elgin free range chickens integrated water use licence

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

. . . .

Elgin Free Range Chickens IWULA

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.


19-1170 28 September 2020 Page iii

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


19-1170 28 September 2020 Page iv

Integrated Water Use License Application (IWULA). The following water uses have been

identified for authorisation and can be seen in the table below:




o Storing water in a reservoir located on the property (falls within the GA

limit).




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


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.


19-1170 28 September 2020 Page v

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


19-1170 28 September 2020 Page vi

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


19-1170 28 September 2020 Page vii

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


19-1170 28 September 2020 Page viii

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


19-1170 28 September 2020 Page 1

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.



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

mailto:[email protected]

mailto:[email protected]



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



Figure 1.1: Elgin Chicken Locality Map



Figure 1.2: Elgin Chicken Property Map



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.



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.



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;



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.


19-1170 28 September 2020 Page 10

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


19-1170 28 September 2020 Page 11

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:




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).




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


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


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 –


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 –


falls beyond the ideal range (<30cmS/m).

• Downstream: pH – 7.25; Electrical Conductivity (EC) – 33 mS/m; and temperature –


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


19-1170 28 September 2020 Page 48

= 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


19-1170 28 September 2020 Page 52

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


19-1170 28 September 2020 Page 54

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.


• 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.


• 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)


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)



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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);

https://drive.google.com/file/d/1luSj6mKfulV81T2F6Fn79_QqlDJbUebF/view

http://www.wrc.org.za/wp-content/uploads/mdocs/PB_2329_Palmiet%20River%20integrated%20catchment%20risk%20assessment.pdf

