (red triangle), proposed WWTW site location options considered (orange

dots) and existing (red) and new irrigation areas (purple and green). (source: SES: Freshwater Impact

Assessment, 2019)

BASIC ASSESSMENT REPORT IN TERMS OF THE EIA REGULATIONS, 2014 (AS AMENDED) – October 2017 Page 10 of

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3. Summary Description of the Proposed Development

Please refer to Annexure B for the proposed layout of the WWTW.

In summary, the following is proposed to be constructed:

• Wastewater Treatment Works with the capacity to treat a maximum of 2 000m3 per day. The development

footprint of the fenced in WWTW facility is 117.26m X 87.65m = 10 277.84m2. The WWTW comprises of

the following:

o Inlet Channel;

o Buffer Tank;

o Decanter Building;

o Clarifier;

o Activated Sludge Reactor;

o Service Water Tank;

o RAS Recirculation Sump and WAS Extraction Sump;

• Rising main pipeline from existing pump station at factory to proposed WWTW (the pipe sections will be

200 NB Class 12 PVC, approximately 200 – 225mm diameter);

• Return main pipeline - return treated effluent to discharge point to river and to existing irrigation area 3km

south (the pipe sections will be 200 NB Class 12 PVC, approximately 200 – 225mm diameter);

• Access road to WWTW (6m wide);

• Emergency effluent retention dam; and

• Rehabilitation (re-contouring and revegetation) of the riverbank in front of the factory;

The development footprint of the fenced in WWTW facility is 117.26m X 87.65m = 10 277.84m2

The approximate footprint of the road is 740m X 6m = 4 440m2

The approximate development footprint (land to be disturbed to install) of the pipelines (rising main from factory

and treated effluent pipeline discharged to Breede River (discharged at factory riverbank) built adjacent to the

access road is 20m wide 1 500m Long = 30 000m2 (3ha). This includes construction vehicle access and

stockpiling area of material and soil. The pipeline trench is proposed to be excavated to a depth 0.2m below

the design pipeline invert level. During the excavation of the trench, topsoil will be separately stockpiled for

subsequent re-introduction into the top of the trench.

Parmalat also propose to construct a small emergency dam with trenching river side of the existing factory. The

dam and trenching will serve as a secondary measure of protection to avoid contamination of the river by

containing effluent leaks in the event of a primary system failure at the pump station and associated pipelines

at the factory site.

Once the effluent from the factory has been treated at the WWTW to General Limit Standards, it is proposed

to be pumped to the effluent storage dam prior to irrigation of the 45ha area (this activity is already taking place

and is proposed to continue taking place except the effluent will be a far better quality having being treated at

the new proposed WWTW). During times when irrigation is not feasible (winter, water-logged soil, effluent dam

nearing full capacity), it is also proposed to discharge treated effluent into the Breede River. The maximum

amount of effluent proposed to be discharged to the river is 2000m3 per day (treatment capacity of the WWTW).

The maximum amount of effluent that can be irrigated per day is 1500m3 of treated effluent (carrying capacity).


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It is also proposed to undertake rehabilitation of the riverbank (re-contouring and re-vegetation) in front of the

factory near the existing discharge outlet pipe.

4. Need & Desirability for the Proposed Development

The need and desirability of the proposed development has been explained above in the introduction and

background section. In summary the development is needed for the following reasons:

• The Parmalat SA Bonnievale facility historically generated between 1 200m3 to 1 300m3 effluent / day (prior

to 2017). In 2017, a decision was taken to relocate the “Simonsberg” plant in Stellenbosch to Bonnievale

and a smaller part to Ladismith. The feta production plant, white mould production plant and processed

cheese production plant was moved to Bonnievale. This has resulted in more processing equipment in

Bonnievale and subsequently more cleaning activities and a considerable increase in effluent wastewater

generated;

• To improve on the water quality of the wastewater currently being irrigated on the remainder of Portion 12

of the Farm no. 175, Rietfontein (existing 45ha irrigation area);

• To improve on the water quality of the wastewater currently being stored in an effluent detention dam

located on the Remainder of Portion 12 of the Farm no. 175, Rietfontein;

• Parmalat’s production capacity has increased considerably over the past few years. The amount of

wastewater produced has therefore also increased. The size of the existing effluent storage dam and

irrigation area is insufficient to contain the wastewater. It is therefore needed to discharge wastewater into

the Breede River. This can only be undertaken if the wastewater is treated to General Limit Values and this

is why the WWTW is required to be installed.

• Bekker (2019) explains that wastewater volume monitoring indicated that the factory started producing a

higher than 1 500 m3 average volume of wastewater per day since the first months of 2018. The increase

in average wastewater production started in the middle of 2017. This led to higher than expected effluent

levels in the retention dam. At the time of report writing, rainy winter months are here, leaving Parmalat

with a problem as the dam is expected to reach its maximum level very soon. The rainy season means that

the current, already saturated irrigation area will be further waterlogged, and no more effluent can therefore

be irrigated to relieve the pressure on the retention dam. Should the dam overflow, or should untreated

effluent be discharged into the river, it will have serious detrimental impacts on the downstream aquatic

habitat.

• The WWTW is needed and desired at this location because the property is opposite the factory and it is

owned by Parmalat. Therefore, costs will be lower to build the pipeline infrastructure from the factory and

the applicant will not need to purchase a new site. In addition, the Option 2 location proposed is a sufficient

distance from residents (approximately 300m from Uitsig community) and would not result in an

unacceptable visual impact as it’s in the “trough” / “valley” between two adjacent hills. The site location is

in an area that used to be an effluent dam site historically and has been mostly disturbed / transformed

already.

• The WWTW is needed and desired at this location because it will have a low impact to aquatic and terrestrial

biodiversity, low visual impact, low nuisance impact (odours) and overall low environmental impact given

the proposed location and buffer area from sensitive receptors.

5. Legislation

Please refer to Appendix E.

Parmalat SA (Pty) Ltd has the following existing licenses / environmental approvals:

• Water Use License in terms of section 21 of the National Water Act

o Section 21(e): engaging in a controlled activity (irrigation). The activity authorised is the irrigation

of 550 000m3 per annum (approximately 1 500m3 per day) by beneficial irrigation of 45ha of kikuyu

grass;


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o Section 21(g): disposing of waste in a manner which may detrimentally impact on a water resource.

The activity authorised is the storing of wastewater in a retention dam with a capacity of 180 000m3.

• Environmental Authorisation in terms of the 2010 EIA Regulations published under the National

Environmental Management Act (This is still to be confirmed as the EA cannot be found in Parmalat’s

records. The DEA & DP has however indicated that the EA exists and are looking in the archives).

o Activity 11: The construction of:

(iv) dams - where such construction occurs within a watercourse or within 32 metres of a

watercourse, measured from the edge of a watercourse, excluding where such construction will

occur behind the development setback line.

o Activity 18: The infilling or depositing of any material of more than 5 cubic metres into, or the

dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more

than 5 cubic metres from:

(i) a watercourse;

• Final Comment / Permit from Heritage Western Cape in terms of Section 38 of the National Heritage

Resources Act

Parmalat SA (Pty) Ltd are currently applying for the following licenses / approvals (the new WULA will

replace the existing WULA once issued):

• Environmental Authorisation in terms of the 2014 EIA Regulations, as amended, published under the

National Environmental Management Act;

A Basic Assessment EIA Process is required for the WWTW, associated pipeline and road infrastructure

because the following activities are listed in the 2014 EIA Regulations for the preferred Option 2 site location

alternative:

Provide the relevant Basic Assessment Listed Activity(ies) as set out in Listing Notice 1 (GN No. R.

983)

Activity 12 The development of infrastructure or structures with a physical footprint of 100m2 or more

where such development occurs –

(a) Within a watercourse;

(b) in front of a development setback; or

(c) if no development setback exists, within 32m from a watercourse, measured from the

edge of the watercourse

Activity19 The infilling or depositing of any material of more than 10m3 into, or the dredging,

excavation, removal or moving of soil, sand shells, shell grit, pebbles or rock of more than

10m3 from -

(i) a watercourse;

Provide the relevant Basic Assessment Listed Activity(ies) as set out in Listing Notice 3 (GN No. R.

985)

Activity 4 The development of a road wider than 4 metres with a reserve less than 13,5 metres

(f) In Western Cape:

i. Areas outside urban areas;

(aa) Areas containing indigenous vegetation

Activity 12 The clearance of an area of 300m2 of indigenous vegetation

i) Western Cape

i) Within any critically endangered or endangered ecosystem listed in terms of

section 52 of the NEMBA or prior to the publication of such a list, within an area

that has been identified as critically endangered in the National Spatial

Biodiversity Assessment 2004;

ii) Within CBAs identified in bioregional plans;

iv) On land, where at the time of the coming into effect of this Notice or thereafter

such land was zoned open space, conservation or had an equivalent zoning;


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v) On land designated for protection or conservation purposes in an

Environmental Management Framework adopted in the prescribed manner, or a

Spatial Development Framework adopted by the MEC or Minister.

Activity 14 The development of:

ii) infrastructure or structures with a physical footprint of 10m2 or more.

Where such development occurs-


(b) in front of a development setback line; or

(c) if no development setback has been adopted, within 32m from a watercourse,

measured from the edge of the watercourse;

In Western Cape:

i. Outside urban areas, in:

(ff) Critical biodiversity areas or ecosystem service areas as identified in

systematic biodiversity plans adopted by the competent authority or in

bioregional plans;

• Full Water Use License in terms of section 21 of the National Water Act;

Activities to be included in WULA:

o Continued irrigation of 1 500m3 per day of existing 45ha irrigation area (has existing WULA but this

is being re-applied for);

o Continued storage of effluent (180 000m3 dam capacity) (has existing WULA but this is being re-

applied for);

o New emergency effluent retention dam at the factory;

o Two other seepage & balancing ponds near the large effluent dam;

o Proposed discharge of treated effluent to the river (post treatment at the new WWTW to GA limits);

o Pipeline and road infrastructure associated with new WWTW crossing watercourses.

The following activities are listed in section 21 of the NWA as a result of the proposed undertaking of the above

activities:

o Section 21 (c) - impeding or diverting the flow of water in a watercourse (pipe installation).

o Section 21 (f) - discharging waste or water containing waste into a water resource through a pipe,

canal, sewer, sea outfall or other conduit.

o Section 21 (g) - disposing of waste in a manner which may detrimentally impact on a water

resource; and

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

o Section 21(e) - engaging in a controlled activity (irrigation) identified as such in section 37(1) or

declared under section 38(1):

• Emergency General Authorisation Water Use Registration in terms of section 21 of the National Water Act;

Activities to be included in GA:

o Two new irrigation areas – 16.5ha + 16ha;

o New effluent retention dam at the second16.5ha irrigation area – effluent disposal;

o Cut off trench at the second 16.5ha irrigation area – effluent disposal;

o Impeding / diverting flow of water courses with above ground pipeline infrastructure;

The following activities are listed in Section 21 of the NWA as a result of the proposed undertaking of the above

activities:

o Section 21 (c) - impeding or diverting the flow of water in a watercourse (pipe installation).

o Section 21 (g) - disposing of waste in a manner which may detrimentally impact on a water

resource; and

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


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o Section 21(e) - engaging in a controlled activity (irrigation) identified as such in section 37(1) or

declared under section 38(1):

The emergency GA application for the two new irrigation areas is a temporary solution to alleviate the problem

until such time as the WWTW is in operation. Once the WWTW is in operation and treated effluent can be

discharged into the river, these two new irrigation areas will be rehabilitated and will no longer be required. It is

for this reason that the two new irrigation areas have not been applied for in the full WULA application.

6. Alternatives

Three site location alternatives have been investigated (all on the same farm), as per the Site Layout Plan in

Appendix B. The table below is a summary of the alternatives investigated.

Table 1: Summary of Alternatives Investigated

Type of

Alternative

Description

of

Alternative

Outcome/ Comments

Site location

alternatives:

Option 1

Option 1: WWTW to be located on the top of the “koppie” nearest to the Breede River

Advantages: Disadvantages:

• No opportunity cost lost in terms of

loss of cultivated agricultural land.

• Furthest from adjacent residents

(greatest buffer), potentially less

nuisance impacts.

• Highest cost to implement due to

excavation in rock required.

• Being located on a “koppie” would have a

high visual impact on the cultural

landscape.

• Unacceptable high botanical impact.

Option 2

(Preferred)

Option 2 (the preferred alternative): WWTW to be located in a mostly disturbed area, where

Parmalat historically stored effluent.


• Lower cost to implement than Option

1.

• This option has the lowest overall

visual impact as it is shielded from

view from Bonnievale Winery located

behind a contour.

• Low botanical impacts expected as

mostly located within already

disturbed areas.

• Low freshwater impacts due to low

ecological significance of the

stormwater drainage channel /

Ecological Support Area.

• Acceptable buffer from Uitsig

community residents (approximately

300m) and Bonnievale Winery

(approximately 800m).

• Access road and pipeline route length

make the cost higher than Option 3.

• Small amount of cultivated agricultural land

lost but insignificant.

Option 3

Option 3: WWTW to be located in a mostly disturbed area, where Parmalat historically stored effluent,

further south from Option 2.



1. This option would in fact be the

lowest overall cost to build.



disturbed areas.

• Marginally lower impact to freshwater

environment as less construction is

proposed within a stormwater

drainage channel / Ecological Support

Area.

• This option would have a high visual

impact to Bonnievale Winery and R317

users.

• Buffer from Bonnievale Winery is <500m


• Small amount of cultivated agricultural

land lost but insignificant.


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WWTW

Biological

Treatment

Technology

Alternatives:

Option A:

The

Proposed

WWTW

Option A: Aerobic Wastewater Treatment

Option A1: Conventional Activated Sludge (“CAS”)

Option A2: Movable Membrane Bioreactor (“MBBR”)

Option A3: Membrane Bio-reactor (“MBR”)

Option A2 was considered but disregarded as unfeasible and unreasonable based on bad

experiences by the holding company of Parmalat SA (Lactalis) elsewhere in the world.

Option A1, “CAS”, is the most commonly used in approximately 250 Lactalis Dairy farms around the

world. (Note: Lactalis is the holding company of Parmalat). “CAS” is flexible, robust and cost-

effective. Operational and maintenance costs are expected to be lower than the other two options

investigated. The drawback of this technology is that it produces significantly more sludge waste than

the other technology types and could be associated with odours if the plant’s operations and the

sludge storage process is not managed correctly.

Option A2, “MBBR”, produces less sludge than CAS but not as little as the MBR, which produces

significantly less sludge than CAS. The advantage is that spare parts are cheaper and long lasting,

so operational expenses are lower than with MBR (Membrane Bio Reactor) but not as low as the CAS

technology.

Option A3, “MBR”, was intensively investigated by Parmalat. They visited dairy factories in East

London and in Ladismith as well as in a Municipal works in Stellenbosch to view this treatment system.

This technology however is associated with high costs, both capital and operating expenditure,

(CAPEX and OPEX), mainly due to membrane installation and replacement and high energy demand.

The MBR process is extremely sensitive, is unable to deal with overloading and has very high

operation and maintenance costs. This treatment technology was therefore disregarded (unfeasible

and unreasonable) due to the high operational costs associated with this design.

Option A1, Aerobic Conventional Activated Sludge, is therefore the only WWTW Treatment

Technology that is feasible and reasonable for this site based on influent and effluent considerations,

operational / maintenance considerations and cost considerations. Other technologies were

considered and investigated but found to be unfeasible. The difference in costs to build and costs to

operate are in the order of millions of Rands and therefore CAS is the only feasible and reasonable

option. It is a flexible and robust system that works well for dairy industries around the world.

Option B:

Option B: Anaerobic Wastewater Treatment

This option was considered but disregarded due to the following reasons:

• “COD” (Chemical Oxygen Demand) of the Parmalat Bonnievale plant is too low to support this

treatment option, therefore its unfeasible.

• Lactalis, the holding company of Parmalat SA, have extensive international experience of these

type of plants, mostly negative. They are converting these type of plants elsewhere in the world

to aerobic design.

No further treatment technology alternatives have therefore been comparatively been assessed as

the proposed treatment technology (Aerobic “CAS” technology) is deemed to be the best practical

option.

No-Go

Option

Option 4

Status Quo remains. Not preferred but assessed as Option 4.

Should the status quo remain and the WWTW not be constructed, significant socio-economic

impacts are likely to occur as a result of significant job losses at the Parmalat factory due to

downscaling that would be required and decrease in production. Should the status quo remain,

there is a significant high risk of water pollution (detrimental) should the effluent dam banks

burst and should additional untreated effluent be discharged into the Breede River. The status

quo is also associated with groundwater, soil, air quality (odours) and nuisance impacts that

are currently occurring and would continue to occur should the WWTW not be constructed as

a result of the current poor quality of effluent being irrigated.

7. Summary Description of the Receiving Environment

7.1 Aquatic Environment

Bekker (2019) explains in the Freshwater Impact Assessment that six freshwater ecosystems were determined

as likely to be impacted upon by the proposed and existing activities associated with the project (this includes

the proposed WWTW, associated infrastructure and the existing as well as the proposed water use activities).


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The watercourses identified as potentially impacted by the project were delineated in the field, classified as

HGM units, and assessed in further detail. The watercourses were assessed as the following:

• HGM 1 (the Breede River);

• HGM 2 (western drainage line);

• HGM 3 (Breede Tributary);

• HGM 4 (new irrigation area tributary);

• HGM 5 (effluent dam tributary); and

• HGM 6 (eastern tributary).

Figure 3 below shows the freshwater ecosystems listed above, likely to be impacted by the proposed WWTW,

associated infrastructure and water use activities (crossing of watercourses, storage of wastewater, discharge

& irrigation of wastewater).

Figure 3: Freshwater ecosystems likely to be impacted upon by the proposed development (Source: SES:

Freshwater Impact Assessment, 2019).

Bekker (2019) explains that the activities associated with the WWTW and pipelines are highly likely to impact

upon the Breede River (HGM 1) and the area draining from the west towards the factory (HGM 2). Two of the

proposed WWTW location alternatives are located within a drainage area (Option 2 & 3) and the third (Option

1) is in closer proximity to the Breede River. The treated WWTW water is proposed to be discharged into the

Breede River by the factory resulting in modifications to the river water quality and flow regime.

Bekker (2019) states that despite water quality problems as a result of intensive agriculture and urban

development, the ecological importance of the Breede River system is high.


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7.2 Botanical Environment

Mc Donald (2019) explains in the botanical impact assessment that the vegetation found on the study area (all

three WWTW options and associated infrastructure) is Breede Shale Renosterveld. This is a low to mid-high

open to dense karroid shrubland that has a high component of succulent plant species.

In the area of the Option 2 pipeline route (the preferred & proposed option), the Breede Shale Renosterveld

has been removed by ploughing of furrows where the effluent from the Parmalat factory was historically

dispersed. The proposed pipeline would be along a disturbed track where there is no longer any renosterveld

vegetation and where the habitat now has very low botanical sensitivity (Mc Donald, 2019).

The location where the proposed Option 2 WWTW would be constructed was formerly a small dam that was

used for the collection and retention of effluent from the Parmalat factory. From this dam the effluent was

dispersed over the ploughed furrows to the east of the dam. This location is highly disturbed and not botanically

sensitive. It could therefore be used without any botanical constraints (Mc Donald, 2019).

In terms of the conservation status of the three sites assessed, in 2017 the Western Cape Biodiversity Spatial

Plan (WCBSP) was published and critical biodiversity and ecologically sensitive areas were mapped.

Option 1 (both WWTW and pipeline) are located in Critical Biodiversity Area 1 (CBA1) and to a very small extent

in an Ecological Support Area 2 (ESA2). The data collected in the botanical survey supports this classification

and mapping.

Option 2 would largely not be in CBA1 or ESA2 except for a small area at the entrance road off the R317 where

the pipeline and access road is proposed.

In the case of Option 3, according to the WCBSP, the WWTW would apparently be located within a CBA1. The

data collected in the botanical survey however does not support this classification and mapping since the Option

3 WWTW site has been mostly disturbed by an historic effluent dam, similar to Option 2.

7.3 Cultural & Heritage Environment

The Breede River floodplain with its agricultural lands and farms can be considered to be a cultural landscape

with aesthetic significance, especially given its contrast with the surrounding semi-arid landscape.

Almond (2019) states in the desktop Paleontological Assessment that there are no records of fossil material

from the Upper Bokkeveld succession in the Bonnievale region. Apart from local evidence for bioturbation, no

fossil remains were recorded within the Traka Subgroup rocks in a previous field-based PIA near Bonnievale

by Almond (2013). It was concluded that the original fossil content of these rocks has probably been

compromised by tectonism (notably pervasive cleavage development) and weathering. Almond (2019) further

explains that despite the inferred high palaeontological sensitivity of the Middle Devonian Adolphspoort

Formation (upper Bokkeveld Group) underlying the Bonnievale WWTW and pipeline project area, previous field

studies suggest that the bedrocks here are usually weathered near-surface and often cleaved, compromising

fossil preservation. No fossil remains were observed within either the Palaeozoic bedrocks or the Late

Caenozoic superficial sediments in the Bonnievale WWTW and pipeline project area during the recent heritage

field study by J. Orton (pers. comm., April 2019).

Orton (2019), a registered archaeologist, explains in the Notice of Intent to Develop submitted the Heritage

Western Cape that there are structures older than 60 years in the area and graveyard but none would be directly

affected by the proposed project.

7.4 Geo-hydrological Environment

GEOSS South Africa (Pty) Ltd undertook a groundwater impact assessment in May 2019. GEOSS found that

the regional aquifer is classified as a fractured aquifer. Groundwater quality underlying the site, as indicated by


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electrical conductivity, is in the range of 300 -1000 mS/m. This is “poor” quality for water with respect to drinking

water standards. The groundwater vulnerability indicates the “ease” with which the groundwater can be polluted

by surface-based contamination sources. With the ‘low’ vulnerability rating associated with the study area, it

has thus been deemed highly unlikely that surface-based activities would impact on the fractured aquifer.

A hydro-census was conducted by GEOSS. It was found that there are little to no groundwater users

surrounding the proposed WWTW site and the effluent disposal site (storage pond and irrigation areas).

The proposed final effluent quality is better than the groundwater in terms of certain parameters and is better

than the current effluent being irrigated in terms of all parameters.

8. Public Participation

A joint public participation process is currently underway. This means that the public participation process for

the water use license application is running concurrently with the public participation process required for the

environmental authorisation application. The 2017 Regulations outlining the Procedural Requirements for

Water Use Licensing, states that for WULA applications a 60 day commenting period is required. The pre-

application BAR is therefore available for a 60 day commenting period. A pre-application consultation meeting

took place with the Department of Environmental Affairs & Development Planning (DEA & DP) on the 7th June

2019.

The following public participation is currently underway:

• A Site Notice has been placed adjacent to the R317 at the proposed entrance road to the WWTW adjacent

to the R317, advertising the proposed development, the opportunity to participate and the availability of the

Pre-Application Draft BAR for a 60 day public participation period;

• A second Site Notice has been placed adjacent to the R317 at the entrance road to the Rietfontein Farm

where the existing 45ha irrigation area and effluent storage pond is located;

• A joint public participation process is being conducted in terms of the 2104 EIA Regulations, as amended,

and the Water Use Licensing Regulations published in 2017;

• One newspaper advertisement has been placed, in the Breederivier Gazette, a local newspaper,

advertising the availability of this Pre-Application Draft BAR and providing the public with the opportunity to

provide SEC with their comments.

• A register of Interested & Affected Parties has been opened and will be updated after the 60 days

commenting period to include all those that have provided comment.

• Notification Letters have been posted to approximately 80 identified adjacent landowners and / or

occupiers, inviting the adjacent landowners and occupiers to register as Interested and / or Affected Parties

(I & AP’s) and to comment on the Pre-Application Draft BAR.

• Colour hardcopies of the Pre-Application Draft BAR Report have been posted to 7 identified Key Authorities

who have been requested to provide their comments on the Draft BAR.

All comments will be responded to in writing and a Comments & Responses Table which will be sent to all

registered I & AP’s in the next version of the Basic Assessment EIA Report detailing our response to the

comments received. All comments received and all responses to the comments will be included in the Final

BAR submission to the DEA & DP.

This pre-application Draft BAR is currently available for a 60-day commenting period. A second round of Public

& Authority Consultation (additional 30 days) will occur. The Draft Basic Assessment EIA Report will be made

available for a second round of consultation, after the application form is submitted, before it is submitted to the

DEA & DP, with all comments received, for final decision making.


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9. Identification & Assessment of Impacts

A summary of the assessed significance2 of the identified impacts (after mitigation is successfully

implemented) is provided in the tables below:

Construction Phase of the WWTW and Associated Infrastructure:

CONSTRUCTION PHASE IMPACTS

IMPACT

IMPACT SIGNIFICANCE (after mitigation)

Option 1 Option 2

Option 3

Option 4:

Status

Quo

Air Quality Impacts: Dust Associated with Construction & Traffic Low (-) Low (-) Low (-) N/A

Visual Impact to cultural landscape: As a result of temporary

construction activities. Low -Med (-)

Low (-) Low-Med (-) N/A

Archaeological / Paleontological Impact: Loss of fossils due to

construction excavations / trenching.

Low - Med (-) Low (-) Low (-) N/A

Botanical Impacts: Loss of Indigenous Vegetation High (-) Low (-) Low (-) N/A

Freshwater Impacts: Construction of WWTW and Pipeline

Infrastructure in a Watercourse & Construction of Discharge Outlet

on Riverbank Resulting in Water Pollution, Flow Modification,

Sedimentation & Erosion and Aquatic Habitat Disturbance

Low (-) Low (-) Low (-) N/A

Noise Impacts: Associated with Construction Machinery & Traffic Low (-) Low (-) Low (-) N/A

Traffic and Safety Impacts: Associated with Delivery of

Construction Materials


Soil & Groundwater Contamination: Associated with Poor Waste

Management Activities, Fuel Spills, Effluent Spills and /or Cement

Batching during Construction Activities


Socio-economic: Creation of Temporary Jobs Medium (+) Medium (+) Medium (+) N/A

Operation Phase of the WWTW and Associated Infrastructure:

OPERATION PHASE IMPACTS

IMPACT


Option 1 Option 2

Option 3

Option 4:

Status Quo

Air Quality Impacts: Odours associated with a WWTW facility

(Option 1 – 3) and storage of sludge or if Status Quo Remains

Irrigation of Poor Quality Effluent Resulting in Odours (Option 4)

Low (-) Low (-) Low (-) High (-)

Noise Impacts: Pumps, compressors (DAF and industrial

water), sludge dewatering equipment


Freshwater Impacts: Discharge of Treated Effluent into Breede

River Resulting in Sedimentation & Erosion, Altered Flow

Regime, Decreased Water Quality and Aquatic Habitat

Medium (-) Medium (-) Medium (-) High (-)

2 The impact assessment methodology used has been closely guided by the DEAT EIA Guideline Document 5, on the

assessment of impacts and alternatives (DEAT 2006); as well as reference to the description of the criteria used for the

assessment of impacts as contained in the DEA&DP Specialist Guidelines Series (2005).


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Disturbance. If status quo remains risk of dam bursting or further

untreated river discharge.

Freshwater Impacts: Operation of the WWTW and Associated

Infrastructure Resulting in Decreased Water Quality & Aquatic

Habitat Disturbance

Medium (-) Medium (-) Medium (-) Low-Med (-)

Visual Impact: Associated with Built Infrastructure Impacting on

the Sense of Place of the Area Medium (-) Low-Med (-)

Medium (-) N/A

Soil & Groundwater Contamination: Leakage of the WWTW,

Emergency Detention Dam and Pipelines

Low-Med (-) Low-Med (-) Low-Med (-) Med-High (-

)

Socio-economic: Creation of Permanent Jobs: High (+) High (+) High (+) High (-)

10. Summary of Key Findings & Key Mitigation Recommended by Specialists

10.1 Freshwater Impact Assessment

Bekker (2019) states the following Key Findings:

• None of the proposed WWTW locations, nor the pipelines to any of them, will have a high impact upon

freshwater habitat. While it is usually preferable to situate the infrastructure outside of drainage areas, these

identified areas are highly degraded already. HGM 2 is critically modified and has little ecological

functioning.

• With the adoption of mitigation measures, the WWTW and pipelines will have a low impact upon this HGM

2 system.

• However, the water use activities will impact upon the Breede River substantially. It is proposed to

discharge the treated effluent into the river. This will increase the water inflows of the system and alter the

abiotic characteristics thereby affecting the biota.

• There is an existing pipe outlet that is currently discharging untreated effluent into the river near the factory

and large earthworks have recently cleared and reshaped the riverbank while excavating material from the

river channel. Therefore, the level of disturbance to habitat in this area caused by the factory is already

substantial.

• Discharging treated effluent into the river is a preferred alternative to the No-Go Option of untreated and

unmonitored effluent continually entering the system. Therefore, with the adoption of strict mitigation

measures and acceptance from DWS, discharging the treated WWTW effluent into the river will not have

a high impact upon freshwater habitat.

• The effluent from the factory is currently piped to an effluent dam, approximately 5 km away, and used for

irrigation of livestock pastures. These activities, as well as the proposed additional irrigation on new areas,

will continue to impact the surrounding watercourses.

• The construction of the effluent dam has not replaced any significant habitat and the HGM 5 stream was

critically modified prior to its construction. However, the possible situation of polluted effluent overflowing

(if the banks burst) could have detrimental impacts upon downstream habitat. Therefore, the impact of the

construction of the dam may be of Low-Medium significance, but the threat it poses to downstream habitat

is High. However, if mitigation is applied this could decrease to Medium impact significance. The irrigation

will obtain a Low-Medium significance if the irrigation water volumes are decreased and the quality be made

to comply. Currently the polluted water is entering the downstream areas and most likely the Breede River.

• The current condition of these systems is cause for serious concern. Almost without exception, these

tributaries have been dredged, bulldozed, channelized and in some instances, levees have been

constructed alongside them to prevent overbank flooding. In most cases only hardy and pioneering annuals

or exotic species remained in the riparian areas, and there was little or no variety of instream habitats.

Some, as well as the Breede Trunk River, had excessive algal growth and/or exotic instream vegetation,

an indication of a nutrient surplus and a breakdown in the self-cleansing functions of the ecosystem.

• They key measure to prevent reduced freshwater habitat integrity is to ensure all effluent associated with

the project is treated appropriately and discharged within the volume limits.

• The impact of not implementing a WWTW to manage effluent is of a High negative significance. The effluent

will continue to pollute and erode aquatic habitat on a regional scale. It results in a negative trajectory of


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change and the River Environmental Classification (REC) will not be obtained. Additionally, without a

method to treat the water and discharge it safely, there is the risk that increased amounts of untreated

effluent will enter the watercourses. This is due to the risk of the dam becoming full, the winter rainfall

season, and waterlogged irrigation fields resulting in a surplus of effluent with no sufficient storage method.

If the WWTW is not implemented then the irrigation water quality will not comply with legislated standards

and the REC of the river will not be realized. It is critical that the WWTW be implemented.

• If the quality of the discharge effluent is not regularly monitored it could result in non-compliance with the

Water Use License water quality limits and this would cause significant water quality pollution and habitat

loss.

Bekker (2019) recommends the following Key Mitigation Measures to be Implemented Immediately:

• The existing discharge pipe outlet to the river must immediately be decommissioned. It is causing pollution

of aquatic habitat; the proliferation of alien invasive species due to increased nutrients, as well as erosion

of the banks. The bank has recently been cleared and excavated. This must immediately be rehabilitated.

It may require recontouring and will definitely require revegetation with indigenous riparian species. During

this work, further erosion and sedimentation must be prevented and the bank stabilised until vegetation

propagates.

• Stop the existing effluent/ contaminated stormwater/wash bay water from seeping into the river. Better

management of wash water (this should not be passed into the river or its floodplain).

• Direct discharge of untreated effluent into the river is not permissible.

Bekker (2019) recommends the following Key Mitigation Measures proposed to be implemented during the

Construction Phase of the WWTW & Associated Infrastructure:

• The designers should refer to the effluent discharge standards stipulated by the Department of Water Affairs

(DWA) for the specific area in which the WWTW is to be designed and constructed. The WWTW must be

designed to meet the effluent discharge standards.

• The wastewater treatment system must be designed to handle peak flow rates and peak levels of

contamination. Failure to get the design right will result in excursions of wastewater quality during peak

times.

• The wastewater pumping stations and treatment plants should be protected against flooding. The treatment

process units (including the emergency pond) should be located at an elevation higher than the 100-year

flood level or otherwise be adequately protected against 100-year flood damage.

• Emergency power supply for pumping stations and treatment plants is required to prevent overflows from

occurring during any power outage.

• Provision must be made on site for the emergency retention of at least 72 hours effluent in the event of

plant failure / malfunction. The storage area must be lined and bermed to minimise potential spillage risk

into the river and it should be no closer than 50m from the edge of the river corridor and such that it does

not readily connect to the stormwater system.

• The proposed pipeline should be constructed in already disturbed areas such as where soils and vegetation

has already been completely transformed by past cultivation activities. There should be limited disturbance

within the drainage line during the construction phase.

• Contaminated runoff from the pipeline installation site should be prevented from directly entering the

drainage channel.

• After construction, the disturbed area should be rehabilitated, particularly to prevent erosion taking place

as well as to prevent the potential colonisation of these areas with invasive alien plants. Rehabilitation

requires removal of invasive alien plants from the riparian zone, some landscaping of the eroded channel,

if required, and re-vegetation rather than bare ground in the steeper areas.

• The construction camp/laydown area should be located away from the drainage areas and river. All

materials should be properly stored and contained; stockpiles must be located away from freshwater habitat

and prevent material from being transported by wind or rain, into any HGM units. Disposal of waste from

the site should also be properly managed. Construction workers should be given ablution facilities at the

construction sites that are located away from the watercourses (at least 20m) and regularly serviced.


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• If the location of the road and pipeline infrastructure cannot be moved above the drainage channel (to avoid

crossing the natural stormwater drainage channel), then an appropriate culvert installation needs to be built

to cross the non-perennial watercourse to avoid modifications in flow (impedance / diverting flow) to HGM2

and damage to the road.


Construction Phase of the Discharge Pipeline into the Breede River:

• The new outlet should be located at least 30m from the current river channel.

• It is recommended that the discharge pipe for the effluent into the river be set back from the river. The

treated effluent could be transferred directly into the channel via a “lay flat discharge pipe”. This approach,

or one with similar objectives, will decrease the impact of the construction of the outlet structure.

• The discharge pipe outlet design should include erosion control measures, such as for example, reno-

mattresses.

• The discharge should flow into the river in a diffuse pattern.

• Bare areas should be re-vegetated with indigenous riparian species.

• The riparian habitat should be rehabilitated and re-stored and the riverbank stabilized from erosion.


Operational Phase of the Discharge Pipeline into the Breede River:


• The treated effluent to be discharged into the river from the WWTW should at least comply with the General

Limits as required in the General Authorisations for water use.

• The outlet should be inspected daily and after major rainfall, to identify erosion gulley’s / channels into or

towards the river. Where such occur, they should be addressed appropriately to prevent concentration of

flows into the river – if a channel is cut into the river, it must be shaped as a shallow trench (side slopes 1:5

or less steep), lined with soil-packed reno if necessary, and planted with stabilising indigenous sedges (e.g.

Juncus kraussii or Cyperus textilis) rather than grasses.

• An effluent monitoring plan must be compiled.

• An Environmental Officer should be appointed and must be contractually bound to implement the

monitoring plan and liaise with the authorities regarding the results.

Bekker (2019) recommends the following Key Mitigation Measures proposed to be implemented for the

Continued Operation of the Effluent Dam and Irrigation Activities:

• Obtain instream dam safety inspections should be undertaken.

• The irrigation system must be designed correctly, therefore an irrigation specialist should be consulted. The

specialist should provide an irrigation plan complete with design parameters and operating characteristics

detailing the irrigation methods, application rates and water scheduling based on soil assessment.

• Treated and stabilised wastewater used for irrigation should be routinely tested and applied at appropriate

rates to avoid environmental problems.

• When the soil is saturated, irrigation waters should be stored until the soil dries sufficiently for irrigation.




Bekker (2019) recommends the following Key Mitigation Measures proposed to be Implemented during the

Operational Phase of the WWTW & Associated Infrastructure:

• The pipeline should be regularly monitored and maintained to ensure that any problems with the pipeline

are rectified before they can impact on any watercourses.

• A stormwater management plan must be developed to ensure water resources are not contaminated during

high rainfall events.


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• Treated effluent should be chemically and microbiologically analysed according to a schedule. Effluent that

does not meet national quality guidelines should not be discharged into the river. In the long term, the

irrigation effluent must also comply with the limits (once the WWTW is in operation). Should guidelines not

be met, the operation of the WWTW should be adjusted in order to improve the quality.

• Pumps, pipelines and other equipment should be regularly inspected and maintained. Spare parts should

be readily available. Downtime should be kept to a minimum in order to prevent spillages and adverse

environmental impacts. Flow meters should be kept in working order and calibrated if necessary.

• Provision must be made for the ongoing maintenance and management of the plant by a professional team,

experienced in its design and use.

• Operators, through training and total quality management procedures, should be encouraged to: identify

potential problems, adopt a regular inspection and maintenance routine, take appropriate corrective

measures when problems do arise, adopt operating and reporting procedures that seek to prevent problems

happening again.

• The WWTW and irrigation managers should develop and maintain contingency plans. The plans should

provide for the avoidance and control of spills, leakage or breakdowns so as to prevent pollution of the

environment.




The following Effluent Monitoring Measures, as recommended by the freshwater specialist, is proposed to

be implemented by Parmalat SA and included in the Effluent Monitoring Plan:

• Effluent will be sampled from the following points and sent for laboratory analysis: COD - inlet & outlet; TSS

- inlet & outlet; Ammonia - inlet & outlet; Nitrates – outlet; Phosphates – outlet; Faecal coliforms – outlet.

• Monitoring of chemical oxygen demand (COD) in effluent must take place twice per week.

• Monitoring of both effluent volumes produced and released into the river as well as of key variables

pertaining to the General Effluent Limits must take place weekly for the first year of installation and

thereafter monthly or as required by any conditions imposed by the Water use Licence.

• Monitoring must be carried out by an independent organisation and the ecological implications of the data

so acquired must be reported on, initially on a monthly basis. Where these data indicate problems in

meeting the General Effluent Limits, urgent measures must be taken to rectify this issue. In the event that

the plant cannot meet the Effluent Limits for more than 2 months, then the plant must be upgraded to

achieve these limits within a period of 4 weeks.

• Monitoring of the water quality and quantity effects of direct or indirect effluent released into the River (water

sampling from the river) must be carried out on at least a quarterly basis, with at least an up- and

downstream site being selected for comparative purposes, at which water samples must be collected /

measured for variables including key nutrients, E. coli bacteria, ammonia, pH, electrical conductivity and

total suspended sediments. Water depth must be measured and compared to a pre-surveyed channel

cross-section and slope, which allows coarse estimates of relative discharge to be made. In the event that

passage of effluent into the river is shown to have a sustained (over two months) measurable effect

resulting in a change in water quality, measures to address such impacts must be sought, including

upgrading of the treatment plant.

• It is important that detailed analysis and discussion of implications of the water quality results be undertaken

by a suitable qualified professional. Taking the samples without the appropriate interpretation is insufficient

and will not assist management.

• Records should be maintained of monitoring data and procedures should be reviewed periodically. Plant

managers should carefully observe the environmental performance of their plants and should institute

remedial action should problems arise.

• Monitoring of indicators must be in accordance with those specified in the water use licence. The volume

and characteristics of wastewater before and after treatment (i.e. treatment plant performance), monitored

weekly (first year) and the volume of treated wastewater discharged to irrigated areas, monitored weekly

(first year). After the first years monthly monitoring may be acceptable depending on a situational analysis.

• The discharge water must be sampled daily during the first two months of operation, assessed accordingly

with reportable findings to the relevant person, and if in constant compliance with the water limits specified


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in the water use license, sampling and analysis can be conducted on a weekly basis for the first year,

followed by a monthly basis thereafter.

• If it is found that the effluent is causing significant impacts upon freshwater habitat, despite being compliant

with the water quality and volume special limits, the treated effluent must be treated further and the limits

reassessed.



10.2 Botanical Impact Assessment

Mc Donald (2019) states the following Key Findings & Recommended Mitigation Measures:

• The site proposed for Option 1 is highly sensitive (high negative impact after mitigation) from a botanical

perspective and it should be rejected as a possible development site.

• The site proposed for Option 2 & 3 share similar vegetation type and characteristics, there is therefore no

overriding criteria that suggest that one is favoured over the other (low negative significance after

mitigation). Option 2 & 3 are acceptable to be developed.

• For the pipeline route / access road route for Option 2 & 3 the route is aligned along disturbed areas

alongside ploughed areas (low botanical sensitivity), however, a small amount (approximately 600m2) of

undisturbed Renosterveld is located in the vicinity of the access road where it starts near the R317. The

pipeline should be re-aligned as to avoid disturbing this intact vegetation.

• For the WWTW location for Option 2 & 3, the location is highly disturbed and not botanically sensitive. It

could therefore be used without any botanical constraints.

• Natural vegetation should be restored along the pipeline route after construction.

10.3 Geohydrological Impact Assessment

Muller (2019) states the following Key Findings:

• The groundwater quality in the monitoring boreholes, hydrocensus boreholes, effluent dam and seepage

ponds are of poor to dangerous quality according to drinking water limits for conductivity, total dissolved

solids, sodium and chloride concentrations.

• No boreholes, registered and unregistered, within a 1km radius of the site are used for drinking water.

• Over irrigation is a concern, with excessive volumes of effluent currently irrigated resulting in a perched

water table and ponding.

• During the construction phase of the WWTW, associated infrastructure and emergency detention dam,

leakage from the proposed construction represents a minor risk of contamination. Reduced natural

infiltration and recharge due to the construction footprint is considered to be a minor risk of very low impact.

• While leakage of treated effluent would improve the natural groundwater quality in some aspects, the

untreated effluent is likely to have a detrimental effect. This is considered to be a minor risk of very low

impact.

• The quality of the effluent in the seepage ponds and effluent storage dam is classified as very high risk in

terms of sodium absorption and very high risk in terms of salinity hazard. This means that the current

effluent stored is not suitable for irrigation.

• The proposed WWTW will result in the production of improved effluent quality.

• The risk of exposure to groundwater is low as the groundwater is not used as a source of water in the area.

Muller (2019) states the following Recommended Mitigation Measures:

• Improved water quality (as a result of the proposed WWTW) must be combined with sound irrigation

scheduling to ensure the land is used optimally.

• WWTW, pipelines and emergency detention ponds must be properly designed and built. Leak detection

monitoring should be implemented via groundwater monitoring. Monitoring should be conducted by a


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qualified hydrogeologist, once every 3 months, for at least 3 years after the WWTW is complete. Quarterly

field chemistry measurements should also be taken, along with annual samples for analysis.

• Regular monitoring of the treated effluent must be implemented to ensure that the quality of the treated

effluent remains within indicated limits.

• It is recommended that one monitoring borehole be drilled at the WWTW site for future site monitoring

(downgradient of the WWTW).

• At the irrigation site, groundwater quality should continue to be monitored and irrigation scheduling

implemented.

• The development of a groundwater monitoring programme will be important for assessing any impacts of

the site on groundwater and the environment.

10.4 Archaeological & Paleontological Assessment

Orton (2019) and Almond (2019) conclude the following Key Findings & Recommended Mitigation

Measures:

• An archaeological survey of the site revealed one possible quartz flake close to the Option 1 WWTW site.

The geology was found to not be favourable for the manufacture of stone artefacts. An equid radius was

uncovered during the geotechnical testing at the Option 2 WWTW site (identified from photographs by Dr

Teresa Steele). The bone is not mineralised and, from its colour, must have been enclosed by soil. It did

not appear to be associated with anything else and there was no way to tell if it was archaeological or not.

On its own it is assumed to be of no significance. A single fragment of probably late 19th century annular

ware (plate fragment) was seen along the pipeline route to Option 1. On its own it is of no significance.

• No significant impacts are expected on archaeological resources.

• The SAHRIS Palaeo-sensitivity map shows the site as being of potentially very high palaeontological

sensitivity. For this reason, and because the surface rocks on site did not look promising from a

palaeontological point of view, a desktop study was commissioned in order to determine whether this was

a significant issue or not. Dr John Almond notes that the underlying rocks are potentially fossiliferous but

that weathering and tectonism often compromise fossil preservation. From the many photographs provided

to him, he saw no reason for concern, at least at the surface, although evidence for tectonic deformation

was largely absent.

• A fossil chance finds procedure, as described below, (ECO response protocol) must be incorporated into

the EMPr for the project and, as such, no further significant impacts are expected.

o Once alerted to fossil occurrence(s): alert site foreman, stop work in area immediately (N.B. safety

first!), safeguard site with security tape / fence / sandbags if necessary.

o Record key data while fossil remains are still in situ:

▪ Accurate geographic location – describe and mark on site map / 1: 50 000 map / satellite

image / aerial photo;

▪ Context – describe position of fossils within stratigraphy (rock layering), depth below

surface;

▪ Photograph fossil(s) in situ with scale, from different angles, including images showing

context (e.g. rock layering);

• If feasible to leave fossils in situ:

o Alert Heritage Resources Authority and project palaeontologist (if any) who will advise on any

necessary mitigation;

o Ensure fossil site remains safeguarded until clearance is given by the Heritage Resources Authority

for work to resume;

• If not feasible to leave fossils in situ (emergency procedure only):

o Carefully remove fossils, as far as possible still enclosed within the original sedimentary matrix

(e.g. entire block of fossiliferous rock);

o Photograph fossils against a plain, level background, with scale;

o Carefully wrap fossils in several layers of newspaper / tissue paper / plastic bags;

o Safeguard fossils together with locality and collection data (including collector and date) in a box

in a safe place for examination by a palaeontologist;


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11. Conclusions & Recommendations of the EAP

• Option 2 has the lowest visual impact to sensitive receptors in comparison to Option 1 & 3 because Option

1 is located on a hilltop and Option 3 closest to the Bonnievale Winery, and adjacent provincial road, a local

tourism destination / route;

• Although comparable / similar to Option 3, Option 2 has the lowest overall negative construction phase

impacts (after mitigation) and the lowest overall negative operation phase impacts. Option 3’s overall

environmental impact is slightly higher as a result of the visual impact of Option 3 to Bonnievale Winery

and adjacent sensitive receptors / road users.

• Option 1 should not be approved because of the high, unacceptable botanical impact. Option 1 would also

be the most expensive to build as it’s located in bedrock on a hill. Option 1, given its location on top of a

hill, also is associated with visual impacts higher than Option 2 & 3. Option 1 should therefore not be

considered for authorisation.

• The NO-GO alternative, assumes the status quo. This therefore assumes that the WWTW will not be built

and that untreated, poor quality effluent will continue to be stored, irrigated and discharged into the Breede

River. The status quo is associated with existing, unacceptable (medium – high) impacts to air quality

(odours), nuisance impacts, freshwater impacts, soil and groundwater contamination. It is therefore a

necessity that the WWTW be built to avoid these environmental and social impacts from continuing to take

place.

• Should the WWTW not be built (NO-GO), the DEA & DP / BGCMA / DWS may issue a Directive to Parmalat

to stop operation. This would have a detrimental socio-economic impact given the hundreds of people who

are dependent on the operating of the business. It is therefore not recommended that the plant be shut

down but rather that short term and long term (the WWTW) mitigation measures be implemented to avoid

and mitigate environmental impacts.

• The findings of this EIA are that it is crucial to approve the WWTW so that it is built and becomes operational

as quickly as possible to avoid / reduce the existing threat to freshwater resources.

• Option 2 (the preferred alternative) is associated with low construction phase impacts if the various

mitigation measures listed above are implemented by Parmalat.

• The most significant operational phase impact is the freshwater impact of discharging effluent into the River

that does not meet the General Limit Standards. It is therefore of the utmost importance that the quality of

the effluent does meet the GA limits prior to discharge and irrigation.

• Discharging to the river, even if the discharge does meet the GA standards, will however still have a medium

negative impact to the water resource. Discharge to the river should only take place when irrigation is not

possible and the effluent storage dam is more than 70% capacity.

• Parmalat SA should investigate further design measures such as Ultrafiltration and Reverse Osmosis in

order to treat the effluent to a standard for re-use in the factory. This should be included in the long term

planning so as to avoid discharge into the river.

• The correct operation of the WWTW will eliminate / reduce many of the existing threats to the freshwater

habitat. However, the incorrect operation (and incorrect implementation of an Effluent Monitoring Plan) of

the WWTW and discharge of effluent into the river which does not meet the limits, will further impact on the

existing threat.

• The impact of not implementing the WWTW and associated infrastructure (the No Go alternative) is

unacceptably high. Additionally, there are existing impacts that should be rectified immediately. Therefore,

following the adoption of the recommendation for inclusion in the EMPr, the impacts associated with the

project can be decreased to acceptable levels.

• They key measure to decrease impacts upon freshwater habitat integrity is to ensure all effluent associated

with the project is treated appropriately and discharged within the volume limits. In order to achieve this,

stringent monitoring is required.


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SECTION A: PROJECT INFORMATION

1. ACTIVITY LOCATION

Location of all proposed

sites:

The proposed WWTW is located on Farm No. 695 in the Swellendam District. The

site is located just outside the town of Bonnievale adjacent to the R317 Provincial

road. The site for the WWTW is opposite the Parmalat Factory on the other side of

the R317.

Farm / Erf name(s) and

number(s) (including

Portions thereof) for each

proposed site:

Option 1: The WWTW and most of the associated infrastructure (roads and pipelines) are located on the remainder of Farm No. 695, Swellendam. A portion of the proposed access road and pipeline infrastructure is located on Farm Uitsig No. 694. It is also proposed to cross the R317 Provincial Road with the pipeline infrastructure. Option 2: (The applicants preferred alternative and the one put forward to be authorised) The WWTW and most of the associated infrastructure (roads and pipelines) are located on the remainder of Farm No. 695, Swellendam. A portion of the proposed access road and pipeline infrastructure, adjacent to the R317, is located on the Remainder of Portion 26 of the Farm Bosjesmansdrift No. 174. It is also proposed to cross the R317 Provincial Road with the pipeline infrastructure. Option 3: The WWTW and most of the associated infrastructure (roads and pipelines) are located on the remainder of Farm No. 695, Swellendam. A portion of the proposed access road and pipeline infrastructure, adjacent to the R317, is located on the Remainder of Portion 26 of the Farm Bosjesmansdrift No. 174. It is also proposed to cross the R317 Provincial Road with the pipeline infrastructure.

Property size(s) in m2 for

each proposed site: Remainder of Farm No 695 = 69.27Ha

Development footprint

size(s) in m2:

Option 1

• The development footprint of the fenced in WWTW facility (all options) is

117.26m X 87.65m = 10 277.84m2

• The approximate footprint of the road is 950m X 6m = 5 700m2

• The approximate development footprint (land to be disturbed to install) of

the pipelines (rising main from factory and treated effluent pipeline

discharged to Breede River (discharged at factory riverbank) built adjacent

to the access road is 20m wide X 1250m long = 25 000m2 (2.5Ha). This

includes construction vehicle access and stockpiling area of material and

soil.

Option 2 (Applicants Preferred Alternative)


117.26m X 87.65m = 10 277.84m2


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• The approximate footprint of the road is 740m X 6m = 4 440m2



discharged to Breede River (discharged at factory river bank) built

adjacent to the access road is 20m wide 1500m Long = 30 000m2 (3ha).

This includes construction vehicle access and stockpiling area of material

and soil.

Option 3


117.26m X 87.65m = 10 277.84m2

• The approximate footprint of the road is 650 X 6m = 3 900m2



discharged to Breede River (discharged at factory river bank) built

adjacent to the access road is 20m wide 1430m Long = 28 600m (2.86Ha).

This includes construction vehicle access and stockpiling area of material

and soil.

Surveyor General (SG) 21

digit code for each

proposed site:

Option 1: Farm No. 695, Swellendam: C07300000000069500000 Farm Uitsig No. 694: C07300000000069400000 R317 Provincial Road: Unknown Option 2: (The applicants preferred alternative) Farm No. 695, Swellendam: C07300000000069500000 Remainder of Portion 26 of the Farm Bosjesmansdrift No. 174: C07300000000017400026 R317 Provincial Road: Unknown Option 3: Farm No. 695, Swellendam: C07300000000069500000 Remainder of Portion 26 of the Farm Bosjesmansdrift No. 174: C07300000000017400026 R317 Provincial Road: Unknown

2. PROJECT DESCRIPTION

(a) Is the project a new development? If “NO”, explain:

YES NO

The WWTW and associated infrastructure, the subject of the Basic Assessment EIA Report, is a new

development. Parmalat (previously Bonitas) has however been in operation adjacent (across the R317 road)

to the site proposed for the WWTW for a number of years. Industrial effluent from the dairy / cheese factory

has been produced since the factory was established. Partially treated effluent has been stored and irrigated

on surrounding lands since the factory was established. Effluent was stored and irrigated on the area where

Option 2 & 3 for the WWTW is now proposed before the large effluent dam was built in 2011 further south.


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(b) Provide a detailed description of the scope of the proposed development (project).

1. Source of Effluent Produced at the Parmalat Factory

In a dairy factory all the equipment in contact with the milk (or the product) needs to be cleaned at least once

per day and in some cases where heat is involved (e.g. pasteurizers), up to 3 times per day.

First there is an initial rinse to flush out final milk or product remains. Thereafter the line or tank is washed with

recirculating caustic which normally is recovered in a “CIP” tank ‘(“Cleaning in Place”). Clean water is then

used to remove all the caustic. A recirculating “acid” wash which is recovered in a “CIP tank as well. A pre-

final rinse with clean water is undertaken followed by a final rinse with a sterilizing agent in it to sterilize the

equipment. The final rinse is recovered to be reused for the first rinse mentioned above.

This cleaning process is required from the milk truck that delivers the milk, every pipe and vessel that is in

contact with milk or product. These cleaning processes are computer controlled and highly optimized.

Approximately 3-5 litres of clean potable water is required for every litre of milk received at the factory.

Parmalat Bonnievale has several areas (sub-factories) within the factory that produces effluent water, as

follows:

• Milk reception (including milk tanker cleaning system);

• Milk holding silos;

• Cheese factory (including cheese milk pasteurizers and cheese vats);

• Butter factory;

• Whey factory (whey is a liquid by product from cheese manufacturing and this liquid need to be

concentrated and spray dried);

• Feta and white mould cheese factories;

• Process cheese factory;

• Milk powder factory; and

• Milk and whey membrane filtration processes.

2. Description of Proposed Development

Please refer to Appendix B for the proposed location options and the proposed layout of the WWTW.

The following infrastructure is proposed to be constructed:

• Wastewater Treatment Works with the capacity to treat a maximum of 2 000m3 of waste effluent per

day. The development footprint of the fenced in WWTW facility is 117.26m X 87.65m = 10 277.84m2.

The WWTW comprises of the following:

o Inlet Channel;

o Buffer Tank;


o Clarifier;





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• Rising main pipeline from existing pump station at factory to proposed WWTW;

• Return main pipeline (return treated effluent to discharge point to river and to existing irrigation area

3km south);

• Access road to WWTW (6m wide); and

• Emergency temporary effluent retention dam.

The above is described in more detail below.

Wastewater Treatment Works

The plant is proposed to treat 2 000 m³/day of industrial wastewater from the factory’s cheesemaking process.

It is proposed to discharge the treated effluent (treated to General Limit Values) to the Breede River and to

continue to irrigate the existing irrigation area located 3km south of the factory. The proposed plant comprises

coarse and fine screening, buffering, dissolved air flotation, biological treatment in the form of activated sludge,

final sedimentation and dewatering of the primary and secondary sludges. The tables below show the required

effluent quality and wastewater characteristics prior to treatment and the proposed effluent discharge and

irrigation quality. The proposed development footprint of the fenced in WWTW facility is 117.26m X 87.65m =

10 277.84m2.

Table 2: Wastewater Characteristics Required Prior to Treatment

Table 3: Proposed Final Effluent Quality Proposed to be Discharged & Irrigated

• Inlet Channel

A concrete channel is proposed with an emergency bypass channel for screening. Two skips are

proposed to temporarily store coarse and fine screenings. Downstream of the screens, the channel

includes a parshall flume for flow measurement and further downstream a small sump with an overflow

weir. The overflow from the sample chamber will gravitate to the Buffer Tank.


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• Buffer Tank

The buffer tank proposed is a rectangular concrete structure, equipped with slow speed vertical shaft

mixers and a coarse bubble diffuser system.

• Decanter Building

It is proposed to construct a brick wall structure with IBR roof cladding to house the buffer tank blower,

drywell for DAF feed pumps, the dissolved air flotation (DAF) unit, a sump for the DAF float and settled

solids equipped with vertical shaft mixers, decanter feed pumps, decanter units, polyelectrolyte make-

up unit, poly dosing pumps, an admin office and motor control room (MCC).

• Clarifier

It is proposed to construct a 26m diameter round concrete structure.

• Activated Sludge Reactor

The proposed activated sludge reactor is a rectangular concrete structure with mechanical slow speed

surface aerators. The main structure is divided into two zones, an aerobic zone and an anoxic zone.

The reactor also includes smaller structures like a recycle chamber, RAS recirculation sump, WAS

extraction sump, degassing tank and an activated sludge contact zone.

Associated Infrastructure

A new rising main is proposed from the existing pump station at the factory (currently pumps effluent to irrigation

area) to the WWTW. A return main is also proposed to return the treated effluent to the pump station from

where a portion of the effluent will be discharged to the Breede River and a portion of the effluent will be

irrigated. The approximate development footprint (area to be disturbed during construction) of the area

proposed for both pipelines (rising main and return pipeline) is 20m wide for the length of the pipeline. This

includes space for vehicles, equipment, topsoil and subsoil stockpiles and storage of pipeline prior to

placement.

A Class 12, 200mm diameter PVC pipeline is proposed for the pipeline infrastructure. The pipeline trench is

proposed to be excavated to a depth 0.2m below the design pipeline invert level. The depth of excavation to

trench invert level will be of the order of 1.4 m below existing ground level. During the excavation of the trench

topsoil will be reserved for subsequent re-introduction into the top of the trench.

The figure below shows the typical pipeline trench cross section proposed.

Figure 4: The pipeline trench cross section proposed.


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The access road proposed is a 6m wide gravel road.

Parmalat also propose to construct a small emergency dam with trenching river-side of the existing factory.

The dam and trenching will serve as a secondary measure of protection to avoid contamination of the river by

temporarily containing effluent leaks in the event of a primary system failure. Once the systems have been

restored the effluent will be pumped back into the factory for treatment. The Conceptual Design of the

emergency retention dam is shown in Appendix

3. Description of Treatment Process

The figures below show the wastewater treatment process, and all inputs and outputs of the treatment process.

Figure 5: The Wastewater Treatment Process Inputs and Outputs (Source: Project Assignments Pty (Ltd)

Process Overview Document)


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Figure 6: Summary of Inputs & Outputs of Proposed WWTW (Source: Project Assignments Pty (Ltd) Process

Overview Document)

Project Assignments Pty (Ltd), a process engineering firm appointed by Parmalat SA, explains that the

treatment process for the proposed WWTW comprises of the following key stages:

Screening

The proposed screening area is a single concrete channel, including a manually-raked coarse bar screen with

50mm bar spacings, followed by an automatic channel drum screen having 0.75mm apertures. If there is a

blockage or mechanical breakdown with these screens, there shall be an emergency bypass channel including

a second manually-raked coarse bar screen, also with 50mm bar spacings.

The coarse screenings will be manually removed into a small adjacent skip. The fine screen shall be equipped

with an integral compaction section, which shall dewater the screenings to around 20% dry solids to reduce

the screenings volume and make screenings handling easier. The compacted fine screenings shall be

discharged to a screw conveyor which will automatically transport the compacted screenings into a small skip

adjacent to the inlet channel.

Downstream of the screens, the channel shall include a parshall flume for flow measurement. Downstream of

this flowmeter there shall be a small sump with an overflow weir, from which an automatic sampler shall

periodically withdraw effluent samples into a refrigerated sample holder (composite or individual samples). The

overflow from the sample chamber will gravitate to the buffer tank.

Flow Equalization

The buffer tank shall have a retention time of one day’s production, viz. 20 hours x 100 m³/h = 2000 m³. The

function of the buffer tank is to modulate the fluctuations in hourly effluent flow and quality, to allow the

downstream processes to operate at a constant feed rate.

The buffer tank shall receive a constant supply of air from a roots-type blower and coarse bubble diffuser

system, to prevent the effluent from becoming anaerobic, acidic and emitting bad odours. The contents of the

buffer tank shall be continuously agitated with slow-speed vertical shaft mixers. Also supplied with the buffer

tank will be alkali (e.g. NaOH) and acid (e.g. HCl) dosing stations, to correct the pH of the buffered effluent

prior to further treatment. Appropriate instrumentation (pH meters) shall be provided for this.


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Adjacent to the buffer tank there shall be a drywell incorporating two (duty/standby) centrifugal pumps on

variable speed. These pumps shall deliver a constant flowrate to the downstream treatment processes.

In addition to the buffer tank, a similar sized calamity tank is proposed to be built. The calamity tank is proposed

to be used if the raw wastewater composition is such that it might compromise the downstream biological stage.

In this event, the wastewater shall be routed to the calamity tank until the factory conditions are normalised.

The off-specification wastewater may then be treated in a special manner (e.g. pH adjusted, or additional

oxidants added), before it is re-introduced to the wastewater plant.

Dissolved Air Flotation

The effluent from the buffer tank shall be pumped at a constant rate to a Dissolved Air Flotation Unit (DAF).

The effluent shall first be conditioned in a flocculator pipe, receiving metered dosages of acid/base, coagulant

and flocculant. The exact quantities of these chemicals are to be determined using further site tests.

In the DAF, microbubbles shall be used to separate fine solids and oils from the wastewater. The DAF shall

also allow heavier solids to settle out. The resulting “float” containing solids and oils, together with the heavier

settled solids (collectively known as “primary sludge”), shall be collected in a separate sump from where the

mixture shall be pumped to a decanter centrifuge for dewatering.

The clarified wastewater shall flow under gravity to the next stage, being Activated Sludge Treatment.

Activated Sludge Treatment

The clarified effluent from the DAF shall gravitate to the Activated Sludge Contact Zone, where it will be mixed

with return activated sludge from the clarifier. In this tank, urea solution shall be dosed in order to supplement

the nitrogen in the raw wastewater.

The aeration in the activated sludge basin shall be provided with mechanical slow speed surface aerators.

These devices will provide mixing as well as oxygen for the biomass (the “activated sludge” or “mixed liquor”)

to multiply and break down the organic matter in the wastewater.

The working volume of the activated sludge basin shall be nominally 5 500 m³. The basin shall be provided

with two zones: an aerobic zone and an anoxic zone.

In the aerobic zone, the carbonaceous material shall be broken down and any excess ammonia and organic

nitrogen shall be hydrolysed and oxidised to nitrates. A recycle stream from the aerobic to the anoxic zone (the

“a-recycle”) shall allow the nitrates formed in the aerobic zone to be converted to nitrogen gas in the anoxic

zone. The nitrogen gas formed is released to the atmosphere. The a-recycle shall take place using vertical-lift

axial flow pumps, delivering the mixed liquor into a gravity recycle channel.

The mixed liquor in the anoxic zone shall be maintained in suspension using slow speed agitators.

Clarification

Mixed liquor from the activated sludge basin shall be routed initially to a degassing tank, where air from the

activated sludge step can disengage from the biomass. It also provides a point to which ferric salts such as

FeCl3 solution can be dosed, to chemically precipitate the orthophosphate in the effluent.

The mixed liquor from the degassing tank shall flow to the clarifier, where the biomass settles and is recycled

to the activated sludge reactor using recycle pumps (the “s-recycle”). Excess settled sludge resulting from the

biomass growth (known as “waste activated sludge (WAS)” or “secondary sludge”) shall be collected and

pumped to a second dewatering decanter centrifuge, similar to that used for the DAF float.

The treated effluent shall overflow from the clarifier into a service water tank and from there to the outfall to the

Breede River and irrigation area. In the service water tank, a treated wastewater autosampler shall draw

periodic samples and store them in a refrigerated container. The service water tank shall also serve as a

reservoir from which service water can be drawn via service water pumps to provide water to the various

WWTP users that are able to utilise treated effluent.


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Sludge Dewatering

The primary and secondary sludges shall be dewatered in decanter centrifuges. The primary sludge shall be

dewatered to approximately 20% dry solids and the secondary sludge to approximately 16% dry solids. It is

estimated that approximately 5 550kg per day of dewatered primary sludge will be produced and approximately

6 300kg per day of dewatered secondary sludge will be produced. The solids shall be collected in skips at the

WWTW. The material shall be used for animal fodder (primary sludge only), fertiliser or it shall be routed to

municipal landfill.

Final Effluent Disinfection

It may be necessary, depending on the level of pathogens in the raw wastewater, that the treated wastewater

undergoes disinfection downstream of clarification. This may take the form of chlorination, either using chlorine

gas, sodium hypochlorite or chlorine dioxide. Ultraviolet disinfection is also a possibility.

4. Description of How the Development Relates to the Listed & Specified Activities

The construction of Option 2 and Option 3 for the WWTW and associated infrastructure, would require

construction within a watercourse and the construction of infrastructure (roads and pipelines) within 32m from

the watercourse. The watercourse has been identified by the freshwater specialist as HGM2. HGM2 is critically

modified and has little ecological functioning. It has been severely disturbed by past activities.

A 6m wide road is proposed to provide access to the WWTW from the R317. A small section of the road

nearest to the R317 will require the removal of a small amount of indigenous vegetation.

As per the Critical Biodiversity Areas Map provided in Appendix D1, all options proposed would require

vegetation removal within mapped CBA areas. The proposed and preferred Option 2, would require vegetation

removal in a mapped CBA area for the first section of the infrastructure adjacent to the R317 road (small and

insignificant amount) as well as a small amount of vegetation removal on the outskirts of the already

transformed historic effluent dam where the WWTW is proposed. It is estimated that approximately 1000m2 –

1500m2 of indigenous vegetation within a CBA area is proposed to be removed.

Please note: This description must relate to the listed and specified activities in paragraph (d) below.

(c) Please indicate the following periods that are recommended for inclusion in the environmental authorisation:

(i) the period within which commencement must occur, 1 year

(ii) the period for which the environmental authorisation should be

granted and the date by which the activity must have been

concluded, where the environmental authorisation does not

include operational aspects;

The activity does include

operational aspects

(iii) the period that should be granted for the non-operational aspects

of the environmental authorisation; and

The WWTW & associated

infrastructure should be in

operation within 1 year of the EA

being issued.

(iv) the period that should be granted for the operational aspects of

the environmental authorisation.

The WWTW & associated

infrastructure should be in

operation within 1 year of the EA

being issued.

Please note: The Department must specify the abovementioned periods, where applicable, in an environmental

authorisation. In terms of the period within which commencement must occur, the period must not exceed 10 years and

must not be extended beyond such 10 year period, unless the process to amend the environmental authorisation

contemplated in regulation 32 is followed.


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(d) List all the listed activities triggered and being applied for.

Please note: The onus is on the applicant to ensure that all the applicable listed activities are applied for and assessed as

part of the EIA process. Please refer to paragraph (b) above.

EIA Regulations Listing Notices 1 and 3 of 2014 (as amended):

Listed

Activity

No(s):

Describe the relevant Basic Assessment

Activity(ies) in writing as per Listing Notice 1

(GN No. R. 983)

Describe the portion of the

development that relates to the

applicable listed activity as per

the project description.

Identify if the activity is

development /

development and

operational /

decommissioning /

expansion / expansion and

operational.

Activity

12

The development of infrastructure or

structures with a physical footprint of

100m2 or more where such

development occurs –


(b) in front of a development setback;

or

(c) if no development setback exists,

within 32m from a watercourse,

measured from the edge of the

watercourse

The construction of Option 2

and Option 3 for the WWTW

and associated

infrastructure, would require

construction within a

watercourse and the

construction of infrastructure

with a footprint of 100m2 or

more (roads and pipelines)

within 32m from the

watercourse. The

watercourse has been

identified by the freshwater

specialist as HGM2. HGM2 is

critically modified and has

little ecological functioning. It

has been severely disturbed

by past activities.

Development and

operational.

Activity

19

The infilling or depositing of any

material of more than 10m3 into, or the

dredging, excavation, removal or

moving of soil, sand shells, shell grit,

pebbles or rock of more than 10m3 from

-

(i) a watercourse;

Development and

operational.

Listed

Activity

No(s): Describe the relevant Basic Assessment

Activity(ies) in writing as per Listing Notice 3

(GN No. R. 985)

Describe the portion of the

development that relates to the

applicable listed activity as per

the project description.

Identify if the activity is

development /

development and

operational /

decommissioning /

expansion / expansion and

operational.

Activity

4 The development of a road wider than

4 metres with a reserve less than 13,5

metres

(f) In Western Cape:

i. Areas outside urban areas;

(aa) Areas containing indigenous

vegetation

A 6m wide road is proposed

to provide access to the

WWTW from the R317. A

small section of the road

nearest to the R317 will

require the removal of a small

amount of indigenous

vegetation.

Development.

Activity

12

The clearance of an area of 300m2 of

indigenous vegetation

i) Western Cape

ii) Within CBAs identified in

bioregional plans;

As per the Critical

Biodiversity Areas Map

provided in Appendix D1, all

options proposed would

require some vegetation

removal within mapped CBA

areas. The proposed and

preferred Option 2, would

require vegetation removal in

Development and

operational.

Activity

14

The development of:

ii) infrastructure or structures with a

physical footprint of 10m2 or more.

Development and

operational.


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Where such development occurs-


(b) in front of a development setback

line; or

(c) if no development setback has been

adopted, within 32m from a

watercourse, measured from the edge

of the watercourse;

In Western Cape:

i. Outside urban areas, in:

(ff) Critical biodiversity areas or

ecosystem service areas as identified

in systematic biodiversity plans

adopted by the competent authority or

in bioregional plans;

a mapped CBA area for the

first section of the

infrastructure adjacent to the

R317 road (small and

insignificant amount) as well

as a small amount of

vegetation removal on the

outskirts of the already

transformed historic effluent

dam where the WWTW is

proposed. It is estimated that

approximately 1000m2 –

1500m2 of indigenous

vegetation within a CBA area

is proposed to be removed.

Waste management activities in terms of the NEM: WA (GN No. 921):

Category A

Listed

Activity

No(s):

Describe the relevant Category A waste

management activity in writing as per GN No. 921

Describe the portion of the development that relates

to the applicable listed activity as per the project

description

N/A

Note: If any waste management activities are applicable, the Listed Waste Management Activities Additional Information

Annexure must be completed and attached to this Basic Assessment Report as Appendix I.

Atmospheric emission activities in terms of the NEM: AQA (GN No. 893):

Listed

Activity

No(s):

Describe the relevant atmospheric emission activity

in writing as per GN No. 893

Describe the portion of the development that relates

to the applicable listed activity as per the project

description.

N/A

(e) Provide details of all components (including associated structures and infrastructure) of the proposed development and

attach diagrams (e.g., architectural drawings or perspectives, engineering drawings, process flowcharts, etc.).

Buildings

Provide brief description below: YES NO

The WWTW comprises of the following built infrastructure, described in detail above:

o Inlet Channel;

o Buffer Tank;


o Clarifier;




Please refer to the WWTW plant layout engineering drawing in AppendixB1 & B2 and the elevations and sections in Appendix B3.


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The process flow diagram for the WWTW is shown in Figure 5 above.

Infrastructure (e.g., roads, power and water supply/ storage)


A new rising main is proposed from the existing pump station at the factory (currently pumps effluent to

irrigation area) to the WWTW. A return main is also proposed to return the treated effluent to the pump station

from where a portion of the effluent will be discharged to the Breede River and a portion of the effluent will be

irrigated. The approximate development footprint (area to be disturbed during construction) of the area

proposed for both pipelines (rising main and return pipeline) is 20m wide for the length of the pipeline. This

includes space for vehicles, equipment, topsoil and subsoil stockpiles and storage of pipeline prior to

placement.

A Class 12, 200mm diameter PVC pipeline is proposed for the pipeline infrastructure. The pipeline trench is

proposed to be excavated to a depth 0.2m below the design pipeline invert level. The depth of excavation to

trench invert level will be of the order of 1.4 m below existing ground level. During the excavation of the trench

topsoil will be reserved for subsequent re-introduction into the top of the trench.

Figure 4 above shows the typical pipeline trench cross section proposed.

The access road proposed is a 6m wide gravel road.

Parmalat also propose to construct a small emergency dam with trenching river-side of the existing factory.

The emergency dam does not require an Environmental Authorisation as it does not trigger the EIA

Regulations as long as the dam is built further than 32m from the delineated watercourses, which is proposed

(delineated by the freshwater specialist). The emergency dam does however require a water use license and

it should be built outside of the 1:100 year floodline or provided with sufficient stormwater management

measures to avoid flood waters from entering the emergency waste storage pond as this would result in water

pollution in the Breede River. The dam and trenching will serve as a secondary measure of protection to avoid

contamination of the river by containing effluent leaks in the event of a primary system failure.

Processing activities (e.g., manufacturing, storage, distribution)


N/A

Storage facilities for raw materials and products (e.g., volume and substances to be stored)


Chemicals proposed to be used to add to the effluent (as listed in Figure 6 above under “inputs”) will be

stored in a secure building.

Waste (domestic waste & sludge waste) will be stored on site temporarily prior to disposal / re-use off site.

The storage facilities for the waste streams are proposed to be as follows:

Domestic Waste: Includes domestic waste produced from employees at the facility (<0.25m3 per day) and

screenings from the inlet works described below.

• Coarse Screenings from inlet works (plastics, metals, paper): Approximately 0.07m3 per day will be

stored in a skip and taken to Ashton Landfill site when the skip is full

• Fine Screenings: 20% dry solids, mostly organic. Approximately 0.7m3 per day will be stored in a skip

and taken to Ashton Landfill site when the skip is full

Sludge: The primary sludge shall be dewatered to approximately 20% dry solids and the secondary sludge

to approximately 16% dry solids. It is estimated that approximately 5 550kg per day of dewatered primary

sludge will be produced and approximately 6 300kg per day of dewatered secondary sludge will be produced.

The solids shall be stored in skips at the WWTW. The material shall be used for animal fodder (primary sludge

only), fertiliser or it shall be routed to municipal landfill.

Storage and treatment facilities for effluent, wastewater or sewage:



143

The proposed development is a wastewater treatment facility, described in detail under the description of

development above.

Storage and treatment of solid waste


Please see section above.

Facilities associated with the release of emissions or pollution.


A wastewater treatment facility is associated with odours but if managed correctly odours will not cause

impacts / nuisances to downwind receptors. The wastewater treatment facility is proposed to treat up to 2

000m3 per day of industrial effluent generated from the cheese making process at Parmalat. Once treated, a

portion of the effluent is proposed to be pumped via an existing rising main to the existing effluent storage

dam to be used to irrigate the 45ha area 3km away on the Rietfontein farm. When irrigation is not possible

(the land needs to rest / waterlogged / winter season) and / or when the capacity of the dam is relatively full,

treated effluent is also proposed to be discharged into the Breede River at a discharge point in front of the

factory.

Other activities (e.g., water abstraction activities, crop planting activities) –


N/A

3. PHYSICAL SIZE OF THE PROPOSED DEVELOPMENT

(a) Property size(s): Indicate the size of all the properties (cadastral units) on which the

development proposal is to be undertaken

Remainder of Farm No 695 = 69.27Ha

69.27Ha Ha

(b) Size of the facility: Indicate the size of the facility where the development proposal is to be

undertaken

The development footprint of the fenced in WWTW facility (all options) is 117.26m X 87.65m = 10 277.84m2

10 277.84 m2

(c) Development footprint: Indicate the area that will be physically altered as a result of

undertaking any development proposal (i.e., the physical size of the development together

with all its associated structures and infrastructure)

The development footprint of the fenced in WWTW facility (all options) is 117.26m X

87.65m = 10 277.84m2


The approximate development footprint (land to be disturbed to install) of the pipelines

(rising main from factory and treated effluent pipeline discharged to Breede River

(discharged at factory riverbank) built adjacent to the access road is 20m wide 1500m

Long = 30 000m2 (3ha). This includes construction vehicle access and stockpiling area

of material and soil.

Total of above = 44 717.84m2 / 4.47Ha

44 717.84 m2

(d) Size of the activity: Indicate the physical size (footprint) of the development proposal

This includes the WWTW and access road only = 1.47Ha

14 717.84 m2

(e) For linear development proposals: Indicate the length (L) and width (W) of the development

proposal

(L) m

(W) m


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The approximate development footprint (land to be disturbed to install) of the pipelines

(rising main from factory and treated effluent pipeline discharged to Breede River

(discharged at factory riverbank) built adjacent to the access road is 20m wide 1 500m

Long = 30 000m2 (3ha). This includes construction vehicle access and stockpiling area

of material and soil.

(f) For storage facilities: Indicate the volume of the storage facility – sludge storage??? TBC m3

(g) For sewage/effluent treatment facilities: Indicate the volume of the facility

(Note: the maximum design capacity must be indicated 2 000

m3per

day

4. SITE ACCESS

(a) Is there an existing access road? YES NO

(b) If no, what is the distance in (m) over which a new access road will be built?


740m

(c) Describe the type of access road planned:

A compacted gravel access road is proposed to be built. The access road is proposed to be built alongside

the pipeline infrastructure and it is proposed to straddle the outskirts of the cultivated land.

Please note: The position of the proposed access road must be indicated on the site plan.


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5. DESCRIPTION OF THE PROPERTY(IES) ON WHICH THE LISTED ACTIVITY(IES) ARE TO BE UNDERTAKEN

AND THE LOCATION OF THE LISTED ACTIVITY(IES) ON THE PROPERTY

5.1 Provide a description of the property on which the listed activity(ies) is/are to be undertaken and the location of the

listed activity(ies) on the property, as well as of all alternative properties and locations (duplicate section below as

required).

The proposed WWTW is located on Farm No 695 in the Swellendam District. The site is located just outside

the town of Bonnievale adjacent to the R317 Provincial road. The site for the WWTW is opposite the Parmalat

Factory on the other side of the R317.

The farm has been 30% disturbed by agriculture (cultivated land) and 30% disturbed by housing (Uitsig

Community). 40% of the farm however is still undisturbed fynbos of a relatively good quality.

Farm No 695 is almost 70ha in size. The three options for the WWTW are all proposed on the western

boundary of the farm. Option 1 is located on top of a “koppie” where the good quality undisturbed fynbos is

located. Most of the pipeline route for alternative 1 has however been disturbed, since the Uitsig community

where established on the farm. The Uitsig community is a formalized community with subdivided erven, they

are mostly employees of Parmalat and are located approximately 300m from Option 2 (the preferred option)

and further away for the other options.

The location of the WWTW and associated pipeline and road infrastructure for Option 2 & 3 are located mostly

within previous disturbed areas as two effluent dams used to be located on the farm, both of which provided

flood irrigation to the agricultural areas below. Although 30% of the farm has been cultivated in the past, only

weeds remain on the previously cultivated land. The road and pipeline infrastructure is proposed to straddle

the outskirts of the cultivated land.

Option 2 & 3 for the WWTW is located at the top of a natural drainage channel (low ecological sensitivity,

non-perennial) for stormwater flow which only receives low flows in rainy periods.

Coordinates of all the proposed activities

on the property or properties (sites):

Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec.)

SEE BELOW SECTION

The co-ordinates below have been approximated using Google Earth Imagery of the Concept Design provided. The detailed design will confirm the exact co-ordinates. Option 2: The Proposed Alternative Co-ordinates of WWTW (fenced in area 4 corners):

Corner 1: 33°57'7.68"S 20° 5'39.54"E

Corner 2: 33°57'7.64"S 20° 5'44.07"E

Corner 3: 33°57'10.38"S 20° 5'39.49"E

Corner 4: 33°57'10.43"S 20° 5'44.06"E

Co-ordinates of access road (start, middle and end):

Start: 33°57'12.98"S 20° 6'7.45"E

Middle: 33°57'12.60"S 20° 6'1.05"E

End: 33°57'8.44"S 20° 5'40.78"E

Co-ordinates of Rising Main Pipeline (start, middle and end):

Start: 33°56'57.06"S 20° 6'24.95"E

Middle: 33°57'12.98"S 20° 6'7.45"E


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End: 33°57'7.87"S 20° 5'43.54"E

Co-ordinates of Return Pipeline (Discharge to Breede River and to Irrigation Areas):

Start: 33°57'9.02"S 20° 5'40.60"E

Middle: 33°57'12.98"S 20° 6'7.45"E

End: 33°56'55.57"S 20° 6'27.01"E

Note: For land where the property has not been defined, the coordinates of the area within which the development is

proposed must be provided in an addendum to this report.

5.2 Provide a description of the area where the aquatic or ocean-based activity(ies) is/are to be undertaken and the

location of the activity(ies) and alternative sites (if applicable).

The activities associated with the WWTW and pipelines are highly likely to impact upon the Breede River

(HGM 1) and the area draining from the west towards the factory (HGM 2). Two of the proposed WWTW

location alternatives (Option 2 & 3) are located within a drainage area and the third is in closer proximity to

the Breede River (Option 1). The treated WWTW water is proposed to be discharged into the Breede River

by the factory resulting in modifications to the river water quality and flow regime (Bekker, 2019).

Figure 7 below shows the three options considered for the WWTW and associated infrastructure in relation

to the aquatic environment.

Figure 7: The three WWTW alternatives and adjacent watercourses. Option 2 (middle option) is proposed to

be built. The discharge point into the Breede River is shown by the red dot.

Coordinates of the boundary /perimeter of

all proposed aquatic or ocean-based

activities (sites) (if applicable):

Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec)

NOT APPLICABLE


143

5.3 For a linear development proposal, please provide a description and coordinates of the corridor in which the proposed

development will be undertaken (if applicable).

Not Applicable

For linear activities: Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec)

• Starting point of the activity

• Middle point of the activity CO-ORDINATES HAVE BEEN PROVIDED ABOVE IN SECTION 5

• End point of the activity

Note: For linear development proposals longer than 1000m, please provide an addendum with co-ordinates taken every

250m along the route. All important waypoints must be indicated and the GIS shape file provided digitally.

5.4 Provide a location map (see below) as Appendix A to this report that shows the location of the proposed development

and associated structures and infrastructure on the property; as well as a detailed site development plan / site map (see

below) as Appendix B to this report; and if applicable, all alternative properties and locations. The GIS shape files (.shp)

for maps / site development plans must be included in the electronic copy of the report submitted to the competent

authority.

Locality

Map:

The scale of the locality map must be at least 1:50 000.

For linear development proposals of more than 25 kilometres, a smaller scale e.g., 1:250 000 can be used.

The scale must be indicated on the map.

The map must indicate the following:

• an accurate indication of the project site position as well as the positions of the alternative sites, if any;

• road names or numbers of all the major roads as well as the roads that provide access to the site(s)

• a north arrow;

• a legend;

• a linear scale;

• the prevailing wind direction (during November to April and during May to October); and

• GPS co-ordinates (to indicate the position of the activity using the latitude and longitude of the centre

point of the site for each alternative site. The co-ordinates should be in degrees and decimal minutes.

The minutes should have at least three decimals to ensure adequate accuracy. The projection that

must be used in all cases is the WGS84 spheroid in a national or local projection).

For an ocean-based or aquatic activity, the coordinates must be provided within which the activity is to be

undertaken and a map at an appropriate scale clearly indicating the area within which the activity is to be

undertaken.

Coordinates must be provided in degrees, minutes and seconds using the Hartebeesthoek94; WGS84 co-

ordinate system.

Site Plan:

Detailed site development plan(s) must be prepared for each alternative site or alternative activity. The site

plans must contain or conform to the following:

• The detailed site plan must preferably be at a scale of 1:500 or at an appropriate scale. The scale must

be indicated on the plan, preferably together with a linear scale.

• The property boundaries and numbers of all the properties within 50m of the site must be indicated on

the site plan.

• The current land use (not zoning) as well as the land use zoning of each of the adjoining properties must

be indicated on the site plan.

• The position of each element of the application as well as any other structures on the site must be

indicated on the site plan.

• Services, including electricity supply cables (indicate aboveground or underground), water supply

pipelines, boreholes, sewage pipelines, storm water infrastructure and access roads that will form part

of the development must be indicated on the site plan.

• Servitudes and an indication of the purpose of each servitude must be indicated on the site plan.

• Sensitive environmental elements within 100m of the site must be included on the site plan, including

(but not limited to):

o Watercourses / Rivers / Wetlands - including the 32 meter set back line from the edge of the bank

of a river/stream/wetland;

o Flood lines (i.e., 1:100 year, 1:50 year and 1:10 year where applicable;

o Ridges;

o Cultural and historical features;

o Areas with indigenous vegetation (even if degraded or infested with alien species).

• Whenever the slope of the site exceeds 1:10, a contour map of the site must be submitted.

• North arrow

A map/site plan must also be provided at an appropriate scale, which superimposes the proposed

development and its associated structures and infrastructure on the environmental sensitivities of the

preferred and alternative sites indicating any areas that should be avoided, including buffer areas.


143

The GIS shape file for the site development plan(s) must be submitted digitally.

6. SITE PHOTOGRAPHS

Colour photographs of the site and its surroundings (taken on the site and taken from outside the site) with a description of each

photograph. The vantage points from which the photographs were taken must be indicated on the site plan, or locality plan

as applicable. If available, please also provide a recent aerial photograph. Photographs must be attached as Appendix C to

this report. The aerial photograph(s) should be supplemented with additional photographs of relevant features on the site. Date

of photographs must be included. Please note that the above requirements must be duplicated for all alternative sites.


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SECTION B: DESCRIPTION OF THE RECEIVING ENVIRONMENT

Site/Area Description

For linear development proposals (pipelines, etc.) as well as development proposals that cover very large sites, it may be

necessary to complete copies of this section for each part of the site that has a significantly different environment. In such cases

please complete copies of Section B and indicate the area that is covered by each copy on the Site Plan.

1. GRADIENT OF THE SITE

Indicate the general gradient of the sites (highlight the appropriate box).

Flat Flatter than 1:10 1:10 – 1:4 Steeper than 1:4

2. LOCATION IN LANDSCAPE

(a) Indicate the landform(s) that best describes the site (highlight the appropriate box(es).

Ridgeline Plateau Side slope of

hill / mountain

Closed

valley

Open

valley Plain

Undulating

plain/low hills Dune Sea-front

(b) Provide a description of the location in the landscape.

With reference to Appendix A Location Map No 1, the site proposed for the WWTW is located on the east

slope of a hill (“Hamerkop”). The site farm upon which the WWTW and associated infrastructure is proposed

is directly south of the Breede River. The WWTW site footprint and associated infrastructure footprint is

proposed within a previously cultivated area, currently comprising of weeds. The proposed development is

located on a mostly disturbed landscape but is surrounded on the west (upslope) by good quality fynbos

vegetation. The landscape comprises of predominantly a rural farming / agri-industry landscape located on

the outskirts of the town of Bonnievale.

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE

(a) Is the site(s) located on or near any of the following (highlight the appropriate boxes)?

Option 1 Option 2

(preferred) Option 3

Shallow water table (less than 1.5m deep) NO NO NO

Seasonally wet soils (often close to water bodies) YES YES YES

Unstable rocky slopes or steep slopes with loose soil YES NO NO

Dispersive soils (soils that dissolve in water) UNSURE UNSURE UNSURE

Soils with high clay content YES YES YES

Any other unstable soil or geological feature NO NO NO

An area sensitive to erosion NO NO NO

An area adjacent to or above an aquifer. NO NO NO

An area within 100m of a source of surface water YES YES YES

An area within 500m of a wetland YES NO NO

An area within the 1:50 year flood zone NO NO NO

A water source subject to tidal influence NO NO NO

(b) If any of the answers to the above is “YES” or “UNSURE”, specialist input may be requested by the Department.

(Information in respect of the above will often be available at the planning sections of local authorities. The 1:50 000 scale

Regional Geotechnical Maps prepared by Geological Survey may also be used).

(c) Indicate the type of geological formation underlying the site.


143

Granite Shale Sandstone Quartzite Dolomite Dolorite Other (describe)

Provide a description.

Mc Donald (2019) explains that the geology of the entire study area near Bonnievale consists of dark grey

mudrock and siltstone of the Bidouw Subgroup, Bokkeveld Group. The parent rock is colloquially called

‘Bokkeveld Shale’ and it gives rise to clay-rich soils as it weathers.

4. SURFACE WATER

(a) Indicate the surface water present on and or adjacent to the site and alternative sites (highlight the appropriate boxes)?

Option 1 Option 2

(preferred) Option 3

Perennial River YES NO UNSURE

Non-Perennial River YES NO UNSURE

Permanent Wetland YES NO UNSURE

Seasonal Wetland YES NO UNSURE

Artificial Wetland YES NO UNSURE

Estuarine / Lagoon YES NO UNSURE

(b) Provide a description.

The activities associated with the WWTW and pipelines are highly likely to impact upon the Breede River (HGM

1) and the area draining from the west towards the factory (HGM 2). Two of the proposed WWTW location

alternatives (Option 2 & 3) are located within a drainage area and the third is in closer proximity to the Breede

River (Option 1). The treated WWTW water is proposed to be discharged into the Breede River by the factory

resulting in modifications to the river water quality and flow regime (Bekker, 2019).

Figure 8 below shows the three options considered for the WWTW and associated infrastructure in relation to

the aquatic environment.

Figure 8: The three WWTW alternatives and adjacent watercourses. Option 2 (middle option) is proposed to

be built. The discharge point into the Breede River is shown by the red dot.


143

Bekker (2019) explains in the Freshwater Impact Assessment that six freshwater ecosystems were determined as

likely to be impacted upon by the proposed and existing activities associated with the project (this includes the

proposed WWTW, associated infrastructure and the existing as well as the proposed water use activities).

The watercourses identified as potentially impacted by the project were delineated in the field, classified as HGM

units, and assessed in further detail. The watercourses were identified as the following:

• HGM 1 (the Breede River);

• HGM 2 (western drainage line);

• HGM 3 (Breede Tributary);

• HGM 4 (new irrigation area tributary);

• HGM 5 (effluent dam tributary); and

• HGM 6 (eastern tributary).

Figure 9 below shows the freshwater ecosystems listed above, likely to be impacted by the proposed WWTW,

associated infrastructure and water use activities (crossing of watercourses, storage of wastewater, discharge &

irrigation of wastewater).

Figure 9: Freshwater ecosystems likely to be impacted upon by the proposed development (Source: SES:

Freshwater Impact Assessment, 2019).

Bekker (2019) describes these 6 freshwater ecosystems in further detail, as follows:

HGM 1 (The Breede River)

Bekker (2019) states that despite water quality problems as a result of intensive agriculture and urban

development, the ecological importance of the Breede River system is high. The reach of the Breede River

assessed is best described as a perennial floodplain river system. The Breede River Valley is known for its

agricultural land and thus riparian habitat has been significantly reduced to accommodate agricultural lands.

Anthropogenic activities have also impacted the abiotic conditions such as decreased water quality (from effluent


143

discharge / fertilizers) and flow volumes (from abstraction). Intensive agriculture and urban development have

resulted in an array of water quality problems in the Breede River.

Activities will impact on the Breede River substantially as it is proposed to discharge treated effluent into the river.

This will increase the water inflows of the system and alter the abiotic characteristics thereby affecting the biota.

The construction of the discharge outlet structure is proposed on the river bank and could therefore directly impact

on freshwater habitat.

HGM 2 (Western Drainage Line)

The Western Drainage Line is critically modified and has little ecological functioning. It has been severely disturbed

by past activities such as the construction of the small effluent dam, the gravity irrigation, the drains, the berms

and tillage for cultivation.

HGM 3 (Breede Tributary)

The HGM 3 system has been described by Bekker (2019) as un unchanneled valley bottom wetland with soils that

are seasonally saturated. This system has been subjected to significant habitat loss from direct impacts from

agricultural fields, dams, roads and indirect impacts such as the current effluent irrigation causing pollution. Despite

its modified state, it has pockets of habitat that remain ecologically functional.

HGM 5 (Effluent Dam Tributary)

The Effluent Dam Tributary is a tributary to HGM3 which joins the Breede River system shortly downstream. HGM

5 has little habitat remaining and negligible ecological functioning. It has been cleared of vegetation, straitened by

drains, dammed in many locations, infilled and heavily polluted from effluent irrigation and storage upstream (the

effluent dam has in the past overflowed). There is currently potential for the effluent dam, located on the system,

to overflow again, and further pollute any remaining habitat.

HGM 4 (New Irrigation Area Tributary) & HGM 6 (Eastern Tributary)

HGM 4 and HGM 6 will not be impacted upon by the proposed WWTW and associated infrastructure or the WULA

activities being applied for to take place on a permanent basis. HGM 4 & 6 will only be impacted upon over the 18

months (approximate) until such time as the WWTW is in operation as Parmalat have expanded their irrigation

areas into these two areas temporarily until the WWTW is in operation.

In conclusion, Bekker (2019) explains that the current condition of the systems described above is cause for

serious concern. Almost without exception, these tributaries have been dredged, bulldozed, channelized and in

some instances, levees have been constructed alongside them to prevent overbank flooding. In most cases only

hardy and pioneering annuals or exotic species remained in the riparian areas, and there was little or no variety

of instream habitats. Some, as well as the Breede Trunk River, had excessive algal growth and/or exotic instream

vegetation, an indication of a nutrient surplus and a breakdown in the self-cleansing functions of the ecosystem.

The images below where extracted from the Freshwater Impact Assessment undertaken by Debbie Bekker from

Sharples Environmental Services cc. They indicate the characteristics of the affected / surrounding watercourses.


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Figure 10: Photographs indicating the characteristics of the watercourses (Source: SES: Freshwater Impact

Assessment, 2019).


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5. THE SEAFRONT / SEA

(a) Is the site(s) located within any of the following areas? (highlight the appropriate boxes).

If the site or alternative site is closer than 100m to such an area, please provide the approximate distance in (m).

AREA YES NO UNSURE If “YES”: Distance

to nearest area (m)

An area within 100m of the high water mark of the sea YES NO UNSURE

An area within 100m of the high water mark of an estuary/lagoon YES NO UNSURE

An area within the littoral active zone YES NO UNSURE

An area in the coastal public property YES NO UNSURE

Major anthropogenic structures YES NO UNSURE

An area within a Coastal Protection Zone YES NO UNSURE

An area seaward of the coastal management line YES NO UNSURE

An area within the high risk zone (20 years) YES NO UNSURE

An area within the medium risk zone (50 years) YES NO UNSURE

An area within the low risk zone (100 years) YES NO UNSURE

An area below the 5m contour YES NO UNSURE

An area within 1km from the high water mark of the sea YES NO UNSURE

A rocky beach YES NO UNSURE

A sandy beach YES NO UNSURE

(b) If any of the answers to the above is “YES” or “UNSURE”, specialist input may be requested by the Department. (The 1:50 000

scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

6. BIODIVERSITY

Note: The Department may request specialist input/studies depending on the nature of the biodiversity occurring on the

site and potential impact(s) of the proposed development. To assist with the identification of the biodiversity

occurring on site and the ecosystem status, consult http://bgis.sanbi.org or [email protected] . Information is also

available on compact disc (“cd”) from the Biodiversity-GIS Unit, Tel.: (021) 799 8698. This information may be updated

from time to time and it is the applicant/ EAP’s responsibility to ensure that the latest version is used. A map of the

relevant biodiversity information (including an indication of the habitat conditions as per (b) below) must be provided

as an overlay map on the property/site plan as Appendix D to this report.

(a) Highlight the applicable biodiversity planning categories of all areas on preferred and alternative sites and indicate the

reason(s) provided in the biodiversity plan for the selection of the specific area as part of the specific category. Also

describe the prevailing level of protection of the Critical Biodiversity Area (“CBA”) and Ecological Support Area (“ESA”)

(how many hectares / what percentages are formally protected).

Please refer to the figure below and to Appendix D1 when reading this section.

http://bgis.sanbi.org/



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Figure 11: WCBSP identified areas in relation to the Parmalat factory and proposed WWTW locations (Source:

SEC Freshwater Impact Assessment).

Systematic Biodiversity Planning Category CBA ESA Other Natural

Area (“ONA”)

No Natural Area

Remaining

(“NNR”)

If CBA or ESA, indicate the reason(s) for its

selection in biodiversity plan and the

conservation management objectives

The vegetation found in the study area (Option 1 – 3) is all of one

type, Breede Shale Renosterveld. Breed Shale Renosterveld is a

Least Threatened Vegetation type. This vegetation type is therefore

not a threatened vegetation type. The 2016 Ecosystem Guidelines

describe a “Least Threatened Ecosystem” as “an ecosystem that has

not experienced a significant loss of natural habitat or deterioration in

ecological condition (i.e. the composition, structure and functioning

are more or less intact).

Option 1 (both WWTW and pipeline) is located in a Critical

Biodiversity Area 1 (CBA1) and to a very small extent in an Ecological

Support Area 2 (ESA2). The data collected in the botanical survey

supports this classification and mapping.

Option 2 would largely not be in CBA1 or ESA2 except for a small

area at the entrance road off the R317 where the pipeline and access

road is proposed. The area proposed for the WWTW is mostly in an

already disturbed footprint of a historic effluent dam, there will

however be a small amount of overlap and vegetation removal from

the CBA1 area.

In the case of Option 3, according to the WCBSP, the WWTW would

apparently be located within a CBA1. The data collected in the

botanical survey however does not support this classification and

mapping since the Option 3 WWTW site has been mostly disturbed

by an historic effluent dam, similar to Option 2. Also similar to Option

2, there would be a small amount of overlap and vegetation removal

from the CBA1 area surrounding the historic effluent dam.

With reference to Figure 11 above, the 2017 WCBSP Handbook

describes the reasons why areas (green areas) could be selected as


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CBA1 areas. Critical Biodiversity Areas (CBAs) are areas that are

required to meet biodiversity targets for species, ecosystems or

ecological processes and infrastructure. These include:

• All areas required to meet biodiversity pattern (e.g. species,

ecosystems) targets;

• Critically Endangered (CR) ecosystems (terrestrial, wetland

and river types);

• All areas required to meet ecological infrastructure targets,

which are aimed at ensuring the continued existence and

functioning of ecosystems and delivery of essential

ecosystem services; and

• Critical corridors to maintain landscape connectivity.

CBAs are areas of high biodiversity and ecological value and need to

be kept in a natural or near-natural state, with no further loss of habitat

or species. Degraded areas should be rehabilitated to natural or near-

natural condition. Only low-impact, biodiversity-sensitive land uses

are appropriate.

In the CBA maps, a distinction is made between CBAs that are likely

to be in a natural condition (CBA 1) and those that are potentially

degraded or represent secondary vegetation (CBA 2).

The Breede Shale Renosterveld on the study area, was therefore

likely selected as a CBA1 category as the areas mapped in green are

in near natural condition on the slopes of a hill.

Describe the site’s CBA/ESA quantitative

values (hectares/percentage) in relation

to the prevailing level of protection of

CBA and ESA (how many hectares / what

percentages are formally protected

locally and in the province)

• The 2016 National Protected Areas Expansion Strategy of South

Africa provides the following statistics for Breede Shale

Renosterveld in South Africa:

• Area: 1032km2

• Conservation Target: 27%

• 20-year Conservation Target: 219.1km2

• Area in Protected Areas: 61.5km2

(b) Highlight and describe the habitat condition on site.

Habitat

Condition

Percentage of habitat

condition class (adding

up to 100%) and area of

each in square metre

(m2)

Description and additional comments and observations (including

additional insight into condition, e.g. poor land management practises,

presence of quarries, grazing/harvesting regimes, etc.)

Natural

Option 1:

80%

Option 1:

30000m2 Option 1 (both WWTW and pipeline) is located in mostly natural

habitat of good condition. Species of Conservation Concern are

located in the WWTW site area. The first section of the pipeline

(closer to the factory) is however in very degraded condition.

Option 2 would largely not be in CBA1 or ESA2 except for a small

area at the entrance road off the R317 where the pipeline and

access road is proposed. The area proposed for the WWTW is

mostly in an already disturbed footprint of a historic effluent dam,

there will however be a small amount of overlap and vegetation

removal from the CBA1 area.

In the case of Option 3, according to the WCBSP, the WWTW would

apparently be located within a CBA1. The data collected in the

Option 2:

5%

Option 2:

2000m2

Option 3:

5%

Option 3:

2000m2

Near Natural

(includes areas

with low to

moderate level

of alien invasive

plants)

Option 1:

10%

Option 1:

4000m2

Option 2

0%

Option 2:

0m2

Option 3:

0%

Option 3:

0m2

Degraded

(includes areas

heavily invaded

by alien plants)

Option 1:

10%

Option 1:

4000m2

Option 2:

0%

Option 2:

0m2

Option 3:

0%

Option 3:

0m2


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Transformed

(includes

cultivation,

dams, urban,

plantation,

roads, etc.)

Option 1:

0%

Option 1:

0m2

botanical survey however does not support this classification and

mapping since the Option 3 WWTW site has been mostly disturbed

by an historic effluent dam, similar to Option 2. Also similar to Option

2, there would be a small amount of overlap and vegetation removal

from the CBA1 area surrounding the historic effluent dam.

Option 2:

90%

Option 2:

40 000m2

Option 3:

90%

Option 3:

38 888m2

(c) Complete the table to indicate:

(i) the type of vegetation present on the site, including its ecosystem status; and

(ii) whether an aquatic ecosystem is present on/or adjacent to the site.

Terrestrial Ecosystems Description of Ecosystem, Vegetation Type, Original Extent,

Threshold (ha, %), Ecosystem Status

Ecosystem threat status as per the

National Environmental

Management: Biodiversity Act, 2004

(Act No. 10 of 2004)

Critically The vegetation found in the study area (Option 1 – 3) is

all of one type, Breede Shale Renosterveld. Breed Shale

Renosterveld is a Least Threatened Vegetation type.

This vegetation type is therefore not a threatened

vegetation type. The 2016 Ecosystem Guidelines

describe a “Least Threatened Ecosystem” as “an

ecosystem that has not experienced a significant loss of

natural habitat or deterioration in ecological condition (i.e.

the composition, structure and functioning are more or

less intact).

Mucina & Rutherford (2006) explain that Breede Shale

Renosterveld is distributed in the Western Cape Province,

in patches in the Breede River Valley from Tulbagh to

Swellendam; more specifically, most of the valley floor

between Tulbagh and Wolseley, isolated small patches to

the vicinity of Worcester, diverse patches between Stettyn

and McGregor south of the Breede River, a near

continuous but irregular band on the southern foothills of

the Langeberg from Philipsdale near Worcester to

Ashton. The most extensive area occurs near Ashton.

McGregor and the confluence of the Riviersonderend and

Breede Rivers west of Swellendam.

In the 2006 assessment, this vegetation type was 31%

transformed and it had a conservation target of 27%. In

2006 it was however classified as a Vulnerable ecosystem

(a threatened ecosystem) and the classification has

changed to a Least Threatened ecosystem.

Endangered

Vulnerable

Least

Threatened

Aquatic Ecosystems

Wetland (including rivers, depressions,

channelled and unchannelled wetlands, flats,

seeps pans, and artificial wetlands)

Estuary Coastline

YES NO UNSURE YES NO YES NO

(d) Provide a description of the vegetation type and/or aquatic ecosystem present on the site, including any important

biodiversity features/information identified on the site (e.g. threatened species and special habitats). Clearly describe the

biodiversity targets and management objectives in this regard.


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Aquatic Ecosystem

The aquatic ecosystems present in the study area has been described in detail in the section above, under

Section 4: Surface Water. Please refer to section 4 above for a detailed description of the aquatic ecosystems

present in the study area.

Terrestrial Ecosystem

As described above, the vegetation found in the study area (Option 1 – 3) is all of one type, Breede Shale

Renosterveld. Breed Shale Renosterveld is a Least Threatened Vegetation type. This vegetation type is

therefore not a threatened vegetation type. The 2016 Ecosystem Guidelines describe a “Least Threatened

Ecosystem” as “an ecosystem that has not experienced a significant loss of natural habitat or deterioration in

ecological condition (i.e. the composition, structure and functioning are more or less intact).

In terms of the conservation status of the three sites assessed, in 2017 the Western Cape Biodiversity Spatial

Plan (WCBSP) was published and critical biodiversity and ecologically sensitive areas were mapped.

Option 1 (both WWTW and pipeline) are located in Critical Biodiversity Area 1 (CBA1) and to a very small

extent in an Ecological Support Area 2 (ESA2). The data collected in the botanical survey supports this

classification and mapping.

Option 2 would largely not be in CBA1 or ESA2 except for a small area at the entrance road off the R317

where the pipeline and access road is proposed.

In the case of Option 3, according to the WCBSP, the WWTW would apparently be located within a CBA1.

The data collected in the botanical survey however does not support this classification and mapping since

the Option 3 WWTW site has been mostly disturbed by an historic effluent dam, similar to Option 2.

Mc Donald (2019) provided a detailed description of the vegetation and species found on the proposed three

WWTW sites and associated infrastructure routes to be as follows:

Option 1

At the start of the pipeline route the vegetation is highly disturbed and degraded with invasion by numerous

weedy species, in particular Kali sp. (Russian tumbleweed), Pennisetum setaceum (fountain grass) and

Atriplex semibaccata. Other species include, Atriplex lindleyi subsp. inflata, Cynodon dactylon,

Drosanthemum sp., Eragrostis curvula, Galenia africana, Malephora lutea, Mesembryanthemum junceum,

Oxalis pes-caprae, Senecio burchellii, Tetragonia sp. and Trachyandra sp. The botanical sensitivity of this

area at the start of the pipeline route is low.

In the middle of the pipeline route, the persistent species indicate that this area was formerly Breede Shale

Renosterveld but it is now extremely degraded. Notable additions to the species mix at this locality were

Pteronia incana, Chrysocoma ciliata and Euryops speciosissimus.

However, from the mid – end of the pipeline route marks the point at which the Breede Shale Renosterveld

has not been disturbed and is in good condition. Species recorded include Adromischus sp., Asparagus

aethiopicus, Asparagus sp. – fine leaves, Ballota africana, Bulbine sp., Carissa haematocarpa, Chrysocoma

ciliata, Cissampelos capensis, Crassula sp., Drosanthemum cf. hispidum, Drosanthemum sp., Ehrharta sp.

(fine leaves), Erepsia sp., Euclea undulata, Euphorbia burmanii, Euphorbia mauritanica, Euryops

speciosissimus, Freesia sp., Galenia africana, Gloveria integrifolia, Helichrysum sp., Hermannia sp., Hibiscus

sp., Indigofera sp. Lampranthus sp., Lycium sp., Mesembryanthemum junceum, Oxalis sp. (pink flowers),

Ruschia caroli, Searsia cf. undulata, Tetragonia sp., Tripteris clandestinum, Tylecodon paniculata and

Vachellia karoo. Additional species recorded at this location were Pteronia cf. pallens (dominant),

Pentaschistis eriostoma, Astroloba rubriflora, and Microloma sagittatum.


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Mc Donald (2019) explains that the vegetation from middle – end of the pipeline route is considered to be

sensitive because it is in good condition and is rich in species. It should not be disturbed. The Option 1

pipeline route should thus be rejected.

The Alternative 1 WWTW is proposed to be located at the top of a hill. A rocky quartzite patch is located on

the hill with the threatened, endemic succulent species Brianhuntleya intrusa. This ‘quartzite patch’ habitat is

particularly sensitive since it is a special habitat and is becoming rare due to conversion by agriculture. The

vegetation at the WWTW site is in excellent condition and should not be disturbed. The following species

were recorded around the WWTW site area: Aspalathus sp., cf. Pegolettia sp., Crassula sp. (1), Crassula sp.

(2), Dodonaea viscosa, Euphorbia burmanii, Euryops speciosissimus, Gloveria integrifolia, Microloma

sagittatum, Pentaschistis eriostoma, Pteronia paniculata, Ruschia caroli, Tetragonia sp., Tylecodon

paniculatum.(Mc Donald; 2019).

For Option 1, Mc Donald (2019) concludes that the site is highly sensitive from a botanical perspective and it

should be rejected as a possible development site.

Option 2

In the area of the Option 2 pipeline route (the preferred & proposed option), the Breede Shale Renosterveld

has been removed by ploughing of furrows where the effluent from the Parmalat factory was historically

dispersed. The proposed pipeline would be along a disturbed track where there is no longer any renosterveld

vegetation and where the habitat now has very low botanical sensitivity (Mc Donald, 2019).

The location where the proposed Option 2 WWTW would be constructed was formerly a small dam that was

used for the collection and retention of effluent from the Parmalat factory. From this dam the effluent was

dispersed over the ploughed furrows to the east of the dam. This location is highly disturbed and not

botanically sensitive. It could therefore be used without any botanical constraints (Mc Donald, 2019).

Mc Donald (2019) explains that the only place where there is renosterveld remaining is in the vicinity of the

start of the pipeline. However, the pipeline should be re-aligned so as to avoid disturbing the intact vegetation.

Option 3

Mc Donald (2019) states that the site proposed for the Option 3 WWTW is almost identical to that of the

Option 2 WWTW but in the next catchment to the south. A large area has also been cleared of renosterveld

and ploughed with a small dam (now dry) used for holding effluent from the Parmalat factory before it was

distributed over the ploughed area. The entire area is transformed and has very low botanical sensitivity.

The pipeline route for Option 3 is aligned along a disturbed track alongside the ploughed area. No

renosterveld remains where the pipeline would be laid. The area has very low botanical sensitivity. (Mc

Donald (2019).

7. LAND USE OF THE SITE

Note: The Department may request specialist input/studies depending on the nature of the land use character of the

area and potential impact(s) of the proposed development.

Untransformed area

(Option 1 only)

Low density

residential Medium density residential High density residential Informal residential

Retail Commercial &

warehousing Light industrial Medium industrial Heavy industrial

Power station Office/consulting

room

Military or police

base/station/compound

Casino/entertainment

complex

Tourism and

Hospitality facility

Open cast mine Underground mine Spoil heap or slimes dam Quarry, sand or borrow

pit

Dam or reservoir

(Option 2 & 3)

Hospital/medical

centre School Tertiary education facility Church Old age home

Sewage treatment

plant

Train station or

shunting yard Railway line

Major road (4 lanes and

more) Airport

Harbour Sport facilities Golf course Polo fields Filling station


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Landfill or waste

treatment site Plantation

Agriculture (pipeline &

road Option 2 & 3)

River, stream or wetland

(Option 2 & Option 3)

Nature

conservation area

Mountain, koppie or

ridge (Option 1 only) Museum Historical building Graveyard

Archaeological

site

Other land uses

(describe):

(a) Provide a description.

The three options for the WWTW are all proposed on the western boundary of the farm. Option 1 is located

on top of a “koppie” where the good quality undisturbed fynbos is located. Most of the pipeline route for

alternative 1 has however been disturbed, since the Uitsig community where established on the farm. The

Uitsig community is a formalized community with subdivided erven, they are mostly employees of Parmalat

and are located approximately 300m from Option 2 (the preferred option) and further away for the other

options.

The WWTW and associated pipeline and road infrastructure for Option 2 & 3 is located mostly within

previous disturbed areas as two effluent dams used to be located on the farm, both of which provided flood

irrigation to the agricultural areas below. Although 30% of the farm has been cultivated in the past, only

weeds remain on the previously cultivated land. The road and pipeline infrastructure are proposed to

straddle the outskirts of the cultivated land.

Option 2 & 3 for the WWTW is located at the top of a natural drainage channel (low ecological sensitivity,

non-perennial) for stormwater flow which only receives low flows in rainy periods.

8. LAND USE CHARACTER OF THE SURROUNDING AREA

(a) Highlight the current land uses and/or prominent features that occur within +/- 500m radius of the site and neighbouring

properties if these are located beyond 500m of the site.

Note: The Department may request specialist input/studies depending on the nature of the land use character of the

area and potential impact(s) of the proposed development.

Untransformed area Low density

residential Medium density residential High density residential Informal residential

Retail Commercial &

warehousing Light industrial Medium industrial Heavy industrial

Power station Office/consulting

room

Military or police

base/station/compound

Casino/entertainment

complex

Tourism and

Hospitality facility

Open cast mine Underground mine Spoil heap or slimes dam Quarry, sand or borrow

pit Dam or reservoir

Hospital/medical

centre School Tertiary education facility Church Old age home

Sewage treatment

plant

Train station or

shunting yard Railway line

Major road (4 lanes and

more) Airport

Harbour Sport facilities Golf course Polo fields Filling station

Landfill or waste

treatment site Plantation Agriculture River, stream or wetland

Nature

conservation area

Mountain, koppie or

ridge Museum Historical building Graveyard

Archaeological

site

Other land uses

(describe):

(b) Provide a description, including the distance and direction to the nearest residential area, industrial area, agri-industrial

area.


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The area west and south of the proposed site options is on a hill, comprising of untransformed Breede Shale

Renosterveld. Downslope of Option 2 & 3 is a previously cultivated transformed agricultural area. The Uitsig

formal residential community, with some informal dwellings, is located within a 500m radius of the site. The

nearest residence is approximately 300m from Option 2 (the preferred Option). The Parmalat cheese making

factory and the Bonnievale Winery is located within the 500m radius, across the R317. A small graveyard is

located adjacent to the pipeline route near the factory.

9. SOCIO-ECONOMIC ASPECTS

a) Describe the existing social and economic characteristics of the community in the vicinity of the proposed site, in order to

provide baseline information (for example, population characteristics/demographics, level of education, the level of

employment and unemployment in the area, available work force, seasonal migration patterns, major economic

activities in the local municipality, gender aspects that might be of relevance to this project, etc.).

The Draft 2019/ 2020 Integrated Development Plan (IDP) for the Langeberg Local Municipality states the

following:

The Langeberg Municipality covers an area of approximately 4 517.4 km2, the Langeberg Municipality includes

the towns of Robertson, Montagu, Ashton, Bonnievale and McGregor, as well as rural areas adjacent to and

between these towns.

The IDP explains that Bonnievale is known as the valley of cheese and wine. It has eight wine cellars and two

cheese factories producing cheese, milk, butter, whey powder and yoghurt.

The three highest risks to the municipal socio-economic status, is the risk of drought, increasing population,

demand for services and stagnating economic growth.

The largest three sectors contributing to the Gross Domestic Profit (GDP) in the municipality are the wholesale

/ retail / accommodation (18.7%), manufacturing (18%) and financial / real estate / business (16%) sectors.

The following situational analysis is included in the IDP:

Demographics / Population

The total population of the Langeberg Municipality (population estimate from 2018) is approximately 112 260

persons, with 28 401 households. The Langeberg Municipality is the smallest municipal area within the Cape

Winelands District. This total is estimated to increase to 131 314 by 2024 which equates to an a 2.6 per cent

growth rate. The estimated population growth rate of Langeberg is therefore above the estimated population

growth of the Cape Winelands of 2.4 per cent.

GDPR Per Capita

Langeberg has the lowest GDRP per capital compared to other municipalities in the Cape Winelands district.

at R56 052 in 2017, Langeberg’s real GDPR per capita is well below that of the Cape Winelands District’s

figure of R71 426, as well as that of the Western Cape’s R87 110.

Access to Services & Housing

The municipal region has relatively good access to basic services, with the percentage of households with

access to basic services (water, refuse removal, electricity, sanitation & housing) ranging between 80% - 98%.

With a total of 28 401 households, 89.3 per cent have access to formal housing.

Labour Force

The majority of workers in the Langeberg labour force in 2016 was dominated by low -skilled workers (47.5

per cent) and only 16.0 per cent were skilled. The number of skilled workers increased much more than that


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of semi-skilled and low skilled workers during the period 2006 – 2016. An improvement in education and

economic performance can contribute to a further decrease in low-skilled workers.

The agriculture, forestry and fishing sector contributed the most jobs in the Langeberg municipal area in 2016

(14 376; 28.1 per cent). Another sector that contributes significantly to employment, is the wholesale and retail

trade, catering and accommodation sector (11 352; 22.2 per cent). The manufacturing sector contributed

significantly less jobs (8.7 per cent) relative to its GDPR contribution (18.0 per cent) to Langeberg economy.

The agriculture, forestry and fishing and manufacturing sector in the Langeberg municipal area reported net

jobs losses (-8 256) between 2006 and 2016. The losses reported in this sector in 2016 and 2017, were due

to the severe drought.

This is a major cause for concern, considering the significant contribution of this sector to the Langeberg

economy. The sector which reported the largest increase in jobs between 2006 and 2016, was wholesale,

retail and trade (3 790), followed by finance, insurance, real estate business services (2 988); community,

social and personnel services (2 079); and transport, storage and communication (943).

Unemployment Rate

The unemployment rate of the municipality (2017 statistic) is approximately 7.1%. Over the last decade, the

unemployment rate has been rising steadily. Unemployment in the Langeberg municipal area started off at a

low 3.6 per cent in 2006, rising steadily to reach 6.2 per cent in 2010, where after it hovered around 6.0 per

cent until 2016, then edged up to 7.1 per cent in 2017. The Langeberg unemployment rate of 7.1 per cent in

2017 is lower than the District’s 10.7 per cent and the Province’s 18.2 per cent.

10. HISTORICAL AND CULTURAL ASPECTS

(a) Please be advised that if section 38 of the NHRA is applicable to your proposed development, you are requested to

furnish this Department with written comment from Heritage Western Cape as part of your public participation process.

Heritage Western Cape must be given an opportunity, together with the rest of the I&APs, to comment on any Pre-

application BAR, a Draft BAR, and Revised BAR.

Section 38 of the NHRA states the following:

“38. (1) Subject to the provisions of subsections (7), (8) and (9), any person who intends to undertake a development

categorised as-

(a) the construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier

exceeding 300m in length;

(b) the construction of a bridge or similar structure exceeding 50m in length;

(c) any development or other activity which will change the character of a site-

(i) exceeding 5 000m2 in extent; or

(ii) involving three or more existing erven or subdivisions thereof; or

(iii) involving three or more erven or divisions thereof which have been consolidated within the past five years; or

(iv) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources

authority;

(d) the re-zoning of a site exceeding 10 000m2 in extent; or

(e) any other category of development provided for in regulations by SAHRA or a provincial heritage resources

authority,

must at the very earliest stages of initiating such a development, notify the responsible heritage resources authority

and furnish it with details regarding the location, nature and extent of the proposed development”.

(b) The impact on any national estate referred to in section 3(2), excluding the national estate contemplated in section

3(2)(i)(vi) and (vii), of the NHRA, must also be investigated, assessed and evaluated. Section 3(2) states the following:

“3(2) Without limiting the generality of subsection (1), the national estate may include—

(a) places, buildings, structures and equipment of cultural significance;

(b) places to which oral traditions are attached or which are associated with living heritage;

(c) historical settlements and townscapes;

(d) landscapes and natural features of cultural significance;

(e) geological sites of scientific or cultural importance;

(f) archaeological and palaeontological sites;

(g) graves and burial grounds, including—

(i) ancestral graves;

(ii) royal graves and graves of traditional leaders;

(iii) graves of victims of conflict;


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(iv) graves of individuals designated by the Minister by notice in the Gazette;

(v) historical graves and cemeteries; and

(vi) other human remains which are not covered in terms of the Human Tissue Act, 1983 (Act No. 65 of 1983);

(h) sites of significance relating to the history of slavery in South Africa;

(i) movable objects, including—

(i) objects recovered from the soil or waters of South Africa, including archaeological and paleontological

objects and material, meteorites and rare geological specimens;

(ii) objects to which oral traditions are attached or which are associated with living heritage;

(iii) ethnographic art and objects;

(iv) military objects;

(v) objects of decorative or fine art;

(vi) objects of scientific or technological interest; and

(vii) books, records, documents, photographic positives and negatives, graphic, film or video material or sound

recordings, excluding those that are public records as defined in section 1(xiv) of the National Archives of South

Africa Act, 1996 (Act No. 43 of 1996)”.

Is Section 38 of the NHRA applicable to the proposed development? YES NO UNCERTAIN

If YES or

UNCERTAIN,

explain:

Section 38 of the National Heritage Resources Act (NHRA) (Act 25 of 1999) states that any

person who wishes to undertake any of the activities listed in Section 38(1) of the NHRA,

must notify the responsible heritage resources authority in order for that authority to identify

whether any heritage resources may be affected by the proposed development, whether any

heritage impact assessments are required before proceeding, whether or not the

development may proceed, and whether any conditions or limitations should be applied to

the development.

Certain activities listed in Section 38(1) of the NHRA are relevant to the proposed

development, namely:

S38(1):

(a) the construction of a road, wall, powerline, pipeline, canal or other similar form of linear

development or barrier exceeding 300m in length;

(c) any development or other activity which will change the character of a site (i) exceeding

5000m2 in extent….

(d) the rezoning of a site exceeding 10 000m2 in extent…”

A Notice of Intent to Develop (NID) must therefore be submitted to the relevant heritage

authority – in this case, Heritage Western Cape – and approval and a written record of

decision must be obtained from this authority before commencing with the proposed

development. This has been undertaken already, please refer to response from HWC in

Appendix E1. Will the development impact on any national estate referred to in Section 3(2) of

the NHRA? YES NO UNCERTAIN

If YES or

UNCERTAIN,

explain: N/A

Will any building or structure older than 60 years be affected in any way? YES NO UNCERTAIN

If YES or

UNCERTAIN,

explain: N/A

Are there any signs of culturally or historically significant elements, as defined in

section 2 of the NHRA, including Archaeological or paleontological sites, on or

close (within 20m) to the site?

YES NO UNCERTAIN

If YES or

UNCERTAIN,

explain:

A small farm graveyard lies alongside the proposed pipeline route for Options 2 and 3. The

graveyard is enclosed by trees and lies on a separate property. The pipeline would be

excavated outside of the enclosing trees within the Parmalat property ensuring that the


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graves would be safe from harm. The two deceased were both named Van Zyl and the dates

of death were 1927 and 1937.

Note: If uncertain, the Department may request that specialist input be provided and Heritage Western Cape must provide

comment on this aspect of the proposal. (Please note that a copy of the comments obtained from the Heritage

Resources Authority must be appended to this report as Appendix E1).

11. APPLICABLE LEGISLATION, POLICIES, CIRCULARS AND/OR GUIDELINES

(a) Identify all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks, and

instruments that are applicable to the development proposal and associated listed activity(ies) being applied for and that

have been considered in the preparation of the BAR.

LEGISLATION, POLICIES, PLANS,

GUIDELINES, SPATIAL TOOLS,

MUNICIPAL DEVELOPMENT

PLANNING FRAMEWORKS, AND

INSTRUMENTS

ADMINISTERING AUTHORITY

and how it is relevant to this

application

TYPE

Permit/license/authorisation/comment

/ relevant consideration (e.g. rezoning

or consent use, building plan approval,

Water Use License and/or General

Authorisation, License in terms of the

SAHRA and CARA, coastal discharge

permit, etc.)

DATE

(if already

obtained):

South African Constitution

Act 108 of 1996

All Authorities should

administer this Act

This Act is relevant because

everyone has a right to an

environment that does not impact

on their health and well-being.

Everyone has the right –

(a) To an environment that is not

harmful to their health or well-

being; and

(b) To have the environment

protected, for the benefit of

present and future generations,

through reasonable legislative and

other measures that –

(i) prevent pollution and ecological

degradation;

(ii) promote conservation; and

(iii) secure ecologically

sustainable development and use

of natural resources while

promoting justifiable economic

and social development.

N/A


Management Act, Act No.

107 of 1998, as amended

Department of

Environmental Affairs and

Development Planning

(DEA & DP)

An Environmental Authorisation

is required following an

Environmental Impact

Assessment.

Pending

2017 Environmental Impact

Assessment (EIA)

Regulations, as amended

Department of



(DEA & DP)

An Environmental Authorisation

is required following an


Assessment.

Pending

The National Water Act 36

of 1998

The Breede Gouritz

Catchment Management

Agency and the

Department of Sanitation

A Water Use License is required

following a Water Use License

Application Process.

2011

(storage &

irrigation)


143

Re-

submission

- Pending

The 2017 Regulations

Regarding the Procedural

Requirements for Water

Use License Applications

and Appeals

The Breede Gouritz


Agency and the


A Water Use License is required

following a Water Use License

Application Process.

2011

(storage &

irrigation)


Management Air Quality

Act (NEM: AQA), Act No 39

of 2004

Provincial Department of



(DEA & DP) and the Local

and District Municipality

Comment / Relevant

Consideration N/A


Management Waste Act of

2008 (Act No 59 of 2008)




(DEA & DP) and the Local

and District Municipality

Comment / Relevant

Consideration N/A

GN R635 Norms &

Standards for Assessment

of Waste for Landfill

Disposal, 2013




(DEA & DP)

Comment / Relevant

Consideration

GN R636 Norms &

Standards for Disposal of

Waste to Landfill, 2013




(DEA & DP)

Comment / Relevant

Consideration

GN R926 Norms &

Standards for the Storage

of Waste, 2013




(DEA & DP)

Comment / Relevant

Consideration

Government Gazette 9225,

Notice No 399 of 1984

Requirements for the

Purification of Wastewater

or Effluent

The Breede Gouritz


Agency and the


Comment / Relevant

Consideration

2013 Regulations Relating

to Compulsory National

Standards for Process

Controllers and Water

Services Works published

under the Water Services

Act, 1997 (GN R813)

Department of Water and

Sanitation

It is required to register the Water

Treatment Works as a Water

Services Works on the Integrated

Regulatory Information System

(IRIS) for the Department of Water

and Sanitation.

Pending

2013 Waste Classification

& Management

Regulations (GN R636)




(DEA & DP)

Comment / Relevant

Consideration

Conservation of

Agricultural Resources Act

43 of 1967


Agriculture

Comment / Relevant

Consideration

National Heritage

Resources Act, 1999 (Act

No. 25 of 1999)

Heritage Western Cape Comment / Relevant

Consideration

Cape Farm Mapper Department of Agriculture This GIS spatial tool was used to

compile biodiversity mapping.


143

Western Cape Spatial

Biodiversity Plan (2017)

SANBI This GIS dataset was utilised to

show the desktop sensitivity of the

site as mapped by SANBI.

2017 Public Participation

Guideline in Terms of


Management Act, 1998


Assessment Regulations




(DEA & DP)

Comment / Relevant

Consideration

2017 Guideline on Need

and Desirability




(DEA & DP)

Comment / Relevant

Consideration

Spatial Planning and Land

Use Management Act, Act

16 of 2013

Langeberg Local

Municipality

Rezoning (Spot zoning) from

agriculture to Industrial Zone 1 is

required following the submission

of a land use application.

Pending

(b) Describe how the proposed development complies with and responds to the legislation and policy context, plans,

guidelines, spatial tools, municipal development planning frameworks and instruments.

LEGISLATION, POLICIES, PLANS,

GUIDELINES, SPATIAL TOOLS,

MUNICIPAL DEVELOPMENT

PLANNING FRAMEWORKS, AND

INSTRUMENTS

Describe how the proposed development complies with and responds:

South African Constitution Act

108 of 1996

The proposed development, a wastewater treatment plant, is a mitigation

measure proposed to be built to reduce existing impacts from occurring,

with the aim of ensuring that peoples health and well being are not

compromised. The freshwater environment should also not be

compromised and therefore various mitigation measures are required to be

implemented to ensure that the water quality discharged into the Breede

River and used for irrigation purposes does not significantly impact on the

water resources.


Management Act, Act No. 107

of 1998, as amended

The National Environmental Management Principles contained in Chapter

1 of the Act are the principles against which the need and desirability of the

proposed development have been investigated.

2014 Environmental Impact

Assessment (EIA)

Regulations, as amended

The proposed development EIA application is in line with the procedural

requirements of the 2014 EIA Regulations, as amended. The listed activities

in the EIA Regulations have been applied for. The impacts of the listed

activities have been thoroughly assessed by the EAP and the specialist

team.

The National Water Act 36 of

1998

Chapter 4 of the National Water Act addresses the use of water and

stipulates the various types of licensed and unlicensed entitlements to the

use of water. The water uses under Section 21 (NWA) that are associated

with the proposed development are most likely section 21 (b), (c), (e), (g)

and (f). Also, according to the Department of Water and Sanitation (DWS),

any structures within a 500meter radius from the boundary of a wetland

constitutes a Section 21(c) and (i) water use and as such requires a water

use license. A water use license application is currently underway.

The National Water Act provides for protection of water resources.

Parmalat SA are required, in terms of this Act, to prevent significant impacts

to water resources. They are therefore proposing to build this WWTW to


143

ensure compliance with the National Water Act, by improving on the existing

wastewater quality.

The 2017 Regulations

Regarding the Procedural

Requirements for Water Use

License Applications and

Appeals

The proposed development WULA application is in line with the procedural

requirements of the 2017 WULA Regulations. The impacts of the section 21

activities have been thoroughly assessed by the EAP and the specialist

team. The BGCMA are the competent authority for the WULA Applications

and are guiding us in terms of these procedural requirements.


Management Air Quality Act

(NEM: AQA), Act No 39 of

2004

Part 6 of the NEM: AQA includes measures in terms of how to control dust,

noise and offensive odours. The National Dust Regulations (2013) where

therefore promulgated by the Minister as well as the Western Cape Noise

Control Regulations (2013). Parmalat SA must comply with the National

Dust Control Regulations (GN No. R. 827 of 1 November 2013),

promulgated in terms of the National Environmental Management: Air

Quality Act, 2004 (Act No. 39 of 2004) (“NEM: AQA”) and the Western Cape

Noise Regulations (2013) during the construction and operational phases.

The dust level limits and noise level limits have been included in the EMPR.


Management Waste Act of

2008 (Act No 59 of 2008)

This act provides for National Norms & Standards for regulating the

management of waste in terms of the assessment, disposal and storage

which is applicable to this proposed development given the amount of

sludge waste (non-hazardous) proposed to be stored and disposed to land.

The Norms and Standards have therefore been considered and the

requirements included in the EMPR.

GN R635 Norms & Standards

for Assessment of Waste for

Landfill Disposal, 2013

The sludge waste produced needs to be assessed in terms of these Norms

& Standards prior to waste disposal to landfill. This requirement has been

included in the EMPR.


for Disposal of Waste to

Landfill, 2013

The sludge waste produced needs to be disposed in terms of these Norms

& Standards prior to waste disposal to landfill. This requirement has been



for the Storage of Waste, 2013

The sludge waste produced needs to be stored in terms of these Norms &

Standards prior to waste disposal to landfill. This requirement has been


Government Gazette 9225,

Notice No 399 of 1984

Requirements for the

Purification of Wastewater or

Effluent

The development proposes to treat the effluent to General Limit standards,

as prescribed in this Government Gazette.

2013 Regulations Relating to

Compulsory National

Standards for Process

Controllers and Water

Services Works published

under the Water Services Act,

1997 (GN R813)

In the water sector, the requirements for operator skills and classification

are regulated by these regulations. The appropriately skilled staff should be

responsible for the day-to-day operational management of the WWTW.

2013 Waste Classification &

Management Regulations (GN

R636)

The sludge waste proposed to be produced will be classified in terms of

these Regulations.

Conservation of Agricultural

Resources Act 43 of 1967

This Act provides for control over the utilization of the natural agricultural

resources of the Republic in order to promote the conservation of the soil,

the water sources and the vegetation and the combating of weeds and

invader plants; and for matters connected therewith. The WWTW and

associated infrastructure is proposed to be built on land zoned for

agriculture and will result in a small loss of agricultural land.


143

Measures have been put in place to ensure avoidance, and if unavoidable

to prevent, impacting on the soil, water resources and the vegetation.

National Heritage Resources

Act, 1999 (Act No. 25 of 1999)

Section 38 of the National Heritage Resources Act (NHRA) (Act 25 of 1999)

states that any person who wishes to undertake any of the activities listed

in Section 38(1) of the NHRA, must notify the responsible heritage

resources authority. Certain activities listed in Section 38(1) of the NHRA

are relevant to the proposed development. A Notice of Intent to Develop

(NID) has therefore been submitted to the relevant heritage authority.

Cape Farm Mapper This spatial tool was used to view the site sensitivities, provide erf and farm

numbers. Various maps were created showing the conservation status,

vegetation status and location of water resources.

Western Cape Spatial

Biodiversity Plan (2017)

This spatial tool was used to view the site sensitivities. Various maps were

created showing the conservation status, vegetation status and location of

water resources.

2017 Public Participation

Guideline in Terms of National

Environmental Management

Act, 1998 Environmental

Impact Assessment

Regulations

The public participation process / procedure was guided by the

requirements of this guideline and the PPP requirements in the EIA

Regulations.

2017 Guideline on Need and

Desirability

The need and desirability of the development was described in terms of this

guideline.

Spatial Planning and Land Use

Management Act, Act 16 of

2013

A land use application will be submitted shortly to apply for a “spot zoning”

to rezone the WWTW for Industry 1.

Note: Copies of any comments, permit(s) or licences received from any other Organ of State must be attached to this report

as Appendix E.


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Section C: PUBLIC PARTICIPATION

The PPP must fulfil the requirements outlined in the NEMA, the EIA Regulations, 2014 (as amended) and if applicable, the NEM:

WA and/or the NEM: AQA. This Department’s Circular EADP 0028/2014 (dated 9 December 2014) on the “One Environmental

Management System” and the EIA Regulations, any subsequent Circulars, and guidelines must also be taken into account.

1. Please highlight the appropriate box to indicate whether the specific requirement was undertaken or whether there was an

exemption applied for.

In terms of Regulation 41 of the EIA Regulations, 2014 (as amended) -

(a) fixing a notice board at a place conspicuous to and accessible by the public at the boundary, on the fence or

along the corridor of -

(i) the site where the activity to which the application relates, is or is to be undertaken;

and YES EXEMPTION

(ii) any alternative site YES EXEMPTION N/A

(b) giving written notice, in any manner provided for in Section 47D of the NEMA, to –

(i) the occupiers of the site and, if the applicant is not the owner or person in control of

the site on which the activity is to be undertaken, the owner or person in control of

the site where the activity is or is to be undertaken or to any alternative site where

the activity is to be undertaken;

YES EXEMPTION N/A

(ii) owners, persons in control of, and occupiers of land adjacent to the site where the

activity is or is to be undertaken or to any alternative site where the activity is to be

undertaken;

YES EXEMPTION

(iii) the municipal councillor of the ward in which the site or alternative site is situated

and any organisation of ratepayers that represent the community in the area; YES EXEMPTION

(iv) the municipality (Local and District Municipality) which has jurisdiction in the area; YES EXEMPTION

(v) any organ of state having jurisdiction in respect of any aspect of the activity; and YES EXEMPTION

(vi) any other party as required by the Department; YES EXEMPTION N/A

(c) placing an advertisement in -

(i) one local newspaper; or YES EXEMPTION

(ii) any official Gazette that is published specifically for the purpose of providing public

notice of applications or other submissions made in terms of these Regulations; YES EXEMPTION N/A

(d) placing an advertisement in at least one provincial newspaper or national

newspaper, if the activity has or may have an impact that extends beyond the

boundaries of the metropolitan or district municipality in which it is or will be

undertaken

YES EXEMPTION N/A

(e) using reasonable alternative methods, as agreed to by the Department, in those

instances where a person is desirous of but unable to participate in the process due

to—

(i) illiteracy;

(ii) disability; or

(iii) any other disadvantage.

YES EXEMPTION N/A

If you have indicated that “EXEMPTION” is applicable to any of the above, proof of the exemption decision must be

appended to this report.

Please note that for the NEM: WA and NEM: AQA, a notice must be placed in at least two newspapers circulating in the

area where the activity applied for is proposed.

If applicable, has/will an advertisement be placed in at least two newspapers? – N /A YES NO

If “NO”, then proof of the exemption decision must be appended to this report.

2. Provide a list of all the State Departments and Organs of State that were consulted:

State Department / Organ of State Date request

was sent:

Date comment

received:

Support / not in support

Cape Winelands District

Municipality

Start of PPP Process Pending TBC

Langeberg Local Municipality Start of PPP Process Pending TBC

Department of Environmental

Affairs & Development Planning

(DEA & DP) – Air Quality

Directorate


DEA & DP: Waste Directorate Start of PPP Process Pending TBC

DEA & DP: Pollution & Chemicals

Directorate



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DEA & DP: Development

Management Directorate Region 1


Heritage Western Cape Start of PPP Process 30th May 2019 Support

Department of Water Affairs Start of PPP Process Pending TBC

Breede Gouritz Catchment

Management Agency


Cape Nature Start of PPP Process Pending TBC

Department of Agriculture Start of PPP Process Pending TBC

Department of Transport Start of PPP Process Pending TBC

3. Provide a summary of the issues raised by I&APs and an indication of the manner in which the issues were incorporated, or

the reasons for not including them.

(The detailed outcomes of this process, including copies of the supporting documents and inputs must be included in a

Comments and Response Report to be attached to the BAR (see note below) as Appendix F).

This pre-application Draft BAR is currently out for an initial 60-day public & authority participation period. No

issues have therefore yet been raised. This section will be updated before the Draft BAR is made available

for its second and final 30-day public & authority participation period and again prior to the submission of the

Final BAR for final decision making.

4. Provide a summary of any conditional aspects identified / highlighted by any Organs of State, which have jurisdiction in

respect of any aspect of the relevant activity.

The only comment received thus far is from Heritage Western Cape following the submission of a Notice of

Intent to Develop form. They provided only one conditional aspect, as follows:

“Should any heritage resources, including evidence of graves and human burials, archaeological material

and paleontological material be discovered, all works must be stopped immediately and Heritage Western

Cape must be notified without delay”.

Note:

Even if pre-application public participation is undertaken as allowed for by Regulation 40(3), it must be undertaken in

accordance with the requirements set out in Regulations 3(3), 3(4), 3(8), 7(2), 7(5), 19, 40, 41, 42, 43 and 44.

If the “exemption” option is selected above and no proof of the exemption decision is attached to this BAR, the application will

be refused.

A list of all the potential I&APs, including the Organs of State, notified and a list of all the registered I&APs must be submitted

with the BAR. The list of registered I&APs must be opened, maintained and made available to any person requesting access to

the register in writing.

The BAR must be submitted to the Department when being made available to I&APs, including the relevant Organs of State

and State Departments which have jurisdiction with regard to any aspect of the activity, for a commenting period of at least

30 days. Unless agreement to the contrary has been reached between the Competent Authority and the EAP, the EAP will be

responsible for the consultation with the relevant State Departments in terms of Section 24O and Regulation 7(2) – which

consultation must happen simultaneously with the consultation with the I&APs and other Organs of State.

All the comments received from I&APs on the BAR must be recorded, responded to and included in the Comments and

Responses Report included as Appendix F of the BAR. If necessary, any amendments made in response to comments received

must be effected in the BAR itself. The Comments and Responses Report must also include a description of the PPP followed.

The minutes of any meetings held by the EAP with I&APs and other role players wherein the views of the participants are

recorded, must also be submitted as part of the public participation information to be attached to the final BAR as

Appendix F.


143

Proof of all the notices given as indicated, as well as notice to I&APs of the availability of the Pre-Application BAR (if applicable),

Draft BAR, and Revised BAR (if applicable) must be submitted as part of the public participation information to be attached to

the BAR as Appendix F. In terms of the required “proof” the following must be submitted to the Department:

• a site map showing where the site notice was displayed, a dated photographs showing the notice displayed on site

and a copy of the text displayed on the notice;

• in terms of the written notices given, a copy of the written notice sent, as well as:

o if registered mail was sent, a list of the registered mail sent (showing the registered mail number, the name of the

person the mail was sent to, the address of the person and the date the registered mail was sent);

o if normal mail was sent, a list of the mail sent (showing the name of the person the mail was sent to, the address

of the person, the date the mail was sent, and the signature of the post office worker or the post office stamp

indicating that the letter was sent);

o if a facsimile was sent, a copy of the facsimile report;

o if an electronic mail was sent, a copy of the electronic mail sent; and

o if a “mail drop” was done, a signed register of “mail drops” received (showing the name of the person the notice

was handed to, the address of the person, the date, and the signature of the person); and

• a copy of the newspaper advertisement (“newspaper clipping”) that was placed, indicating the name of the

newspaper and date of publication (of such quality that the wording in the advertisement is legible).

SECTION D: NEED AND DESIRABILITY

Note: Before completing this section, first consult this Department’s Circular EADP 0028/2014 (dated 9 December 2014) on the

“One Environmental Management System” and the EIA Regulations, 2014 (as amended), any subsequent Circulars, and

guidelines available on the Department’s website: http://www.westerncape.gov.za/eadp). In this regard, it must be noted that

the Guideline on Need and Desirability in terms of the Environmental Impact Assessment (EIA) Regulations, 2010 published by

the national Department of Environmental Affairs on 20 October 2014 (GN No. 891 on Government Gazette No. 38108 refers)

(available at: http://www.gov.za/sites/www.gov.za/files/38108__891.pdf) also applied to EIAs in terms of the EIA Regulations,

2014 (as amended).

1. Is the development permitted in terms of the property’s existing land use rights? YES NO Please explain

No. The property is currently zoned for Agriculture and the proposed development is an industrial activity. A

land use application is however underway. A spot zoning is being applied for with the Langeberg Local

Municipality to rezone the site to Industrial Zone 1.

2. Will the development be in line with the following?

(a) Provincial Spatial Development Framework (“PSDF”). YES NO Please explain

Objective 9 of the Western Cape PSDF (2009) is to minimize consumption of scarce environmental resources.

Within this strategic objective, Policy RC20 states that “Existing waste water treatment works (WWTWs)

should be progressively improved and realised by means of regulatory measures and thereafter maintained

so that the water quality of the rivers and water-bodies with which they are associated achieve minimum

potable (drinking), contact, phosphate, nitrate and e-coli standards. This requires that they comply with the

effluent quality requirements set out in their licenses”

The proposed WWTW will improve the capacity, functioning and operational efficiency of the existing process

in which wastewater is treated. The new WWTW will be constructed in accordance with all relevant norms,

standards and best practise guidelines in order to ensure the protection of water resources and human health

and well-being. The effluent that will be discharged to the environment will be treated to the General Limit

Standards specified by the Department of Water & Sanitation. The proposed project is therefore aligned with

the PSDF.

The more recent PSDF (2014) highlights that investment in infrastructure (including maintenance and

upgrading of existing infrastructure) is needed to bring about the desired urban spatial transitions envisaged

in the PSDF.

(b) Urban edge / edge of built environment for the area. YES NO Please explain

The development falls outside of the Bonnievale Urban Edge. A development of this nature, a WWTW, should

be built outside of the urban edge as to not impact significantly on the community.

(c) Integrated Development Plan and Spatial Development Framework of the Local

Municipality (e.g., would the approval of this application compromise the

integrity of the existing approved and credible municipal IDP and SDF?).

YES NO Please explain

http://www.westerncape.gov.za/eadp

http://www.gov.za/sites/www.gov.za/files/38108__891.pdf


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INTEGRATED DEVELOPMENT PLAN (IDP)

The Langeberg Draft IDP (2019-2020) states that the Langeberg Municipality intends to create an enabling

environment for economic growth and decent employment (stated as part of Strategic Objective No 3 – Local

Economic Development). Parmalat SA provides hundreds of jobs to the Bonnievale community. These jobs

are directly dependant on the construction of the WWTW being approved. Further jobs will also be created

during the construction and operation of the WWTW and associated infrastructure.

The IDP further indicates that it plans to align National Objectives / Outcomes listed in the National

Development Plan with Langeberg Municipality’s Strategic Objectives. The following National Outcomes have

been aligned with the Strategic Objectives of the Langeberg Municipality:

National Outcome (National Development Plan) Langeberg Strategic Objective

Outcome 2: A long and health life for all South

Africans

SO4 An Efficient, effective, responsive and

accountable administration

Outcome 4: Decent employment through inclusive

economic growth.

SO3 Local Economic Development: Create an

enabling environment for economic growth and

decent employment

Outcome 10: Environmental assets and natural

resources that is well protected and continually

enhanced.

Outcome 11: Create a better South Africa and

contribute to a better and safer Africa and World.

SO3 Local Economic Development: Create an

enabling environment for economic growth and

decent employment

SO4 An Efficient, effective, responsive and

accountable administration

The IDP Vision for the Municipality is as follows: “To create a stable living environment and sustainable living

conditions for all citizens”. The development of the WWTW and associated infrastructure will greatly improve

on the status quo with the aim of creating sustainable conditions for those surrounding businesses and

residents.

The proposed project is thus aligned with the strategic objectives and vision of the local IDP.

SPATIAL DEVELOPMENT FRAMEWORK

According to the SDF for the Langeberg Municipality (figure below) (2011), the undeveloped areas of the

proposed development site are currently assigned a spatial planning category of Other Natural Areas /

Extensive Agriculture.


143

Figure 12: The SDF for Bonnievale (2015). The proposed site (Option 2) indicated by the red arrow. Spot zoning of Industry 1 Zone may be accommodated in Other Natural Areas / Extensive Agriculture. The development is therefore not expected to compromise the integrity of the existing approved local SDF. (d) An Environmental Management Framework (“EMF”) adopted by this Department.

(e.g., Would the approval of this application compromise the integrity of the

existing environmental management priorities for the area and if so, can it be

justified in terms of sustainability considerations?)


To the best of our knowledge there is no EMF adopted.

(e) Any other Plans (e.g., Integrated Waste Management Plan (for waste

management activities), etc.)). YES NO Please explain

Mott Mc Donald, on behalf of the Langeberg Local Municipality, compiled a 3rd Generation Integrated

Waste Management Plan, dated May 2017.

One of the key goals for waste management in the municipality is to promote waste minimisation, reuse,

recycling and recovery. A Key Performance Area of the IWMP is the 2019/2020 year is to ensure that all

businesses / industries have developed a Waste Management Plan, identifying areas where resources are

being wasted and can be used more efficiently, through re-use, the introduction of new technologies or selling

waste to other businesses who could utilise the recovered material to produce new products or provide

services.

Parmalat SA Bonnievale are a relatively large industry in Bonnievale and should therefore have a Waste

Management Plan in place. Seeming that the WWTW is in effect an extension of the factory the dry sludge

waste produced at the WWTW and temporarily stored in waste skips at the WWTW site, should form part of

the Waste Management Plan.

Options should be identified (composting, fertilizer for agriculture etc) for the re-utilisation of the sludge waste,

once it has been produced, tested and classified, instead of the sludge going to landfill.

At the proposed WWTW, the primary sludge shall be dewatered to approximately 20% dry solids and the

secondary sludge to approximately 16% dry solids. It is estimated that approximately 5 550kg per day of


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dewatered primary sludge will be produced and approximately 6 300kg per day of dewatered secondary

sludge will be produced. The solids shall be stored in skips at the WWTW. The material shall be used for

animal fodder (primary sludge only), fertiliser or it shall be routed to municipal landfill (last resort).

Parmalat have committed to investigating further the potential re-use options for the sludge. This will be

included in their Waste Management Plan. This will also be in their benefit due to the costs associated with

landfill disposal.

3. Is the land use (associated with the project being applied for) considered within

the timeframe intended by the existing approved SDF agreed to by the relevant

environmental authority (in other words, is the proposed development in line with

the projects and programmes identified as priorities within the credible IDP)?


Yes, this has been explained in (c) above.

4. Should development, or if applicable, expansion of the town/area concerned in

terms of this land use (associated with the activity being applied for) occur on the

proposed site at this point in time?


No, the development of the industrial WWTW is not expected to result in the expansion of the town.

5. Does the community/area need the project and the associated land use

concerned (is it a societal priority)? (This refers to the strategic as well as local level

(e.g., development is a National Priority, but within a specific local context it could

be inappropriate.)


Parmalat are irrigating more than that allowed for in the license and the wastewater quality is exceeding the

required water quality limits. This has resulted in localised odours, waterlogged soil and vegetation loss,

further reducing the ability of the grass to absorb the water. Impacts to the freshwater environment has also

taken place and is currently taking place as wastewater has been / is being discharged to the Breede River

that exceeds the General Limit Values.

The effluent storage dam is currently at almost full capacity (10m depth). The storage dam also receives

natural stormwater runoff. We are currently in winter and therefore irrigation of effluent from the dam is not

always possible if the soils are waterlogged in rainy periods. Given the poor quality of effluent in the storage

dam (180 000m3), should the dam banks collapse as a result of exceeding the storage capacity, this would

significantly impact on the downstream watercourses

It is therefore a societal priority to construct the WWTW.

6. Are the necessary services available together with adequate unallocated

municipal capacity (at the time of application), or must additional capacity be

created to cater for the project? (Confirmation by the relevant municipality in this

regard must be attached to the BAR as Appendix E.)


This is a small scale WWTW with a limited operational staffing component. Limited services are required from

the municipality to support the development. Only one permanent staff member will be on site during the

operational phase. The following services are proposed:

Potable water: The Langeberg Municipality will provide potable water (small volume for human use at the

WWTP). A small potable water pipeline will be laid parallel to the pipelines proposed for effluent to connect

to the municipal water main.

Electricity: Electricity will be supplied from Eskom by an overhead powerline.

Sewerage Treatment: A septic tank coupled with a French drain treatment system is proposed, given the low

number of operational staff.

7. Is this project provided for in the infrastructure planning of the municipality and if

not, what will the implication be on the infrastructure planning of the municipality YES NO Please explain


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(priority and placement of services and opportunity costs)? (Comment by the

relevant municipality in this regard must be attached to the BAR as Appendix E.)

There will be no implication on the infrastructure planning of the municipality.

8. Is this project part of a national programme to address an issue of national concern

or importance? YES NO Please explain

No.

9. Do location factors favour this land use (associated with the development

proposal and associated listed activity(ies) applied for) at this place? (This relates

to the contextualisation of the proposed land use on the proposed site within its

broader context.)


The WWTW is needed and desired at this location because the property is opposite the factory and it is

owned by Parmalat. Therefore, costs will be lower to build the pipeline infrastructure from the factory and the

applicant will not need to purchase a new site. In addition, the Option 2 location proposed is a sufficient

distance from residents (approximately 300m from Uitsig community) and would not result in an unacceptable

visual impact as it is located in the “trough” / “valley” of two adjacent hills. The site location is in an area that

used to be an effluent dam site historically and has been mostly disturbed / transformed already.

The WWTW is needed and desired at this location because it will have a low impact to aquatic and terrestrial

biodiversity, low visual impact, low nuisance impact (odours) and overall low environmental impact given the

proposed location and buffer area from sensitive receptors.

10. Will the development proposal or the land use associated with the development

proposal applied for, impact on sensitive natural and cultural areas (built and

rural/natural environment)?


See above response.

11. Will the development impact on people’s health and well-being (e.g., in terms

of noise, odours, visual character and ‘sense of place’, etc.)? YES NO Please explain

See above response.

12. Will the proposed development or the land use associated with the proposed

development applied for, result in unacceptable opportunity costs? YES NO Please explain

No opportunity cost lost has been identified.

13. What will the cumulative impacts (positive and negative) of the proposed land use associated with the development

proposal and associated listed activity(ies) applied for, be?

Cumulative impacts are impacts expected in addition to those already occurring impacts, which will therefore

impact further on existing negative impacts.

Cumulative impacts to the freshwater environment are expected to occur as a result of the construction of

the discharge outlet, WWTW, pipe and road infrastructure within an / or adjacent to watercourses and the

discharge of up to 2 000m3 per day of treated wastewater into the Breede River.

Bekker (2019) explains that the surrounding agricultural activities have already had a significant impact on

the river and tributaries in the area. Terrestrial and aquatic disturbances from the past have resulted in areas

heavily invaded by alien biota. Without mitigation the cumulative impact of the new WWTW, associated road

and pipeline is expected to result in further degradation of the condition of the river. However, considering

the current degraded state of the river and the impacts of the existing activities undertaken by Parmalat


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Bonnievale, the relative cumulative impact of the proposed construction of the WWTW and associated

infrastructure would not be high. The relative cumulative impact of discharge of poor quality effluent is

however expected to have a detrimental cumulative impact if not mitigated by appropriate treatment to at

least General Limit Values.

14. Is the development the best practicable environmental option for this land/site? YES NO Please explain

This land / site could practically be better suited for agriculture or to remain undeveloped but it is not an

unpractical option for the site to build a small scale WWTW as it is not expected to have an opportunity cost

lost associated with farming or any significant biodiversity impact.

The site is a very good practical environmental option for the WWTW given the already disturbed nature of

the site and its distance from sensitive receptors.

15. What will the benefits be to society in general and to the local communities? Please explain

It is expected to benefit society and the local community because the sooner the wastewater can be treated

to an improved quality and the sooner treated effluent can also be discharged to the Breede River, following

the construction of the treatment plant, the existing impacts associated with the status quo can be reversed /

prevented from continuing (odours, nuisances, water quality, freshwater habitat).

16. Any other need and desirability considerations related to the proposed development? Please explain

The WWTW and associated infrastructure is needed and desired for the following reasons:

• The Parmalat SA Bonnievale facility used to generate between 1200m3 to 1300m3 effluent / day (prior to

2017). In 2017, a decision was taken to relocate the “Simonsberg” plant in Stellenbosch to Bonnievale

and a smaller part to Ladismith. The feta production plant, white mould production plant and processed

cheese production plant was moved to Bonnievale. This has resulted in more processing equipment in

Bonnievale and subsequently more cleaning activities and a considerable increase in effluent wastewater

generated;

• To improve on the water quality of the wastewater currently being irrigated on the remainder of portion

12 of the farm no. 175, Rietfontein (existing 45ha irrigation area);

• To improve on the water quality of the wastewater currently being stored in an effluent detention dam

located on the remainder of portion 12 of the farm no. 175, Rietfontein;

• Parmalat’s production capacity has increased considerably over the past few years. The amount of

wastewater produced has therefore also increased. The size of the existing effluent storage dam and

irrigation area is not large enough to contain the wastewater. It is therefore needed to discharge

wastewater into the Breede River. This can only be undertaken if the wastewater is treated to General

Limit Values and this is why the WWTW is required to be installed.

• Bekker (2019) explains that wastewater volume monitoring indicated that the factory started producing a

higher than 1 500 m3 average volume of wastewater per day since the first months of 2018. The increase

in average wastewater production started in the middle of 2017. This led to higher than expected effluent

levels in the retention dam. The rainy winter months are here, leaving Parmalat with a problem since the

dam is expected to reach its maximum level soon. The rainy season means that the current, already

saturated irrigation area will be further waterlogged, and no more effluent can therefore be irrigated to

relieve the pressure on the retention dam. Should the dam overflow, or should untreated effluent be

discharged into the river, it will have detrimental impacts on the downstream aquatic habitat.

17. Describe how the general objectives of Integrated Environmental Management as set out in Section 23 of the NEMA

have been taken into account:

The manner in which these objectives have been taken into account is as follows:

• Compliance with and integration of the principles of environmental management is addressed in the

following section (Section 18 below).


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• All the actual and potential impacts on the environment, socio-economic conditions and cultural heritage,

the risks and consequences and alternatives and options for mitigation of activities, with a view to

minimizing negative impacts, maximizing benefits have been identified, predicted and evaluated (see

Section F).

• Public participation will be adequate and an appropriate opportunity will be afforded for public participation

in decisions that may affect the environment. The local community and Organs of State having jurisdiction

over the proposed development will be given an opportunity to participate (see Appendix F for details).

18 Describe how the principles of environmental management as set out in Section 2 of the NEMA have been taken into

account:

• All relevant environmental, social and economic aspects of the proposed development have been

identified, described, assessed and any residual impacts mitigated where applicable. The disadvantages

and benefits have been considered in this process. This integrated approach has led to the identification

of the Best Practicable Environmental Option for the development.

• The direct and indirect impacts and cumulative impacts associated with the proposed development on

the surrounding environment have been assessed in this report and mitigated against in the conditions

of the EMPr. With the protection of environmental resources ensured by the proposed location, layout

and design, people’s environmental rights and their access to environmental resources (such as polluted

water) are not restricted by the proposed development. The proposed development will improve on the

effluent discharge quality and improve on the current infringes to people’s environmental rights as a result

of the existing impacts occurring. In addition, the EMPr ensures that responsibility for management of

any risks associated with the development, including the costs for remediation of any environmental

damage that could occur, rests with the applicant.

• Appropriate specialist input has been obtained into the suitability of the current site. The proposal is

therefore suitably located and suitably designed to ensure minimal impact on any sensitive environmental

aspects on site and in the surrounding area.

• The regional planning context of the proposed activity has guided the development planning in order to

ensure that the development is not in conflict with the planning imperatives for the area.

• The NEMA EIA Regulations (2014) and the DEA’s Guideline on Public Participation (2017) have been

consulted for this application process. The relevant Organs of State with jurisdiction over the proposed

development have been provided with an opportunity to review and comment on the Basic Assessment

Report. Thus, there is an opportunity for environmental considerations to be included in decision-making

by these Organs of State.

• All reports compiled during this Basic Assessment process will be made accessible to the public, thus

ensuring an open and transparent process and allowing the interests, needs and values of the public to

be considered during the assessment process where possible. No particular community is more at risk

than another in terms of possible impacts associated with the development. The development includes

measures to minimise all associated impacts so that any and all nearby receptors are protected and

environmental justice is served.

• There is a low biodiversity impact associated with the construction phase of the proposed WWTW and

associated infrastructure in terms of impacts to vegetation and water resources. The expected operation

phase impacts to the freshwater environment can be mitigated to a medium level of impact significance

provided that the recommended mitigation measures are implemented by Parmalat SA. The proposed

development is not associated with any impacts to the heritage or cultural environment.


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SECTION E: DETAILS OF ALL THE ALTERNATIVES CONSIDERED

Note: Before completing this section, first consult this Department’s Circular EADP 0028/2014 (dated 9 December 2014) on the

“One Environmental Management System” and the EIA Regulations, 2014 (as amended), any subsequent Circulars, and

guidelines available on the Department’s website http://www.westerncape.gov.za/eadp.

The EIA Regulations, 2014 (as amended) defines “alternatives” as “ in relation to a proposed activity, means different means

of fulfilling the general purpose and requirements of the activity, which may include alternatives to the—

(a) property on which or location where the activity is proposed to be undertaken;

(b) type of activity to be undertaken;

(c) design or layout of the activity;

(d) technology to be used in the activity; or

(e) operational aspects of the activity;

(f) and includes the option of not implementing the activity;”

The NEMA (section 24(4)(a) and (b) of the NEMA, refers) prescribes that the procedures for the investigation, assessment and

communication of the potential consequences or impacts of activities on the environment must, inter alia, with respect to every

application for environmental authorisation –

• ensure that the general objectives of integrated environmental management laid down in the NEMA and the National

Environmental Management Principles set out in the NEMA are taken into account; and

• include an investigation of the potential consequences or impacts of the alternatives to the activity on the environment

and assessment of the significance of those potential consequences or impacts, including the option of not implementing

the activity.

The general objective of integrated environmental management (section 23 of NEMA, refers) is, inter alia, to “identify, predict

and evaluate the actual and potential impact on the environment, socio-economic conditions and cultural heritage, the risks

and consequences and alternatives and options for mitigation of activities, with a view to minimising negative impacts,

maximising benefits, and promoting compliance with the principles of environmental management” set out in the NEMA.

The identification, evaluation, consideration and comparative assessment of alternatives directly relate to the management of

impacts. Related to every identified impact, alternatives, modifications or changes to the activity must be identified, evaluated,

considered and comparatively considered to:

• in terms of negative impacts, firstly avoid a negative impact altogether, or if avoidance is not possible alternatives to better

mitigate, manage and remediate a negative impact and to compensate for/offset any impacts that remain after

mitigation and remediation; and

• in terms of positive impacts, maximise impacts.

1. DETAILS OF THE IDENTIFIED AND CONSIDERED ALTERNATIVES AND INDICATE THOSE ALTERNATIVES

THAT WERE FOUND TO BE FEASIBLE AND REASONABLE

Note: A full description of the investigation of alternatives must be provided and motivation if no reasonable or feasible

alternatives exists.

(a) Property and location/site alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise

positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:



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Three site location alternatives have been investigated (all on the same farm), as per the Site Layout Plan in

Appendix B and the figure below.

Figure 13: The Three Site Location Alternatives and Associated Access Roads & Pipeline Infrastructure. Option 2 is the preferred location alternative.

The following three site location alternatives have been comparatively assessed in this Environmental Impact

Assessment and by the specialists:

• Option 1: WWTW to be located on the top of the “koppie” nearest to the Breede River

• Option 2 (the preferred alternative): WWTW to be located in a mostly disturbed area, where Parmalat

historically stored effluent and on cultivated land.

• Option 3: WWTW to be located in a mostly disturbed area, where Parmalat historically stored effluent,

and on cultivated land, further south from Option 2.

Each of the above site location alternatives for the WWTW results in alternative pipeline and access roads.

(b) Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts,

or detailed motivation if no reasonable or feasible alternatives exist:

No activity alternatives have been identified that can meet the objective of the development, which is to

improve on the water quality and have an additional discharge area (the river) because the existing 45ha

irrigation area is not large enough to accommodate the quantity of effluent.

(c) Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive

impacts, or detailed motivation if no reasonable or feasible alternatives exist:


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The findings of the freshwater impact assessment indicated that the proposed route of the access road and

pipeline infrastructure crosses a watercourse (HGM 2). Although there is no problem with crossing this

watercourse (non-perennial, low ecological significance), the option of re-aligning the access road and

pipeline infrastructure to be north of the watercourse is an alternative option to be considered to avoid the

need to construct a culvert / crossing. This option is still being investigated, more information in this regard

will be available in the Draft BAR (this is the Pre-Application Draft BAR).

(d) Technology alternatives (e.g., to reduce resource demand and increase resource use efficiency) to avoid negative

impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable

or feasible alternatives exist:

Figure 14 below shows various types of biological wastewater treatment options that could be considered.

Figure 14: The Various Types of Aerobic Biological Aerobic Treatment options (source: Tecroveer, 2019)

The following technology alternatives have been investigated by Parmalat SA in terms of wastewater

treatment technologies:

1. Option A: Aerobic Wastewater Treatment

Aerobic wastewater treatment is a process where bacteria utilize oxygen to degrade organic matter (generally

quantified as biochemical oxygen demand or BOD) and other pollutants involved in various production

systems. The degradation of BOD is achieved through aerobic bacteria in a system. The bacteria utilize

oxygen as an electron receptor in order to convert the organic material (BOD or oxygen demand) to carbon

dioxide. Via this process they multiply, which in turn creates more bugs to break down more BOD. With

aerobic treatment, micro-organisms convert organics into carbon dioxide and new biomass (sludge) in the

presence of oxygen. Although aerobic systems require higher amounts of energy for aeration and produce

more sludge than anaerobic systems, they play a necessary role in the wastewater treatment train. These

systems allow industrial processors to meet strict environmental requirements so that wastewater can be

discharged safely.

The following aerobic wastewater treatment systems were considered by Parmalat SA:

o Option A1: Conventional Activated Sludge (“CMAS”)

CMAS (Complete Mix Activated Sludge) is a process whereby the biomass is freely “swimming” and

consumes the BOD/COD and other organics within the water as it comingles (Tecroveer; 2019). A

conventional active sludge system consists of an aeration tank, which is used for biological


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degradation, and a sedimentation tank, where the sludge in separated from the treated wastewater.

Active sludge systems are flexible, robust and cost-effective.

o Option A2: Mixed Bed Bioreactor (“MBBR”)

Mixed Bed Bioreactor (MBBR) is a process whereby the media is placed in the wastewater in a very

high concentration and aerated to provide aeration and mixing. The biomass is attached to the media

and consumes the BOD/COD within the water as it comingles (Tecroveer; 2019). The upstream

screening for the removal of grit and grease is required, but particles smaller than 3mm are allowed

to pass and even a manual screening is acceptable. In contrast to the MBR (Membrane Bio Reactor)

the MBBR (Mixed Bed Bio Reactor) only uses bacteria for the breakdown of impurities.

MBBR plants contain particles (e.g. produced from UV-stabilised polyethylene), on which bacteria

grow, developing a biofilm on the free moving particles, which reduce the impurities and, therefore,

the sludge mass (but not as effectively as an MBR plant). Sludge settlement is required after the bio-

reactor in the form of lamella technology. The advantage is that spare parts are cheaper and long

lasting, so operational expenses are lower than with MBR (Membrane Bio Reactor).

o Option A3: Membrane Bio-reactor (“MBR”)

Membrane bioreactor (MBR) is the combination of a membrane process like microfiltration or

ultrafiltration with a biological wastewater treatment process, the activated sludge process. MBR

technology is based on the combination of conventional activated sludge treatment together with a

process filtration through a membrane with a pore size between 10 nm and 0.4 microns

(micro/ultrafiltration), which allows sludge separation. The membrane is a barrier that retains all

particles, colloids, bacteria and viruses, providing a complete disinfection of treated water.

Furthermore, it can operate at higher concentrations of sludge (up to 12 g/l instead of the usual 4 g/l

in conventional systems), which significantly reduces the volume of the reactors and sludge

production. This technology however is associated with high costs, both capital and operating

expenditure, (CAPEX and OPEX), mainly due to membrane installation and replacement and high

energy demand. The MBR process is extremely sensitive, is unable to deal with overloading and has

very high operation and maintenance costs.

Figure 15 & 16 below show examples of these wastewater treatment systems elsewhere.

Figure 15: An Example of a MBBR (source: Tecroveer; 2019)


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Figure 16: An Example of a Conventional Activated Sludge Wastewater Facility, similar to what is proposed to be developed (source: Tecroveer; 2019)

2. Option B: Anaerobic Wastewater Treatment

Anaerobic treatment is a process where wastewater or material is broken down by micro-organisms without

the aid of dissolved oxygen. However, anaerobic bacteria can and will use oxygen that is found in the oxides

introduced into the system or they can obtain it from organic material within the wastewater. Anaerobic

treatment is an energy-efficient process in which micro-organisms transform organic matter in the wastewater

into biogas in the absence of oxygen. To achieve this oxygen-free environment, the entry of air into anaerobic

tanks is prevented, typically by a gastight cover.

Anaerobic treatment is often used to treat warm industrial wastewater, and the process offers several benefits

over aerobic treatment, including lower energy requirements, less chemicals, and less sludge production.

The sludge is stable and safe to use as a soil enhancer. Methane-rich biogas is produced through the

anaerobic process.

(e) Operational alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive

impacts, or detailed motivation if no reasonable or feasible alternatives exist:

Operational alternatives, in terms of types of WWTW to be in operation, has been described above.

Operational alternatives in terms of sludge disposal / re-use options are currently being investigated. Ideally,

given the non-hazardous nature of the sludge, it can be used for animal fodder / fertilizer. Until such time as

alternative re-use options have been investigated in more detail, the sludge is proposed to be mechanically

dewatered and the then stored (relatively dry product) on site in storage skips and transported to the local

municipality landfill site on regular basis.


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(f) The option of not implementing the activity (the ‘No-Go’ Option):

Should the status quo remain and the WWTW not be constructed, significant socio-economic impacts are

likely to occur as a result of significant job losses at the Parmalat factory due to downscaling that would be

required and decrease in production. Should the status quo remain, there is a significant high risk of water

pollution (detrimental) should the effluent dam banks burst and should additional untreated effluent be

discharged into the Breede River. The status quo is also associated with groundwater, soil, air quality (odours)

and nuisance impacts that are currently occurring and would continue to occur should the WWTW not be

constructed as a result of the current poor quality of effluent being irrigated.

Bekker (2019) explains in the freshwater impact assessment that the NO-GO alternative (status quo remains)

means that no action will be taken towards preventing overflow of the existing effluent retention dam and

handling the excess effluent produced by the Parmalat Factory since 2017. This alternative will lead to the

retention dam reaching its full capacity and overflowing into downstream aquatic habitat. Due to the effluent

in the dam being only partially treated wastewater the damage to aquatic habitat would likely be severe. The

water quality currently being irrigated does not even comply with parameters as set out for irrigation purposes,

meaning that it is beyond complying with safe water quality parameters for effluent being released into a

natural system. The No-Go alternative will result in continued pollution, erosion, sedimentation, combined

with the unmonitored flow inputs and habitat loss due to the abnormal increased levels of nutrients, and will

lead to additional alien plant invasion.

(g) Other alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or

detailed motivation if no reasonable or feasible alternatives exist:

N/A

(h) Provide a summary of all alternatives investigated and the outcome of each investigation:

The table below summarises the alternatives investigated and the outcome of each investigation.

Table 4: Summary of Alternatives Investigated

Type of

Alternative

Description

of

Alternative

Outcome/ Comments

Site location

alternatives:

Option 1

Option 1: WWTW to be located on the top of the “koppie” nearest to the Breede River


• No opportunity cost lost in terms of

loss of cultivated agricultural land.

• Furthest from adjacent residents

(greatest buffer), potentially less

nuisance impacts.

• Highest cost to implement due to

excavation in rock required.

• Being located on a “koppie” would have a

high visual impact on the cultural

landscape.

• Unacceptable high botanical impact.

Option 2

(Preferred)

Option 2 (the preferred alternative): WWTW to be located in a mostly disturbed area, where

Parmalat historically stored effluent.



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1.

• This option has the lowest overall

visual impact as it is shielded from

view from Bonnievale Winery located

behind a contour.



disturbed areas.

• Low freshwater impacts due to low

ecological significance of the

stormwater drainage channel /

Ecological Support Area.

• Acceptable buffer from Uitsig

community residents (approximately

300m) and Bonnievale Winery


• Access road and pipeline route length

make the cost higher than Option 3.

• Small amount of cultivated agricultural land

lost but insignificant.

Option 3

Option 3: WWTW to be located in a mostly disturbed area, where Parmalat historically stored

effluent, further south from Option 2.



1. This option would in fact be the

lowest overall cost to build.



disturbed areas.

• Marginally lower impact to freshwater

environment as less construction is

proposed within a stormwater

drainage channel / Ecological Support

Area.

• This option would have a high visual

impact to Bonnievale Winery and R317

users.

• Buffer from Bonnievale Winery is <500m


• Small amount of cultivated agricultural

land lost but insignificant.

WWTW

Biological

Treatment

Technology

Alternatives:

Option A: The

Proposed

WWTW

Option A: Aerobic Wastewater Treatment

Option A1: Conventional Activated Sludge (“CAS”)

Option A2: Movable Membrane Bioreactor (“MBBR”)

Option A3: Membrane Bio-reactor (“MBR”)

Option A2 was considered but disregarded as unfeasible and unreasonable based on bad

experiences by the holding company of Parmalat SA (Lactalis) elsewhere in the world.

Option A1, “CAS”, is the most commonly used in approximately 250 Lactalis Dairy farms around the

world. (Note: Lactalis is the holding company of Parmalat). “CAS” is flexible, robust and cost-

effective. Operational and maintenance costs are expected to be lower than the other two options

investigated. The draw back of this technology is that it produces significantly more sludge waste

than the other technology types and could be associated with odours if the plants operations and the

sludge storage process is not managed correctly.

Option A2, “MBBR”, produces less sludge than CAS but not as little as the MBR, which produces

significantly less sludge than CAS. The advantage is that spare parts are cheaper and long lasting,

so operational expenses are lower than with MBR (Membrane Bio Reactor) but not as low as the

CAS technology.

Option A3, “MBR”, was intensively investigated by Parmalat. They visited dairy factories in East

London and in Ladismith as well as in a Municipal works in Stellenbosch to view this treatment system.

This technology however is associated with high costs, both capital and operating expenditure,

(CAPEX and OPEX), mainly due to membrane installation and replacement and high energy demand.

The MBR process is extremely sensitive, is unable to deal with overloading and has very high

operation and maintenance costs. This treatment technology was therefore disregarded (unfeasible

and unreasonable) due to the high operational costs associated with this design.

Option A1, Aerobic Conventional Activated Sludge, is therefore the only WWTW Treatment

Technology that is feasible and reasonable for this site based on influent and effluent considerations,

operational / maintenance considerations and cost considerations. Other technologies were

considered and investigated but found to be unfeasible. The difference in costs to build and costs to

operate are in the order of millions of Rands and therefore CAS is the only feasible and reasonable

option. It is a flexible and robust system that works well for dairy industries around the world.


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Option B:

Option B: Anaerobic Wastewater Treatment

This option was considered but disregarded due to the following reasons:

• “COD” (Chemical Oxygen Demand) of the Parmalat Bonnievale plant is too low to support this

treatment option, therefore its unfeasible.

• Lactalis, the holding company of Parmalat SA, have extensive international experience of these

type of plants, mostly negative. They are converting these type of plants elsewhere in the world

to aerobic design.

No further treatment technology alternatives have therefore been comparatively been assessed as

the proposed treatment technology (Aerobic “CAS” technology) is deemed to be the best practical

option.

No-Go

Option

Option 4

Status Quo remains. Not preferred but assessed as Option 4.

Should the status quo remain and the WWTW not be constructed, significant socio-economic

impacts are likely to occur as a result of significant job losses at the Parmalat factory due to

downscaling that would be required and decrease in production. Should the status quo

remain, there is a significantly high risk of water pollution (detrimental) should the effluent

dam banks burst and should additional untreated effluent be discharged into the Breede River.

The status quo is also associated with groundwater, soil, air quality (odours) and nuisance

impacts that are currently occurring and would continue to occur should the WWTW not be

constructed as a result of the current poor quality of effluent being irrigated.

(i) Provide a detailed motivation for not further considering the alternatives that were found not feasible and reasonable,

including a description and proof of the investigation of those alternatives:

Option B, Anaerobic Wastewater Treatment was not considered further (found to be unfeasible) due to the

following reasons:

• “COD” (Chemical Oxygen Demand) of the Parmalat Bonnievale plant is too low to support this treatment

option, therefore its unfeasible.

• Lactalis, the holding company of Parmalat SA, have extensive international experience of these type of

plants, mostly negative. Lactalis are converting their anaerobic plants elsewhere in the world to aerobic

design.

Option A2, Movable Membrane Bioreactor (“MBBR”) and Option A3 (“MBR”) was not considered further

(found to be unfeasible and unreasonable) du to the following reasons:

• Technology is associated with high costs, both capital and operating expenditure, (CAPEX and

OPEX), mainly due to membrane installation and replacement and high energy demand.

• The MBR process is extremely sensitive, is unable to deal with overloading and has very high

operation and maintenance costs.

• This treatment technology was therefore disregarded (unfeasible and unreasonable) due to the high

operational costs associated with this design and operation.

• This technology has a higher risk of plant failure which could also result in a higher risk to pollution

of the environment.

• The holding company of Parmalat SA (Lactalis) has hundreds of dairy farms throughout the world.

They have bad experiences with these technologies in terms of operational and maintenance

challenges / costs.

2. PREFERRED ALTERNATIVE

(a) Provide a concluding statement indicating the preferred alternative(s), including preferred location, site, activity and

technology for the development.


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The preferred site location is Option 2. The preferred technology is Option A1: Conventional Activated Sludge

(“CAS”).

The Option 2 site location is a good site as it has been placed an acceptable buffer distance from the sensitive

receptors (300m from Uitsig community and approximately 700m from Bonnievale Winery & adjacent small

holding). This option would therefore not result in an unacceptable visual impact. In addition, it’s in the “trough”

/ “valley” of two adjacent hills further reducing the visual impact. The site location for Option 2 WWTW &

associated infrastructure is in an area that used to be an effluent dam site historically and has been mostly

disturbed / transformed already. The WWTW is needed and desired at this location because it will have a low

impact to aquatic and terrestrial biodiversity, low visual impact, low nuisance impact (odours) and overall low

environmental impact given the proposed location and buffer area from sensitive receptors.

The CAS technology is the preferred technology and the only feasible and reasonable option. CAS is the

most commonly used in approximately 250 Lactalis Dairy farms around the world. CAS is flexible, robust and

cost-effective. Operational and maintenance costs are expected to be lower than the other two options

investigated. This technology is the only reasonable and feasible option due to influent and effluent

considerations, operational / maintenance considerations and cost considerations. The difference in costs to

build and costs to operate are in the order of millions of rand and therefore CAS is the only feasible and

reasonable option. It is a flexible and robust system that works well for dairy industries around the world.


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SECTION F: ENVIRONMENTAL ASPECTS ASSOCIATED WITH THE ALTERNATIVES Note: The information in this section must be DUPLICATED for all the feasible and reasonable ALTERNATIVES.

1. DESCRIBE THE ENVIRONMENTAL ASPECTS ASSOCIATED WITH THE PROPOSED DEVELOPMENT AND ITS

ALTERNATIVES, FOCUSING ON THE FOLLOWING:

(a) Geographical, geological and physical aspects:

As a result of the geographical location of the site the following environmental aspects / impacts are

associated with the development proposal (not including botanical and freshwater ecological impacts):

Construction Phase:

• Soil & Groundwater Contamination: Associated with poor waste management activities, fuel spills

and /or cement batching during construction activities

• Air Quality Impacts: Dust: Dust levels may increase as a result of construction phase traffic and

activities, including earth moving activities to excavate trenches.

• Noise Impacts: Noise impacts may result due to construction activities & machinery on the site.

Excavations and associated earth-moving activities may generate noise and vibration which may

pose a nuisance to surrounding residents and other land users. Movement of heavy vehicles to &

from the site may generate noise, which may affect surrounding residents.

• Traffic & Safety: It is proposed to deliver materials and equipment to the site during the construction

phase of the development. Vehicles may impact on road safety conditions on the R317 due to an

increase in construction phase vehicles entering and exiting the site and they may impact on the

condition of the existing road network.

• Visual Impacts – existing cultural landscape: The construction phase is associated with temporary

disturbance as a result of construction (trench excavations, vehicles, machinery, fencing & signage)

that may have a negative visual impact to the area’s “sense of place” and sensitive receptors for a

temporary duration.

• Socio-economic – Creation of employment and income opportunities (positive impact):

Temporary employment opportunities will be provided during the construction phase to those residing

in the geographical area.

Operation Phase:

• Air Quality Impacts: Odours / Nuisances associated with a WWTW facility and the waste sludge

storage.

• Visual Impact: Associated with built infrastructure impacting on the sense of place / cultural

landscape of the area.

• Soil & Groundwater Contamination: Leakage of the WWTW, emergency detention dam and

pipelines.

• Soil & Groundwater Contamination: Over irrigation of poor water quality on the irrigation area.

• Socio-economic – Creation of employment and income opportunities (positive impact):

Permanent employment opportunities will be provided during the construction phase to those residing

in the geographical area.


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• Noise Impacts: Pumps, compressors (DAF and industrial water), sludge dewatering equipment will

create localised noise.

(b) Ecological aspects:

Will the proposed development and its alternatives have an impact on CBAs or ESAs?

If yes, please explain:

Also include a description of how the proposed development will influence the quantitative values

(hectares/percentage) of the categories on the CBA/ESA map.

YES NO

The proposed development will not influence the quantitative values of the categories on the CBA/ ESA map.

Option 1 (both WWTW and pipeline) is located in Critical Biodiversity Area 1 (CBA1) and to a very small

extent in an Ecological Support Area 2 (ESA2). The data collected in the botanical survey supports this

classification and mapping.

Option 2, the proposed and preferred option, would largely not be in CBA1 or ESA2 except for a small area

at the entrance road off the R317 where the pipeline and access road is proposed. The WWTW is proposed

within an aquatic ESA area (historic effluent dam).

In the case of Option 3, according to the WCBSP, the WWTW would apparently be located within a CBA1.

The data collected in the botanical survey however does not support this classification and mapping since

the Option 3 WWTW site has been mostly disturbed by an historic effluent dam, similar to Option 2.

The following ecological impacts (botanical and freshwater) have been identified:

Construction Phase:

• Botanical Impacts: Loss / removal of indigenous vegetation to build infrastructure. A small amount

of indigenous vegetation is proposed to be lost at the beginning of the road and for the construction

of the WWTW footprint.

• Freshwater Impacts: Construction of WWTW and pipeline infrastructure in a drainage line &

construction of discharge outlet on the riverbank resulting in water pollution, flow modification,

sedimentation & erosion and aquatic habitat disturbance

Operation Phase:

• Freshwater Impacts: Discharge of treated effluent into the Breede River resulting in sedimentation

& erosion, altered flow regime, decreased water quality and aquatic habitat disturbance.

• Freshwater Impact: Storage of effluent and irrigation of effluent could result in altered flow regimes,

decreased water quality and aquatic habitat disturbance.

• Freshwater Impacts: Operation of the WWTW and associated infrastructure resulting in decreased

water quality & aquatic habitat disturbance.

Bekker (2019) describes the freshwater impacts in more detail to be as follows:

Disturbance/loss of aquatic vegetation and habitat

The disturbance or loss of aquatic vegetation and habitat refers to the direct physical destruction or

disturbance of aquatic habitat caused by vegetation clearing, disturbance of riparian habitat, encroachment

and colonisation of habitat by invasive alien plants.


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Sedimentation and erosion

Sedimentation and erosion refers to the alteration in the physical characteristics of the river as a result of

increased turbidity and sediment deposition, caused by soil erosion and earthworks that are associated with

construction activities, as well as instability and collapse of unstable soils during project operation. These

impacts can result in the deterioration of aquatic ecosystem integrity and a reduction/loss of habitat for aquatic

dependent flora & fauna.

Water Pollution

Water and/or soil pollution cause negative changes in the physical, chemical and biological characteristics of

water resources (i.e. water quality). This can result in possible deterioration in aquatic ecosystem integrity

and a reduction in, or loss of, species of conservation concern (i.e. rare, threatened/endangered species).

Flow Modification

The changes in the quantity, timing and distribution of water inputs and flows within the watercourse. Possible

ecological consequences associated with this impact may include: deterioration in freshwater ecosystem

integrity, reduction/loss of habitat for aquatic dependent flora & fauna, and a reduction in the supply of

ecosystem goods & services. Flow modification, whether due to hardened surfaces or stormwater impacts,

is one of the most significant impacts associated with the development.

Will the proposed development and its alternatives have an impact on terrestrial vegetation, or aquatic

ecosystems (wetlands, estuaries or the coastline)?


YES NO

This has been described above.

Will the proposed development and its alternatives have an impact on any populations of threatened plant

or animal species, and/or on any habitat that may contain a unique signature of plant or animal species?


YES NO

Not if the Option 2 or 3 locations are approved. Option 1 however could impact on threatened plant or animal

species of conservation concern. The botanical assessment found that a few species of conservation

significance was recorded near the Option 1 WWTW site. Mc Donald (2019) states that the hilltop near the

WWTW site for option 1 has a rocky quartzite patch of vegetation where a threatened endemic succulent

species, Brianhuntleya intrusa is located.

Describe the manner in which any other biological aspects will be impacted:

None identified.

Will the proposed development also trigger section 63 of the NEM: ICMA? YES NO


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If yes, describe the following:

(i) the extent to which the applicant has in the past complied with similar authorisations;

(ii) whether coastal public property, the coastal protection zone or coastal access land will be affected, and if so, the

extent to which the proposed development proposal or listed activity is consistent with the purpose for establishing and

protecting those areas;

(iii) the estuarine management plans, coastal management programmes, coastal management lines and coastal

management objectives applicable in the area;

(iv) the likely socio-economic impact if the listed activity is authorised or is not authorised;

(v) the likely impact of coastal environmental processes on the proposed development;

(vi) whether the development proposal or listed activity—

(a) is situated within coastal public property and is inconsistent with the objective of conserving and enhancing coastal

public property for the benefit of current and future generations;

(b) is situated within the coastal protection zone and is inconsistent with the purpose for which a coastal protection zone is

established as set out in section 17 of NEM: ICMA;

(c) is situated within coastal access land and is inconsistent with the purpose for which

coastal access land is designated as set out in section 18 of NEM: ICMA;

(d) is likely to cause irreversible or long-lasting adverse effects to any aspect of the coastal

environment that cannot satisfactorily be mitigated;

(e) is likely to be significantly damaged or prejudiced by dynamic coastal processes;

(f) would substantially prejudice the achievement of any coastal management objective; or

(g) would be contrary to the interests of the whole community;

(vii) whether the very nature of the proposed activity or development requires it to be located within

coastal public property, the coastal protection zone or coastal access land;

(viii) whether the proposed development will provide important services to the public when

using coastal public property, the coastal protection zone, coastal access land or a coastal

protected area; and

(ix) the objects of NEM: ICMA, where applicable.

(c) Social and Economic aspects:

What is the expected capital value of the project on completion? R80 million

What is the expected yearly income or contribution to the economy that will be generated by

or as a result of the project?

R6 million/ annum (normal

operating costs of the WWTP)

Will the project contribute to service infrastructure? YES NO

Is the project a public amenity? YES NO

How many new employment opportunities will be created during the development phase? 100

What is the expected value of the employment opportunities during the development phase? R10 million

What percentage of this will accrue to previously disadvantaged individuals? 90%

How will this be ensured and monitored (please explain):

The construction contracts and work will where possible and economically feasible be allocated to local contractors and subcontractors so that the construction money is spent in the local community.

How many permanent new employment opportunities will be created during the operational

phase of the project?

5 new positions @ R12,000/ month each= R720,000

What is the expected current value of the employment opportunities during the first 10 years? R7.2 million

What percentage of this will accrue to previously disadvantaged individuals? 80%

How will this be ensured and monitored (please explain):

Appointments will be made to previously disadvantage people.

Any other information related to the manner in which the socio-economic aspects will be impacted:

The Parmalat factory is major employer in this area with approximately 1 000+ people directly and indirectly dependent on the business. The construction of the WWTP will allow the factory to continue business. The cleaned water from this WWTP will be used to continue farming on the existing farms which will enhance economic activity in the region. This WWTP will require regular maintenance and this be done by small local contractors in the region.


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(d) Heritage and Cultural aspects:

The following heritage / cultural impacts have been identified:

Construction Phase:

• Archaeological / Paleontological Impacts: Loss of Fossils during the construction phase as a result

of the construction of the WWTW foundation and pipeline trench excavations.

• Visual Impacts – existing cultural landscape: The construction phase is associated with temporary

disturbance as a result of construction (trench excavations, vehicles, machinery, fencing & signage)

that may have a negative visual impact to the area’s “sense of place” and sensitive receptors for a

temporary duration.

Operational Phase:

• Visual Impact: Associated with built infrastructure impacting on the sense of place / cultural

landscape of the area and to sensitive receptors that can see the WWTW.

2. WASTE AND EMISSIONS

(a) Waste (including effluent) management

Will the development proposal produce waste (including rubble) during the development phase? YES NO

If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and

estimated quantity per type? Unknown m3

Standard construction waste (rubble & domestic waste and a small amount of hazardous

waste) will be generated during the construction phase, e.g. hardened excess concrete,

cement packets, broken bricks and tiles, paint cans, waste rags / oil, sealant and adhesive

cans, carpeting offcuts, steel offcuts; etc. The quantity is unknown but is expected to be

small amounts.

Builders rubble, domestic waste and hazardous waste storage areas will be separate. The

building contractors will dispose of the waste at the local landfill site.

Will the development proposal produce waste during its operational phase? YES NO


estimated quantity per type?

Sludge: Approximately

1.1ton per day

General domestic waste (packaging, etc.) and some office waste will be produced.

Sludge waste will be produced daily. The primary and secondary sludges produced shall be

dewatered in decanter centrifuges. The primary sludge shall be dewatered to approximately

20% dry solids and the secondary sludge to approximately 16% dry solids. It is estimated

that approximately 5 550kg per day of dewatered primary sludge will be produced and

approximately 6 300kg per day of dewatered secondary sludge will be produced.

The sludge solids shall be collected in skips at the WWTW. The material shall be used for

animal fodder (primary sludge only), fertiliser or it shall be routed to municipal landfill for

disposal.


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Will the development proposal require waste to be treated / disposed of on site? YES NO


estimated quantity per type per phase of the proposed development to be treated/disposed of?

2000m3 per day of effluent

The proposed development itself is a waste treatment facility. Effluent is therefore proposed

to be treated at the development, up to a maximum of 2 000m3 per day.

If no, where and how will the waste be treated / disposed of? Please explain.

Indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated

quantity per type per phase of the proposed development to be treated/disposed of?

m3

Builders rubble, domestic waste and hazardous waste storage areas will be separate. The

building contractors will dispose of the waste at the local landfill site.

The sludge solids shall be collected in skips at the WWTW. The material shall be used for

animal fodder (primary sludge only), fertiliser or it shall be routed to municipal landfill for

disposal. Another option currently being investigated is for the sludge waste to be re-used

at Distell’s anaerobic WWTP in Worcester. Because of the seasonality of Distell’s business,

they may require the sludge waste produced at Parmalat’s WTP to sustain their plant during

low season. This option is still being investigated.

Liquid wastewater, treated to General Limit Standards, will be disposed to land (45ha

irrigation area) and to the Breede River (maximum of 2 000m3 per day but discharge to the

river will only take place when irrigation is not possible or required).

Has the municipality or relevant authority confirmed that sufficient capacity exists for treating / disposing

of the waste to be generated by the development proposal?

If yes, provide written confirmation from the municipality or relevant authority.

YES NO

Will the development proposal produce waste that will be treated and/or disposed of at another facility

other than into a municipal waste stream? YES NO

If yes, has this facility confirmed that sufficient capacity exists for treating / disposing of the waste to be

generated by the development proposal?

Provide written confirmation from the facility.

YES NO

Does the facility have an operating license? (If yes, please attach a copy of the licence.) YES NO

Facility name: Distell WWTW and the Bonnievale Landfill site

Contact person:

Cell: Postal address:

Telephone: Postal code:

Fax: E-mail:

Describe the measures that will be taken to reduce, reuse or recycle waste:

Investigations are currently underway to find alternative uses for the sludge to avoid disposal to the municipal

landfill site. More information in this regard will be provided in the Draft BAR (next version of the BAR Report).

This is a water scarce region, therefore, instead of discharging waste effluent to the river, when possible the

effluent wastewater will be irrigated (re-use of effluent for farmers benefit as the cattle feed on the kikuyu

grass).

(b) Emissions into the atmosphere

Will the development proposal produce emissions that will be released into the atmosphere? YES NO

If yes, does this require approval in terms of relevant legislation? YES NO

If yes, what is the approximate volume(s) of emissions released into the atmosphere? m3

Describe the emissions in terms of type and concentration and how these will be avoided/managed/treated/mitigated:


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During the construction phase, dust emissions may result from the disturbance of soil, excavations, traffic on

dusty roads etc.

During the operational phase odour emissions may result from the storage of the removed fat from the DAF,

buffer tank and sludge tank / storage skips. To reduce odours sludge will be stored in an agitated tank to

prevent gas storage. In the buffer tank there will be aeration on the buffer pool to reduce odour nuisance.

Odours are not expected to impact on sensitive receptors given the buffer area to the nearest residents.

Odours will therefore be localised at the plant and managed to be avoided / reduced.

3. WATER USE

(a) Indicate the source(s) of water for the development proposal by highlighting the appropriate box(es).

Municipal Water board Groundwater River, Stream,

Dam or Lake Other

The project will

not use water

Note: Provide proof of assurance of water supply (e.g. Letter of confirmation from the municipality / water user associations,

yield of borehole)

(b) If water is to be extracted from a groundwater source, river, stream, dam, lake or any

other natural feature, please indicate the volume that will be extracted per month: N/A m3

(c) Does the development proposal require a water use permit / license from DWS? YES NO

If yes, please submit the necessary application to the DWS and attach proof thereof to this application as an Appendix.

(d) Describe the measures that will be taken to reduce water demand, and measures to reuse or recycle water:

This is a water scarce region, therefore, instead of discharging waste effluent to the river, when possible the

effluent wastewater will be irrigated (re-use of effluent for farmers benefit as the cattle feed on the kikuyu

grass).

Ultrafiltration and Reverse Osmosis will be required to treat the effluent to a quality whereby it can be re-used

in the Parmalat factory. These additional treatment measures are not at this stage proposed to be installed

at the WWTW facility but could be installed within the same development footprint area in the future (without

an EIA), when funds are available.

4. POWER SUPPLY

(a) Describe the source of power e.g. municipality / Eskom / renewable energy source.

Power will be supplied form the Langeberg Municipality

(b) If power supply is not available, where will power be sourced?

A 1000Kva standby diesel generator will be installed at the WWTP.

5. ENERGY EFFICIENCY

(a) Describe the design measures, if any, that have been taken to ensure that the development proposal will be energy

efficient:


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The following energy efficient designs will be incorporated:

• Maximum use of gravity to let effluent flow naturally from high too low to the various treatment

sections.

• Maximum use of VSD ( “variable speed drives” ) to reduce energy usage.

• LED lighting.

• Oversized piping systems to reduce friction losses.

(b) Describe how alternative energy sources have been taken into account or been built into the design of the project, if

any:

None.

6. TRANSPORT, TRAFFIC AND ACCESS

Describe the impacts in terms of transport, traffic and access.

Minor construction phase impacts could take place as a result of the delivery of construction materials to

the site.

The operational phase of the WWTW is not associated with traffic impacts.

7. NUISANCE FACTOR (NOISE, ODOUR, etc.)

Describe the potential nuisance factor or impacts in terms of noise and odours.

The potential nuisance factors are:

• Noise: Pumps, compressors (DAF and industrial water), sludge dewatering;

• Odours: Removed fat from the DAF, buffer tank, sludge tank;

This has been described above under air emissions because odour is regarded as an air quality / emissions

impact.

Note: Include impacts that the surrounding environment will have on the proposed development.

8. OTHER

None.


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SECTION G: IMPACT ASSESSMENT, IMPACT AVOIDANCE, MANAGEMENT, MITIGATION

AND MONITORING MEASURES

1. METHODOLOGY USED IN DETERMINING AND RANKING ENVIRONMENTAL IMPACTS AND RISKS

ASSOCIATED WITH THE ALTERNATIVES

(a) Describe the methodology used in determining and ranking the nature, significance consequences, extent, duration and

probability of potential environmental impacts and risks associated with the proposed development and alternatives.

The Basic Assessment was undertaken in accordance with the principles of Integrated Environmental

Management as detailed in Section 23 of NEMA and in the NEMA EIA Regulations.

The impact assessment is aimed at determining the likely significance of any impacts (positive or negative)

associated with the development. The significance of the impacts is determined by investigating certain key

aspects, or parameters, of the potential impact, which are determined by the nature of the activity, as well as

the nature of the receiving environment. Aspects investigated include the extent, duration and timing,

probability of the impact occurring and magnitude of the impact.

The impact assessment methodology used has been closely guided by the DEAT EIA Guideline Document

5, on the assessment of impacts and alternatives (DEAT 2006); as well as reference to the description of the

criteria used for the assessment of impacts as contained in the DEA&DP Specialist Guidelines Series (2005).

Table 5: Methodology in determining the extent, duration, probability, significance, reversibility and

cumulative impact of an environmental impact (to be read with impact tables below).

Determination of Extent (Scale):

Site Specific The impact is limited to the development site (development footprint) or part

thereof.

Local The impacted area includes the whole or a measurable portion of the site, but

could affect the area surrounding the development, including the neighbouring

properties and wider municipal area.

Regional The impact would affect the broader region (e.g. neighbouring towns) beyond

the boundaries of the adjacent properties.

National The impact would affect the whole country (if applicable).

Determination of Duration:

Temporary The impact will be limited to part of the construction phase or less than one

month.

Short term The impact will continue for the duration of the construction phase, or less than

one year.

Medium term The impact will continue for part the operational phase

Long term

The impact will continue for the entire operational lifetime of the development

but will be mitigated by direct human action or by natural processes thereafter.

Permanent This is the only class of impact that will be non-transitory. Such impacts are

regarded to be irreversible, irrespective of what mitigation is applied.


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Determination of Probability:

Improbable The possibility of the impact occurring is very low, due either to the

circumstances, design or experience.

Probable There is a possibility that the impact will occur to the extent that provisions must

therefore be made.

Highly

probable

It is most likely that the impacts will occur at some stage of the development.

Plans must be drawn up to mitigate the activity before the activity commences.

Definite The impact will take place regardless of any prevention plans.

Determination of Significance (without mitigation):

No

significance

The impact is not substantial and does not require any mitigation action.

Low The impact is of little importance but may require limited mitigation.

Medium

The impact is of sufficient importance and is therefore considered to have a

negative impact. Mitigation is required to reduce the negative impacts to

acceptable levels.

Medium-High The impact is of high importance and is therefore considered to have a negative

impact. Mitigation is required to manage the negative impacts to acceptable

levels.

High

The impact is of great importance. Failure to mitigate, with the objective of

reducing the impact to acceptable levels, could render the entire development

option or entire project proposal unacceptable. Mitigation is therefore essential.

Very High The impact is critical. Mitigation measures cannot reduce the impact to

acceptable levels. As such the impact renders the proposal unacceptable.

Determination of Significance (with mitigation):

No

significance

The impact will be mitigated to the point where it is regarded to be insubstantial.

Low The impact will be mitigated to the point where it is of limited importance.

Medium Notwithstanding the successful implementation of the mitigation measures, the

impact will remain of significance. However, taken within the overall context of

the project, such a persistent impact does not constitute a fatal flaw.

High Mitigation of the impact is not possible on a cost-effective basis. The impact

continues to be of great importance, and, taken within the overall context of the

project, is considered to be a fatal flaw in the project proposal.

Determination of Reversibility:

Completely

Reversible

The impact is reversible with implementation of minor mitigation measures

Partly Reversible The impact is partly reversible but more intense mitigation measures

Barely Reversible The impact is unlikely to be reversed even with intense mitigation measures


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Irreversible The impact is irreversible and no mitigation measures exist

Determination of Degree to which an Impact can be Mitigated:

Can be mitigated The impact can be completely mitigated

Can be partly

mitigated The impact can be partly mitigated

Can be barely

mitigated It is possible to mitigate the impact only slightly

Not able to mitigate It is not possible to mitigate the impacts

Determination of Loss of Resources:

No loss of resource The impact will not result in the loss of any resources

Marginal loss of

resource

The impact will result in marginal loss of resources

Significant loss of

resources

The impact will result in significant loss of resources

Complete loss of

resources

The impact will result in a complete loss of all resources

Determination of Cumulative Impact:

Negligible The impact would result in negligible to no cumulative effects

Low The impact would result in insignificant cumulative effects

Medium The impact would result in minor cumulative effects

High The impact would result in significant cumulative effects

Other factors which are also considered in the assessment of impacts include whether the impact is direct,

indirect or cumulative. A direct impact can be explained as being a direct result of activities associated with

the development, such as damage of on-site infrastructure due to a fire.

An indirect impact would be a downstream, secondary or “knock-on” impact resulting from an impact directly

associated with the development (such as aquatic habitat impacts as a result of water pollution).

A cumulative impact would be an impact which already occurs in the receiving environment associated with

other activities taking place in proximity to the development, such as the existing freshwater impacts (water

pollution, flow modification, aquatic habitat) occurring in the area.

Other factors considered include whether the impact is reversible; and whether the impact could cause an

irreplaceable loss of resources.

The assessment of the potential impacts has been based on SEC’s extensive experience related to

environmental impact assessment as well as specialist assessment and input, where applicable.

The impact assessment will also be informed by input and comment from stakeholders once public

participation is undertaken. The potential impacts have been assessed after review by the professional team,

including specialists where required, and on the basis of professional judgement.


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It must be noted that determining the significance of impacts, although carefully and systematically

considered, still remains a subjective judgement, as there are no truly objective measures that can be used

to judge significance.

Practicable mitigation measures (where warranted) have been identified to minimize the potential impacts

associated with proposed upgrade. The significance of any potential impact before and after mitigation is also

provided to give an indication of the effectiveness of the proposed mitigation measures.

(b) Please describe any gaps in knowledge.

The gaps in knowledge at the time of compiling this report are as follows:

• No conceptual or detailed design of the discharge outlet structure is available. Only the point of

discharge has been provided.

• No detailed design of the emergency detention pond is available. A Concept Design showing the

footprint and volume has however been provided.

• No stormwater management plan is yet available for the WWTW, associated infrastructure,

emergency detention pond, effluent storage area, irrigation areas.

• Specific details on where the sludge is proposed to be disposed, re-use options and location of the

sludge storage area was at the time of compiling this report not yet available. Investigations are

currently underway.

(c) Please describe the underlying assumptions.

The following assumptions have been made:

• Analysis results of the sludge was not available at the time of compiling this report as sludge has not

yet been produced. It has however been assumed that based on analysis from sludge at similar

facilities, the sludge is assumed to also be non-hazardous.

• The location of the proposed WWTW, emergency effluent detention dam and effluent discharge point

/ discharge structure and associated road and pipeline infrastructure is a conceptual design that has

been based on geotechnical and civil engineering input. It is therefore assumed to be reasonably

accurate despite the fact that the detailed civil engineering design phase has not yet been

undertaken. The exact co-ordinates of the route of the pipeline and road is therefore uncertain but

has at this stage been reasonably accurately estimated.

(d) Please describe the uncertainties.

None.

(e) Describe adequacy of the assessment methods used.

The assessment methods used include criteria as set out in legislation and accompanying guidelines with

particular reference to the Basic Assessment Report, as well as methodology employed by the specialist who

is bound by laws and requirements of their profession. Standard methods and procedures were employed to

provide the information as set out in this document and are deemed as adequate to the proposed activity.

The following methods were employed to assess the impact:

• Site visits to the affected areas were undertaken to determine the nature and sensitivity of the site, as

well as to gain insight into the status quo of activities and surrounding land-uses.

• A Freshwater Impact Assessment was undertaken by Sharples Environmental Services (SEC).

• A Botanical Impact Assessment was undertaken by Bergwind Botanical Surveys.

• A Geohydrological Assessment was undertaken by GEOSS.


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• A Desktop Paleontological Assessment was undertaken by John Almond.

• A Heritage Survey and site inspection was undertaken by Jason Orton from ASHA Consulting.

• A Geotechnical Assessment was undertaken by JG Afrika.

• The applicable legislation, guidelines and policies were considered.

• Discussions were held with the client, authorities, specialists and the farmer who owns the irrigation area.

The specialist assessments informed the findings of this EIA. Given the above, it is deemed that sufficient

information has been obtained and included to meet the requirements of the 2014 EIA Regulations and that

the impacts of the site have been adequately assessed and reported on.

2. IDENTIFICATION, ASSESSMENT AND RANKING OF IMPACTS TO REACH THE PROPOSED ALTERNATIVES

INCLUDING THE PREFERRED ALTERNATIVE WITHIN THE SITE

Note: In this section the focus is on the identified issues, impacts and risks that influenced the identification of the alternatives.

This includes how aspects of the receiving environment have influenced the selection.

(a) List the identified impacts and risks for each alternative.

Option 1: The three site location alternatives all have the following impacts:

Construction Phase Impacts:

• Air Quality Impacts: Dust associated with construction & traffic.

• Visual Impact to Cultural Landscape: As a result of temporary construction

activities.

• Archaeological / Paleontological Impact: Loss of fossils due to construction

excavations / trenching.

• Botanical Impacts: Loss of indigenous vegetation in development footprint.

• Freshwater Impacts: Construction of WWTW and pipeline infrastructure in a

watercourse & construction of discharge outlet on riverbank resulting in water

pollution, flow modification, sedimentation & erosion and aquatic habitat

disturbance.

• Noise Impacts: Associated with construction machinery & traffic.

• Traffic and Safety Impacts: Associated with delivery of construction materials.

• Soil & Groundwater Contamination: Associated with poor waste management

activities, fuel spills, effluent spills and /or cement batching during construction

activities.

• Socio-economic: Creation of temporary jobs.

Operational Phase Impacts:

• Air Quality Impacts: Odours associated with a WWTW facility and sludge

handling.

• Noise Impacts: Pumps, compressors (DAF and industrial water), sludge

dewatering equipment

• Freshwater Impacts: Discharge of treated effluent into Breede river resulting in

sedimentation & erosion, altered flow regime, decreased water quality and aquatic

habitat disturbance.

• Freshwater Impacts: Operation of the WWTW and associated infrastructure

resulting in decreased water quality & aquatic habitat disturbance.

• Visual Impact: Associated with built infrastructure impacting on the sense of

place of the area

• Soil & Groundwater Contamination: Leakage of the WWTW, emergency

detention dam and pipelines.

• Socio-economic: Creation of permanent jobs.

Option 2:

Option 3:


143

No-go Alternative:

Because of the fact that the NO-GO Alternative assumes the status quo, which assumes

the continued effluent management activities, the following impacts are expected to occur

if the proposed WWTW is not authorised (the existing impacts will continue and become

worse).

• Soil & Groundwater Contamination: Over irrigation of poor water quality (status

quo)

• Air Quality: Continued irrigation of poor quality effluent resulting in odours and

nuisance indirect impacts.

• Freshwater Impacts: Continued discharge of untreated effluent into Breede river

resulting in sedimentation & erosion, altered flow regime, decreased water quality

and aquatic habitat disturbance. Risk of additional discharge and dam banks

bursting.

(b) Describe the impacts and risks identified for each alternative, including the nature, significance, consequence, extent,

duration and probability of the impacts, including the degree to which these impacts can be reversed; may cause

irreplaceable loss of resources; and can be avoided, managed or mitigated.

The following table serves as a guide for summarising each alternative. The table should be repeated for each alternative

to ensure a comparative assessment. (The EAP has to select the relevant impacts identified in blue in the table below for

each alternative and repeat the table for each impact and risk).


Planning, Design & Construction Phase

1. Air Quality Impacts

Option 1: Option 2: Option 3: Option 4: NO – GO

(Status Quo Remains)

Description of Impact: Dust associated with construction activities & construction generated traffic. The Uitsig community are

located adjacent to the proposed access to option 1 & 2.

N/A

Nature of impact: Negative N/A

Extent and duration of impact: Local Extent; Short Term Duration N/A

Probability of occurrence: Probable N/A

Degree to which the impact can be

reversed: Irreversible N/A

Degree to which the impact may

cause irreplaceable loss of

resources:

No loss of resources N/A

Cumulative impact prior to

mitigation: Negligible N/A

Indirect Impact None N/A

Residual Impacts None N/A

Significance rating of impact prior

to mitigation Low-Medium Low-Medium Low N/A


mitigated: Can be mitigated N/A

Proposed mitigation:

1. If dust issues occur, dust can be suppressed on access roads and the construction site during dry periods by the regular

application of non- potable water or a biodegradable soil stabilisation agent.

2. All vehicles transporting sand need to have tarpaulins covering their loads which will assist in any windblown sand occurring off

the trucks.

3. Low speed limits are to be implemented when transporting materials to the site to reduce dust generation.

4. Parmalat SA must comply with the National Dust Control Regulations (GN No. R. 827 of 1 November 2013), promulgated in terms

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

5. A Complaints Register must be available at the site office for inspection by the ECO of dust complaints that may have been

received.


2. Visual Impact

6. The appointed ECO must undertake regular site inspections for the duration of the construction phase, and to produce regular

ECO monitoring audit reports, auditing on the compliance of Parmalat SA with the conditions of the EA and the approved EMP in

terms of dust management.

Cumulative impact post mitigation: Negligible N/A

Significance rating of impact after

mitigation Low (-) Low (-) Low (-) N/A



Description of Impact: Temporary construction activities may cause a visual impact to sensitive receptors due to earth

moving activities, construction traffic, materials storage, construction site camp etc.

N/A








resources:







to mitigation Medium Low - Medium Medium N/A




1. Consult with the ECO when determining the appropriate site for the site camp.

2. The site camp must be kept neat and tidy and free of litter at all times.

3. Waste must be managed according to the EMP and the mitigation measures listed below in terms of waste management. Good

housekeeping practices on site must be maintained to ensure the site is kept neat and tidy.


3. Archaeological / Paleontological Impact

4. The site camp, storage facilities, stockpiles, waste bins, and any other temporary structures on site should be located in such a

way that they will present as little visual impact to surrounding residents and road users as possible.

5. The site camp may require visual screening via shade cloth or other suitable material.

6. Construction vehicles must enter and leave the site during working hours.

7. The appointed ECO must undertake regular site inspections for the duration of the construction phase, and to produce short ECO

monitoring audit reports, auditing on the compliance of Parmalat SA with the conditions of the EA and the approved EMP.



mitigation Low Medium (-) Low (-) Low Medium (-) N/A



Description of Impact: Fossils and / or archaeological material may be damaged or lost as a direct result of excavations and

trenching during the construction phase.

N/A


Extent and duration of impact: Site Specific Extent; Permanent Duration N/A

Probability of occurrence: Improbable N/A





resources:

Marginal loss of resources N/A


mitigation: None N/A




to mitigation Medium Low Low N/A




4. Botanical Impacts


1. A fossil chance finds procedure, as described below, (ECO response protocol) must be incorporated into the EMPr for the project

and, as such, no further significant impacts are expected.

a. Once alerted to fossil occurrence(s): alert site foreman, stop work in area immediately (N.B. safety first!), safeguard site

with security tape / fence / sandbags if necessary.

b. Record key data while fossil remains are still in situ:

i. Accurate geographic location – describe and mark on site map / 1: 50 000 map / satellite image / aerial photo;

ii. Context – describe position of fossils within stratigraphy (rock layering), depth below surface;

iii. Photograph fossil(s) in situ with scale, from different angles, including images showing context (e.g. rock

layering);

2. If feasible to leave fossils in situ:

a. Alert Heritage Resources Authority and project palaeontologist (if any) who will advise on any necessary mitigation;

b. Ensure fossil site remains safeguarded until clearance is given by the Heritage Resources Authority for work to resume;

3. If not feasible to leave fossils in situ (emergency procedure only):

a. Carefully remove fossils, as far as possible still enclosed within the original sedimentary matrix (e.g. entire block of

fossiliferous rock);

b. Photograph fossils against a plain, level background, with scale;

c. Carefully wrap fossils in several layers of newspaper / tissue paper / plastic bags;

d. Safeguard fossils together with locality and collection data (including collector and date) in a box in a safe place for

examination by a palaeontologist;

e. Alert Heritage Resources Authority and project palaeontologist (if any) who will advise on any necessary mitigation;



mitigation Low - Medium (-) Low (-) Low (-) N/A



Description of Impact: Loss of indigenous vegetation when land clearing, excavations of trenches and construction of the

WWTW footprint.

N/A


Extent and duration of impact: Site Specific Extent; Permanent Duration N/A


Probability of occurrence: Definite N/A


reversed: Partly reversible N/A



resources:

Significant loss of resource Marginal loss of resource Marginal loss of resource N/A



Indirect Impact Loss of vegetation is associated with indirect impacts such as loss of fauna and erosion. N/A

Residual Impacts Loss of vegetation for the route of the pipeline could result in increased surface runoff & erosion. N/A


to mitigation Medium Low - Medium Medium N/A




1. The site proposed for Option 1 is highly sensitive (high negative impact after mitigation) from a botanical perspective and it should

be rejected as a possible development site.

2. A small amount (approximately 600m2) of undisturbed Renosterveld is located in the vicinity of the access road where it starts

near the R317. The pipeline should be re-aligned as to avoid disturbing this intact vegetation.

3. Natural vegetation should be restored along the pipeline route after construction.

4. NO -GO areas should be clearly demarcated, in consultation with the ECO, prior to construction activities taking place.

5. It will be required to demarcate NO-GO boundaries around the development footprint of the WWTW to avoid damaging / loss of

vegetation. It will also be required to demarcate NO-GO areas near the river when the emergency pond in constructed.

6. The outer boundary of the development area must be surveyed, pegged and fenced off. If deemed necessary by the ECO, the

outer boundary of the working area can be enclosed with orange barrier netting, bonnox fencing, shade netting, droppers or wire/

danger tape, or similar – as feasible and practical. The fencing should be retained and maintained for the duration of the

construction period, and should not be moved during construction unless agreed otherwise with the ECO. The demarcation

boundary should be tight around the footprint of the proposed facilities, typically allowing a working area of no more than 3-5m

around the building/ facility footprint – unless otherwise agreed with the ECO. This demarcation boundary is to ensure that land-

clearing activities are restricted to only that area strictly required for the proposed development, and to prevent unnecessary

disturbance of soil surfaces and vegetation outside of the development footprint.

7. Sensitive areas which must not be disturbed during development must be demarcated as “no-go” areas. The Critical Biodiversity

Areas and Ecological Support Areas surrounding the site and any other sensitive areas identified by the ECO must be regarded

as no-go areas.


5. Freshwater Impacts

8. As part of the environmental awareness training workers on site must be advised that the Breede River is an environmentally

sensitive area that may not be accessed anywhere else except for the proposed construction area within the floodplain under any

circumstances. This instruction must be emphasized and enforced throughout all phases of the development.

9. No-go areas must be protected from disturbance and are off-limits to all construction workers, vehicles and machinery during all

phases of the development. No vegetation may be cleared from within the no – go areas, and no dumping of any material (waste,

topsoil, subsoil etc.) may occur in these areas.



mitigation High (-) Low (-) Low (-) N/A



Description of Impact:

Construction of WWTW and Pipeline Infrastructure in a Watercourse & Construction of Discharge

Outlet on Riverbank Resulting in Water Pollution, Flow Modification, Sedimentation & Erosion and

Aquatic Habitat Disturbance

N/A


Extent and duration of impact: Local Extent; Medium Term Duration N/A






resources:

Marginal loss of resource Marginal loss of resource Marginal loss of resource N/A


mitigation: Medium N/A

Indirect Impact Aquatic habitat disturbance is an indirect impact of water pollution. N/A

Residual Impacts Loss of aquatic habitat. N/A


to mitigation Medium (-) Low – Medium (-) Low – Medium (-) N/A





1. The existing discharge pipe outlet to the river must immediately be decommissioned. It is causing pollution of aquatic habitat; the

proliferation of alien invasive species due to increased nutrients, as well as erosion of the banks. The bank has recently been

cleared and excavated. This must immediately be rehabilitated. It may require recontouring and will definitely require revegetation

with indigenous riparian species. During this work, further erosion and sedimentation must be prevented and the bank stabilised

until vegetation propagates.

2. Stop the existing effluent/ contaminated stormwater/wash bay water from seeping into the river. Better management of wash

water (this should not be passed into the river or its floodplain).

3. Direct discharge of untreated effluent into the river is not permissible.

4. The designers should refer to the effluent discharge standards stipulated by the Department of Water Affairs (DWA) for the specific

area in which the WWTW is to be designed and constructed. The WWTW must be designed to meet the effluent discharge

standards.

5. The wastewater treatment system must be designed to handle peak flow rates and peak levels of contamination. Failure to get

the design right will result in excursions of wastewater quality during peak times.

6. The wastewater pumping stations and treatment plants should be protected against flooding. The treatment process units

(including the emergency pond) should be located at an elevation higher than the 100-year flood level or otherwise be adequately

protected against 100-year flood damage.

7. Emergency power supply for pumping stations and treatment plants is required to prevent overflows from occurring during any

power outage.

8. Provision must be made on site for the emergency retention of at least 72 hours effluent in the event of plant failure / malfunction.

The storage area must be lined and bermed to minimise potential spillage risk into the river and it should be no closer than 50m

from the edge of the river corridor and such that it does not readily connect to the stormwater system.

9. The proposed pipeline should be constructed in already disturbed areas such as where soils and vegetation has already been

completely transformed by past cultivation activities. There should be limited disturbance within the drainage line during the

construction phase.

10. Contaminated runoff from the pipeline installation site should be prevented from directly entering the drainage channel.

11. After construction, the disturbed area should be rehabilitated, particularly to prevent erosion taking place as well as to prevent the

potential colonisation of these areas with invasive alien plants. Rehabilitation requires removal of invasive alien plants from the

riparian zone, some landscaping of the eroded channel, if required, and re-vegetation rather than bare ground in the steeper

areas.

12. The construction camp/laydown area should be located away from the drainage areas and river. All materials should be properly

stored and contained; stockpiles must be located away from freshwater habitat and prevent material from being transported by

wind or rain, into any HGM units. Disposal of waste from the site should also be properly managed. Construction workers should

be given ablution facilities at the construction sites that are located away from the watercourses (at least 20m) and regularly

serviced.


6. Noise Impacts

13. If the location of the road and pipeline infrastructure cannot be moved above the drainage channel (to avoid crossing the natural

stormwater drainage channel), then an appropriate culvert installation needs to be built to cross the non-perennial watercourse

to avoid modifications in flow (impedance / diverting flow) to HGM2 and damage to the road.

14. The new outlet should be located at least 30m from the current river channel.

15. It is recommended that the discharge pipe for the effluent into the river be set back from the river. The treated effluent could be

transferred directly into the channel via a “lay flat discharge pipe”. This approach, or one with similar objectives, will decrease the

impact of the construction of the outlet structure.

16. The discharge pipe outlet design should include erosion control measures, such as for example, reno-mattresses.

17. The discharge should flow into the river in a diffuse pattern.

18. Bare areas should be re-vegetated with indigenous riparian species.

19. The riparian habitat should be rehabilitated and re-stored and the riverbank stabilized from erosion.

Cumulative impact post mitigation: Low N/A






Noise impacts may result due to construction activities and machinery on the site. Excavations and

associated earth-moving activities may generate noise and vibration which may pose a nuisance to

surrounding residents and other land users. Movement of heavy vehicles to and from the site may

generate noise, which may affect surrounding residents.

N/A








resources:





7. Traffic and Safety Impacts




to mitigation Low Low-Medium Low N/A




1. A complaints register will be opened in which noise complaints will be recorded.

2. Excavations and earth-moving activities should be restricted to normal construction working hours (7:30am – 17:30pm).

3. Vehicles and equipment should be kept in good working condition. If deemed necessary, machinery and equipment should be

fitted with mufflers/ exhaust silencers. No unnecessary disturbances should be allowed to emanate from the construction site.

4. The appointed ECO must undertake regular site inspections for the duration of the construction phase, and to produce regular

ECO monitoring audit reports, auditing on the compliance of the Parmalat SA with the conditions of the EA and the approved

EMP.







Materials and equipment will be delivered to the site during the construction phase of the

development. Vehicles may impact on road safety conditions due to an increase in construction phase

vehicles entering and exiting the site and they may impact on the condition of the existing road

network.

N/A


Extent and duration of impact: Site Specific Extent; Short Term Duration N/A






resources:



8. Soil & Groundwater Contamination



Indirect Impact Safety of pedestrians is an indirect impact of construction traffic. N/A



to mitigation Low Low Low N/A




1. The Contractor must ensure that any large or abnormal loads that must be transported to/ from the site are routed appropriately,

and that appropriate safety precautions are taken during transport to prevent road accidents.

2. All vehicles will be legally compliant.

3. All drivers will be competent and in possession of an appropriate valid driver’s license.

4. All vehicles travelling on site will adhere to the specified speed limits.

5. The movement of all vehicles will be controlled such that they remain on designated routes.

6. No member of the workforce will be permitted to drive a vehicle under the influence of alcohol or narcotic substances.







Construction activities will generate waste. In addition, fuel, oil, lubricants and other pollutants may

leak from vehicles/ machinery and contaminate the soil. Pollution and soil contamination could also

occur from chemical toilets, cement mixing directly on the soil and storm water runoff may flow over

the site camp area and carry contaminants off-site.

N/A









resources:



mitigation: Low N/A

Indirect Impact Groundwater contamination is an indirect impact of soil contamination. N/A



to mitigation Low - medium Low - medium Low - medium N/A




1. Incidents that fall within the ambit of section 30(1)(a) of the National Environment Management Act, 1998 (Act No. 107 of 1998)

(“NEMA”) must be dealt with in accordance with the stipulated requirements. In the event of accidental spills; containment and

clean-up must commence immediately. Reporting of any incidents must be directed to the Local Municipality and to Mr. Simon

Botha of the DEA & DP: Pollution and Chemicals Management Directorate [Tel: (021) 483 0752; E-mail:

[email protected] ].

2. All chemicals used or stored on the site must have Material Safety Data Sheets.

3. In the event of a significant spill or leak of hazardous substances, such an incident must be immediately contained and reported

to all relevant authorities within the stipulated timeframe.

4. No “hot works” may take place in fuel storage and refuelling areas.

5. During the construction phase of the development, an experienced contractor will be appointed and it will be ensured that the

correct protocols are followed that relate to the handling of materials, thereby minimising the likelihood of such an incident

occurring.

6. Adequate training of construction personnel will ensure that incidents resulting in product spills are minimised and that the correct

actions are taken in the event of an incident.

7. Parmalat SA is responsible for the documentation of evidence related to all disposed contaminated products, waste or residues

that have been generated during construction.

In addition, the following general management measures will be implemented to avoid contamination of soil and groundwater:

Waste Management:

1. Hazardous waste bins must be kept on an impermeable bunded surface capable of holding at least 110% of the volume of the

bins.

2. Skips/ bins must be provided with secure lids or covering that will prevent scavenging and windblown waste or dust.

3. Waste bins/skips must be regularly emptied and must not be allowed to overflow.



4. Construction workers must be instructed not to litter and to place all waste in the appropriate waste bins provided on site.

5. All waste generated during the construction phase should be separated into the different waste streams (rubble / hazardous /

general) for recycling purposes, prior to removal from the construction site by a reputable contractor to a recycling facility or for

disposal at an appropriately licenced waste disposal facility.

6. All waste generated on site (general and hazardous waste must be disposed of appropriately at a licensed Waste Disposal Facility

(WDF).

Pollution Management – hydrocarbons (oil, fuel etc.)

1. Vehicles and machinery must be in good working order and must be regularly inspected for leaks.

2. If a vehicle or machinery is leaking pollutants it must, as soon as possible, be taken to an appropriate location for repair.

3. Repairs to vehicles/ machinery may take place on site, within a designated maintenance area at the site camp. Drip trays, tarpaulin

or other impermeable layer must be laid down prior to undertaking repairs.

4. Refuelling of vehicles/ machinery may only take place at the site camp or vehicle maintenance yard. Where refuelling must occur,

drip trays should be utilised to catch potential spills/ drips.

5. Drip trays must be utilised during decanting of hazardous substances and when refilling chemical/ fuel storage tanks.

6. Drip trays must be placed under generators (if used on site) water pumps and any other machinery on site that utilises fuel/

lubricant, or where there is risk of leakage/spillage.

7. Soil contaminated by hazardous substances must be excavated and disposed of as hazardous waste.

Pollution Management – Ablution facilities

1. Chemical toilets should be kept at the site camp, on a level surface and secured from blowing over.

2. Toilets must be located well outside of any storm water drainage lines and may not be linked to the storm water drainage system

in any way.

3. Chemical toilets must be regularly emptied and the waste disposed of at an appropriate wastewater disposal/ treatment site. Care

must be taken to prevent spillages when moving or servicing chemical toilets.

Cement Batching:

1. Cement batching must take place on an impermeable surface large enough to retain any slurry or cement water run-off. If

necessary, plastic/ bidim lined detention ponds (or similar) should be constructed to catch the run-off from batching areas. Once

the water content of the cement water/ slurry has evaporated the dried cement should be scraped out of the detention pond and

disposed of at an appropriate disposal facility authorised to deal with such waste

2. Cement batching should take place on already transformed areas within the footprint of the facility.

3. Unused cement bags must be stored in such a way that they will be protected from rain. Empty cement bags must not be left

lying on the ground and must be disposed of in the appropriate waste bin.


9. Socio-economic Benefit

4. Washing of excess cement/concrete into the ground is not allowed. All excess concrete/ cement must be removed from site and

disposed of at an appropriate location.







Approximately 100 temporary employment opportunities will be provided during the construction

phase at a value of approximately R10 million. The capital value of the project upon completion of

construction is approximately R80 million rand. The development provides a benefit to the local

community in terms of job provision.

N/A

Nature of impact: Positive N/A

Extent and duration of impact: Regional Extent; Long Term Duration N/A



reversed: N/A - This is a positive benefit proposed to be enhanced. N/A



resources:

N/A - This is a positive benefit proposed to be enhanced. N/A


mitigation: Medium positive N/A

Indirect Impact N/A - This is a positive benefit proposed to be enhanced. N/A

Residual Impacts N/A - This is a positive benefit proposed to be enhanced. N/A


to mitigation Medium (+) Medium (+) Medium (+) N/A


mitigated: Can be enhanced N/A

Proposed enhancement:

1. Local Contractors as well as local suppliers should be used during the construction phase whenever possible. The tender

documents will require contactors to use local employees and provide some skills development during the construction process.

2. Approximately 90% of the construction labour should be to previously disadvantaged individuals.


Operational Phase

1. Air Quality Impacts

Cumulative impact post

enhancement: Medium positive N/A


mitigation Medium (+) Medium (+) Medium (+) N/A



Description of Impact: Odours associated with a WWTW facility (Option 1 – 3) and storage of sludge

Continued (status quo)

irrigation of poor quality

effluent resulting in odours

Nature of impact: Negative Negative

Extent and duration of impact: Local Extent; Long Term Duration Local Extent; Long Term

Duration

Probability of occurrence: Improbable Definite


reversed: Partly reversible

N/A – The NO-GO assumes

that the status quo remains



resources:

No loss of resources No loss of resources


mitigation: Negligible Negligible

Indirect Impact Foul smelling odours could cause nuisances and pests. Tourism related businesses are located in the area which could be affected

by odours / nuisances to their guests.

Residual Impacts See indirect impacts above.


to mitigation Medium

Medium Medium N/A – The NO-GO assumes



mitigated: Can be mitigated




2. Noise Impacts


1. To reduce odours sludge will be stored in an agitated tank to prevent gas storage. In the buffer

tank there will be aeration on the buffer pool to reduce odour nuisance.

2. Dewatered sludge should be stored in the designated enclosed skips and not stored in uncovered

stockpiles on site.

3. WWTW facilities must be regularly cleaned/ washed down/ disinfected as necessary to control

odours and prevent the proliferation of pests.

4. The Applicant must ensure that the operation of the WWTW does not cause ambient air quality

at the WWTW to become non-compliant with the ambient air quality standards specified by the

National Environmental Management Air Quality Act, or other relevant legislation.

5. A Complaints Register must be kept on site to record odour complaints.

6. If complaints are received during the operational phase during normal working conditions

regarding odours, additional odour control measures must be investigated and implemented.



Cumulative impact post mitigation: Negligible Negligible


mitigation Low (-) Low (-) Low (-) High (-)




Noise impacts may result due to the operation of pumps, compressors (DAF and industrial water) and

the sludge dewatering equipment.

N/A


Extent and duration of impact: Local Extent; Medium Term Duration N/A






resources:





3. Freshwater Impacts – Discharge into the Breede River

Indirect Impact Nuisances N/A



to mitigation Low Low Low N/A




1. Noise generated from the WWTW must comply with the Western Cape Noise Control Regulations, 2013 (Provincial Notice 200

of 20 June 2013).

2. A Complaints Register must be kept on site to record noise complaints, if any.

3. If noise complaints are received during normal operating conditions, additional noise control measures must be investigated and

implemented.






Description of Impact: Discharge of treated effluent into Breede River resulting in sedimentation & erosion, altered flow

regime, decreased water quality and aquatic habitat disturbance

If status quo remains there is

a risk of the dam bursting

resulting in a significant

overflow of untreated effluent

into the river. If the status quo

remains continued untreated

river discharge at the factory

is assumed to take place.


Extent and duration of impact: Regional Extent; Long Term Duration Regional Extent; Long Term

Duration

Probability of occurrence: Highly probable Highly probable


reversed: Irreversible






resources:

Significant loss of resource Significant loss of resources


mitigation: Medium Medium

Indirect Impact Aquatic habitat loss / disturbance is an indirect impact of water pollution /altered flow regime.

Residual Impacts Aquatic habitat loss.


to mitigation High

High High N/A – The NO-GO assumes








• Discharge of treated effluent should only take place when irrigation of the effluent is not possible.

Therefore, during times when irrigation of the full irrigation crop capacity is possible (1500m3 per

day in summer months) then only 500m3 per day should be discharged to the river (assuming

max treatment capacity at the WWTW of 2000m3 per day is reached). When irrigation of the kikuyu

crop is not feasible (waterlogged soils / winter months), a maximum of 2000m3 per day can be

discharged to the river. As soon as irrigation is possible again, the land should be irrigated instead

of discharging to the river.

• The treated effluent to be discharged into the river from the WWTW should at least comply with

the General Limits as required in the General Authorisations for water use.

• The outlet should be inspected daily and after major rainfall, to identify erosion gulley’s / channels

into or towards the river. Where such occur, they should be addressed appropriately to prevent

concentration of flows into the river – if a channel is cut into the river, it must be shaped as a

shallow trench (side slopes 1:5 or less steep), lined with soil-packed reno if necessary, and

planted with stabilising indigenous sedges (e.g. Juncus kraussii or Cyperus textilis) rather than

grasses.

• An Effluent Monitoring Plan must be compiled.



• The following Effluent Monitoring Measures, as recommended by the freshwater specialist, is

proposed to be implemented by Parmalat SA and included in the Effluent Monitoring Plan:




o Effluent will be sampled from the following points and sent for laboratory analysis: COD -

inlet & outlet; TSS - inlet & outlet; Ammonia - inlet & outlet; Nitrates – outlet; Phosphates

– outlet; Faecal coliforms – outlet.

o Monitoring of chemical oxygen demand (COD) in effluent must take place twice per week.

o Monitoring of both effluent volumes produced and released into the river as well as of key

variables pertaining to the General Effluent Limits must take place weekly for the first year

of installation and thereafter monthly or as required by any conditions imposed by the

Water use Licence.

o Monitoring must be carried out by an independent organisation and the ecological

implications of the data so acquired must be reported on, initially on a monthly basis.

Where these data indicate problems in meeting the General Effluent Limits, urgent

measures must be taken to rectify this issue. In the event that the plant cannot meet the

Effluent Limits for more than 2 months, then the plant must be upgraded to achieve these

limits within a period of 4 weeks.

o Monitoring of the water quality and quantity effects of direct or indirect effluent released

into the River (water sampling from the river) must be carried out on at least a quarterly

basis, with at least an up- and downstream site being selected for comparative purposes,

at which water samples must be collected / measured for variables including key

nutrients, E. coli bacteria, ammonia, pH, electrical conductivity and total suspended

sediments. Water depth must be measured and compared to a pre-surveyed channel

cross-section and slope, which allows coarse estimates of relative discharge to be made.

In the event that passage of effluent into the river is shown to have a sustained (over two

months) measurable effect resulting in a change in water quality, measures to address

such impacts must be sought, including upgrading of the treatment plant.

o It is important that detailed analysis and discussion of implications of the water quality

results be undertaken by a suitable qualified professional. Taking the samples without the

appropriate interpretation is insufficient and will not assist management.

o Records should be maintained of monitoring data and procedures should be reviewed

periodically. Plant managers should carefully observe the environmental performance of

their plants and should institute remedial action should problems arise.

o Monitoring of indicators must be in accordance with those specified in the water use

licence. The volume and characteristics of wastewater before and after treatment (i.e.

treatment plant performance), monitored weekly (first year) and the volume of treated

wastewater discharged to irrigated areas, monitored weekly (first year). After the first

years monthly monitoring may be acceptable depending on a situational analysis.


4. Freshwater Impacts – WWTW, Associated Infrastructure

o The discharge water must be sampled daily during the first two months of operation,

assessed accordingly with reportable findings to the relevant person, and if in constant

compliance with the water limits specified in the water use license, sampling and analysis

can be conducted on a weekly basis for the first year, followed by a monthly basis

thereafter.

o If it is found that the effluent is causing significant impacts upon freshwater habitat,

despite being compliant with the water quality and volume special limits, the treated

effluent must be treated further and the limits re-assessed.

Cumulative impact post mitigation: Negligible Medium


mitigation Medium (-) Medium (-) Medium (-) High (-)




Operation of the WWTW (including operation of large effluent storage dam and irrigation of treated

wastewater) and operation of associated infrastructure (including pipelines and emergency retention

dam in front of factory) resulting in decreased water quality & aquatic habitat disturbance. The new

proposed emergency pond in front of the factory (emergency untreated wastewater storage) is located

within the 1:100 year floodline.

Continued operation of large

effluent dam (assuming

banks don’t burst) & irrigation

of untreated wastewater



Duration

Probability of occurrence: Highly probable Probable


reversed: Irreversible Irreversible



resources:

Significant loss of resource Significant loss of resource



Indirect Impact Aquatic habitat loss / disturbance is an indirect impact of water pollution /altered flow regime.


Residual Impacts Aquatic habitat loss.


to mitigation High High High Medium


mitigated: Can be mitigated Can be mitigated


The following Mitigation Measures will be implemented for the Continued Operation of the Effluent

Dam and Irrigation Activities:

1. Obtain instream dam safety inspections should be undertaken.

2. The irrigation system must be designed correctly, therefore an irrigation specialist should be

consulted. The specialist should provide an irrigation plan complete with design parameters and

operating characteristics detailing the irrigation methods, application rates and water scheduling

based on soil assessment.

3. Treated and stabilised wastewater used for irrigation should be routinely tested and applied at

appropriate rates to avoid environmental problems.

4. When the soil is saturated, irrigation waters should be stored until the soil dries sufficiently for

irrigation.

5. An effluent monitoring plan must be compiled.

6. An Environmental Officer should be appointed and must be contractually bound to implement the


7. Effluent that is pumped to the effluent storage dam from the WWTW should be treated to at least

General Limit Standards.

8. The effluent storage dam should not be allowed to reach more than 90% of its capacity to reduce

risk of spilling into the watercourses of effluent that might not be of the required quality (General

Limit Values).

9. The effluent storage dam should not be used as an emergency storage dam for plant

malfunctions. The dam is not lined and should comprise of reasonably good quality effluent ready

to be irrigated.

The following Mitigation Measures will be implemented during the Operational Phase of the WWTW

& Associated Infrastructure:

10. A “calamity” dam is proposed at the WWTW site which can store up to 24 hours of effluent should

malfunctions occur at the WWTW.

11. Plant operators must be appropriately qualified and skilled.




12. The pipeline should be regularly monitored and maintained to ensure that any problems with the

pipeline are rectified before they can impact on any watercourses.

13. Treated effluent should be chemically and microbiologically analysed according to a schedule.

Effluent that does not meet national quality guidelines should not be discharged into the river. In

the long term, the irrigation effluent must also comply with the limits (once the WWTW is in

operation). Should guidelines not be met, the operation of the WWTW should be adjusted in order

to improve the quality.

14. Pumps, pipelines and other equipment should be regularly inspected and maintained. Spare parts

should be readily available. Downtime should be kept to a minimum in order to prevent spillages

and adverse environmental impacts. Flow meters should be kept in working order and calibrated

if necessary.

15. A stormwater management plan must be developed to ensure water resources are not

contaminated during high rainfall events and that flooding of the river does not reach the area

where the pump stations and emergency dam is located.

16. During high rainfall events and when the river starts to flood, if untreated effluent is located in the

dam it must be pumped back into the factory.

17. The emergency pond must be lined with an impermeable plastic lining.

18. The emergency pond must have stormwater management berms and trenches built around it to

ensure that risk of water pollution is avoided.

19. Provision must be made for the ongoing maintenance and management of the plant by a

professional team, experienced in its design and use.

20. Operators, through training and total quality management procedures, should be encouraged to:

identify potential problems, adopt a regular inspection and maintenance routine, take appropriate

corrective measures when problems do arise, adopt operating and reporting procedures that seek

to prevent problems happening again.

21. The WWTW and irrigation managers should develop and maintain contingency plans. The plans

should provide for the avoidance and control of spills, leakage or breakdowns so as to prevent

pollution of the environment.

22. An effluent monitoring plan must be compiled.

23. An Environmental Officer should be appointed and must be contractually bound to implement the


Cumulative impact post mitigation: Medium Medium


mitigation Medium (-) Medium (-) Medium (-) Low – Medium (-)


5. Visual Impact

6. Soil & Groundwater Contamination



Description of Impact: Associated with built infrastructure impacting on the sense of place of the area / cultural landscape N/A


Extent and duration of impact: Local Extent; Permanent Term Duration N/A






resources:







to mitigation Medium (-) Low – Medium (-) Medium (-) N/A


mitigated: Can be barely mitigated N/A


1. The fencing of the WWTW should not be cement palisade but rather a clear view fence type.

2. Indigenous vegetation must be re-established in disturbed areas (pipeline route, site camp, areas surrounding the WWTW.



mitigation Medium (-) Low – Medium (-) Medium (-) N/A



Description of Impact: Leakage of the WWTW, Emergency Detention Dam and effluent pipelines could result in soil and

groundwater contamination

Continued irrigation of poor

quality untreated effluent


over a 45ha area adjacent to

freshwater systems



Duration

Probability of occurrence: Highly probable Probable


reversed: Irreversible Irreversible



resources:

Significant loss of resource Marginal loss of resource



Indirect Impact Groundwater contamination is an indirect impact of soil contamination. If exposure to the contaminated groundwater occurs, health

impacts could occur.

Residual Impacts Health impacts.


to mitigation Medium Medium Medium High



Can be mitigated by further

treatment of effluent


1. Improved water quality (as a result of the proposed WWTW) must be combined with sound

irrigation scheduling to ensure the land is used optimally.

2. WWTW, pipelines and emergency detention ponds must be properly designed and built. Leak

detection monitoring should be implemented via groundwater monitoring.

3. Monitoring should be conducted by a qualified hydrogeologist, once every 3 months, for at least

3 years after the WWTW is complete. Quarterly field chemistry measurements should also be

taken, along with annual samples for analysis.

4. Regular monitoring of the treated effluent must be implemented to ensure that the quality of the

treated effluent remains within indicated limits.

5. It is recommended that one monitoring borehole be drilled at the WWTW site for future site

monitoring (downgradient of the WWTW).

6. At the irrigation site, groundwater quality should continue to be monitored and irrigation scheduling

implemented.




7. Socio-economic Benefit

7. The development of a Groundwater Monitoring Programme will be important for assessing any

impacts of the site on groundwater and the environment.

Cumulative impact post mitigation: Medium Medium


mitigation Low - Medium (-) Low - Medium (-) Low - Medium (-) Medium – High (-)




The Parmalat SA factory is major employer in this area with approximately 1 000 people directly and

indirectly dependent on the business. The operation of the WWTP will allow the factory to continue

business. The operational phase of the WWTW will result in 5 additional employment opportunities in

addition to the hundreds already provided by Parmalat.

If the status quo remains, the

Parmalat SA factory will most

likely need to shut down

given the impact to the

environment taking place as

a result of poor effluent

quality being irrigated and

discharged to the river. This

will have a detrimental socio-

economic impact.

Nature of impact: Positive Negative


Duration

Probability of occurrence: Definite Probable


reversed: N/A – this is a positive benefit Completely reversible



resources:

N/A – this is a positive benefit No loss of natural resource


mitigation: High Medium

Indirect Impact Income generation, well – being, financial security for hundreds of employees. If the factory shuts down,

hundreds of people will be


unemployed, this will result in

loss of income and could

indirectly impact on poverty

levels, social well-being,

crime levels.

Residual Impacts See indirect impacts See indirect impacts


to mitigation High High High High


mitigated: N/A – This is a positive impact proposed to be enhanced

N/A – the NO-GO assumes

the factory will close / status

quo

Proposed enhancement:

• This WWTP will require regular maintenance. This will be undertaken by small local contractors in the region.

• The operators of the WWTW are provided with the appropriate skills and training.

Cumulative impact post

enhancement: High High


mitigation High (+) High (+) High (+) High (-)


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(c) Provide a summary of the site selection matrix.

With reference to section 4 (iii) below, the Option 2 site is the selected site being put forward to the DEA &

DP to be approved based on the fact that, although comparable / similar to Option 3, Option 2 has the lowest

overall negative construction phase impacts (after mitigation) and the lowest overall negative operation

phase impacts. Option 3’s overall environmental impact is slightly higher as a result of the visual impact of

Option 3 to Bonnievale Winery and adjacent sensitive receptors / road users.

Option 1 should not be approved because of the high, unacceptable botanical impact. Option 1 would also

be the most expensive to build as it’s located in bedrock on a hill. Option 1, given its location on top of a hill,

also is associated with visual impacts higher than Option 2.

(d) Outcome of the site selection matrix.

Option 2 is the preferred development with the overall lowest environmental and social impact.

3. SPECIALIST INPUTS/STUDIES, FINDINGS AND RECOMMENDATIONS

Note: Specialist inputs/studies must be attached to this report as Appendix G and must comply with the content requirements

set out in Appendix 6 of the EIA Regulations, 2014 (as amended). Also take into account the Department’s Circular EADP

0028/2014 (dated 9 December 2014) on the “One Environmental Management System” and the EIA Regulations, 2014,

any subsequent Circulars, and guidelines available on the Department’s website

(http://www.westerncape.gov.za/eadp).

Provide a summary of the findings and impact management measures identified in any specialist report and an

indication of how these findings and recommendations have been included in the BAR.

Summary of Key Findings & Key Mitigation Recommended by Specialists

Freshwater Impact Assessment

Bekker (2019) states the following Key Findings:

• None of the proposed WWTW locations, nor the pipelines to any of them, will have a high impact upon

freshwater habitat. While it is usually preferable to situate the infrastructure outside of drainage areas,

these identified areas are highly degraded already. HGM 2 is critically modified and has little ecological

functioning.

• With the adoption of mitigation measures, the WWTW and pipelines will have a low impact upon this

HGM 2 system.

• However, the water use activities will impact upon the Breede River substantially. It is proposed to

discharge the treated effluent into the river. This will increase the water inflows of the system and alter

the abiotic characteristics thereby affecting the biota.

• There is an existing pipe outlet that is currently discharging untreated effluent into the river near the

factory and large earthworks have recently cleared and reshaped the riverbank while excavating material

from the river channel. Therefore, the level of disturbance to habitat in this area caused by the factory is

already substantial.

• Discharging treated effluent into the river is a preferred alternative to the No-Go Option of untreated and

unmonitored effluent continually entering the system. Therefore, with the adoption of strict mitigation

measures and acceptance from DWS, discharging the treated WWTW effluent into the river will not have

a high impact upon freshwater habitat.



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• The effluent from the factory is currently piped to an effluent dam, approximately 5 km away, and used

for irrigation of livestock pastures. These activities, as well as the proposed additional irrigation on new

areas, will continue to impact the surrounding watercourses.

• The construction of the effluent dam has not replaced any significant habitat and the HGM 5 stream was

critically modified prior to its construction. However, the possible situation of polluted effluent overflowing

(if the banks burst) could have detrimental impacts upon downstream habitat. Therefore, the impact of

the construction of the dam may be of Low-Medium significance, but the threat it poses to downstream

habitat is High. However, if mitigation is applied this could decrease to Medium impact significance. The

irrigation will obtain a Low-Medium significance if the irrigation water volumes are decreased and the

quality be made to comply. Currently the polluted water is entering the downstream areas and most likely

the Breede River.

• The current condition of these systems is cause for serious concern. Almost without exception, these

tributaries have been dredged, bulldozed, channelized and in some instances, levees have been

constructed alongside them to prevent overbank flooding. In most cases only hardy and pioneering

annuals or exotic species remained in the riparian areas, and there was little or no variety of instream

habitats. Some, as well as the Breede Trunk River, had excessive algal growth and/or exotic instream

vegetation, an indication of a nutrient surplus and a breakdown in the self-cleansing functions of the

ecosystem.

• They key measure to prevent reduced freshwater habitat integrity is to ensure all effluent associated with

the project is treated appropriately and discharged within the volume limits.

• The impact of not implementing a WWTW to manage effluent is of a High negative significance. The

effluent will continue to pollute and erode aquatic habitat on a regional scale. It results in a negative

trajectory of change and the River Environmental Classification (REC) will not be obtained. Additionally,

without a method to treat the water and discharge it safely, there is the risk that increased amounts of

untreated effluent will enter the watercourses. This is due to the risk of the dam becoming full, the winter

rainfall season, and waterlogged irrigation fields resulting in a surplus of effluent with no sufficient storage

method. If the WWTW is not implemented then the irrigation water quality will not comply with legislated

standards and the REC of the river will not be realized. It is critical that the WWTW be implemented.

• If the quality of the discharge effluent is not regularly monitored it could result in non-compliance with the

Water Use License water quality limits and this would cause significant water quality pollution and habitat

loss.

Bekker (2019) recommends the following Key Mitigation Measures to be Implemented Immediately:

• The existing discharge pipe outlet to the river must immediately be decommissioned. It is causing

pollution of aquatic habitat; the proliferation of alien invasive species due to increased nutrients, as well

as erosion of the banks. The bank has recently been cleared and excavated. This must immediately be

rehabilitated. It may require recontouring and will definitely require revegetation with indigenous riparian

species. During this work, further erosion and sedimentation must be prevented and the bank stabilised

until vegetation propagates.

• Stop the existing effluent/ contaminated stormwater/wash bay water from seeping into the river. Better

management of wash water (this should not be passed into the river or its floodplain).



Construction Phase of the WWTW & Associated Infrastructure:

• The designers should refer to the effluent discharge standards stipulated by the Department of Water

Affairs (DWA) for the specific area in which the WWTW is to be designed and constructed. The WWTW

must be designed to meet the effluent discharge standards.

• The wastewater treatment system must be designed to handle peak flow rates and peak levels of

contamination. Failure to get the design right will result in excursions of wastewater quality during peak

times.


143

• The wastewater pumping stations and treatment plants should be protected against flooding. The

treatment process units (including the emergency pond) should be located at an elevation higher than

the 100-year flood level or otherwise be adequately protected against 100-year flood damage.

• Emergency power supply for pumping stations and treatment plants is required to prevent overflows from

occurring during any power outage.

• Provision must be made on site for the emergency retention of at least 72 hours effluent in the event of

plant failure / malfunction. The storage area must be lined and bermed to minimise potential spillage risk

into the river and it should be no closer than 50m from the edge of the river corridor and such that it does

not readily connect to the stormwater system.

• The proposed pipeline should be constructed in already disturbed areas such as where soils and

vegetation has already been completely transformed by past cultivation activities. There should be limited

disturbance within the drainage line during the construction phase.

• Contaminated runoff from the pipeline installation site should be prevented from directly entering the

drainage channel.

• After construction, the disturbed area should be rehabilitated, particularly to prevent erosion taking place

as well as to prevent the potential colonisation of these areas with invasive alien plants. Rehabilitation

requires removal of invasive alien plants from the riparian zone, some landscaping of the eroded channel,

if required, and re-vegetation rather than bare ground in the steeper areas.

• The construction camp/laydown area should be located away from the drainage areas and river. All

materials should be properly stored and contained; stockpiles must be located away from freshwater

habitat and prevent material from being transported by wind or rain, into any HGM units. Disposal of

waste from the site should also be properly managed. Construction workers should be given ablution

facilities at the construction sites that are located away from the watercourses (at least 20m) and regularly

serviced.

• If the location of the road and pipeline infrastructure cannot be moved above the drainage channel (to

avoid crossing the natural stormwater drainage channel), then an appropriate culvert installation needs

to be built to cross the non-perennial watercourse to avoid modifications in flow (impedance / diverting

flow) to HGM2 and damage to the road.


Construction Phase of the Discharge Pipeline into the Breede River:

• The new outlet should be located at least 30m from the current river channel.

• It is recommended that the discharge pipe for the effluent into the river be set back from the river. The

treated effluent could be transferred directly into the channel via a “lay flat discharge pipe”. This approach,

or one with similar objectives, will decrease the impact of the construction of the outlet structure.

• The discharge pipe outlet design should include erosion control measures, such as for example, reno-

mattresses.

• The discharge should flow into the river in a diffuse pattern.

• Bare areas should be re-vegetated with indigenous riparian species.

• The riparian habitat should be rehabilitated and re-stored and the riverbank stabilized from erosion.


Operational Phase of the Discharge Pipeline into the Breede River:


• The treated effluent to be discharged into the river from the WWTW should at least comply with the

General Limits as required in the General Authorisations for water use.

• The outlet should be inspected daily and after major rainfall, to identify erosion gulley’s / channels into or

towards the river. Where such occur, they should be addressed appropriately to prevent concentration of

flows into the river – if a channel is cut into the river, it must be shaped as a shallow trench (side slopes

1:5 or less steep), lined with soil-packed reno if necessary, and planted with stabilising indigenous sedges

(e.g. Juncus kraussii or Cyperus textilis) rather than grasses.



143



Bekker (2019) recommends the following Key Mitigation Measures proposed to be implemented for the

Continued Operation of the Effluent Dam and Irrigation Activities:

• Obtain instream dam safety inspections should be undertaken.

• The irrigation system must be designed correctly, therefore an irrigation specialist should be consulted.

The specialist should provide an irrigation plan complete with design parameters and operating

characteristics detailing the irrigation methods, application rates and water scheduling based on soil

assessment.

• Treated and stabilised wastewater used for irrigation should be routinely tested and applied at appropriate

rates to avoid environmental problems.

• When the soil is saturated, irrigation waters should be stored until the soil dries sufficiently for irrigation.




Bekker (2019) recommends the following Key Mitigation Measures proposed to be Implemented during the

Operational Phase of the WWTW & Associated Infrastructure:

• The pipeline should be regularly monitored and maintained to ensure that any problems with the pipeline

are rectified before they can impact on any watercourses.

• A stormwater management plan must be developed to ensure water resources are not contaminated

during high rainfall events.

• Treated effluent should be chemically and microbiologically analysed according to a schedule. Effluent

that does not meet national quality guidelines should not be discharged into the river. In the long term,

the irrigation effluent must also comply with the limits (once the WWTW is in operation). Should guidelines

not be met, the operation of the WWTW should be adjusted in order to improve the quality.

• Pumps, pipelines and other equipment should be regularly inspected and maintained. Spare parts should

be readily available. Downtime should be kept to a minimum in order to prevent spillages and adverse

environmental impacts. Flow meters should be kept in working order and calibrated if necessary.

• Provision must be made for the ongoing maintenance and management of the plant by a professional

team, experienced in its design and use.

• Operators, through training and total quality management procedures, should be encouraged to: identify

potential problems, adopt a regular inspection and maintenance routine, take appropriate corrective

measures when problems do arise, adopt operating and reporting procedures that seek to prevent

problems happening again.

• The WWTW and irrigation managers should develop and maintain contingency plans. The plans should

provide for the avoidance and control of spills, leakage or breakdowns so as to prevent pollution of the

environment.




The following Effluent Monitoring Measures, as recommended by the freshwater specialist, is proposed to

be implemented by Parmalat SA and included in the Effluent Monitoring Plan:

• Effluent will be sampled from the following points and sent for laboratory analysis: COD - inlet & outlet;

TSS - inlet & outlet; Ammonia - inlet & outlet; Nitrates – outlet; Phosphates – outlet; Faecal coliforms –

outlet.

• Monitoring of chemical oxygen demand (COD) in effluent must take place twice per week.


143

• Monitoring of both effluent volumes produced and released into the river as well as of key variables

pertaining to the General Effluent Limits must take place weekly for the first year of installation and

thereafter monthly or as required by any conditions imposed by the Water use Licence.

• Monitoring must be carried out by an independent organisation and the ecological implications of the data

so acquired must be reported on, initially on a monthly basis. Where these data indicate problems in

meeting the General Effluent Limits, urgent measures must be taken to rectify this issue. In the event that

the plant cannot meet the Effluent Limits for more than 2 months, then the plant must be upgraded to

achieve these limits within a period of 4 weeks.

• Monitoring of the water quality and quantity effects of direct or indirect effluent released into the River

(water sampling from the river) must be carried out on at least a quarterly basis, with at least an up- and

downstream site being selected for comparative purposes, at which water samples must be collected /

measured for variables including key nutrients, E. coli bacteria, ammonia, pH, electrical conductivity and

total suspended sediments. Water depth must be measured and compared to a pre-surveyed channel

cross-section and slope, which allows coarse estimates of relative discharge to be made. In the event

that passage of effluent into the river is shown to have a sustained (over two months) measurable effect

resulting in a change in water quality, measures to address such impacts must be sought, including

upgrading of the treatment plant.

• It is important that detailed analysis and discussion of implications of the water quality results be

undertaken by a suitable qualified professional. Taking the samples without the appropriate interpretation

is insufficient and will not assist management.

• Records should be maintained of monitoring data and procedures should be reviewed periodically. Plant

managers should carefully observe the environmental performance of their plants and should institute

remedial action should problems arise.

• Monitoring of indicators must be in accordance with those specified in the water use licence. The volume

and characteristics of wastewater before and after treatment (i.e. treatment plant performance),

monitored weekly (first year) and the volume of treated wastewater discharged to irrigated areas,

monitored weekly (first year). After the first years monthly monitoring may be acceptable depending on a

situational analysis.

• The discharge water must be sampled daily during the first two months of operation, assessed

accordingly with reportable findings to the relevant person, and if in constant compliance with the water

limits specified in the water use license, sampling and analysis can be conducted on a weekly basis for

the first year, followed by a monthly basis thereafter.

• If it is found that the effluent is causing significant impacts upon freshwater habitat, despite being

compliant with the water quality and volume special limits, the treated effluent must be treated further and

the limits reassessed.



Botanical Impact Assessment

Mc Donald (2019) states the following Key Findings & Recommended Mitigation Measures:

• The site proposed for Option 1 is highly sensitive (high negative impact after mitigation) from a botanical

perspective and it should be rejected as a possible development site.

• The site proposed for Option 2 & 3 share similar vegetation type and characteristics, there is therefore

no overriding criteria that suggest that one is favoured over the other (low negative significance after

mitigation). Option 2 & 3 are acceptable to be developed.

• For the pipeline route / access road route for Option 2 & 3 the route is aligned along disturbed areas

alongside ploughed areas (low botanical sensitivity), however, a small amount (approximately 600m2) of

undisturbed Renosterveld is located in the vicinity of the access road where it starts near the R317. The

pipeline should be re-aligned as to avoid disturbing this intact vegetation.

• For the WWTW location for Option 2 & 3, the location is highly disturbed and not botanically sensitive. It

could therefore be used without any botanical constraints.



143

Geohydrological Impact Assessment

Muller (2019) states the following Key Findings:

• The groundwater quality in the monitoring boreholes, hydro-census boreholes, effluent dam and seepage

ponds are of poor to dangerous quality according to drinking water limits for conductivity, total dissolved

solids, sodium and chloride concentrations.

• No boreholes, registered and unregistered, within a 1km radius of the site are used for drinking water.

• Over irrigation is a concern, with excessive volumes of effluent currently irrigated resulting in a perched

water table and ponding.

• During the construction phase of the WWTW, associated infrastructure and emergency detention dam,

leakage from the proposed construction represents a minor risk of contamination. Reduced natural

infiltration and recharge due to the construction footprint is considered to be a minor risk of very low

impact.

• While leakage of treated effluent would improve the natural groundwater quality in some aspects, the

untreated effluent is likely to have a detrimental effect. This is considered to be a minor risk of very low

impact.

• The quality of the effluent in the seepage ponds and effluent storage dam is classified as very high risk

in terms of sodium absorption and very high risk in terms of salinity hazard. This means that the current

effluent stored is not suitable for irrigation.

• The proposed WWTW will result in the production of improved effluent quality.

• The risk of exposure to groundwater is low as the groundwater is not used as a source of water in the

area.

Muller (2019) states the following Recommended Mitigation Measures:

• Improved water quality (as a result of the proposed WWTW) must be combined with sound irrigation

scheduling to ensure the land is used optimally.

• WWTW, pipelines and emergency detention ponds must be properly designed and built. Leak detection

monitoring should be implemented via groundwater monitoring. Monitoring should be conducted by a

qualified hydrogeologist, once every 3 months, for at least 3 years after the WWTW is complete. Quarterly

field chemistry measurements should also be taken, along with annual samples for analysis.

• Regular monitoring of the treated effluent must be implemented to ensure that the quality of the treated

effluent remains within indicated limits.

• It is recommended that one monitoring borehole be drilled at the WWTW site for future site monitoring

(downgradient of the WWTW).


implemented.

• The development of a groundwater monitoring programme will be important for assessing any impacts of

the site on groundwater and the environment.

Archaeological & Paleontological Assessment

Orton (2019) and Almond (2019) conclude the following Key Findings & Recommended Mitigation

Measures:

• An archaeological survey of the site revealed one possible quartz flake close to the Option 1 WWTW site.

The geology was found to not be favourable for the manufacture of stone artefacts. An equid radius was

uncovered during the geotechnical testing at the Option 2 WWTW site (identified from photographs by Dr

Teresa Steele). The bone is not mineralised and, from its colour, must have been enclosed by soil. It did

not appear to be associated with anything else and there was no way to tell if it was archaeological or

not. On its own it is assumed to be of no significance. A single fragment of probably late 19th century


143

annular ware (plate fragment) was seen along the pipeline route to Option 1. On its own it is of no

significance.

• No significant impacts are expected on archaeological resources.

• The SAHRIS Palaeo-sensitivity map shows the site as being of potentially very high palaeontological

sensitivity. For this reason, and because the surface rocks on site did not look promising from a

palaeontological point of view, a desktop study was commissioned in order to determine whether this was

a significant issue or not. Dr John Almond notes that the underlying rocks are potentially fossiliferous but

that weathering and tectonism often compromise fossil preservation. From the many photographs

provided to him, he saw no reason for concern, at least at the surface, although evidence for tectonic

deformation was largely absent.

• A fossil chance finds procedure, as described below, (ECO response protocol) must be incorporated into

the EMPr for the project and, as such, no further significant impacts are expected.

o Once alerted to fossil occurrence(s): alert site foreman, stop work in area immediately (N.B.

safety first!), safeguard site with security tape / fence / sandbags if necessary.

o Record key data while fossil remains are still in situ:

▪ Accurate geographic location – describe and mark on site map / 1: 50 000 map / satellite

image / aerial photo;

▪ Context – describe position of fossils within stratigraphy (rock layering), depth below

surface;

▪ Photograph fossil(s) in situ with scale, from different angles, including images showing

context (e.g. rock layering);

• If feasible to leave fossils in situ:



o Ensure fossil site remains safeguarded until clearance is given by the Heritage Resources

Authority for work to resume;

• If not feasible to leave fossils in situ (emergency procedure only):

o Carefully remove fossils, as far as possible still enclosed within the original sedimentary matrix

(e.g. entire block of fossiliferous rock);

o Photograph fossils against a plain, level background, with scale;

o Carefully wrap fossils in several layers of newspaper / tissue paper / plastic bags;

o Safeguard fossils together with locality and collection data (including collector and date) in a box

in a safe place for examination by a palaeontologist;



4. ENVIRONMENTAL IMPACT STATEMENT

Provide an environmental impact statement of the following:

(i) A summary of the key findings of the EIA.

The key findings of the Environmental Impact Assessment are as follows:

1. Option 2 has the lowest visual impact to sensitive receptors in comparison to Option 1 & 3 because

Option 1 is located on a hilltop and Option 3 is closest to the Bonnievale Winery, and the adjacent

provincial road, a local tourism destination / route;

2. Although comparable / similar to Option 3, Option 2 has the lowest overall negative construction phase

impacts (after mitigation) and the lowest overall negative operation phase impacts. Option 3’s overall

environmental impact is slightly higher as a result of the visual impact of Option 3 to Bonnievale Winery

and adjacent sensitive receptors / road users.

3. Option 1 should not be approved because of the high, unacceptable botanical impact. Option 1 would

also be the most expensive to build as it’s located in bedrock on a hill. Option 1, given its location on


143

top of a hill, also is associated with visual impacts higher than Option 2 & 3. Option 1 should therefore

not be considered for authorisation.

4. The NO-GO alternative, assumes the status quo. This therefore assumes that the WWTW will not be

built and that untreated, poor quality effluent will continue to be stored, irrigated and discharged into

the Breede River. The status quo is associated with existing, unacceptable (medium – high) impacts

to air quality (odours), nuisance impacts, freshwater impacts, soil and groundwater contamination. It

is therefore a necessity that the WWTW be built to avoid these environmental and social impacts from

continuing to take place.

5. Should the WWTW not be built (NO-GO), the DEA & DP / BGCMA / DWS may issue a Directive to

Parmalat to stop operation. This would have a detrimental socio-economic impact given the hundreds

of people who are dependent on the operating of the business. It is therefore not recommended that

the plant be shut down but rather that short term and long term (the WWTW) mitigation measures be

implemented to avoid and mitigate environmental impacts.

6. The findings of this EIA is that it is crucial to approve the WWTW so that it is built and becomes

operational as quickly as possible.

7. Option 2 (the preferred alternative) is associated with low construction phase impacts if the various

mitigation measures listed above are implemented by Parmalat.

8. The most significant operational phase impact is the freshwater impact of discharging effluent into the

River that does not meet the General Limit Standards. It is therefore of the utmost importance that the

quality of the effluent does meet the GA limits prior to discharge and irrigation. Discharge to the river

should only take place when irrigation is not possible and the effluent storage dam is more than 70%

capacity.

9. Given the location of the new proposed emergency dam to be within the 1:100 year floodline (the

existing pump station is also within the 1:100 year floodline) there is a low risk of the river flooding into

the emergency dam. The area proposed for the dam has only ever been flooded with river water once

in recorded history and the chance that untreated effluent is in the emergency pond at the same time

as the 1:100 year flood is very small. The emergency pond is crucial to have a back up storage in this

location when the pump station fails. There is no other location option for the pond. Stormwater

management measures will be implemented (high pond boundary walls) to reduce the risk even

further.

10. The correct operation of the WWTW will eliminate / reduce many of the existing threats to freshwater

habitat. However, the incorrect operation (and incorrect implementation of an Effluent Monitoring Plan)

of the WWTW and discharge of effluent into the river which does not meet the limits, will further impact

on the existing threat.

11. The impact of not implementing any of these strategies (the No Go alternative) is unacceptably high.

Additionally, there are exiting impacts that should be rectified immediately. Therefore, following the

adoption of the recommendation for inclusion in the EMPr, the impacts associated with the project can

be decreased to acceptable levels.

12. They key measure to decrease impacts upon freshwater habitat integrity is to ensure all effluent

associated with the project is treated appropriately and discharged within the volume limits. In order to

achieve this, stringent monitoring is required.

(ii) Has a map of appropriate scale been provided, which superimposes the proposed development and

its associated structures and infrastructure on the environmental sensitivities of the preferred site,

indicating any areas that should be avoided, including buffers?

N/A – all areas outside of the development footprint of the WWTW and the 20m corridor for

the pipeline infrastructure must be avoided.

YES NO

(iii) A summary of the positive and negative impacts that the proposed development and alternatives will cause in the

environment and community.

The tables below are a summary of the positive and negative impacts that the proposed development and

alternative sites will cause on the environment and community.

Construction Phase of the WWTW and Associated Infrastructure:


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CONSTRUCTION PHASE IMPACTS

IMPACT


Option 1 Option 2

Option 3

Option 4:

Status

Quo

Air Quality Impacts: Dust Associated with Construction & Traffic Low (-) Low (-) Low (-) N/A

Visual Impact to cultural landscape: As a result of temporary

construction activities. Low -Med (-)

Low (-) Low-Med (-) N/A

Archaeological / Paleontological Impact: Loss of fossils due to

construction excavations / trenching.

Low - Med (-) Low (-) Low (-) N/A

Botanical Impacts: Loss of Indigenous Vegetation High (-) Low (-) Low (-) N/A

Freshwater Impacts: Construction of WWTW and Pipeline

Infrastructure in a Watercourse & Construction of Discharge Outlet

on Riverbank Resulting in Water Pollution, Flow Modification,

Sedimentation & Erosion and Aquatic Habitat Disturbance


Noise Impacts: Associated with Construction Machinery & Traffic Low (-) Low (-) Low (-) N/A

Traffic and Safety Impacts: Associated with Delivery of

Construction Materials


Soil & Groundwater Contamination: Associated with Poor

Waste Management Activities, Fuel Spills, Effluent Spills and /or

Cement Batching during Construction Activities


Socio-economic: Creation of Temporary Jobs Medium (+)

Medium

(+)

Medium (+) N/A

Operation Phase of the WWTW and Associated Infrastructure:

OPERATION PHASE IMPACTS

IMPACT


Option 1 Option 2

Option 3

Option 4:

Status Quo

Air Quality Impacts: Odours associated with a WWTW facility

(Option 1 – 3) and storage of sludge or if Status Quo Remains

Irrigation of Poor Quality Effluent Resulting in Odours (Option

4)

Low (-) Low (-) Low (-) High (-)

Noise Impacts: Pumps, compressors (DAF and industrial

water), sludge dewatering equipment


Freshwater Impacts: Discharge of Treated Effluent into

Breede River Resulting in Sedimentation & Erosion, Altered

Flow Regime, Decreased Water Quality and Aquatic Habitat

Disturbance. If status quo remains risk of dam bursting or

further untreated river discharge.

Medium (-) Medium (-) Medium (-) High (-)

Freshwater Impacts: Operation of the WWTW and Associated

Infrastructure Resulting in Decreased Water Quality & Aquatic

Habitat Disturbance

Medium (-) Medium (-) Medium (-) Low-Med (-)

Visual Impact: Associated with Built Infrastructure Impacting

on the Sense of Place of the Area Medium (-) Low-Med (-)

Medium (-) N/A

Soil & Groundwater Contamination: Leakage of the WWTW,

Emergency Detention Dam and Pipelines

Low-Med (-) Low-Med (-) Low-Med (-) Med-High (-)

Socio-economic: Creation of Permanent Jobs: High (+) High (+) High (+) High (-)


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5. IMPACT MANAGEMENT, MITIGATION AND MONITORING MEASURES

(a) Based on the assessment, describe the impact management, mitigation and monitoring measures as well as the impact

management objectives and impact management outcomes included in the EMPr. The EMPr must be attached to this

report as Appendix H.

The impact management, mitigation and monitoring measures (to avoid or reduce impacts) have been listed

in the impact tables above under “proposed mitigation” and they have also been repeated in the attached

EMPr.

The impact management objectives, as listed in the EMPr, for each phase of the development proposal, are

as follows:

The following impact management objectives and outcomes have been identified for inclusion in the EMPr:

Planning and Design Phase:

OBJECTIVE OUTCOMES

Compile and Implement a Rehabilitation

Plan for the rehabilitation of the riverbank at

factory

• Rehabilitation of the riverbank in front of the factory.

• Restoration of aquatic habitat.

• Rehabilitation of erosion.

Compile an Effluent Monitoring Plan for

WWTW, effluent dams, discharge &

irrigation areas

• Wastewater discharged into the Breede River meets

the General Limit Water Quality Standards in terms of

all constituents, for discharge into a watercourse.

• Wastewater irrigated on the 45ha irrigation area meets

the General Limit Water Quality Standards in terms of

all constituents, for irrigation of wastewater.

Compile an Irrigation Plan • Ensure optimal use of the land in terms of optimal

irrigation volumes and grazing capacity (kikuyu

production).

• Avoid over-irrigation, waterlogging and under-irrigation.

Compile Contingency Plans for the WWTW,

emergency pond & irrigation areas

• Prevent environmental pollution incidents.

Compile a detailed Storm Water

Management Plan based on the conceptual

designs

• Impacts to the environment caused by storm water

runoff or flooding of the river during the construction

and operation phase are avoided.

• Water resources are not contaminated during high

rainfall events.

Compile a Groundwater Monitoring

Programme

• To ensure groundwater contamination is not taking

place as a result of the WWTW and water use activities.

Compile Detailed Civil Engineering Designs

for the WWTW and associated infrastructure

• The Detailed Civil Engineering Design is based on the

Conceptual Designs already compiled to avoid a

change in impact as a result of a change in

development description or additional listed activities

being triggered in the EIA Regulations

Appoint an Environmental Control Officer

and undertake environmental awareness

training

• The conditions of Environmental Authorisation and the

requirements of the EMP are implemented and

monitored during all phases of the development, which

will promote sound environmental management on

site.

• All onsite staff are aware and understands the

individual responsibilities in terms of this EMPr.


143

Establishment of Site Camp and associated

site facilities

• Before the start of the construction phase a site camp

must be established with all the required ablutions,

waste management infrastructure and fire fighting

equipment where the vehicles and equipment can be

stored.

• Impacts on the environment are minimised during site

establishment and the development footprint is kept to

a demarcated development area.

Enhance Socio-Economic Benefit by

employing local labour

• The socio-economic benefit is to the local community

and to previously disadvantaged individuals.

Construction Phase

OBJECTIVE OUTCOMES

Avoid contamination and pollution of the soil

and groundwater.

• To avoid the contamination of soil and groundwater by

inappropriate waste management practises, fuel and

oil spills, chemical toilet spills and inappropriate

cement mixing.

Limit traffic impacts to existing road users

and pedestrians

• During the construction phase of the development

while materials are being delivered to the site,

damages to road infrastructure does not occur and the

safety to pedestrians is not at unacceptable risk.

• Traffic congestion is managed as to reduce congestion

associated with delivery of materials

Noise management • The surrounding environment, land users, residents

and passers-by do not experience significant nuisance

impacts related to noise and vibration

Dust management • The surrounding environment, land users, residents

and passers-by do not experience significant nuisance

impacts related to dust.

Reduce the visual impact of the construction

phase activities

• Temporary construction activities may cause a visual

impact to sensitive receptors due to earth moving

activities, construction traffic, materials storage,

construction site camp etc.

Avoid loss / destruction of fossils /

archaeological material

• Avoid damaging or loss of fossils and / or

archaeologically significant material

Reduce the loss of indigenous vegetation • To disturb as little indigenous vegetation as practically

possible.

Reduce aquatic habitat impacts • The construction phase of the WWTW, access roads,

pipelines and emergency pond in front of the factory

does not result in erosion, flow modification,

sedimentation and water pollution impacts resulting in

aquatic habitat impact

Post Construction Rehabilitation Phase

OBJECTIVE OUTCOMES

Rehabilitate & stabilise disturbed areas and

ensure environmentally sensitive closure of

the construction site.

• The site is neat and tidy.


143

• There is no construction-related waste or pollution

remaining on site.

• All fuel spills are cleaned up.

• The riparian habitat is re-stored and the riverbank

stabilized post construction of the emergency pond.

Operation Phase

OBJECTIVE OUTCOMES

Avoid odours.

• Nearby farmers and other sensitive receptors do not

experience odours and nuisances as a result of the

operation of the WWTW.

Noise management • Nearby farmers and other sensitive receptors do not

experience noise disturbances and nuisances as a

result of the operation of the WWTW.

Reduce aquatic habitat impacts associated

with discharge into river

• Avoid, and if unavoidable, to reduce freshwater

impacts to the Breede River


with operation of emergency pond

• Avoid flooding event of the Breede River from causing

untreated effluent in the emergency pond from

entering the river.

• Avoid groundwater seepage from the untreated

effluent entering the river.


with WWTW and pipelines

• To avoid leakages / overflows from occurring which

could result in untreated effluent entering the natural

drainage channel flowing into the Breede River.


with effluent storage dam & irrigation area

• Avoid effluent storage dam reaching maximum

capacity which could result in effluent overflowing into

the Breed River tributary (there is a spillway on the

dam).

• Avoid effluent in the storage dam of poor quality (not

GA Limits) leading to irrigation of poor quality and

freshwater resources risk.

• Avoid over-irrigation leading to aquatic impacts.

Limit the visual impact • The WWTW does not have a significant visual impact

to sensitive receptors

Avoid soil and groundwater contamination • Avoid untreated effluent entering the soil &

groundwater.

• Avoid over-irrigation leading to soil and groundwater

impacts

Enhance socio-economic benefit • Provide permanent jobs to the local community

(b) Describe any provisions for the adherence to requirements that are prescribed in a Specific Environmental Management

Act relevant to the listed activity or specified activity in question.

None.


143

(c) Describe the ability of the applicant to implement the management, mitigation and monitoring measures.

Parmalat SA, Bonnievale, must appoint external service providers to undertake the monitoring measures and

to Audit the operational phase of the WWTW. Parmalat SA have been in non-compliance with various

conditions, management, mitigation and monitoring measures of the WULA since it was issued in 2011 and

there is therefore concern on the implementation of the licenses / authorisations. The design of the proposed

WWTW (with a capital cost of approximately R80 million rand) however, has been specifically designed to

treat the effluent to the correct standard. The ability of the design is therefore good. The operators of the

WWTW must have the correct qualifications and experience and effluent must be stored in emergency

detention should the quality not meet the standards.

(d) Provide the details of any financial provisions for the management of negative environmental impacts, rehabilitation and

closure of the proposed development.

N/A

(e) Provide the details of any financial provisions for the management of negative environmental impacts, rehabilitation and

closure of the proposed development.

N/A

(f) Describe any assumptions, uncertainties, and gaps in knowledge which relate to the impact management, mitigation and

monitoring measures proposed.

The gaps in knowledge at the time of compiling this report are as follows:

• The 1:100 year floodline of the Breede River is not known. It is not known if the proposed emergency

effluent detention pond in front of the factory is within the 1:100 year flood line or not.

• No conceptual or detailed design of the discharge outlet structure is available. Only the point of

discharge has been provided.

• No detailed design of the emergency detention pond is available. A Concept Design showing the

footprint and volume has however been provided.

• No stormwater management plan is yet available for the WWTW, associated infrastructure,

emergency detention pond, effluent storage area, irrigation areas.

• Specific details on where the sludge is proposed to be disposed, re-use options and location of the

sludge storage area was at the time of compiling this report not yet available. Investigations are

currently underway.

The following assumptions have been made:

• Analysis results of the sludge was not available at the time of compiling this report as sludge has not

yet been produced. It has however been assumed that based on analysis from sludge at similar

facilities, the sludge is assumed to also be non-hazardous.

• The location of the proposed WWTW, emergency effluent detention dam and effluent discharge point

/ discharge structure and associated road and pipeline infrastructure is a conceptual design that has

been based on geotechnical and civil engineering input. It is therefore assumed to be reasonably

accurate despite the fact that the detailed civil engineering design phase has not yet been

undertaken. The exact co-ordinates of the route of the pipeline and road is therefore uncertain but

has at this stage been reasonably accurately estimated.


143

Bekker (2019) states that due to the significant amount of agriculture in the floodplain and catchment, as well

as urbanisation and infrastructure malfunctions, it is not easy to make any direct links (uncertainties) regarding

the poor water quality results in the watercourses. However, we have determined that there is currently

untreated effluent entering the Breede River from a discharge pipe at the factory that correlates with the

eutrophic conditions in this location. Additionally, the existing quality of the effluent stored in the dam and

then irrigated, exceeds the general limits for such use, which also indirectly correlates with the concerning

water pollution in the tributary. Therefore, there is sufficient information to state that the factory is causing (at

least indirectly) a decline in the water quality of the watercourses surrounding the effluent use activities.


143

SECTION H: RECOMMENDATIONS OF THE EAP AND SPECIALISTS

(a) In my view as the appointed EAP, the information contained in this BAR and the documentation

attached hereto is sufficient to make a decision in respect of the listed activity(ies) applied for. YES NO

(b) If the documentation attached hereto is sufficient to make a decision, please indicate below whether, in your opinion,

the listed activity(ies) should or should not be authorised:

Listed activity(ies) should be authorised: YES NO

Provide reasons for your opinion

The proposed development is a mitigation requirement to improve on the unacceptable high risks currently

taking place to the freshwater environment. Parmalat SA are aware of the status quo and have therefore

implemented short term solutions to avoid / reduce the existing risks. The WWTW is a necessity for the

business to continue to operate as they must improve on the effluent quality and in the near future the quantity

(re-use strategy within the factory).

(c) Provide a description of any aspects that were conditional to the findings of the assessment by the EAP and Specialists

which are to be included as conditions of authorisation.

• Discharge to the Breede River should only take place when irrigation is not possible and when the effluent

storage dam is >70% capacity.

• Effluent must meet the General Limits before it is discharged to the river or irrigated to land.

(d) If you are of the opinion that the activity should be authorised, please provide any conditions, including mitigation

measures that should in your view be considered for inclusion in an environmental authorisation.

The mitigation measures recommended by the specialists and the EAP have been listed in the EMPR.

The following mitigation measures, given their importance to be implemented, should however be listed as

conditions of the Environmental Authorisation:

• The riverbank in front of the factory should be rehabilitated in line with a Rehabilitation Plan to be

compiled by a freshwater specialist.

• Direct discharge of untreated effluent or effluent that does not meet the General Limit into the river is

not permissible.

• The emergency pond in front of the factory must be placed above the 1:100 year floodline or

otherwise be adequately protected against 100-year flood damage.

• The new discharge outlet should be located at least 30m from the current river channel.

• An Effluent Monitoring Plan must be compiled.



• The irrigation system must be designed correctly, therefore an irrigation specialist should be

consulted. The specialist should provide an Irrigation Plan complete with design parameters and

operating characteristics detailing the irrigation methods, application rates and water scheduling

based on soil assessment.

• Treated and stabilised wastewater used for irrigation should be routinely tested and applied at

appropriate rates to avoid environmental problems.

• A Stormwater Management Plan must be developed to ensure water resources are not contaminated

during high rainfall events and to ensure that should the river flood no untreated waste enters the

river from the emergency dam.

• The WWTW and irrigation managers should develop and maintain Contingency Plans. The plans

should provide for the avoidance and control of spills, leakage or breakdowns so as to prevent

pollution of the environment.


• One monitoring borehole must be drilled at the WWTW site for future site monitoring (downgradient

of the WWTW).


143


implemented.

• A Groundwater Monitoring Programme must be development by a geo-hydrological specialist.

• Within the next 5 years, a Feasibility Assessment should be undertaken to assess the feasibility of

further treatment by Ultrafiltration and Reverse Osmosis or other system with the aim of re-using the

treated effluent within the factory. This should be a long-term objective to avoid discharge into the

river entirely. It would also considerably reduce water costs given the dependency of Parmalat on

potable water supply (approximately 3-5 litres of clean potable water is required for every litre of milk

produced at the factory).

(e) Please indicate the recommended periods in terms of the following periods that should be specified in the

environmental authorisation:

i. the period within which commencement must

occur;

1 year

ii. the period for which the environmental

authorisation is granted and the date on

which the development proposal will have

been concluded, where the environmental

authorisation does not include operational

aspects;

The activity does include operational aspects

iii. the period for which the portion of the

environmental authorisation that deals with

non-operational aspects is granted; and

The WWTW & associated infrastructure should be in operation within 1 year of the EA being issued.

iv. the period for which the portion of the

environmental authorisation that deals with

operational aspects is granted.

The WWTW & associated infrastructure should be in operation within 1 year of the EA being issued.


143

SECTION I: APPENDICES

The following appendices must be attached to this report:

APPENDIX Attached

Appendix A: Locality Map (s) X

Appendix B:

Layout Plan & WWTW Process Flow X

B1: Layout of Three Options & Associated Infrastructure X

B2: Detailed Site Layout Plan for WWTW Design X

B3: Elevations and Sections for WWTW X

B4: WWTW Process Flow Diagram X

B5: Concept Design of Emergency Detention Pond Pending

B6: Concept Design of Discharge Outlet into Breede River Pending

B7: Conceptual Stormwater Management Design Pending

Appendix C: Photographs X

Appendix D:

Biodiversity Overlay Map(s) X

D1: Critical Biodiversity & Ecological Support Areas X

D2: Freshwater Ecosystems Likely to be Impacted Upon X

D3: NFEPA, Non-Perennial Rivers & Wetlands X

Appendix E:

Existing Approvals / Licenses X

E1: Copy of comment from HWC

E2: Existing Water Use License (effluent storage & irrigate)

X

X

Appendix F:

Public Participation Information: X

Appendix F1: Register of Interested & Affected Parties X

Appendix F2: Site Notice & Proof of Placement X Proof

Pending

Appendix F3: Newspaper Advertisements & Proof of

Placements

X Proof

Pending

Appendix F4: Proof of Notification Pending

Appendix F5: All Comments Received Pending

Appendix F6: Comments & Responses Table Pending

Appendix G:

Specialist Report(s) X

Appendix G1: Freshwater Impact Assessment X

Appendix G2: Botanical Impact Assessment X

Appendix G3: Geo-hydrological Impact Assessment X

Appendix G4: Heritage Notice of Intent to Develop

Appendix H: Environmental Management Plan X

Appendix I: CV of EAP X


143

SECTION J: DECLARATIONS

THE APPLICANT

Note: Duplicate this section where there is more than one applicant.

I …………………………………………..……….., in my personal capacity or duly authorised thereto,

hereby declare/affirm all the information submitted as part of this Report is true and correct, and that

I –

• am aware of and understand the content of this report;

• am fully aware of my responsibilities in terms of the NEMA, the EIA Regulations in terms of the

NEMA (Government Notice No. R. 982, refers) (as amended) and any relevant specific

environmental management Act and that failure to fulfil these requirements may constitute an

offence in terms of relevant environmental legislation;

• have provided the EAP and Specialist, Review EAP (if applicable), and Review Specialist (if

applicable), and the Competent Authority with access to all information at my disposal that is

relevant to the application;

• will be responsible for complying with conditions that may be attached to any decision(s) issued

by the Competent Authority;

• will be responsible for the costs incurred in complying with the conditions that may be attached

to any decision(s) issued by the Competent Authority;

Note: If acting in a representative capacity, a certified copy of the resolution or power of attorney

must be attached.

Signature of the Applicant:

Name of Organisation:

Date:


143

THE ENVIRONMENTAL ASSESSMENT PRACTITIONER

I ………………………………………………………., as the appointed EAP hereby declare/affirm:

• the correctness of the information provided as part of this Report;

• that all the comments and inputs from stakeholders and I&APs have been included in this Report;

• that all the inputs and recommendations from the specialist reports, if specialist reports were

produced, have been included in this Report;

• any information provided by me to I&APs and any responses by me to the comments or inputs

made by I&APs;

• that I have maintained my independence throughout this EIA process, or if not independent, that

the review EAP has reviewed my work (Note: a declaration by the review EAP must be submitted);

• that I have throughout this EIA process met all of the general requirements of EAPs as set out in

Regulation 13;

• I have throughout this EIA process disclosed to the applicant, the specialist (if any), the Department

and I&APs, all material information that has or may have the potential to influence the decision of

the Department or the objectivity of any report, plan or document prepared as part of the

application;

• have ensured that information containing all relevant facts in respect of the application was

distributed or was made available to I&APs and that participation by I&APs was facilitated in such

a manner that all I&APs were provided with a reasonable opportunity to participate and to

provide comments;

• have ensured that the comments of all I&APs were considered, recorded and submitted to the

Department in respect of the application;

• have ensured the inclusion of inputs and recommendations from the specialist reports in respect

of the application, if specialist inputs and recommendations were produced;

• have kept a register of all I&APs that participated during the PPP; and

• am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations,

2014 (as amended).

Signature of the EAP:

Name of Company:

Date:


143

THE REVIEW ENVIRONMENTAL ASSESSMENT PRACTITIONER

I ………………………………………………………., as the appointed Review EAP hereby declare/affirm:

• that I have reviewed all the work produced by the EAP;

• the correctness of the information provided as part of this Report;

• that I have, throughout this EIA process met all of the general requirements of EAPs as set out in

Regulation 13;

• I have, throughout this EIA process disclosed to the applicant, the EAP, the specialist (if any), the

review specialist (if any), the Department and I&APs, all material information that has or may have

the potential to influence the decision of the Department or the objectivity of any report, plan or

document prepared as part of the application; and


2014 (as amended).

Signature of the

Review EAP:

Name of Company:

Date:


143

THE SPECIALIST

Note: Duplicate this section where there is more than one specialist.

I ……………………………………, as the appointed Specialist hereby declare/affirm the correctness of

the information provided or to be provided as part of the application, and that I :

• in terms of the general requirement to be independent:

o other than fair remuneration for work performed in terms of this application, have no business,

financial, personal or other interest in the development proposal or application and that there

are no circumstances that may compromise my objectivity; or

o am not independent, but another specialist (the “Review Specialist”) that meets the general

requirements set out in Regulation 13 has been appointed to review my work (Note: a

declaration by the review specialist must be submitted);

• in terms of the remainder of the general requirements for a specialist, have throughout this EIA

process met all of the requirements;

• have disclosed to the applicant, the EAP, the Review EAP (if applicable), the Department and

I&APs all material information that has or may have the potential to influence the decision of the

Department or the objectivity of any report, plan or document prepared or to be prepared as

part of the application; and


2014 (as amended).

Signature of the Specialist:

Name of Company:

Date:


143

THE REVIEW SPECIALIST

I ………………………………………………………., as the appointed Review Specialist hereby

declare/affirm:

• that I have reviewed all the work produced by the Specialist(s);

• the correctness of the specialist information provided as part of this Report;

• that I have, throughout this EIA process met all of the general requirements of specialists as set out

in Regulation 13;

• I have, throughout this EIA process disclosed to the applicant, the EAP, the review EAP (if

applicable), the Specialist(s), the Department and I&APs, all material information that has or may

have the potential to influence the decision of the Department or the objectivity of any report,

plan or document prepared as part of the application; and

• I am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations,

2014 (as amended).

Signature of Review Specialist:

Name of Company:

Date:

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