elgin free range chickens integrated water use licence
TRANSCRIPT
GCS (Pty) Ltd. Reg No: 2004/000765/07 Est. 1987
Offices: Durban Gaborone Johannesburg Lusaka Maseru Ostrava Pretoria Windhoek
Directors: AC Johnstone (Managing) PF Labuschagne AWC Marais S Napier W Sherriff (Financial)
Non-Executive Director: B Wilson-Jones www.gcs-sa.biz
63 Wessel Road, Rivonia, 2128 PO Box 2597, Rivonia, 2128 South Africa
Tel: +27 (0) 11 803 5726 Fax: +27 (0) 11 803 5745 Web: www.gcs-sa.biz
Elgin Free Range Chickens
Integrated Water Use Licence Application
(IWULA)
Report
Version – Public Review
28 September 2020
Elgin Free Range Chickens
GCS Project Number: 19-1170
Client Reference: Elgin Free Range
Chickens IWULA
. . . .
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19-1170 28 September 2020 Page ii
Elgin Free Range Chickens Integrated Water Use Licence Application (IWULA)
Report Version – Public Review
28 September 2020
Elgin Free Range Chickens 19-1170
DOCUMENT ISSUE STATUS
Report Issue Public Review
GCS Reference Number
19-1170
Client Reference Elgin Free Range Chickens IWULA
Title Elgin Free Range Chickens Integrated Water Use Licence Application (IWULA
Name Signature Date
Author Shayna-Ann Cuthbertson
28 September 2020
Document Reviewer Kate Cain 28 September 2020
Unit Director Adam Gunn 28 September 2020
LEGAL NOTICE
This report or any proportion thereof and any associated documentation remain the property of GCS until the mandator effects payment of all fees and disbursements due to GCS in terms of the GCS Conditions of Contract and Project Acceptance Form. Notwithstanding the aforesaid, any reproduction, duplication, copying, adaptation, editing, change, disclosure, publication, distribution, incorporation, modification, lending, transfer, sending, delivering, serving or broadcasting must be authorised in writing by GCS.
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EXECUTIVE SUMMARY
Background:
Elgin Free Range Chickens (Elgin) are currently the leading exclusively free-range chickens’
supplier in South Africa. Elgin has a facility located in Grabouw in the Western Cape. The
facility falls within the Theewaterskloof Local Municipality which forms part of the Overberg
District Municipality. The facility is located within the G40C quaternary catchment within the
Breede-Gouritz Water Management Area (WMA).
With the drought conditions currently occurring in the Western Cape, Elgin have opted to
supplement the municipal water with groundwater that is abstracted from a borehole located
on the property.
In 2019, a Water Use Regulatory Assessment was conducted by ENSafrica to identify the types
of authorisations a company would typically expect to see for the water uses undertaken on
the property and determines whether the requisite authorisations exist or do not exist. It was
determined that Elgin would need to apply for an IWULA. From this report, it was determined
that the following water uses in terms of Section 21 of the National Water Act, 1998 (Act No.
36 of 1998) (NWA) would need to be applied for:
• Section 21(a) – Taking water from a water resource:
o Abstraction of water from a borehole located on the property.
• Section 21(b) – Storing water:
o Storing water in a reservoir located on the property (falls within the GA
limit).
• Section 21(c) and (i) - Impeding or diverting the flow of water in a watercourse and
altering the beds, banks, course or characteristics of a water course:
o Infrastructure within 500m of a channelled valley bottom wetland.
• Section 21(f) – Discharging waste or water containing waste into a water resource
through a pipe, canal. Sewer, sea outfall or other conduit:
o Discharge of backwash effluent from cleaning the facility into a nearby
wetland.
However, Elgin decided not to discharge into the wetland, but instead the Water Treatment
Plant (WTP) backwash water is being re-directed into the Municipal effluent grid.
Water Use to be Licenced:
Elgin currently trigger water uses in terms of Section 21 of the National Water Act, 1998 (Act
No. 36 of 1998) (NWA) which require authorisation from the DHSWS in the form of an
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Integrated Water Use License Application (IWULA). The following water uses have been
identified for authorisation and can be seen in the table below:
• Section 21(a) – Taking water from a water resource:
o Abstraction of water from a borehole located on the property.
• Section 21(b) – Storing water:
o Storing water in a reservoir located on the property (falls within the GA
limit).
• Section 21(c) and (i) - Impeding or diverting the flow of water in a watercourse and
altering the beds, banks, course or characteristics of a water course:
o Infrastructure within 500m of a channelled valley bottom wetland.
Water Uses – Elgin Free Range Chickens
Water Use No.
Section 21(a) Water Use Description
Site Name Co-ordinates Property Volume (m³/a)
1 Groundwater abstraction for operational use
EC BH1 34° 8'56.56"S 19° 0'19.30"E
ERF 8611 127 750m3/a (350m3/day)
Water Use No.
Section 21(b) Water Use Description
Site Name Co-ordinates Property Capacity (m3)
2 Storage of clean water Elgin Reservoir
34° 8'54.60"S 19° 0'16.56"E
ERF 8611 500m3
Water Use No.
Section 21(c) and (i) Water Use Description
Site Name Co-ordinates Property Capacity (m3)
3 Infrastructure within 500m of a channelled valley bottom wetland
Elgin’s facility 34° 8'53.40"S 19° 0'17.11"E
ERF 8611 Not applicable
Potential Environmental Impacts
The following potential impacts will have to be monitored and evaluated:
• Impact of abstraction on surrounding groundwater levels;
• Impact of operation of WTP within the DHSWS 20m buffer; and
• Impact of site run-off water into the Channelled Valley Bottom Wetland.
These impacts have been identified and mitigation measures provided and detailed in Section
5.5 of this report.
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CONTENTS PAGE
1 INTRODUCTION .......................................................................................................................... 1
1.1 ACTIVITY BACKGROUND .................................................................................................................. 1 1.2 CONTACT DETAILS ......................................................................................................................... 2 1.3 REGIONAL SETTING AND LOCATION OF ACTIVITY .................................................................................. 2
1.3.1 Regional Setting ................................................................................................................ 2 1.3.2 Magisterial District and Local Municipality ...................................................................... 3
1.4 PROPERTY DESCRIPTION .................................................................................................................. 3 1.5 PURPOSE OF THE REPORT ................................................................................................................ 6
2 CONCEPTUALISATION OF THE ACTIVITY ..................................................................................... 7
2.1 DESCRIPTION OF THE ACTIVITY ......................................................................................................... 7 2.2 EXTENT OF THE ACTIVITY ................................................................................................................. 7 2.3 KEY ACTIVITY RELATED PROCESSES AND PRODUCTS .............................................................................. 7 2.4 ACTIVITY LIFE DESCRIPTION ............................................................................................................. 9 2.5 ACTIVITY INFRASTRUCTURE DESCRIPTION ......................................................................................... 10 2.6 KEY WATER USES AND WASTE STREAMS .......................................................................................... 11
2.6.1 Water Uses ..................................................................................................................... 11 2.6.2 Waste Streams ................................................................................................................ 11
2.7 ORGANISATIONAL STRUCTURE OF ACTIVITY ....................................................................................... 12 2.8 BUSINESS AND CORPORATE POLICIES ............................................................................................... 14
2.8.1 Sustainability Policy ........................................................................................................ 14 2.8.2 Environment, Health and Safety (EHS) Policy ................................................................. 16
3 REGULATORY WATER AND WASTE MANAGEMENT FRAMEWORK ............................................ 16
3.1 SUMMARY OF ALL WATER USES ..................................................................................................... 16 3.2 EXISTING LAWFUL WATER USE ....................................................................................................... 16 3.3 RELEVANT EXEMPTIONS ................................................................................................................ 17 3.4 GENERALLY AUTHORISED WATER USES ............................................................................................ 17 3.5 NEW WATER USES TO BE LICENSED ................................................................................................. 18 3.6 WASTE MANAGEMENT ACTIVITIES (NEM:WA) ................................................................................ 20 3.7 WASTE RELATED AUTHORISATIONS ................................................................................................. 21 3.8 OTHER AUTHORISATIONS (EIAS, EMPS, RODS, REGULATIONS) ........................................................... 21 3.9 LEGISLATION ............................................................................................................................... 22
3.9.1 Constitution of South Africa, 1996 (Act No.108 of 1996) ................................................ 22 3.9.2 National Environmental Management Act, 1998 (Act No. 107 of 1998) ........................ 22 3.9.3 The National Water Act, 1998 (Act No.36 of 1998) ........................................................ 23
4 PRESENT ENVIRONMENTAL SITUATION .................................................................................... 26
4.1 CLIMATE .................................................................................................................................... 26 4.1.1 Regional Climate ............................................................................................................. 26 4.1.2 Rainfall ............................................................................................................................ 26 4.1.3 Evaporation..................................................................................................................... 26
4.2 SURFACE WATER ......................................................................................................................... 26 4.2.1 Water Management Area (WMA) .................................................................................. 26 4.2.2 Surface Water Hydrology ................................................................................................ 26 4.2.3 Surface Water Quality .................................................................................................... 28 4.2.4 Mean Annual Run-off ...................................................................................................... 29 4.2.5 Resource Class and River Health ..................................................................................... 29 4.2.6 Receiving Water Quality Objectives and Reserve ........................................................... 29 4.2.7 Surface Water User Survey ............................................................................................. 31 4.2.8 Sensitive Areas Survey (Wetlands) .................................................................................. 31
4.3 GROUNDWATER .......................................................................................................................... 39 4.3.1 Aquifer Characterisation ................................................................................................. 40
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4.3.2 Aquifer Testing ................................................................................................................ 40 4.3.3 Hydrocensus .................................................................................................................... 41 4.3.4 Groundwater Quality ...................................................................................................... 45 4.3.5 Potential Pollution Source Identification ........................................................................ 46 4.3.6 Groundwater Reserve Determination ............................................................................. 46
4.4 SOCIO-ECONOMIC ENVIRONMENT................................................................................................... 51 4.4.1 Regional Context ............................................................................................................. 51 4.4.2 Local Context .................................................................................................................. 51
5 ANALYSIS AND CHARACTERIZATION OF THE WATER USE ACTIVITY .......................................... 55
5.1 SITE DELINEATION FOR CHARACTERIZATION ...................................................................................... 55 5.2 WATER AND WASTE MANAGEMENT ............................................................................................... 55
5.2.1 Process Water ................................................................................................................. 55 5.2.2 Stormwater ..................................................................................................................... 56 5.2.3 Groundwater ................................................................................................................... 56 5.2.4 Waste .............................................................................................................................. 56
5.3 OPERATIONAL MANAGEMENT ........................................................................................................ 60 5.3.1 Organisational Structure................................................................................................. 60 5.3.2 Resources and Competence ............................................................................................ 61 5.3.3 Education and Training ................................................................................................... 61 5.3.4 Internal and External Communication ............................................................................ 61 5.3.5 Awareness Raising .......................................................................................................... 62
5.4 MONITORING AND CONTROL ......................................................................................................... 63 5.4.1 Water Quality Monitoring and Bio-monitoring .............................................................. 63 5.4.2 Groundwater Monitoring ................................................................................................ 67 5.4.3 Waste Monitoring ........................................................................................................... 67
5.5 RISK ASSESSMENT/ BEST PRACTICE ASSESSMENT ............................................................................... 68 5.5.1 Impact Assessment Methodology ................................................................................... 68 5.5.2 Impacts Identified ........................................................................................................... 69
5.6 ISSUES AND RESPONSES FROM PUBLIC CONSULTATION PROCESS ........................................................... 72 5.6.1 Stakeholder Database ..................................................................................................... 72 5.6.2 Landowner Consultation ................................................................................................. 72 5.6.3 Notification Documents .................................................................................................. 72 5.6.4 Public Comment Period ................................................................................................... 72
5.7 MATTERS REQUIRING ATTENTION/ PROBLEM STATEMENT .................................................................. 73 5.8 ASSESSMENT OF LEVEL AND CONFIDENCE OF INFORMATION ................................................................. 73
6 WATER AND WASTE MANAGEMENT ........................................................................................ 73
6.1 WATER AND WASTE MANAGEMENT PHILOSOPHY .............................................................................. 73 6.1.1 Process Water ................................................................................................................. 73 6.1.2 Stormwater ..................................................................................................................... 73 6.1.3 Groundwater ................................................................................................................... 74 6.1.4 Waste .............................................................................................................................. 74
6.2 STRATEGIES ................................................................................................................................ 74 6.2.1 Process Water ................................................................................................................. 74 6.2.2 Storm Water ................................................................................................................... 74 6.2.3 Groundwater ................................................................................................................... 74 6.2.4 Waste .............................................................................................................................. 75
6.3 PERFORMANCE OBJECTIVES/ GOALS ................................................................................................ 75 6.4 MEASURES TO ACHIEVE AND SUSTAIN PERFORMANCE OBJECTIVES ........................................................ 76 6.5 OPTION ANALYSES AND MOTIVATION FOR IMPLEMENTATION OF PREFERRED OPTIONS ............................. 76 6.6 IWWMP ACTION PLAN ............................................................................................................... 76 6.7 CONTROL AND MONITORING ......................................................................................................... 77
6.7.1 Monitoring of Change in Baseline (Environment) Information ....................................... 77 6.7.2 Audit and Report on Performance Measures.................................................................. 78
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6.7.3 Audit and Report on Relevance of IWWMP Action Plan ................................................. 78
7 CONCLUSION ............................................................................................................................ 78
7.1 REGULATORY STATUS OF ACTIVITY .................................................................................................. 78 7.2 STATEMENT OF WATER USES REQUIRING AUTHORISATION .................................................................. 79 7.3 SECTION 27 MOTIVATION ............................................................................................................. 79 7.4 PROPOSED LICENCE CONDITIONS .................................................................................................... 79
8 REFERENCES ............................................................................................................................. 80
LIST OF FIGURES
Figure 1.1: Elgin Chicken Locality Map ............................................................... 4 Figure 1.2: Elgin Chicken Property Map............................................................... 5 Figure 2.1: Elgin's company history .................................................................. 10 Figure 2.2: Elgin's organisational structure ........................................................ 13 Figure 3.1: Elgin Free Range Chickens Reservoir .................................................. 18 Figure 3.2: Elgin's Proposed Water Uses ............................................................ 19 Figure 4.1: WMA and Quaternary Catchments ..................................................... 27 Figure 4.2: Water Treatment Plant backwash water already collected and redirected into the municipal effluent grid ................................................................................ 30 Figure 4.2: (Left) CVBW has been infilled with building rubble; (right) preferential flow paths within the CVBW conveying stormwater from the adjacent urban and industrial areas ..... 31 Figure 4.3: Photographs of the Klipdrif River, upstream of the study area. .................. 32 Figure 4.4: Photograph of the Klipdrif River, downstream of the study area. ................ 32 Figure 4.5: Photographs illustrating the location of the Water Treatment Plant (WTP) effluent discharge point draining into the wetland in the investigation area ........................... 33 Figure 4.6: (Left) contaminated surface water runoff leaving the study area; (right) preferential flow path formed as a result of the contaminated run-off into the CVBW. .... 34 Figure 4.7: Delineated watercourses associated with the study and investigation areas ... 35 Figure 4.8: A close up of the study area indicating the various outlet points into the adjacent CVBW .................................................................................................... 36 Figure 4.9: Hydrocensus Borehole localities ....................................................... 44 Figure 4.10: Delineated Sub-catchment with WARMS Boreholes shown on map .............. 49 Figure 4.11: Theewaterskloof Municipal locality (Theewaterskloof Municipality, 2020) .... 51 Figure 4.12: Population structure (Theewaterskloof Municipality, 2020) ...................... 53 Figure 4.13: Social realities (Theewaterskloof Municipality, 2020) ............................. 55 Figure 5.1: Awareness raising topic at Elgin ....................................................... 63 Figure 5.2: Recommended Monitoring Points (MP) in relation to the study area and WTP discharge point ......................................................................................... 65
LIST OF TABLES
Table 1.1: Contact Details .............................................................................. 2 Table 1.2: Property details of farm ................................................................... 3 Table 3.1: New water uses being applied for ...................................................... 18 Table 4.1: RQO for the Palmiet River (GN 42053) ................................................. 30 Table 4.2: Classification of the watercourses located in the investigation area ............. 35 Table 4.3: The PES Category result for the Channelled Valley-Bottom Wetland ............. 36 Table 4.4: Ecosystem service provision for the Channelled Valley-Bottom Wetland ......... 37 Table 4.5: EIS result for the Channelled Valley-Bottom Wetland ............................... 38 Table 4.6: Hydrocensus Borehole Information ..................................................... 43 Table 4.7: Target Water Quality Range for Iron with effects.................................... 45 Table 4.8: Quaternary Catchment Details for Catchment G40C ................................ 46
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Table 4.9: WARMS Borehole/s Details ............................................................... 46 Table 4.10: Groundwater Balance Calculation for the delineated sub-catchment ........... 47 Table 4.11: Guide for determining the level of stress of a groundwater resource unit ..... 50 Table 4.12: Theewaterskloof population (Theewaterskloof Municipality, 2020) ............. 52 Table 5.1: Water usage at Elgin ..................................................................... 55 Table 5.2: GPS co-ordinates for recommended monitoring points .............................. 64 Table 5.3: General limit values for the discharging of wastewater into a water resource (GN 665 of 2013) ............................................................................................ 64 Table 5.4: Proposed monitoring requirements for Elgin .......................................... 66 Table 5.5: Recommended Water Level Monitoring Plan for Borehole EC BH1 ................. 67 Table 5.6: Severity .................................................................................... 68 Table 5.7: Spatial Scale - How big is the area that the aspect is impacting on? .............. 68 Table 5.8: Duration .................................................................................... 69 Table 5.9: Frequency of the activity - How often do you do the specific activity? .......... 69 Table 5.10: Frequency of the incident/impact - How often does the activity impact on the environment? ........................................................................................... 69 Table 5.11: Legal Issues - How is the activity governed by legislation? ........................ 69 Table 5.12: Detection - How quickly/easily can the impacts/risks of the activity be detected on the environment, people and property? ........................................................ 69 Table 5.13: Impact Ratings ........................................................................... 69 Table 5.14: Impact descriptions for Elgin .......................................................... 70 Table 6.1: IWWMP Action Plan ....................................................................... 77
LIST OF ANNEXURES
ANNEXURE A Hydrogeological Investigation
ANNEXURE B Freshwater Ecological Assessment
ANNEXURE C Section 27 Motivation
ANNEXURE D Waste Management Procedure
ANNEXURE E Environmental Authorisation Issued
ANNEXURE F Stormwater Layout Plan
ANNEXURE G Discharge Permit
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1 INTRODUCTION
1.1 Activity Background
The history of Elgin Free Range Chickens (Elgin) dates back to 1996 where chickens were
raised for family and friends. In 1998, ‘Elgin Free Range Chickens’ was born as a backyard
business suppling local businesses on order. The business grew over 2 years and an abattoir
was bought and registered. A great demand saw Elgin producing 15 000 chickens per week.
By 2007, Elgin bought their own hatchery to supply their growers and by 2008, Elgin received
their first certification with Hazard Analysis Critical Control Points (HACCP). In 2012, Elgin
opened their first factory store to the public and in 2013, they upgraded their Food Safety
System to ISO22000:2005.
Three more factory stores were opened (Somerset West, Montague Gardens and Tokai) in
2014 and in 2015, and another factory store in Durbanville was opened. In addition, Parklands
and Kenilworth stores opened in 2017 with a store in Hermanus and George opened in 2018.
In 2018, Elgin bought their first farm, Löttershof and also expanded into the hospitality sector
by launching their Food Service Product Range. Their abattoir was expanded a second time
and Elgin opened 2 more factory stores in Paarl and Mitchells Plain in 2019. From 40 000
chickens per week in 2007, to 132 000 chickens per week in 2020, Elgin has grown into the
leading exclusively free-range chickens’ supplier in South Africa that is dominating the
market.
Elgin has a poultry abattoir facility located in Grabouw in the Western Cape. The facility falls
within the Theewaterskloof Local Municipality which forms part of the Overberg District
Municipality. The facility is located within the G40C quaternary catchment within the Breede-
Gouritz Water Management Area (WMA).
Elgin currently triggers water uses in terms of Section 21 of the National Water Act, 1998 (Act
No. 36 of 1998) (NWA) which require authorisation from the Department Human Settlements,
of Water and Sanitation (DHSWS) in the form of an Integrated Water Use License Application
(IWULA). The following water uses have been identified for authorisation:
• Section 21(a) – Taking water from a water resource (abstraction of water from a
borehole);
• Section 21(b) – Storing water (falling within the General Authorisation limits);
• Section 21(c) – Impeding or diverting the flow of water in a watercourse; and
• Section 21(i) – Altering the beds, banks, course or characteristics of a water course.
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GCS Water and Environment (Pty) Ltd (GCS) were appointed to undertake the IWULA process
in order to authorise the required water uses triggered. This report serves as the technical
report pertaining to the IWULA.
1.2 Contact Details
Elgin Free Range Chickens (Pty) Ltd is the applicant for this application. Refer to Table 1.1
for the contact details of the applicant as well as the details of the consultant compiling this
application.
Table 1.1: Contact Details
Applicant
Company Name Elgin Free Range Chickens (Pty) Ltd
Telephone Number +27 (0) 21 859 2795
Contact Person Cato Rabie
Contact Person Mobile Number +27 (0) 83 65 0144
Email Address [email protected]
Postal Address P.O Box 1176 Grabouw 7160
Physical Address Industrial Road Grabouw Western Cape
Water Use Authorisation Consultant
Company Name GCS Water and Environment (Pty) Ltd
Telephone Number 011 803 5726
Contact Person Shayna-Ann Cuthbertson / Kate Cain
Email Address [email protected] / [email protected]
Postal Address PO Box 2597 Rivonia 2128
Physical Address 63 Wessel Road Rivonia 2128
1.3 Regional Setting and Location of Activity
1.3.1 Regional Setting
The facility that is owned by Elgin with regards to this application is located in Grabouw in
the Western Cape. Grabouw is located approximately 65km south-east of Cape Town, over
Sir Lowry's Pass from Somerset West, along the N2 highway. The town is the commercial
centre for the vast Elgin Valley, the largest single export fruit-producing area in Southern
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Africa, which extends between the Hottentots-Holland, Kogelberg, Groenland, and Houwhoek
Mountains. Refer to Figure 1.1 for a map showing the location of the facility.
1.3.2 Magisterial District and Local Municipality
The facility falls within the Theewaterskloof Local Municipality which forms part of the
Overberg District Municipality. Refer to Figure 1.1 for a map showing the location of the
facility within the municipal boundaries.
1.4 Property Description
Elgin’s project area ranges over an area of approximately 2.3640 hectares (Ha) and is located
on the northern side of Industrial Road, Grabouw, Western Cape Province of South Africa
(Figure 1.2).
Table 1.2 lists the property details of the facility where the water uses occur at Elgin.
Table 1.2: Property details of farm Property Name Land Owner Title Deed
ERF 8611 Grabouw in the Theewaterskloof Municipality Division of Caledon
Elgin Poultry Abattoir Pty Ltd
T000013396/2019
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Figure 1.1: Elgin Chicken Locality Map
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Figure 1.2: Elgin Chicken Property Map
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1.5 Purpose of the Report
This document serves as the technical report to motivate the authorisation of the water uses
triggered by Elgin. As per Annexure B of Regulation GN267, the document has been compiled
in the form of an Integrated Water and Waste Management Plan (IWWMP) as the Section
21(a), (b), (c) and (i) is required for an industrial activity.
The purpose of the report therefore includes:
• Compilation of a site specific, implementable, management plan addressing all the
identified water use and waste management relates aspects of a specific activity, in
order to meet set goals and objectives in accordance with Integrated Water Resource
Management (IWRM) principles;
• Provision of a management plan to guide the water user regarding the water and
waste related measures which should be implemented on site in a progressive,
structured manner in the short, medium and long term;
• Documentation of all the relevant information, as specified in the IWWMP Guideline
as compiled by the DHSWS, to enable DHSWS to make a decision regarding the
authorisation of a water use;
• Clarification of the content of the IWWMP for DHSWS officials and the water users,
as the various regional offices of DHSWS might have different interpretations
regarding the contents of the IWWMP;
• Standardisation of the format of supporting documentation which DHSWS requires
during the submission of an IWULA;
• Provision of guidance on the content of information required in an IWWMP as part of
the water use authorisation process and level of detail that DHSWS requires to enable
them to evaluate the supporting documentation to make a decision on authorising a
water use; and;
• Ensuring that a consistent approach is adopted by DHSWS and the various Regional
Offices and Catchment Management Agencies (CMA) with regards to IWWMPs.
The report also strives to show the DHSWS that the selected management measures included
into the IWWMPs action plan adhere to the SMART concept which refers to:
• S – Sustainable;
• M – Measurable;
• A – Achievable;
• R – Resources Allocated; and
• T – Timeframe Specific.
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2 CONCEPTUALISATION OF THE ACTIVITY
2.1 Description of the Activity
Elgin is a poultry abattoir located in Grabouw, Western Cape. Chickens that have reached a
certain age are brought to the abattoir to be slaughtered. A wide variety of chicken products
are produced and provided to a variety of market sectors.
2.2 Extent of the Activity
The IWULA is developed to cover the project’s entire area of operations in order to manage
all water issues on site. The project area will be over a total area of 2 3640Ha.
2.3 Key Activity Related Processes and Products
Breeding & Rearing Farms - TWK Chicks (Pty) Ltd
At our breeding and rearing farms, we raise chicken flocks for
the purpose of laying fertilized eggs for broiler production.
Broiler = A chicken bred and raised specifically for meat
production.
Hens usually begin laying fertilized eggs at 16-21 weeks of age.
These fertilized eggs are removed daily from the chicken houses
and are taken to our hatchery.
Laying flocks are depopulated when egg production declines at
around 60 weeks.
Hatchery - Caledon Hatchery (Pty) Ltd
Fertilized eggs are collected and transported to our Hatchery
where they are stored in optimal hygienic conditions. The
hatchery then sets and hatches eggs according to the market
demand for chicken products.
As the 1-day old chicks hatch from eggs, they are vaccinated and
placed on a Free-Range Grower farm within 24 hours.
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Free Range Grower Farms – Elgin Free Range Chickens (EFRC)
Agri Operations (Pty) Ltd
We have seven contracted grower farms raising broiler chicks in
a free- range environment.
1-Day-old chicks are placed and raised in the free-range farm
system to about 36-38 days, dependent on market demand, then
they are depopulated for slaughter.
All our farms are recognised by the South African Government:
The Department of Director Veterinary Quarantine and Public
Health, Department of Agriculture, Land Reform and Rural
Development. Our grower farms follow strict rearing codes to
meet the highest possible standards of Free-Range broiler
production and animal welfare as set out by International,
National and Provincial legislation and guidelines.
They are audited by independent audit companies such as the
UK body FAI Farms and local certification bodies LTL and ASFQ.
Primary Processing - Elgin Poultry Abattoir (Pty) Ltd
All Elgin Free Range Chickens are slaughtered at one site,
registered as - Elgin Poultry Abattoir - Registration Certificate
No HT A7 003P.
Our Free-Range system is built on Animal welfare principles and
utmost care is taken during catching, transport and slaughter.
These processes are carefully micromanaged daily and audited
regularly by independent external auditors, international animal
welfare experts, the NSPCA and local authorities. Slaughtered
carcasses are washed, cleaned and chilled for further processing
into a wide product range for the market.
Secondary processing – Elgin Free Range Chickens (Pty) Ltd
We produce a wide variety of chicken products to a variety of
market sectors:
Rough Offal: Organs: Heads, Feet, Mala, Bags & Bulk;
Red Offal: Organs: Necks, Livers, Hearts, Gizzards, Bags & Bulk;
Chunks: Chicken bones and Soup Packs;
Fillets: Breast Fillets, Thigh Fillets, Drum Fillets,
Tenderloins/Mini Fillets, Breast Strips; Bone-less, Skin-
on/Skinless;
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Portions: Breasts, Leg Quarters (LQ), Thighs, Drums, Wings;
Bone- in, Skin-on/Skinless; and
Whole Birds: Whole Birds (WB).
Outsourced Processed Products: All finished products that are
produced by approved FMCG companies to be sold under EFRC
branding – EFRC Crumbed Range; EFRC Smoked Range;
Value Added (VA) – Rotisserie: Butter basted WB;
VA Roasts: Whole or partially de-boned WB, Stuffed and butter
basted;
VA - Butterfly (B/Fly): Whole or Half Chickens, flavoured and
butter basted;
VA – Foil Roasts: Fillets; Fully Deboned WB; Wings; Cocktail
Wings; Drums; Thighs; LQ; LQ Steaks that are flavoured and
butter basted;
VA-Mince: Flavoured and non-flavoured minced lines including
mince and formed mince products (meat balls and patties);
VA – Sausages: Variety of flavours and formats;
VA – Portions: Variety of flavoured portions; and
VA – Skewers: Skin-on/Skinless; Bone-in/Boneless; Chicken
skewers in a variety of flavours.
Chicken Waste: Blood, Feathers, Condemned material collected
and disposed of by licensed waste removal company Averda to
landfill. Various projects and initiatives underway to support
‘zero to landfill’ initiative.
2.4 Activity Life Description
The history of Elgin Free Range Chickens (Elgin) dates back to 1996 where chickens were
raised for family and friends. From small scale production in 1996 to producing 132 000
chickens per week in 2020, Elgin has grown into the leading exclusively free-range chickens’
supplier in South Africa. Elgin’s life description and history can be seen in Figure 2.1.
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Figure 2.1: Elgin's company history
2.5 Activity Infrastructure Description
All Elgin Free Range Chickens are slaughtered at one site registered with the Department of
Agriculture as - Elgin Poultry Abattoir, Registration Certificate No HT A7 003P. The abattoir
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is purpose built, and was expanded in 2017 to increase the capacity for the increase in market
demand as per section 3.8 below.
2.6 Key Water Uses and Waste Streams
2.6.1 Water Uses
With the drought conditions currently occurring in the Western Cape, Elgin have opted to
supplement the municipal water with groundwater that is abstracted from a borehole located
on the property.
The abstraction for groundwater from a borehole is a considered a water use in terms of
Section 21 of the National Water Act, 1998 (Act No. 36 of 1998) (NWA). The storage of water
is also considered a water use in terms of Section 21 as well as Elgin’s facility being within
500m of a wetland. These water uses require authorisation from the DHSWS. As a result, the
following water uses are being applied for as part of this application:
• Section 21(a) – Taking water from a water resource:
o Abstraction of water from a borehole located on the property.
• Section 21(b) – Storing water:
o Storing of Potable SANS 241 water in a reservoir located on the property (falls
within the GA limit). The water in the reservoir is received from the water
treatment plant. The reservoir water supplies the abattoir and factory with
clean water to slaughter chicken and process the carcasses for the market.
In addition, the water is used for drinking water and as an ingredient in food
(i.e. sausages).
• Section 21(c) and (i) - Impeding or diverting the flow of water in a watercourse and
altering the beds, banks, course or characteristics of a water course:
o Infrastructure within 500m of a channelled valley bottom wetland.
Refer to Section 3 for detailed information regarding the water uses for Elgin.
2.6.2 Waste Streams
The waste streams associated with the Elgin are:
• General waste;
• Blood waste;
• Condemned waste;
• Feather waste;
• Mala sweepings;
• Chicken manure;
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• Hazardous waste;
• Biohazardous waste; and
• Effluent (water, organic matter, chemicals and residual blood particles).
Refer to Section 5.2.4 of this report for more details pertaining to the waste generated on
site and the management thereof.
2.7 Organisational Structure of Activity
Refer toFigure 2.2 for the organisational structure at Elgin.
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Figure 2.2: Elgin's organisational structure
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2.8 Business and Corporate Policies
2.8.1 Sustainability Policy
The Sustainability Policy guides Elgin in their efforts to embed sustainability into all aspects
of manufacturing, processing and distribution of poultry meat to the market.
This policy helps:
• To meet all applicable legal environmental requirements;
• To limit resource consumption and waste;
• To increase efficiency;
• To differentiate Elgin from their competition; and
• To improve their reputation with stakeholders.
2.8.1.1 Elgin’s Promise, Mission and Vision
Promise:
Elgin Free Range Chickens is a lifestyle, not a label.
Vision:
To be recognised as the leading supplier of the finest quality, free range chicken, humanely
raised and produced, to a rapidly growing market. To attract and inspire customers from all
market sectors with our product quality and innovation, so as to achieve a strong national
and global footprint, carried and serviced by well-run, ethical and sustainable business units,
with high productivity and efficiency.
Mission:
To support the Vision, Elgin will create diverse product ranges directed at the defined needs,
requirements and price-points of each market sector and will supply & deliver to the
identified markets with pro-active, efficient and collaborative operational and logistical
solutions. Elgin’s strong sales and marketing drive, conveying the right message on the right
platform and engaging the right customer, will enable them to expand into new markets and
regions. Elgin will inspire our staff to grow within the Company by recognising their
achievements and contributions. Elgin will be responsible in their processes and help build a
sustainable business and community.
To enable this, Elgin will:
• Always act humanely and ethically;
• Develop an effective organisation of skilled & committed people;
• Ensure the superior quality of their products and services;
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• Be effective in their growing, processing and technical operations;
• Be effective in the use of their finances and assets;
• Produce accurate and timeous marketing and financial information; and
• All to the advantage of their key stakeholders.
Elgin’s Commitments:
Elgin is cognisant of the environmental challenges that the area faces, such as the scarcity
of natural resources and the decline in biodiversity. Being a trusted producer of authentic
free-range chicken, Elgin Free Range Chickens acknowledges the need to meet their customer
expectations on environmental responsibilities and practices. Elgin knows that sustainable
considerations within all business decisions made will be essential to the success in growing
their business and to create lasting value.
Elgin Free Range Chickens is therefore committed to:
• Monitor Key Performance Indicators for the goals that have the greatest impact on
sustainability;
• Monitor efficiencies, quality and productivity which translates to ‘doing more with
fewer resources and less waste’;
• Recover value from by-products;
• Responsibly re-use packaging and re-cycle redundant equipment and packaging;
• Develop new lines with packaging reductions taken into consideration;
• Incorporate environmentally sustainable solutions where possible with new building
projects and renovations;
• Source broilers directly from approved, local contracted growers;
• Source ingredients, chemicals and food contact material from approved suppliers;
• Set standards for our key suppliers to improve the sustainability of the goods and
services that we purchase;
• Avoid unnecessary travel throughout the business;
• Provide training for their employees on sustainability issues;
• Have the systems and processes in place to ensure that they comply with all relevant
laws and regulations governing business, society, the environment and health and
safety;
• Be an active and responsible participant in the community where they operate;
• Respect the social and cultural diversity of their employees and strive to attract and
retain the best talent in the market. This includes providing a safe and healthy work
place; and
• Support local charities and create opportunities for employees to matriculate and
become computer literate.
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2.8.2 Environment, Health and Safety (EHS) Policy
Elgin recognise that the effective management of Environment, Health and Safety (EHS)
management system is an integral part of their overall business performance. Therefore, they
are committed to provide their employees with all the necessary knowledge and equipment
to ensure a safe and healthy working environment. Elgin will continually strive to meet a
ZERO HARM approach to all employees, contractors, visitors and the environment.
It is the intent of this policy that all activities that are executed by or on behalf of Elgin Free
Range Chickens (EFRC) are done according to:
• A zero-tolerance approach regarding company safety values;
• Identify, assess and manage risks regarding health and safety of employees, external
parties, the local community and the environment;
• Compliance to applicable regulations, municipal bylaws, as well as EFRC policies and
procedures;
• Uphold EHS principles with integrity and continually strive to improve the
management of workplace risks;
• Safe practices and procedures in connection with the procurement, handling, use and
disposal of hazardous substances;
• Established requirements for responding to incidents and emergencies;
• Clearly assigned roles and responsibilities;
• Continually improve the EHS competencies of EFRC employees through internal and
external training; and
• Provision of personal protective equipment (PPE), as applicable.
3 REGULATORY WATER AND WASTE MANAGEMENT FRAMEWORK
3.1 Summary of all Water Uses
Refer to Section 3.5 for the summary of water uses triggered in terms of Section 21 of the
NWA that are being applied for as part of this application. There are no previous water uses
licensed at the facility.
3.2 Existing Lawful Water Use
Existing Lawful Water Use (ELWU) is defined in Section 32 of the National Water Act 1998,
(Act No. 36 of 1998) (NWA) as any water use which has taken place at any time during a
period of two years immediately before the date of commencement of the NWA or which has
been declared an existing lawful water use under Section 33 and which was authorised by or
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under any law which was in force immediately before the date of commencement of the
NWA.
There are no existing lawful water use taking place on the property. All water uses triggered
are being applied for as part of the IWULA and will be authorised in terms of a Water Use
License issued by the DHSWS.
3.3 Relevant Exemptions
Not applicable to this application.
3.4 Generally Authorised Water Uses
The water uses triggered for this activity includes Section 21(a), (b), (c) and (i). Section 21(a)
falls outside the General Authorisation (GA) limits, however, Section 21(b) falls within the
GA limits and is also being applied for in this application.
Elgin is storing clean water at the facility. The details of the storage facility are as follows:
• A reservoir was installed in an existing open structure with an existing concrete
foundation on Previous Erf 2759 (2 576 m2) (Figure 3.1);
• The reservoir currently has a capacity of 250m3; and
• It is proposed increase this capacity to 500m3.
Government Gazette Notice 538 of 2016 (dated 2nd September 2016) states that the GA limits
for the storage water within quaternary catchment G40C is 2 000m3. The proposed storage
of 500m3 therefore falls within the GA limits.
Refer to Figure 3.1 for a picture of the reservoir storage tank.
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Figure 3.1: Elgin Free Range Chickens Reservoir
3.5 New Water Uses to be Licensed
The water uses triggered for Elgin require authorisation in terms of Section 21 (a) and (b) of
the NWA. Refer to Table 3.1 for a summary of the water uses being applied for. The
highlighted water use falls within the GA limits as discussed in Section 3.4 but has been
included as part of this application for authorisation. Refer to Figure 3.2 for the localities of
the water uses being applied for.
Table 3.1: New water uses being applied for Water Uses – Elgin Free Range Chickens
Water Use No.
Section 21(a) Water Use Description
Site Name Co-ordinates Property Volume (m³/a)
1 Groundwater abstraction for operational use
EC BH1 34° 8'56.56"S 19° 0'19.30"E
ERF 8611 127 750m3/a (350m3/day)
Water Use No.
Section 21(b) Water Use Description
Site Name Co-ordinates Property Capacity (m3)
2 Storage of clean water Elgin Reservoir
34° 8'54.60"S 19° 0'16.56"E
ERF 8611 500m3
Water Use No.
Section 21(c) and (i) Water Use Description
Site Name Co-ordinates Property Capacity (m3)
3 Infrastructure within 500m of a channelled valley bottom wetland
Elgin’s facility 34° 8'53.40"S 19° 0'17.11"E
ERF 8611 Not applicable
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Figure 3.2: Elgin's Proposed Water Uses
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3.6 Waste Management Activities (NEM:WA)
The National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (NEM:WA)
fundamentally reformed the law regulating waste management, and for the first time
provides a coherent and integrated legislative framework addressing all the steps in the waste
management hierarchy. The objectives of the NEM:WA are to protect health, well-being and
the environment by providing reasonable measures for, inter alia, remediating land where
contamination presents, or may present, a significant risk of harm to health or the
environment. The objectives of the NEM: WA are structured around the steps in the waste
management hierarchy, which is the overall approach that informs waste management in
South Africa. The waste management hierarchy consists of options for waste management
during the lifecycle of waste, arranged in descending order of priority; i.e. waste avoidance,
reduction, re-use, recycling, recovery, treatment, and safe disposal as a last resort.
NEMA, as previously mentioned, introduced a number of additional guiding principles into
South African environmental legislation, including the life-cycle approach to waste
management, producer responsibility, the precautionary principle and the polluter pays
principle (i.e. the sustainability principles as contained in Section 2 of NEMA). Section 5(2)
of the NEM: WA stipulates that the Act should be interpreted and guided in accordance with
these sustainability principles. The NEM: WA, furthermore, echoes the duty of care provision,
in terms of Section 28 of NEMA, by obliging holders of waste to take reasonable measures to
implement the waste management hierarchy. Section 16(1) of the NEM: WA provides that:
“A holder of waste must, within the holder’s power, take all reasonable measures to –
a) Avoid the generation of waste and where such generation cannot be avoided,
to minimise the toxicity and amounts of waste that are generated;
b) Reduce, re-use, recycle and recover waste;
c) Where waste must be disposed of, ensure that the waste is treated and
disposed of in an environmentally sound manner;
d) Manage the waste in such a manner that it does not endanger health or the
environment or cause a nuisance through noise, odour or visual impacts;
e) Prevent any employee or any person under his or her supervision from
contravening this Act; and
f) Prevent the waste from being used for an unauthorised purpose.”
While the NEM: WA creates a comprehensive legal framework for waste management, its
provisions will be meaningless without measures to monitor and, where necessary, enforce
compliance. Compliance monitoring is supported by a range of reporting provisions contained
in the NEM:WA. In addition to compliance reports for waste management licences and norms
and standards, the NEM: WA has provisions for annual performance reports on the
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implementation of provincial and local Integrated Waste Management Plans. Industry Waste
Management Plans are subject to review at intervals to be determined by the authority that
mandated the plan, which in the case of mines would be the DMR. Furthermore,
Environmental Management Inspectors and Waste Management Officers can request a Waste
Impact Report where they suspect a contravention of the Act, licence conditions or
exemption conditions.
The NEM: WA provides for a licensing regime specific to waste management activities. It
replaces the historical system of permits issued in terms of the repealed Section 20 of the
ECA. Transitional arrangements allow existing permits granted in terms of ECA to be regarded
as licences in terms of the NEM: WA until the Minister requires a licence application as per
the NEM: WA category of the waste management activity (i.e. category A or B). The NEM: WA
waste management categories determine the environmental assessment procedure (which is
the equivalent of the NEMA EIA regulations' requirements) required to obtain a licence.
Category A activities require a Basic Assessment (BA) process to be undertaken, whilst
Category B activities require a Scoping and Environmental Impact Report (S&EIR) process to
be undertaken.
The recently amended legislation concerning EIAs makes reference to the development of
norms and standards which may guide EIA applications and Environmental Authorisations in
the future. The production of appropriate norms and standards for specific forms of
developments is ongoing and it is anticipated that this will eventually provide the opportunity
to further streamline the EIA procedures in relation to particular forms of developments.
Depending on the location of developments, it is important to note that applicable Norms
and Standards are no different from regulations in law in that they are both equally binding.
No waste management activities at Elgin have been triggered according to the NEM:WA.
3.7 Waste Related Authorisations
Elgin has a municipal discharge permit for effluent that is discharged into the sewer system.
The discharge permit from the Theewaterskloof Municipality is dated 18th February 2019 and
is attached as Annexure D.
3.8 Other Authorisations (EIAs, EMPs, RODs, Regulations)
Elgin was issued with an Environmental Authorisation in terms of the National Environmental
Management Act (NEMA), 1998 (Act No. 107 of 1998) on the 24th February 2015 (EIA Ref:
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16/3/1/1/E4/11/2068/14) (Annexure E). The authorisation was given for the expansion of
existing buildings and infrastructure on Erven 2759, 2760 and 2761 in two phases over a period
of four to five years in order to increase the size of existing operations at the abattoir, to
include, inter alia, the following:
• Expansion of the packing area;
• Expansion of the holding room and chillers;
• Expansion of the bulk storage area;
• Expansion of the crate washing area;
• Expansion of the price marking area;
• Construction of a new dispatch, dock levellers and a marshalling yard;
• New internal access road (ring road) to improve separate access for the live bird
trucks as required by the Department of Agriculture (one access road constructed on
Erf 2761 and one existing access road on Erf 2759); and
• A stormwater retention pond.
3.9 Legislation
3.9.1 Constitution of South Africa, 1996 (Act No.108 of 1996)
The Constitution of the Republic of South Africa, 1996 (Act No.108 of 1996) compels all to
ensure the fundamental rights of all citizens. Section 24 of the act states the following:
Everyone has the right:
a) To an environment that is not harmful to their health or wellbeing, and
b) To have an environment protected for the benefit of present and future generations
through reasonable legislative and other measures that-
I. Prevent pollution and ecological degradation;
I. Promote conservation; and
II. Secure ecologically sustainable development and use of natural resources while
promoting justifiable economic and social development.
The environmental legislation promulgated since the constitution has given legal effect to
this section of the Constitution.
3.9.2 National Environmental Management Act, 1998 (Act No. 107 of 1998)
The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) is South
Africa’s overarching framework for environmental legislation. The NEMA sets out the
principles of Integrated Environmental Management (IEM). The NEMA aims to promote
sustainable development, with wide-ranging implications for national, provincial, and local
government. Included amongst the key principles is that all development must be
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environmentally, economically and socially sustainable and that environmental management
must place people and their needs at the forefront, and equitably serve their physical,
developmental, psychological, cultural and social interest.
The NEMA is the environmental framework legislation promulgated to replace the
Environmental Conservation Act, 1989 (Act No. 73 of 1989), and ensure that the
environmental rights contemplated in Section 24 of the Constitution are realised. NEMA sets
out:
• the fundamental principles that need to be incorporated in the environmental
decision making process;
• the principles that are necessary to achieve sustainable development;
• provides for duty of care to prevent, control and rehabilitate the effect of significant
pollution and environmental degradation; and
• it allows for the prosecution of environmental crimes.
The NEMA provides for the identification of activities which will impact the environment.
These activities were promulgated in terms of Regulations 982, 983, 984 and 985, published
4 December 2014 and require environmental authorisation.
The impacts of the listed activities must be investigated, assessed and reported to the
competent authority before authorisation to commence with such listed activities can be
granted.
3.9.3 The National Water Act, 1998 (Act No.36 of 1998)
The purpose of the National Water Act, 1998 (Act No. 36 of 1998) (NWA) is to ensure that the
nation’s water resources are protected, used, developed, conserved, managed and
controlled. Sections 40 and 42 of NWA provides for the responsible authority to request public
participation and an assessment of the likely effect of the proposed licence the protection,
use, development, conservation, management and control of the water resource.
The NWA defines 11 consumptive and non-consumptive water uses in terms of Section 21 of
the NWA:
• Section 21(a): Taking water from a water resource;
• Section 21(b): Storing water;
• Section 21(c): Impeding or diverting the flow of water in a watercourse;
• Section 21(d): Engaging in a stream flow reduction activity;
• Section 21(e): Engaging in a controlled activity: irrigation of any land with waste or
water containing waste;
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• Section 21(f): Discharging waste or water containing waste into a water resource
through a pipe, canal, sewer or other conduit
• Section 21(g): Disposing of waste in a manner which may detrimentally impact on a
water resource;
• Section 21(h): Disposing in any manner of water which contains waste from, or
which has been heated in any industrial or power generation process;
• Section 21(i): Altering the bed, banks, course or characteristics of a watercourse;
• Section 21(j): Removing, discharging or disposing of water found underground if it
is necessary for the efficient continuation of an activity or for the safety of people;
• Section 21(k): Using water for recreational purposes.
Water uses that are not permissible in terms of Schedule 1 of the NWA need to be authorised
under a tiered authorisation system as a General Authorisation in terms of the General
Authorisations as published under section 39 of the NWA or as a water use licence, as provided
for in terms of section 21 of the NWA.
The authorisation system allows for the “Reserve” and provides for public consultation
processes in the establishment of strategies and decision making and guarantees the right to
appeal against such decision.
Section 27 of the NWA specifies that the following factors regarding water use authorisation
be taken into consideration:
• The efficient and beneficial use of water in the public interest;
• The socio-economic impact of the decision whether or not to issue a licence;
• Alignment with the catchment management strategy;
• The impact of the water use and possible resource directed measures; and
• Investments made by the applicant in respect of the water use in question.
Section 26(1) of the NWA states:
• Subject to subsection (4), the Minister may make regulations:
• (a) limiting or restricting the purpose, manner or extent of water use;
• (b)requiring that the use of water from a water resource be monitored,
measured and recorded;
• (c) requiring that any water use be registered with the responsible authority;
• (d) prescribing the outcome or effect which must be achieved by the
installation and operation of any water work;
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• (e) regulating the design, construction, installation, operation and
maintenance of any water work, where it is necessary or desirable to monitor
any water use or to protect a water resource;
• (f) requiring qualification for and registration of persons authorised to design,
construct, install, operate and maintain any water work, in order to protect
the public and to safeguard human life and property;
• (g) regulating or prohibiting any activity in order to protect a water resource
or instream or riparian habitat;
• (h) prescribing waste standards which specify the quantity, quality and
temperature of waste which may be discharged or deposited into or allowed
to enter a water resource;
• (i) prescribing the outcome or effect which must be achieved through
management practices for the treatment of waste, or any elements of waste,
before it is discharged or deposited into or allowed to enter a water resource;
• (j) requiring the waste discharged or deposited into or allowed to enter a
water resource be monitored and analysed, and prescribing methods for such
monitoring and analysis;
• (k) prescribing procedural requirements for license applications;
• (l) relating to transactions in respect of authorisations to use water,
including but not limited to:
▪ (i) the circumstances under which a transaction may be permitted;
▪ (ii)the conditions subject to which a transaction may take place; and
▪ (iii) the procedure to deal with a transaction;
• (m) prescribing methods for making a volumetric determination of water to
be ascribed to a stream flow reduction activity for the purpose of water use
allocation and the imposition of charges;
• (n) prescribing procedures for the allocation of water by means of public
tender or auction; and
• (o) prescribing:
▪ (i) procedures for obtaining; and
▪ (ii) the required contents of, assessments of the likely effect which
any proposed licence may have on the quality of the water resource
in question.
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4 PRESENT ENVIRONMENTAL SITUATION
4.1 Climate
4.1.1 Regional Climate
Overall, the Western Cape climate is typically Mediterranean, with warm, dry summers and
mild, moist winters and low summer rainfall prevail. Summer temperatures in December to
February range from around 15 to 27 degrees Celsius (ºC), whilst in the winter months of June
to August average temperatures are between 7 to 20 ºC.
4.1.2 Rainfall
The mean annual precipitation (MAP) for the G40C quaternary catchment is approximately
1 367.1 mm of rainfall per annum with 112.10 mm of that rainfall recharging the groundwater
system.
4.1.3 Evaporation
The average potential mean annual evaporation (S-Pan) for G40C quaternary catchment is
1 410mm/a according to the Water Resources of South Africa 2012 Study (Bailey & Pitman,
2015).
4.2 Surface Water
4.2.1 Water Management Area (WMA)
Elgin is located within the G40C quaternary catchment within the Breede-Gouritz Water
Management Area (WMA) (Figure 4.1).
4.2.2 Surface Water Hydrology
From the 1:50 000 Topographical Map and observations on site, the site gently slopes in a
southernly direction towards the Palmiet River. High lying areas are situated to the north of
the site with the Steenbras River draining / flowing west from the high lying areas. The
Klipdrif River is a located 135m north from the project area and flows into the Palmiet River
which flows to the Kogelberg Dam. Elgin’s facility is located approximately 2km west from
the Palmiet River.
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Figure 4.1: WMA and Quaternary Catchments
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4.2.3 Surface Water Quality
The Water Research Commission completed a research project titled ‘Palmiet River –
Integrated catchment risk assessment’ in 2017. The research was conducted in the Palmiet
River and its tributaries (Klipdrif and Swannies rivers) which pass through the urban area of
Grabouw in the Overberg West sub-catchment of the Breede-Gouritz WMA. This site was
selected because industrial, agricultural and domestic wastewater and runoff resulted in
elevated organic loads in the rivers downstream, causing eutrophication and low dissolved
oxygen levels.
Specific pollutants (related to anthropogenic activities surrounding the Palmiet River and
tributaries) were identified and their toxicity, significance and effect are described in the
final report to the study. The research found that these all posed a threat to the human
health and the environment. The medium and compartments relevant to modelling the
exposure, fate and transport of pollutants in the Palmiet sub-catchment of Grabouw are as
follows:
1. The pollutants from anthropogenic activities is released to surface water;
2. Through sorptions embedded into the sediment; or
3. Released directly onto the surface soil.
The pollutants are transported either via the stormwater system into the wastewater
treatment system and then into the river system; or via the stormwater system into a wetland
and then into the river system; or via the stormwater system into the river system; or directly
into the river system. Laboratory analysis reveal that pollutant concentration levels for
especially certain pesticides and trace elements enters the river system at high levels. The
concentration levels were used as input into a practical statistical model risk assessment to
predict direction and spread for a distance of about 7km – the distance of urban and industrial
influence. Beyond this distance agricultural areas become more apparent.
Moreover, a Freshwater Ecological Assessment was undertaken by FEN Consulting (Pty) Ltd in
June 2020. Refer to Annexure B for the full assessment. During the Freshwater Ecological
Assessment, in situ water quality parameters were measured within the Klipdrif River
(upstream and downstream of the backwash effluent discharge point) during the site
assessment:
• Upstream: pH – 7.04; Electrical Conductivity (EC) – 69 mS/m; and temperature –
17.3°C. In accordance with the Resource Quality Objectives of South Africa, the EC
falls beyond the ideal range (<30cmS/m).
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• Downstream: pH – 7.25; Electrical Conductivity (EC) – 33 mS/m; and temperature –
16.6°C. In accordance with the Resource Quality Objectives of South Africa, the EC
falls beyond the ideal range (<30 mS/m and between pH 6.5 – pH 8.0).
It should be noted that surface water run-off via the stormwater outlet originates from the
project area as well as the surrounding catchment which enters the study area via a
stormwater inlet on the south eastern boundary of the study area. This stormwater,
containing litter and potentially other contaminants is compounded with the water washing
down from the waste area and also exits the study area via the stormwater outlet
4.2.4 Mean Annual Run-off
According to Bailey & Pitman (2015), the mean annual runoff (MAR) for G40C quaternary
catchment is 533.59 million m3/a.
4.2.5 Resource Class and River Health
The Palmiet River class for the Integrated Unit of Analysis (IUA) is II and the Target Ecological
Category (TEC) which needs to be achieved or maintained in a C.
4.2.6 Receiving Water Quality Objectives and Reserve
Elgin’s facility is located approximately 2km from the Palmiet River which flows to the
Kogelberg Dam. The Resource Quality Objectives (RQO) for the Palmiet River are presented
in Table 4.1 and the water quality objectives for the Palmiet River cannot exceed the limits
presented in the table.
It must be noted that Elgin are no longer discharging, and the WTP backwash water is
being re-directed into the municipal effluent grid (Figure 4.2).
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Figure 4.2: Water Treatment Plant backwash water already collected and redirected into the municipal effluent grid
Table 4.1: RQO for the Palmiet River (GN 42053)
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4.2.7 Surface Water User Survey
Irrigation to support agriculture constitutes the main water use in the WMA, followed by
urban water use.
4.2.8 Sensitive Areas Survey (Wetlands)
A Freshwater Ecological Assessment was undertaken by FEN Consulting (Pty) Ltd in June 2020.
Refer to Annexure B for the full assessment. A desktop study was conducted in which possible
watercourses were identified for on-site investigation, and relevant national and provincial
databases were consulted.
*It should be noted that the Freshwater Ecological Assessment was undertaken when Elgin
was discharging from the site. It must be noted that Elgin are no longer discharging, and
the WTP backwash water is being re-directed into the municipal effluent grid (Figure 4.2).
4.2.8.1 Field Verification Findings
No watercourses were noted within the study area, however, the Klipdrif River and an
associated Channelled Valley Bottom Wetland (CVBW) is located adjacent to the northern
boundary of the study area.
The CVBW (with an extent of 28ha within the investigation area) was identified to the north
of the study area, with the active channel flowing in a south easterly direction. The CVBW
was noted to be significantly disturbed due to stormwater channels and preferential flow
paths traversing the wetland, building rubble infill, extensive cattle grazing (Figure 4.3) and
proliferation of alien and invasive vegetation species such as Pennisetum clandestinum,
Spartium junceum, Paspalum distichum, Seriphium plumosum, Persicaria lapathifolia,
Cortaderia selloana, Acacia saligna and Acacia mearnsii.
Figure 4.3: (Left) CVBW has been infilled with building rubble; (right) preferential flow paths within the CVBW conveying stormwater from the adjacent urban and industrial areas
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The upstream reaches of the active channel are densely vegetated with invasive vegetation
species, dominated by tree species such as Acacia mearnsii and Acacia saligna, and creeper
species such as Ipomoea cairica. It was also noted that the channel, upstream from the study
area, is heavily polluted with solid waste which has resulted in flow restrictions in some areas
(Figure 4.4).
Figure 4.4: Photographs of the Klipdrif River, upstream of the study area.
The water within the downstream active channel was moderately fast flowing, compared to
upstream, as a result of the stormwater inputs from the surrounding high density residential
developments. It was noted that the marginal vegetation is dominated by large alien tree
species, predominantly Acacia mearnsii (Figure 4.5).
Figure 4.5: Photograph of the Klipdrif River, downstream of the study area.
As mentioned previously, in situ water quality parameters were measured within the Klipdrif
River (upstream and downstream of the backwash effluent discharge point) during the site
assessment:
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• Upstream: pH – 7.04; Electrical Conductivity (EC) – 69 mS/m; and temperature –
17.3°C. In accordance with the Resource Quality Objectives of South Africa, the EC
falls beyond the ideal range (<30cmS/m).
• Downstream: pH – 7.25; Electrical Conductivity (EC) – 33 mS/m; and temperature –
16.6°C. In accordance with the Resource Quality Objectives of South Africa, the EC
falls beyond the ideal range (<30 mS/m and between pH 6.5 – pH 8.0).
The Water Treatment Plant (WTP) is located in the north-western corner of the study area,
discharging process backwash effluent into the adjacent CVBW (Figure 4.6). The outlet was
noted to be highly eroded, despite informal mitigatory measures. From the outlet, the water
dispersedly enters the CVBW. It must be noted that Elgin are no longer discharging, and
the WTP backwash water is being re-directed into the municipal effluent grid (Figure 4.2).
Figure 4.6: Photographs illustrating the location of the Water Treatment Plant (WTP) effluent discharge point draining into the wetland in the investigation area
Additional to the backwash effluent discharge from the WTP (which will no longer take place),
contaminated surface water run-off was also noted to enter the adjacent CVBW which exits
the study area via a stormwater outlet located on the north eastern boundary of the study
area. The surface water runoff originates from:
a) The general waste area associated with the Elgin’s abattoir footprint located in the
north eastern portion of the study area. This water was noted to be putrid and was
contaminated by process waste from the abattoir (Figure 4.7). Water enters a
stormwater channel where after it flows through the stormwater outlet and is
subsequently washed down into the CVBW; and
b) Stormwater from the surrounding catchment which enters the study area via a
stormwater inlet on the south eastern boundary of the study area. This stormwater,
containing litter and potentially other contaminants is compounded with the water
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washing down from the waste area and also exits the study area via the stormwater
outlet.
A distinct preferential flow path is visible within the CVBW which has formed as a result of
all the above mentioned run-off from the stormwater outlet (Figure 4.7).
Figure 4.7: (Left) contaminated surface water runoff leaving the study area; (right) preferential flow path formed as a result of the contaminated run-off into the CVBW.
4.2.8.2 Watercourse Delineation
The outer boundary of the CVBW was delineated according to the guidelines advocated by
DWAF (2008), taking into consideration soil characteristics as defined by Job (2009). The
delineations as presented in this report are regarded as a best estimate based on the site
conditions present at the time of assessment.
During the field assessment, the following indicators were used in order to determine the
boundary of the watercourses within the investigation area:
• Topography/elevation was used to determine in which parts of the landscape the
CVBW would most likely occur;
• Obligate and facultative vegetation species were used in conjunction with terrain
units as well as the point where a distinct change in the vegetation composition was
observed to determine the watercourse boundaries. This included Zantedeschia
aethiopica and Juncus spp. (although species identification was limited due to
extensive grazing of the area); and
• Soil form indicators were used to determine the presence of soils that are associated
with prolonged and frequent saturation with key indicators including gleying,
mottling, organic streaking and increased clay content, as well as alluvial soils. A
distinct chroma change was evident within the first 30cm of the soil surface of the
soil sample taken within the wetland.
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4.2.8.3 Watercourse Classification
The CVBW as described above were classified according to the Classification System outlined
in Annexure C of the Freshwater Ecological Assessment Report (Annexure B) as an Inland
System, located within the Southern Folded Mountains Ecoregion. Table 4.2 below presents
the classification from level 3 to 4 of the ‘Classification System of Wetlands and other Aquatic
Ecosystems’ (Ollis et al, 2013).
Table 4.2: Classification of the watercourses located in the investigation area Watercourse Level 3: Landscape Unit Level 4: Hydrogeomorphic (HGM) Type
Channelled valley
bottom wetland
Valley floor: The base of a
valley, situated between two
distinct valley side-slopes.
Channelled valley-bottom wetland: a
valley-bottom wetland with a river
channel running through it.
Refer to Figure 4.8 and Figure 4.9 which provides a visual representation of the study area
and the delineated boundary of the CVBW, as well as the location of the associated
infrastructure and discharge points.
Figure 4.8: Delineated watercourses associated with the study and investigation areas
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Figure 4.9: A close up of the study area indicating the various outlet points into the adjacent CVBW
4.2.8.4 Wetland Assessment Outcomes
Present Ecological Status (PES)
The Present Ecological State (PES) of the CVBW was determined through the use of the Wet-
health tool, and an overall scoring of 5,46 (Category C) was calculated. Table 4.3 summarises
the wet-health outcomes for hydrology, geomorphology and vegetation.
Table 4.3: The PES Category result for the Channelled Valley-Bottom Wetland
Modifiers of the CVB wetland include surrounding urban and industrial development, trench
excavations through the wetland, disposal of building rubble as well as disturbances relating
to cattle grazing. Increased water inputs as a result of stormwater runoff conveyed from the
surrounding urban infrastructure and industrial developments (potentially impacting water
quality) has impacted the hydrological regime of the CVB wetland, and also resulted in
proliferation of the alien invasive vegetation species such as Pennisetum clandestinum,
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Spartium junceum, Paspalum distichum, Seriphium plumosum, Persicaria lapathifolia,
Cortaderia selloana, Acacia saligna and Acacia mearnsii.
Ecosystem Services Provision
The ecosystem services for the CVBW was determined, considering the surrounding impacts
and current inputs into the wetland from Elgin’s abattoir. Table 6 summarises the outcomes.
Table 4.4: Ecosystem service provision for the Channelled Valley-Bottom Wetland
The CVBW is considered to provide an intermediate level of ecosystem services, with a
moderately high service provision for sediment trapping, phosphate, nitrate and toxicant
assimilation as well as erosion control. The reduction in the remaining service provision is
mainly attributed to the seriously modified condition of the CVBW as a result of extensive
grazing, alterations to the hydrological flow and the density and distribution of alien and
invasive vegetation throughout the wetland. The CVBW is not of particular cultural value but
is utilised by the surrounding community for cattle grazing.
Ecological Importance and Sensitivity (EIS)
The Ecological Importance and Sensitivity (Roundtree and Kotze, 2013) was calculated for
the CVBW and the following was determined applicable. The system is considered of
moderate ecological importance and sensitivity on a landscape scale, mainly as a result of
the Southwest Sand Fynbos wetland vegetation type within which it is located (according to
NFEPA, 2011) which is considered to be critically endangered (Mbona et al. 2015). However,
no remnants of this vegetation group were identified at the time of the site visit and it is
considered unlikely that any species that are representative of this vegetation group will be
found due to the large scale impacts on the CVBW and the surrounding areas. The hydro-
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functional importance of the system is considered to be moderate while the direct human
benefits are considered to be low (Table 4.5).
Table 4.5: EIS result for the Channelled Valley-Bottom Wetland
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Recommended Ecological Category (REC) and Recommended Management Objective
(RMO)
The Present Ecological State of Category C must be maintained throughout the operational
phase of the Elgin’s abattoir. It is, however, noted that the impacts and disturbances to the
CVBW that resulted in the Category C PES are outside of the control of Elgin’s abattoir and a
larger catchment management and rehabilitation approach would be required in order to
improve the ecological state of the system. It must be noted that Elgin are no longer
discharging, and the WTP backwash water is being re-directed into the municipal effluent
grid.
4.3 Groundwater
A hydrogeological investigation was undertaken by GCS in 2020. Refer to Annexure A for the
full hydrogeological report.
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4.3.1 Aquifer Characterisation
According to the 1:500 000 Hydrogeological map series 3126 Cape Town (Moseki et al, 2003)
the site is underlain by a fractured type of aquifer. A fractured aquifer has a fractured zone,
down to a depth where the rock is becoming fresh or solid in appearance. Fractured aquifers
in this area can have borehole yield ranging from 2.0 – 5.0 l/s. Groundwater would most likely
be found on these fractures occurring from the folding of the Bokkeveld Group. The fracturing
of rocks occur as a result of released or induced pressure.
4.3.2 Aquifer Testing
The aquifer test was undertaken by subcontractors (De Villiers Visser). Two types of aquifer
tests was conducted on the boreholes: A) step test; and B) constant rate test under the
supervision on GEOSS.
A step test allows for the determination of the aquifers response to stress (pumping) and
efficiency. These steps are conducted at increasing rates to determine the water level
response within the borehole. Based on the water level data a pumping rate for the constant
discharge (long duration) test was selected.
The borehole was pumped for 24 hours at a constant rate. The water level within the borehole
was monitored during the pumping. This data was used to determine the aquifer
characteristics, such as transmissivity and storage.
After pumping the water levels with the borehole was monitored to determine the recovery
of the water levels with time. This allows for the evaluation of dewatering and pumping
schedules.
The aquifer test data was analysed to determine the following:
• Sustainable yield;
• Abstraction schedule;
• Pump inlet depth; and
• Management.
Yield testing was conducted by De Villiers Visser under the supervision of GEOSS between the
5th to the 7th of August 2019. The yield testing included a step test, a 24 hour constant rate
test and a recovery test (the data can be seen in the GEOSS report attached in Appendix A of
Annexure A). GCS reviewed the yield testing and the results can be summarized as follows:
• The borehole EC_BH1 had a static water level of 1.83 mbgl with a total depth of 81
mbgl;
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• The pump was installed at a depth of 72 mbgl during the aquifer test;
• During the constant discharge test the borehole was pumped for 24 hours at a
constant yield of 5.55 l/s;
• A total drawdown of 14.5 meters was achieved out of the 70.74 meters of available
drawdown; and
• The borehole recovered to within 95% of the static water level within 3.5 hours after
pumping stopped.
The pump test was analysed using the excel base FC program, developed by the institute for
Groundwater Studies in Bloemfontein. This program is utilized in order to estimate the
sustainable yield of the borehole using from the Constant Discharge Test (CDT) the following
methods were used:
• Cooper-Jacob approximation of the Theis solution for confined aquifers;
• The Barker Generalised Radial Flow Model (GRFO for hydraulic tests in fractured
rock);
• Flow characteristic (FC) method using first and second derivative calculations.
The average sustainable yield from calculated from the boreholes is 5.45 l/s (19 620 l/hr)
with the recommended abstraction rate given as 5.4 l/s (19 440 l/hr) for a 24hour abstraction
period with 0 hours for recovery. The transmissivity calculated for the boreholes was 54.8
m2/d (using the Basic FC method) and 33.7 m2/d (calculated from the CooperJ-Jacob
equation).
GCS reviewed the data from the GEOSS (2019) report and it is recommended that the borehole
be pumped at 5.4 l/s for 18 hours a day and left to recover for 6 hours before pumping
commences again. This should allow for an abstraction volume of 349 920 l/day.
4.3.3 Hydrocensus
A hydrocensus was carried out by GCS on the (10th of February 2020) in and around the site
in order to identify any sensitive groundwater users and verify abstraction volumes. The
delineated sub-catchment and boreholes found during the hydrocensus can be seen displayed
in Figure 4.10. All the data collected during the hydrocensus is summarised in Table 4.6.
One other borehole (EC BH3) was found within the sub-catchment containing the site. The
borehole was not in use at the time of the site visit. The borehole is located on the outside
of the north-western boundary of the site.
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Borehole EC BH2 was found outside of the western boundary of the sub-catchment. The
borehole has a reservoir system with five 10 000L JoJo tanks storing water from the borehole.
Borehole EC BH 4 was located on the outside of the north eastern boundary of the sub-
catchment and the borehole is used for domestic purposes with 60 people dependent on the
borehole.
The hydrocensus revealed that the population within the sub-catchment is not very reliant
on groundwater as their water source and that they are mainly using municipal water supply.
A large part of the sub-catchment consists of built-up urban area.
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Table 4.6: Hydrocensus Borehole Information
BH ID Coordinates
Depth Collar Height
SWL Known yield
Pump type Powered
by: Reservoir
Volume Abstracted
Used For Comments Latitude Longitude
[-] DD DD [mbgl] [m] [mbgl] [L/s] [-] [-] [L] [L/d] [-] [-]
EC BH1 -34.149043 19.005361 81 N/A N/A 5.4 Submersible Electricity N/A 349 920 Agriculture Borehole on site
at Elgin Free Range Chickens
EC BH2 -34.150390 9.002720 N/A N/A N/A N/A N/A N/A 5 X 10000 Jojo Tanks
N/A N/A Vantage 1 borehole
EC BH3 -34.147950 9.004420 N/A N/A N/A N/A N/A N/A N/A N/A Not in use De Kok borehole (borehole not in
use)
EC BH4 -34.142860 19.017590 N/A N/A N/A N/A Submersible Electricity N/A 9 000 Domestic Fruits End
Note/s: [-] - not applicable [N/A] - Not Applicable [DD] - decimal degrees [m] - metres [mbgl] - meters below ground level [mbch] - meters below collar height [L/s] - Liters / second [L] - Liters [L/d] Liters / day Coordinates
- Projection: Geographic
Datum: WGS84
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Figure 4.10: Hydrocensus Borehole localities
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4.3.4 Groundwater Quality
Groundwater samples were collected from production borehole and the results were analysed
by a SANAS accredited laboratory (Vinlab) in the Western Cape. The results were reviewed
by GCS and it was found that the levels of Iron within the borehole exceeded the SANS 241:
drinking water quality standards. The water should be treated if it is intended to be used for
either drinking water or irrigation. Refer to Annexure A for the full report.
4.3.4.1 Effect on Human Health
The effect of drinking water containing constituents exceeding the SANS 241-1:2015 drinking
water quality standards are detailed below. As a precautionary measure, it is recommended
that the target water quality range (TWQR) not be exceeded because of the potential acute
and/or irreversible effects on human health (DWAF, 1996) (Table 4.7).
Table 4.7: Target Water Quality Range for Iron with effects Chloride Range Effects
TWQR
0 – 0.1 No Taste, other aesthetic or health effects associated with consumption and use
0.1 – 0.3
Very slightly effects on taste and marginal other aesthetic effects deposits in
plumping with associated problems may begin to occur. No health effects; the
water is generally well tolerated
0.3 – 1.0 Adverse aesthetic effects (taste) gradually increases as do possible problems
with plumbing. No health effects
CWQ
1 – 10
Pronounced aesthetic effects (taste) along with problems with plumbing. Slight
health effects expected in young children, and sensitive individuals
10 – 30
Severe aesthetic effects (taste and effects on the plumbing (slimy coatings).
Slight iron overload possible in some individuals. Chronic health effects in young
children and sensitive individuals in the range 10 – 20 mg /R and occasional
acute effects towards the upper end of this range
30 – 100 As above
Long term health effects gradually increase
100 – 300 As above
Long term health effects. Acute toxicity may begin to appear
300 – 3 000 As above
Chronic and acute health effects. Accidental iron poisoning from water is rare
3 000 – 30 000 As above
Lethal toxicity occurs
Notes:
TWQR - Target Water Quality Range
CWQ - Current Water Quality
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4.3.5 Potential Pollution Source Identification
The sources of pollution for groundwater can be caused by spillage and/or runoff of
contaminants such as organic matter, fuel, oil, wash-water, sediment, and hazardous
chemicals. In addition, the sources of pollution for the wetland can be caused the improper
treatment of the effluent water.
4.3.6 Groundwater Reserve Determination
4.3.6.1 Quaternary Catchment
Data from relevant hydrogeological databases including, the Groundwater Resource Directed
Measures (GRDM) was obtained from the DHSWS. The site falls within quaternary catchment
B41H as indicated in Table 4.8. The recharge for the quaternary catchment is 34.8mm/a
which amounts to 5.6% of the mean annual precipitation of 621.4mm/a.
Table 4.8: Quaternary Catchment Details for Catchment G40C
Quaternary Catchment
Total Area Recharge Rainfall Groundwater
level
[-] [km2] [mm/a] [mm/a] [mbgl]
G40C 144.6 112.10 1 367.1 11.4 Note/s:
[-] - not applicable [mbgl] - meters below ground level [km2] - square kilometers [mm/a] - millimeters / annum
4.3.6.2 Sub-catchment Delineation
In order to delineate a sub-catchment for the site within the quaternary catchment ArcGIS is
used (which provides a method to describe the physical characteristics of a surface). Using a
digital elevation model as input, it is possible to delineate a drainage system and then
quantify the characteristics of that system. The tools in the extension let you determine, for
any location in a grid, the upslope area contributing to that point and the down slope path
water would follow. This data is important during the numerical model boundary selection
and impact assessment. The delineated sub-catchment is presented in Figure 4.11.
WARMS Database Boreholes for quaternary catchment B20A
The Water Use Registering and Licensing database (WARMS) data was obtained from the
Department of water affairs and Forestry (now DHSWS) and are shown in Table 4.9. No
registered users are located within the sub-catchment containing the site as shown in Figure
4.11.
Table 4.9: WARMS Borehole/s Details
Name Latitude Longitude Register Status WU Sector Registered Volume
[-] [DD] [DD] [-] [-] [m3/annum]
22065863/1 -34.21200 19.05456 Cancelled IRR 2 000
22066522/1 -33.42917 18.87000 Cancelled WSS 0
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Name Latitude Longitude Register Status WU Sector Registered Volume
[-] [DD] [DD] [-] [-] [m3/annum]
22080258/1 -34.45333 19.44056 Cancelled LIV 50 000
22065783/1 -34.24722 19.09167 Cancelled IRR 9 000
22064604/3 -34.22083 19.04611 Cancelled IRR 2 000
22064980/1 -34.22639 19.06528 Cancelled SC1 10 000
22078412/1 -34.18847 19.18847 Cancelled WSS 5 000
22030892/1 -34.17778 19.02917 Cancelled IRR 2 000
22046171/1 -34.17778 19.02917 Registered WSS 2 000
22031739/2 -34.14028 18.99861 Registered WSS 365
22065952/1 -34.24567 19.09169 Cancelled WSS 2 000
22066425/2 -34.13550 19.02275 Registered SC1 1 200
22066425/3 -34.13739 19.02206 Registered SC1 1 500
22066498/2 -34.13739 19.02206 Registered SC1 300
22065998/3 -34.21561 19.05717 Cancelled IRR 0
22064864/1 -34.14444 19.00167 Cancelled WSS 1 800
22037528/3 -31.99250 19.26722 Cancelled IRR 0
22037528/5 -34.11730 19.03790 Cancelled IRR 279 000
22037528/6 -31.99917 19.28306 Cancelled IRR 195 264
22037528/7 -31.99583 19.26889 Cancelled IRR 390 528
22037528/8 -31.99583 19.26889 Cancelled IRR 429 580
22037528/9 -31.99944 19.28222 Cancelled IRR 282 896
22109406/4 -34.11730 19.03790 Cancelled IRR 279 000
22109406/5 -31.99917 19.28306 Cancelled IRR 195 264
22109406/6 -31.99583 19.26889 Cancelled IRR 390 528
22109406/7 -31.99583 19.26889 Cancelled IRR 429 580
22109406/8 -31.99944 19.28222 Cancelled IRR 282 896
22065480/1 -34.14528 19.00806 Registered IRR 32 500
22065872/2 -34.23347 19.06514 Cancelled IRR 0
22103055/2 -34.16806 19.00694 Registered SC1 5 000
22064560/2 -34.12129 19.02426 Registered IRR 12 000
22064515/2 -34.22333 19.03167 Cancelled IRR 3 650
22045109/4 -34.14490 19.05770 Registered IRR 4 600
22066416/2 -34.18056 19.00694 Closed SC1 5 000
22066309/1 -34.14222 19.01389 Registered IRR 10 000
22008284/1 -32.42083 18.76000 Cancelled IRR 981
22031472/4 -34.22389 19.10194 Cancelled IRR 12 500
22065505/2 -34.24028 19.08806 Cancelled IRR 157 475
22067790/1 -34.13359 19.02722 Registered SC1 2 400
Total [m3/annum] 3 489 807
Groundwater Balance
A groundwater balance was calculated for the sub-catchment to determine the surplus
available for abstraction, as presented in Table 4.10. The results show that the total amount
of groundwater recharge is equal to 422.3m3/day and the total amount of groundwater
abstracted currently is equal to 360m3/day.
Table 4.10: Groundwater Balance Calculation for the delineated sub-catchment
Quaternary Catchment G40C
Sub-Catchment
Size 1.38 km2
1 375 425 m2
Groundwater Recharge 112.10 mm/a
0.11210 m/a
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= 1 375 425 m2
= 154 188 m3/a
= 422.43 m3/day
Basic Human Need GRDM 265.41 m3/day
Abstraction Volumes
Hydrocensus Boreholes - m3/day
On site Usage 350 m3/day
Current Usage from GRDM 60.48 m3/day
Groundwater Contribution to Baseflow
24.11 m3/a
0.07 m3/day
Total Use 360 m3/day
Surplus Amount 62.75 m3/day
Scale of Abstraction
85 of recharge (Class B medium scale abstraction >60% of recharge)
From the sub-catchment preliminary water balance calculation, medium scale abstraction
(85.56% of the recharge – category B) is taking place.
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Figure 4.11: Delineated Sub-catchment with WARMS Boreholes shown on map
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Water Quantity
The recent status of a groundwater resource unit can be assessed in terms of sustainable use,
observed ecological impacts or water stress. Since no information about ecological impacts
of groundwater abstraction is available, the concept of water stress was applied for the
classification process.
The concept of stressed water resources is addressed by the National Water Act but is not
defined. Part 8 of the Act gives some guidance by providing the following qualitative
examples of ‘water stress’:
• Where demands for water are approaching or exceed the available supply;
• Where water quality problems are imminent or already exist; or
• Where water resource quality is under threat.
To provide a quantitative means of defining stress, a groundwater stress index was developed
by dividing the volume of groundwater abstracted from a groundwater unit by the estimated
recharge to that unit (Parsons and Wentzel, 2007).
Stress Index = Groundwater Abstraction / (Recharge – Baseflow)
= 359.7m3/day / (422.4m3/day – 24.11m3/day)
= 0.903
The stress-index and classes described in Table 4.11, is a guide for determining the level of
stress of a groundwater resource unit, based on abstraction, baseflow and recharge (modified
after Parsons and Wentzel, 2007).
Table 4.11: Guide for determining the level of stress of a groundwater resource unit
Present Status Category Description Stress Index
A Unstressed or low level of stress
<0.05
B 0.05-0.2
C Moderate levels of stress
0.2 – 0.5
D 0.5 – 0.75
E Highly Stressed 0.75 – 0.95
F Critically stressed >0.95
Due to the total abstraction of 359.7m3/day the groundwater resource unit is classified as
highly stressed.
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4.4 Socio-economic Environment
4.4.1 Regional Context
Elgin’s facility falls within the Theewaterskloof Local Municipality. Theewaterskloof
Municipality is the largest local authority in the Overberg District with an area of
approximately 3 258km² and houses 14 wards, embracing the City of Cape Town on its
western boundary and sharing the eastern coastline with the Overstrand Municipality (Figure
4.12). It is the most populous municipality in the Overberg district with 42% of the total
district population. Theewaterskloof Municipality can be categorised as a rural area with
open spaces and farming activities as it is clear from the land and areas occupied by
agriculture, small holdings and other land uses (Theewaterskloof Municipality, 2020)
Figure 4.12: Theewaterskloof Municipal locality (Theewaterskloof Municipality, 2020)
4.4.2 Local Context
1.1.1.1 Population and growth
According to Stats SA, the population of Theewaterskloof totals 122 000 people for 2020
(Table 4.12). However, the latest Integrated Development Plan (IDP) (2020) stated that all
local intelligence indicated that even those of the municipality’s sources that contain the
highest estimates reflect an understatement of the population and population growth. A
recent estimate by a local community organisation (Greyton Council) already estimate the
Theewaterskloof population to be above 140 000 and indicating that Grabouw hosts about
41% of the total population. Though much higher than official sources, there are even local
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organisation that feel this too is an under estimate with certain local’s feeling that Grabouw
alone account for more than 100 000 residents. This could be justifiable looking at the rapid
expansion of “Siyanyanzela” where a new ward was established literally overnight.
This growth rate in Theewaterskloof poses huge challenges on the service delivery for the
municipality. Based on even the lowest average annual growth rates of 1.5% (Stats 2011), the
population of Theewaterskloof will increase by more than 1800 residents per annum. Taking
an average household size of four, this equates to about an additional 450 households that
would require services. The problem is intensified due to the fact that most of the growth
into the area is deemed to fall within the category of indigent households.
Table 4.12: Theewaterskloof population (Theewaterskloof Municipality, 2020)
1.1.1.2 Age Structure and Gender
In 2018, there was a significantly larger share of young working age people between 20 and
34 (26.0%), compared to what is estimated in 2023 (22.6%) (Figure 4.13). This age category
of young working age population will decrease over time. The fertility rate in 2023 is
estimated to be slightly higher compared to that experienced in 2018; and the share of
children between the ages of 0 to 14 years is projected to be slightly smaller (23.9%) in 2023
when compared to 2018 (24.7%).
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Figure 4.13: Population structure (Theewaterskloof Municipality, 2020)
The 2011 Census indicate Theewaterskloof population at 108 790 and Community Survey
estimates predict it to be at 117 109 translating into a growth rate over the period (2011 –
2016) of 7.6%. The Social Economic Profile (SEP 2019) (which are estimates provided by the
provincial government) estimate the municipality population to have increased to 120 823 in
2019 and to reach 125 285 by 2023 translating into a growth rate of 3.69% over a five year
period. Theewaterskloof has the largest population figures in the district, representing 40.3%
of total population in the Overberg district. IHS (IHS Information and Insight) on its turn
predict population figures to be in the regions of 119 000.
Theewaterskloof Local Municipality's male/female split in population was 101.4 males per
100 females in 2018. The Theewaterskloof Local Municipality has significantly more males
(50.36%) relative to South Africa (48.95%), and what is typically seen in a stable population.
This is usually because of physical labour intensive industries such as construction and
farming. In total there were 58 900 (49.64%) females and 59 800 (50.36%) males.
1.1.1.3 Education
The number of people without any schooling in Theewaterskloof Local Municipality accounts
for 51.67% of the number of people without schooling in the district municipality, 3.46% of
the province and 0.13% of the national. In 2018, the number of people in Theewaterskloof
Local Municipality with a matric was only 17 900 which is a share of 34.38% of the district
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municipality's total number of people that has obtained a matric. The number of people with
a matric and a Postgrad degree constitutes 22.22% of the district municipality, 0.71% of the
province and 0.11% of the national.
The number of learners enrolled in the Theewaterskloof municipal area increased by 5.3% (or
989 learners) between 2016 and 2018. The greatest increase was between 2017 and 2018
when the number of learners increased by 2.7% or 513 learners. Between 2016 and 2018,
there was a negative correlation between learner enrolment and the learner-teacher ratio.
The learner-teacher ratio deteriorated marginally from 28.9 learners per teacher 2016 to
29.6 learners per teacher 2018 (Theewaterskloof Municipality, 2020).
In contrast to growing enrolment rates, the Grade 10 to 12 retention rate has decreased from
2016 to 2018. The decrease is solely due to the period between 2016 and 2017 when the
Grade 10 to 12 retention rate dropped by 6.3% points. The decreasing retention rate is
correlated with a decrease in the matric pass rate which decreased by 13.2% points between
2016 and 2018, from 92.4% in 2016 to 79.2% in 2018. Thus, in the Theewaterskloof
Municipality, the number of students who stay enrolled between Grades 10 to 12 is decreasing
and the pass rate of those who stay till the matric examinations is decreasing which will
influence the overall skills level of the workforce in the municipal area.
Changes in the learner-teacher ratio can affect learner performance. The learner-teacher
ratio in the Theewaterskloof municipal area decreased from 45.7 in 2015 to 44.7 in 2016 and
further decreased to 44.6 in 2017. Factors influencing the learner-teacher ratio include the
ability of schools to employ more educators when needed and the ability to collect fees. This
concern has also been highlighted in communities such as Botrivier and Villiersdorp in various
engagements.
1.1.1.4 Social Realities
The Theewaterskloof Local Municipality contains the following social realities (Figure 4.14):
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Figure 4.14: Social realities (Theewaterskloof Municipality, 2020)
5 ANALYSIS AND CHARACTERIZATION OF THE WATER USE ACTIVITY
5.1 Site Delineation for Characterization
Refer to Section 1.4 for the extent of the project area.
5.2 Water and Waste Management
5.2.1 Process Water
The water supply at Elgin will be pumped from the borehole located on the property (EC BH1)
in addition to the water received from the municipality (groundwater to supplement
municipal supply). Clean potable water (SANS 241) comes from the water treatment plant
(UF) and is stored in the reservoir. The reservoir supplies the abattoir and factory with water
to slaughter the chickens and process the carcasses for the market. Refer to Table 5.1 for a
summary of the water usage at Elgin.
Table 5.1: Water usage at Elgin m3 - Daily m3 - Weekly m3 - Month
Borehole extraction - untreated/raw 339 1694 7335
Borehole backwashes/Filtration losses of treatment plant 113 567 2456
Borehole Supply - to factory [part of Combined Supply] 227 1133 4904
Municipal Supply - to factory [part of Combined Supply] 140 698 3022
Combined Supply - to factory 366 1830 7926
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m3 - Daily m3 - Weekly m3 - Month
Processing - Day 282 1409 6103
Staff Hygiene [part of Processing - Day] 4 19 83
Product Ingredients [part of Processing - Day] 0.13 0.63 2.71
Processing - Night 84 421 1823
Cleaning [part of Processing - Night] 56 280 1212
5.2.2 Stormwater
Stormwater measures have been installed at Elgin. These include stormwater catchpits
throughout the site as well as stormwater channels. The stormwater layout plan can be seen
in Annexure F.
5.2.3 Groundwater
The groundwater from the borehole will be managed through daily monitoring of the
groundwater level as well as monitoring the quality of groundwater bi-annually.
5.2.4 Waste
As per Directorate: Waste Management; Department of Environmental Affairs and
Development Planning Western Cape Government: The Department view abattoir waste
which is derived from non-infected animals as general waste, inclusive of condemned waste
(i.e. not fit for human consumption, but not derived from infectious animals). Animal waste
from infected animals is regarded as hazardous waste.
All chicken slaughtered at Elgin Poultry Abattoir, holds a health declaration confirming their
status as non-infected. The waste management procedure (Annexure D) applies to the
management of all waste on site, including dead birds, meat, rough/red offal, raw materials
and ingredients, plastic, card-board, paper and any other waste by-product produced during
the preparation of the final product.
In the unlikely event that a notifiable disease is detected on grower farms, the state vet and
governing bodies will be informed and slaughter shall be conducted under red-cross permits.
Waste from this slaughter batch shall be classified as hazardous. Hazardous waste will be
removed, transported and landfilled in specific zones as directed by the authorities.
5.2.4.1 Waste Management – Action/Method
Dedicated waste area + cleaning
• Waste shall be stored temporary on an impervious, curbed, drained, dedicated and
secure waste area with security monitoring;
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• Wheely bins that are used for waste transport shall be cleaned (inside and outside)
end of shift;
• The waste area shall be cleaned continuously by the Receiving team; and
• The area shall be left cleaned end of shift.
General waste
• Examples: glass, metals, organics, paper, plastic, textiles;
• General waste is generated through-out the whole facility;
• Waste is collected into a clear refuse bag;
• The full refuse bags are transferred through various exit points from the factory to
the dedicated waste area on a continuous basis;
• General Waste can be split into 2 categories:
o Non-Recyclable General Waste; and
o Recyclable General Waste.
Non-Recyclable General Waste
• Non-Recyclable general waste (in refuse bags) shall be temporary stored in Wheely
bins at the waste area for collection by the Theewaterskloof Municipality;
• Non-Recyclable General waste is collected 3 times a week (prior arrangements in
place) and is managed weekly;
• The Production Management and Team Leader shall ensure that sufficient refuse
containers are provided for the collection of general waste; and
• They will alert the Head of Procurement when wheely bins are broken and in an
unusable condition and needs to be replaced.
Food waste (landfill waste) in skips
• Examples: blood, feathers, manure, stomach contents, mala, hashed condemned
material/meat and ingredients;
• Food waste can be split into 2 categories:
o Chicken waste: Any part of the chicken or by-product that cannot be utilised
as its original intended use due to spoilage, damaged or contamination etc;
and
o Non-chicken waste: Any ingredient that cannot be utilised for production due
to spoilage, damage or contamination.
• Skips shall be leak proof and lidded for the temporary storage of abattoir solid waste.
Food Waste shall be disposed in 2 options:
Option A: Landfill
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• Full skips are removed by a licensed waste removal company to a certified landfill
site:
o Licenced waste removal company – Averda;
o Landfill site - Vissershok Landfill Facility, Frankdale Rd, Milnerton;
Classification Hazardous (H:h); and
o Safe disposal certificates shall be issued per weight received at the landfill
site that is linked with an invoice and PO Number for traceability purposes.
Option B: Bio digestion
• Elgin Fruit Juices (EFJ) who holds a valid waste management licence (REF
E13/2/10/1-E4/11-WL00011/11) for the anaerobic digestion of non-infectious
abattoir waste, blood and animal anatomicals (lungs, intestines, kidneys, and skin).
Option C: Composting
• Various composting initiatives currently under investigation.
Blood waste
Option A: Bio digestion
• EFJ delivers a clean stainless-steel tanks and flow bins to Elgin site;
• Blood is collected and transported by EFJ daily;
• Upon entry to EFJ, blood will be weighed and ticketed;
• Weekly kg’s and invoices will be received from EFJ to monitor kg’s disposed from
Elgin’s site;
• Monthly invoices are generated from Elgin to EFJ; and
• Arrangements and approvals cleared with Department of Agriculture.
Option B: Landfill
• During the slaughtering bleeding steps the blood is collected in the trough and flow
by means of gravity through a pipe into a skip;
• The skip is transferred to the waste area by means of the receiving forklift; and
• The blood will be mixed into waste in skips.
Condemned waste
Option A: Landfill
• Dead on arrival broilers and other condemned meat are collected per Meat Inspection
Point in theft and leak proof bins marked “DOA”, “CONDEMNED”, “PLANT REJECT”
and “FARM REJECT” (Note, this is still classified as general waste); and
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• These bins are weighed and the weights recorded. The contents of the bins are
hashed and then emptied into wheely bins which are transferred to skip bins at the
waste area.
Feather waste – general
Option A: Landfill
• Feathers fall on a conveyor system in defeathering;
• The conveyor system leads via a feather press system;
• Water drained from the feather press flow into the effluent system;
• Dry/ pressed feathers are being moved by hand into a collection rocker bin;
• Feathers are emptied from the rocker bin, into a collection skip; and
• The skips are temporary stored until removal by the certified waste removal
company.
Mala sweepings
Option A: Landfill
• Mala room floor sweepings are collected from the floor daily;
• Sweepings are collected and stored in a wheely bin and kept in the mala room; and
• Full wheely bins are emptied with a forklift into waste skips.
Option B: Bio digestion
• Clean, leakproof bins from EFJ will be stored on the premises;
• An EFJ bin will be placed in the Mala room;
• Mala sweepings will be collected in the EFJ bins;
• A forklift will load the bin onto the transportation;
• Bins will receive a lid for transportation;
• Upon entry to EFJ, sweepings will be weighed and ticketed; and
• Weekly safe disposal documentation will be received from EFJ.
Chicken manure
Option A: Landfill
• Manure, if collected, will be placed in bins; and
• Bins will be transported to the Waste Area for removal.
Option B: Bio digestion
• Manure will be added into the EFJ bins before collection;
• Bins will receive a lid for transportation; and
• No manure may be stored inside the Mala Room.
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Hazardous waste
Electronic waste
• All electronic waste including batteries will be collected in a dedicated area at the
IT Department; and
• IT will inform the Technical Department when the waste area is full for arrangements
for removal to be made.
Empty containers
• Including below, shall be removed by the service provider. Job cards will only be
closed, when the area of work has been cleared of loose cans and consumables:
o Pesticide containers;
o Anti-Freeze containers;
o Drain cleaner containers;
o Oil paint cans/containers;
o Rodenticide containers; and
o Cleaning chemical containers.
Fuel
• Including below, shall be managed by the Head of Logistics and disposed of properly:
o Fuel Containers; and
o Used motor oil containers including filters.
Biohazardous waste
• Any infectious waste contaminated with potentially infectious agents or other
materials that are deemed a threat to public health or the environment; and
• Including below, shall be removed by a licenced service provider:
o All first aid consumables infected with human blood;
o Sanitary pads; and
o Tissues/Toilet paper infected with human blood.
5.3 Operational Management
5.3.1 Organisational Structure
Please refer to Section 2.7 for a diagram illustrating the organisational structure of Elgin.
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5.3.2 Resources and Competence
Refer to Figure 2.2 illustrating the resources and competence at Elgin. In addition, a
sustainability team, which is led by the Technical Department, has been created to drive
environmental management and sustainability at Elgin.
5.3.3 Education and Training
Internal and external training is of high importance at Elgin. Continuous training programmes
are designed to train all staff. Training schedules are set-up by the Technical Department. In
terms of internal training, it mostly relates to food safety, health & safety and process
implementation. In addition, Maintenance and Production procedures are trained with new
equipment installations and commissioning.
All training modules are formally logged on records, and competencies are evaluated for each
trainee. During the year external training is also scheduled which includes: firefighting, first
aid, forklift training, animal welfare, Woolworths Food Safety & Quality training course, and
food safety awareness training.
5.3.4 Internal and External Communication
5.3.4.1 External Communication
External communication is performed using methods that include:
• E-mail communication;
• The company website;
• Formal company letters to service level providers, retail outlets and customers;
• Packaging information on ID labels and company branding on distribution and
advertisement;
• Telephone communication;
• External industry communication such as customer requirements, supplier
requirements, anf legislative requirements communicate through certifying body
announcements and advertisements; and
• Microsoft/ Skype/ Zoom applications to do remote meetings.
5.3.4.2 Internal Communication
Internal communication is done by:
• Meetings with teams;
• E-mail communication;
• Formal memorandums on notice boards;
• Telephone communication; and
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• More visual methods include posters or graphs in the factory to trend and display
progress to staff.
Internal training records are proof of communication which is accompanied with competence
evaluations.
5.3.5 Awareness Raising
Awareness raising is important at Elgin and is done by the sustainability team (Green Team).
Awareness weeks are created to inform and educate staff about a topic or issue with the
intention of influencing their attitudes, behaviours and beliefs towards the achievement of a
defined purpose or goal. In 2019, Elgin held a weeklong awareness campaign covering the
topic of ‘Clean-up and Recycling’. Refer to Figure 5.1 for the awareness raising topic ‘Clean-
up and Recycle Week’ schedule.
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Figure 5.1: Awareness raising topic at Elgin
5.4 Monitoring and Control
5.4.1 Water Quality Monitoring and Bio-monitoring
Prudent monitoring of the CVBW will be required for the duration of the operational phase,
as this will ensure a continual flow of data, enabling all parties involved to accurately assess
and manage any potential impacts which may arise from the future effluent discharge
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activities. It must be noted that Elgin are no longer discharging, and the WTP backwash
water is being re-directed into the municipal effluent grid.
Even though discharge will not take place, it is important to monitor to determine any
potential impacts. In order to achieve reliable data, it is recommended that water quality
points must be taken at the WTP, the contaminated surface water run-off discharge point,
upstream and downstream of the study area.
Table 5.2 provides anticipated co-ordinates for the water quality monitoring points and
Figure 5.2 provides a visual representation for the locations in relation to the study area.
Table 5.2: GPS co-ordinates for recommended monitoring points Monitoring Point Name Location GPS-Co-ordinates
MP 2 Upstream of study area 34° 8'51.01"S 19° 0'12.84"E
MP 1 WTP outlet point 34° 8'53.06"S 19° 0'15.98"E
MP 4 Polluted surface water run-off
discharge point
34° 8'55.99"S 19° 0'20.21"E
MP 3 Downstream of study area 34° 8'50.71"S 19° 0'28.14"E
Visual conditions at each point must be recorded and photographic evidence taken;
On-site testing of biota specific water quality parameters must include the parameters listed
in Table 5.3.
Table 5.3: General limit values for the discharging of wastewater into a water resource (GN 665 of 2013)
Parameter unit General Limit
pH pH 5.5 < pH < 9.5
EC mS/m@25ºC <150
COD Mg/l <75
Ammonia (NH4-N) Mg/l < 6
NO3/NO2-N Mg/l < 15
Chlorine Mg/l < 0.25
Suspended Solids Mg/l < 25
Phosphorous Mg/l < 10
Fluoride Mg/l < 1.0
Faecal coliform/ E-Coli MPN/100ml < 1000
Results should comply with the RQOs for habitat integrity, riparian vegetation, macro-
invertebrates and fish as per Table 4.1. Reporting to be included as part of the annual
Environmental Compliance Officer (ECO) monitoring report to be submitted to the competent
authority.
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Table 5.4 provides additional monitoring actions that must be undertaken. Should the
monitored water quality, as monitored above, not be in line with the Water Resource Quality
Objectives, a qualified service provider will be required to develop a compliance plan and
improve the treatment capacity of the onsite WTP.
Figure 5.2: Recommended Monitoring Points (MP) in relation to the study area and WTP discharge point
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Table 5.4: Proposed monitoring requirements for Elgin
* It must be noted that Elgin will not be discharging any water into the wetland area and the WTP backwash water will be re-directed into the municipal effluent grid.
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5.4.2 Groundwater Monitoring
It is recommended that the water level in EC BH1 be monitored on a daily basis with the use
of an electronic water level meter (level logger)(Table 5.5). The data obtained from this
logger should be downloaded regularly to evaluate the recommended abstraction volume.
Data is to be interpreted by a hydrogeologist in order to determine if water levels are
decreasing over time (wet and dry seasons).
Table 5.5: Recommended Water Level Monitoring Plan for Borehole EC BH1
Borehole ID
Latitude Longitude Sampling
Frequency Method
[-] [DD] [DD] [-] [-]
EC BH1 -34.149043 19.005361 Daily Electronic Water Level Monitor
(Level Logger) Notes:
[-] - not applicable [DD] - decimal degrees Coordinates - Projection: Geographic
Datum: WGS84
Bi-annual groundwater quality analysis of EC BH1 is recommended as tabulated in Table 4.7.
5.4.3 Waste Monitoring
All abattoir effluent water and ablution effluent is pumped into the Theewaterskloof grid for
treatment. This is authorised in terms of a discharge permit from the Theewaterskloof
Municipality dated 18th February 2019. The waste generated from the activities at Elgin comes
from the effluent generated from cleaning the water treatment plant which is later released
into the wetland.
Effluent monitoring consists of:
• Two samples of effluent water is sampled monthly and analysed by two separate
independent laboratories;
• Sampling point: Front man hole near gate 3;
• Sampling frequency: Monthly;
• Two samples drawn by A.L Abbott (SANAS Accredited Water laboratory) testing on
behalf of Theewaterskloof, and a reference sample tested at Bemlab (SANAS
Accredited Water laboratory);
• It is the responsibility of the Technical Department to have the reference sample
analysed;
• All results from the laboratories will be recorded and compiled into an Excel sheet
for trending purposes. The results from A.L. Abbott will also be compiled into the
Excel sheet. Permission given by Theewaterskloof for A.L. Abbott to share the results;
and
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• The results will be shared with senior management.
5.5 Risk Assessment/ Best Practice Assessment
5.5.1 Impact Assessment Methodology
The following methodology was used to rank these impacts. Clearly defined rating and
rankings scales (Table 5.6 to Table 5.12) were used to assess the impacts associated with the
proposed activities. The impacts identified by each specialist study and through public
participation were combined into a single impact rating table for ease of assessment.
Each impact identified was rated according the expected magnitude, duration, scale and
probability of the impact (Table 5.13).
To ensure uniformity, the assessment of potential impacts will be addressed in a standard
manner so that a wide range of impacts is comparable. For this reason, a clearly defined
rating scale will be provided to the specialist to assess the impacts associated with their
investigation.
Each impact identified will be assessed in terms of scale (spatial scale), magnitude (severity)
and duration (temporal scale). Consequence is then determined as follows:
Consequence = Severity + Spatial Scale + Duration
The Risk of the activity is then calculated based on frequency of the activity and impact, how
easily it can be detected and whether the activity is governed by legislation. Thus:
Likelihood = Frequency of activity + frequency of impact + legal issues + detection
The risk is then based on the consequence and likelihood.
Risk = Consequence x likelihood
In order to assess each of these factors for each impact, the ranking scales in Table 5.6– Table
5.12 were used.
Table 5.6: Severity
Insignificant / non-harmful 1
Small / potentially harmful 2
Significant / slightly harmful 3
Great / harmful 4
Disastrous / extremely harmful / within a regulated sensitive area 5
Table 5.7: Spatial Scale - How big is the area that the aspect is impacting on?
Area specific (at impact site) 1
Whole site (entire surface right) 2
Local (within 5km) 3
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Regional / neighboring areas (5km to 50km) 4
National 5
Table 5.8: Duration
One day to one month (immediate) 1
One month to one year (Short term) 2
One year to 10 years (medium term) 3
Life of the activity (long term) 4
Beyond life of the activity (permanent) 5
Table 5.9: Frequency of the activity - How often do you do the specific activity?
Annually or less 1
6 monthly 2
Monthly 3
Weekly 4
Daily 5
Table 5.10: Frequency of the incident/impact - How often does the activity impact on the
environment?
Almost never / almost impossible / >20% 1
Very seldom / highly unlikely / >40% 2
Infrequent / unlikely / seldom / >60% 3
Often / regularly / likely / possible / >80% 4
Daily / highly likely / definitely / >100% 5
Table 5.11: Legal Issues - How is the activity governed by legislation?
No legislation 1
Fully covered by legislation 5
Table 5.12: Detection - How quickly/easily can the impacts/risks of the activity be
detected on the environment, people and property?
Immediately 1
Without much effort 2
Need some effort 3
Remote and difficult to observe 4
Covered 5
Environmental effects will be rated as either of high, moderate or low significance on the
basis provided in Table 5.13.
Table 5.13: Impact Ratings
RATING CLASS
1 – 55 (L) Low Risk
56 – 169 M) Moderate Risk
170 – 600 (H) High Risk
5.5.2 Impacts Identified
The impacts identified for Elgin and shown in Table 5.14.
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Table 5.14: Impact descriptions for Elgin
Impact description Impact before mitigation
Impact after mitigation
Mitigation measures Action plan Responsible person
No.
Phases Activity Aspect (cause of the impact)
Impact Risk Rating
Risk Rating
Groundwater
1 Operation Plant operation
Abstraction of Groundwater
Lowering of water table
M M
Developing a sustainable abstracting programme where the borehole intended to be used for water supply will undergo aquifer testing in order to determine a sustainable abstraction rate; -Groundwater level monitoring should be conducted and data should be interpreted by a hydrogeologist; and the borehole intended to be used for water supply will be licenced.
Refer to groundwater monitoring section
Operations or Site Manager (Environmental representative on site)
Wetland
2 Operation
Operation of WTP within the DHSWS 20m buffer
Edge effects of the WTP to the adjacent CVBW, including movement of personnel, contaminated run-off and potential sedimentation
• Proliferation of alien and invasive vegetation species. • Changes to ecological and socio-cultural service provision. • Changes to sediment balance.
*Refer to paragraph
below M
Refer to the Freshwater Ecological Assessment Report (Annexure B)
Operations or Site Manager (Environmental representative on site)
3 Operation
Site run-off water into the CVBW
• Contaminated runoff entering the CVBW. • Water quality deterioration
• Impacts to the reserve and resource quality objectives. • Impacts on water quality. • Changes to ecological and
*Refer to paragraph
below H
Refer to the Freshwater Ecological Assessment Report (Annexure B)
Operations or Site Manager (Environmental representative on site)
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Impact description Impact before mitigation
Impact after mitigation
Mitigation measures Action plan Responsible person
No.
Phases Activity Aspect (cause of the impact)
Impact Risk Rating
Risk Rating
in the CVBW due to water not meeting general limits. • Impacts to the water quality in the larger catchment, including the Palmiet River.
socio-cultural service provision. • Changes to hydrological function and sediment balance.
*The DHSWS risk assessment was applied under the current conditions observed on site, prior to implementation of listed remediation measures,
since the WTP is already discharging backwash effluent into the CVBW; and
*Although the risk assessment is usually undertaken under post-mitigation conditions, it was not deemed applicable in this case as the construction
activities. As such all scoring was undertaken based on the current conditions and remediation actions were recommended.
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5.6 Issues and Responses from Public Consultation Process
Public participation is an essential and legislative requirement for any environmental
authorisation process. The principles that demand communication with society at large are
best embodied in the principles of the National Environmental Management Act 1998 (Act No.
107 of 1998) (NEMA), South Africa’s overarching environmental law.
Section 41 (4) of the NWA provides that the competent authority, the DHSWS, may, at any
stage of the application process, require the applicant to place a suitable notice in
newspapers and other media, and to take other reasonable steps as directed by the
competent authority to bring the application to the attention of relevant organs of state,
interested persons and the general public. The required Public Participation Process (PPP) is
outlined in the Government Notice Regulation 267, Regulations Regarding the Procedural
Requirements for Water Use Licence Applications and Appeals published in Government
Gazette 40713 on 24 March 2017.
As such, the following PPP was undertaken for this IWULA in accordance with GNR.267:
• Erecting of Site Notices;
• Distribution of Background Information Documents (BIDs) to adjacent landowners,
the respective local governments and any other Interested and Affected Party (I&AP)
that requested said document; and
• Placement of an advertisement in the local newspaper (District Mail) on the 24th
September 2020.
5.6.1 Stakeholder Database
5.6.2 Landowner Consultation
5.6.3 Notification Documents
5.6.3.1 Site Notices
5.6.3.2 Background Information Document
5.6.3.3 Media Advertisement
5.6.4 Public Comment Period
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5.7 Matters Requiring Attention/ Problem Statement
This section is not applicable to the Elgin.
5.8 Assessment of Level and Confidence of Information
All information contained in this IWWMP was sourced from the specialist studies conducted
for the project area. The specialists appointed to undertake the various investigations are
considered to be competent in their particular fields. In light of the above, the level of
confidence with regards to the information and reports used to compile this document is
high.
6 WATER AND WASTE MANAGEMENT
6.1 Water and Waste Management Philosophy
The following philosophies have been created to ensure the correct management of the water
at Elgin’s operations.
6.1.1 Process Water
The following objectives/goals relate to Process Water:
• Optimise the re-use of process water;
• Ensure water is not unnecessarily abstracted or wasted;
• Manage water quality according to the performance objectives included in the
conditions of all the environmental authorisations;
• Ensure that water quality remains within the requirements set by DHSWS; and
• Management of the process water infrastructure in such a manner that risk will be
avoided.
6.1.2 Stormwater
The following objectives/goals relate to Stormwater:
• To ensure at all times the effective separation of clean and dirty water and the
protection of clean water;
• Ensure that dirty water footprints are reduced to the smallest possible catchment
size;
• Implement a storm water management plan on site based on best practice principles;
• Effective maintenance of all stormwater structures and infrastructure; and
• Containment and re-use of dirty water in the process.
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6.1.3 Groundwater
The following objectives/goals relate to Groundwater:
• Conduct all activities in such a manner that it will not pose unnecessary threats to
the groundwater resources in terms of quality and quantity;
• Conduct groundwater monitoring on a quarterly basis to assist in identifying risks
early so that management measures can be implemented timeously; and
• Inspect and monitor all aspects that lead to the protection of the groundwater regime
on a regular basis.
6.1.4 Waste
The philosophy for the management of the various waste streams on site is:
• Eliminate:
o Remove the waste source;
o Substitute for a product that will produce less waste; and
o Stop poor waste practices.
• Control at the source:
o Restrict waste: Contain or attenuate the waste source; and
o Proper maintenance and good housekeeping of plant, equipment and
machinery.
• Minimise:
o Restrict waste. (Admin. controls);
o Re-use and recycle waste; and
o Competent on-going supervision is needed to ensure compliance.
6.2 Strategies
6.2.1 Process Water
Process water management will consist of:
• Investigating new alternatives for process water treatment and re-use.
6.2.2 Storm Water
Storm water management will comprise of the following:
• Regular monitoring of surface water quality; and
• Regular monitoring and maintenance of stormwater control structures.
6.2.3 Groundwater
Groundwater management strategies will comprise of the following:
• Continued, regular monitoring of groundwater levels and quality.
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6.2.4 Waste
Waste management strategies will consist of:
• Implementation of good housekeeping and best practises;
• Investigating new, cleaner and more cost effective technologies to reduce and
manage waste;
• Monitor compliance with best practises; and
• Creating environmental awareness and sensitivity through improvements to the
induction programme for employees.
6.3 Performance Objectives/ Goals
The following objectives and strategies are followed in order to achieve the Safety, Health,
Environment and Quality Policy:
• Compliance:
o Identify all applicable legislation and other applicable requirements to the
identified environmental aspects and will ensure that the operations remain
in compliance with such legislation and requirements.
• Pollution Prevention:
o Identify the impacts that all operations, processes and products have on the
environment and will ensure that pollution on the environment is prevented
or minimised.
• Improvement:
o Set objectives and targets to improve environmental performance and the
Environmental Management System and will continually strive to find even
better sustainable solutions to problems.
• Competence:
o Ensure that all people who perform work for or on behalf of Elgin are
competent and understand the impact of their activities on the environment,
and their role in the prevention of pollution and the maintenance of the
Environmental Management System.
• Communication:
o Actively communicate this policy to persons working for and on behalf of
Elgin to ensure that they understand the content intent and will make it
available to the public.
• Review:
o Review the continued sustainability and adequacy of this policy at least
annually to ensure it remains valid at all times.
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6.4 Measures to Achieve and Sustain Performance Objectives
The IWWMP must clearly demonstrate that they have incorporated all of the above
objectives/principles or, alternatively, must clearly motivate why any of the above principles
are not relevant.
The water resource can be protected in the following ways by applying water conservation,
pollution prevention and minimisation of impacts principles:
• Reduction in the level of contamination of water through implementation of pollution
prevention strategies thereby increasing the economic reuse of the water without
treatment; and
• Minimisation of impacts through capture, containment, reuse & reclamation of
contaminated water thereby preventing discharges/releases.
6.5 Option Analyses and Motivation for Implementation of Preferred Options
Elgin is an existing operation and as such, no alternatives have been investigated as these
were previously investigated before the operations were constructed.
6.6 IWWMP Action Plan
An Action Plan provided herein shall provide water and waste management options for issues
requiring immediate attention at the Elgin. The broad objective of the Action Plan is to
provide robust and sustainable water and waste management practice for the mining
operation. The following aspects will be addressed as part of the Action Plan:
• Key performance areas
• Objectives
• Roles and responsibilities
• Timeframes
The compilation of an IWWMP is a long-term commitment in terms of resources requirements
including technical investigations that are conducted. These also require disbursing financial
resources to implement management measures which can in most cases take months. With
this in mind, this IWWMP has been developed for medium term (i.e. first 5 years of operation
of the facility), with the Action Plan herein reviewed and updated every year. It is thus the
intention of the facility to have yearly interaction with DHSWS and update the Action Plan
accordingly. Refer to Table 6.1 for Elgin’s IWWMP Action Plan.
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Table 6.1: IWWMP Action Plan Action Implementation Date Person Responsible
1 Maintenance and cleaning of storm water management trenches.
On going Sustainability Department
2 Installation of a metering device to accurately measure water use proposed for abstraction from the borehole
Before use of borehole Technical Department
3 Weekly Site Inspections weekly Sustainability Department
4 Monthly management inspections Monthly Sustainability Department
5 Groundwater Monitoring Quarterly Sustainability Department /Contractor
6 Surface Water Monitoring Monthly Sustainability Department /Contractor
7 Bio-monitoring (Erosion and Sedimentation)
Monthly and after each major rainfall event
Sustainability Department /Contractor
8 Bio-monitoring (Alien Vegetation Control)
• During and after growing season;
• Regrowth of alien vegetation should be monitored monthly during the first year after the construction phase;
• Thereafter monitoring must be done annually
Sustainability Department /Contractor
9 WUL Audits (Internal) Annually Sustainability Department
10 WUL Audits (external) Annually Contractor
11 Update Water Balance Annually Sustainability Department /Contractor
12 Employee Training New employees and after employees return from leave
Sustainability and Training Department
6.7 Control and Monitoring
6.7.1 Monitoring of Change in Baseline (Environment) Information
6.7.1.1 Surface Water
Refer to Section 5.4.1 for the monitoring and control of the surface water at Elgin.
6.7.1.2 Groundwater
Refer to Section 5.4.2 for the monitoring and control of the groundwater at Elgin.
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6.7.1.3 Bio-monitoring
Refer to Section 5.4.1 for the monitoring and control of the bio-monitoring at Elgin.
6.7.2 Audit and Report on Performance Measures
Each component within the IWUL (when issued) will have an associated audit and
performance review component. Regular review and auditing is important to ensure systems
are up-to-date and still relevant for current situations. Evaluation is required to verify its
appropriateness and suitability by comparing performance to objectives set. Changes or
adjustments to systems are required where review/auditing highlights shortcomings or gaps.
An internal audit will be undertaken within the first three months of the licence issuance and
receipt, with the aim to allow the operation to assess the licence for accuracy and to ensure
the way forward in terms of the licence requirements are understood internally. Thereafter,
the following year an external audit will be undertaken. Subsequently internal and external
audits will be alternated annually, such that either an internal or external audit is undertaken
on an annual basis, with the audit type alternated.
Performance should be measured against:
• Annually – alternating internal and external audits per annum, such that only one
audit is conducted per annum; and
• DHSWS reporting (conducted bi-annually).
6.7.3 Audit and Report on Relevance of IWWMP Action Plan
Audits of the water and waste management programmes are undertaken in line with license
requirements. They include assessments of performance in relation to the action plan, whilst
reviewing the relevance of all provisions or commitments in the plan.
7 CONCLUSION
7.1 Regulatory Status of Activity
Elgin was issued with an Environmental Authorisation in terms of the National Environmental
Management Act (NEMA), 1998 (Act No. 107 of 1998) on the 24th February 2015 (EIA Ref:
16/3/1/1/E4/11/2068/14) (Annexure E).
In addition, a Water Use Regulatory Assessment was conducted by ENSafrica to identify the
types of authorisations a company would typically expect to see for the water uses
undertaken on the property and determines whether the requisite authorisations exist or do
not exist. It was determined that Elgin would need to apply for an IWULA.
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7.2 Statement of Water Uses Requiring Authorisation
Elgin currently triggers water uses in terms of Section 21 of the National Water Act, 1998 (Act
No. 36 of 1998) (NWA) which require authorisation from the Department of Human
Settlements, Water and Sanitation (DHSWS) in the form of an Integrated Water Use License
Application (IWULA). The following water uses have been identified for authorisation:
• Section 21(a) – Taking water from a water resource;
• Section 21(b) – Storing water (applying as a General Authorisation);
• Section 21(c) – Impeding or diverting the flow of water in a watercourse; and
• Section 21(i) – Altering the beds, banks, course or characteristics of a water course.
7.3 Section 27 Motivation
Refer to Annexure C for the Section 27 Motivation Report.
7.4 Proposed Licence Conditions
The following recommendations were provided in the Hydrogeological Investigation:
• It is recommended that the borehole be pumped at a yield of 5.4 l/s for 18 hours and
left to recover for 6 hours before pumping commences again;
• The water from borehole EC BH1 should be treated if it is to be utilized;
• The water level within the borehole and the quantity thereof, should be monitored
according to Table 5.5; and
• The borehole should also be fitted with a dry-run system and the reservoir be
monitored with a float system, this should ensure the longevity of the equipment and
the optimal use of the groundwater resource.
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8 REFERENCES
Department of Water and Sanitation. (2018). Government Gazette (GN 42053): Proposed
Classes of Water Resources and Resource Quality Objectives for the Breede-Gouritz Water
Management Area.
Bailey, A. & Pitman, W., 2015. Water Resources of South Africa 2012 Study (WR2012):
Executive Summary Version 1. WRC Report No. K5/2143/1, Gezina, South Africa: Water
Research Commission Report.
Theewaterskloof Municipality. (2020). Draft Integrated Development Plan 2020/21-2021-22.
Available from:
https://drive.google.com/file/d/1luSj6mKfulV81T2F6Fn79_QqlDJbUebF/view
The Water Research Commission. (2017). Palmiet River – Integrated catchment risk
assessment. Available from: http://www.wrc.org.za/wp-
content/uploads/mdocs/PB_2329_Palmiet%20River%20integrated%20catchment%20risk%20as
sessment.pdf
Consulted Specialist Studies Conducted for Elgin:
• Hydrogeological Investigation (GCS); and
• Freshwater Ecological Assessment (FEN Consulting);