FRAMEWORK EMP (femp) FOR OPEN CYCLE GAS TURBINE POWER STATION AND ASSOCIATED INFRASTRUCTURE NEAR MOSSEL BAY

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1 FRAMEWORK EMP (femp) FOR OPEN CYCLE GAS TURBINE POWER STATION AND ASSOCIATED INFRASTRUCTURE NEAR MOSSEL BAY ACTIVITY ASPECT IMPACT MITIGATION MEASURE: 1. COMPLIANCE WITH ENVIRONMENTAL LEGISLATION All Activities (OCGT substation, access road, fuel pipeline, water supply conveyance, transmission Proteus substation) Compliance with Regulation of Environment Conservation Act Compliance with Sections 38(1) 38(8) of National Heritage Resources Act. Delay in onset of activity Suspension of Prosecution Delay in issuing of ECA iv RoD Delay in onset of activity Suspension of Prosecution Objective: To ensure that requi authorisation has been received 1) Complete the statutory i process Objective: To ensure that the requi heritage inputs have been integrated into the process 1) Solicit comment from HWC v / SAHRA vi as part of the consultation process 2) Complete permit application process if required RoD ii ( appeal adjudication if relevant) received from DEAT iii Comment from HWC/ SAHRA Permit(s) to destroy identified resources (if required) received from HWC/ SAHRA Consultant Consultant process process Prior to Prior to submission of (for comment) Prior to (for any permits) OCGT substation Compliance with NEM vii Air Quality Act Air Pollution Prevention Act Suspension of operational Prosecution Objective: To ensure that requi authorisation has been received 1) Complete permit application process. Permit received from DEAT: Air Quality Control Air Quality process APPA viii / NEMAQA ix permit Applications Prior to Water source conveyance Compliance with Sections 40 & 41 of National Water Act Delay in issuing of the ECA RoD Delay in onset of activity Suspension of Objective: To ensure that the requi authorisation has been received 1) Solicit comment from DWAF x as part of the consultation process 2) Complete water use licence application if required Comment from DWAF Requi water use licence received from DWAF (if existing PetroSA supply not acceptable) Consultant process Water use licence application Prior to submission of (for comment) Prior to (for any permits) Prosecution 1

2 2. ENVIRONMENTAL INPUT INTO TENDER DRAFTING AND ADJUDICATION All Activities (OCGT substation, access road, fuel pipeline, water supply conveyance, transmission Proteus substation) Engineering Design of identified Compile tender Specifications Design incompatible with. during Objective: To ensure the design takes into account the 1) Assimilate requirements into the design Objective: To ensure acceptable of issues during 1) Incorporate relevant specifications (both general project specific) into the Tender xi 2) Incorporate relevant payment items into the Bill of Quantities Design meets objectives does not degrade the Tender ation include requirements Engineering Design Engineering Design technical In-house EMPs (i.e. for Line Substation / Refurbishment Work) Tender Design & Design Review Stage Tender Design & Design Review Stage Review by Tender Adjudication during Objective: To ensure acceptable of issues during 1) Assess ability of Tenderers to adequately manage the issues Tender evaluation report contain reference to ability of tenderers Successful show clear commitment to capacity for meeting the obligations Engineering Design technical In-house Agreement Tenderer Questionnaire (i.e. for Line Substation / Refurbishment Work) Tender Design & Design Review Stage Review by 2

3 3. ENVIRONMENTAL INPUT INTO DESIGN All Activities (OCGT substation, access road, fuel pipeline, water supply conveyance, transmission Proteus substation) Detailed design of Design fails to respond optimally to the considerations Objective: To ensure that the design responds to the identified constraints opportunities 1) Carefully consider the design level mitigation measures recommended by the various specialists, especially with respect to visual aesthetics, noise, air quality flora. 2) Balance technical financial considerations against constraints opportunities in finalising the design of key elements 3) Incorporate in-house procedures, especially with respect to bird collisions perching, into the design Design meets objectives does not degrade the Engineering Design technical In-house procedures (e.g. for bird collisions bird perching) Tender Design & Design Review Stage Fuel pipeline Negotiation with lowners Selection of preferred route Lowners unfairly prejudiced by proposed siting, routing or tower configuration Route that degrades unnecessarily poses heightened health safety risk Objective: To ensure adequate regard has been taken of lowner concerns that these are appropriately addressed 1) Initiate negotiations with lowners timeously 2) Address reasonable expectations/ requests were possible 3) In event of impasse follow legal expropriation route, but ensure that extent of expropriation is minimised, restrictions on l use are minimised reasonable costs are paid Objective: To ensure selection of BPEO xii for fuel pipeline route 1) Select route that curtails impacts enhances benefits, whilst being technically feasible affordable 2) In adjudicating the preferred routing, careful consideration must be given to in particular the risks associated with the pipeline. Location of does not prejudice any lowners. Ideally, lowners should be satisfied with outcome of negotiations process. In event of impasse requiring expropriation, lowners should be afforded reasonable appropriate rights/ access Routing meets objective. Selected route minimises any negative impacts, maximises any benefits minimise health safety risks (in-house ) (due to schedule) process In-house procedures for lowner negotiations expropriation Ideally initiated prior to submission of final (which indicates preferred options) Finalised prior to Prior to submission of 3

4 Water source conveyance Finalisation of conveyance type route xiii Route that degrades unnecessarily does not guarantee surety of supply for OCGT Objective: To ensure selection of BPEO for water conveyance type routing 1) Select route that curtails impacts enhances benefits, whilst being technical feasible affordable Alignment meets objective. Selected alignment minimises any negative impacts, maximises any benefits ensures a reliable supply of water to the OCGT on the long-term (due to schedule) Prior to submission of Access road Selection of preferred route Route that degrades unnecessarily, particularly with respect to visual aesthetics loss of indigenous flora Objective: To ensure selection of BPEO for alignment for the access road 1) Select alignment that curtails impacts enhances benefits, whilst being technical feasible affordable Alignment meets objective. Selected alignment minimises any negative impacts maximises any benefits (due to schedule) Prior to submission of Transmission lines Selection of preferred route Selection of preferred tower configuration Route that degrades visual aesthetics of area has unacceptable impact on lowners with respect to luse Tower configuration that degrades visual aesthetics of the area Objective: To ensure selection of BPEO for transmission line route 1) Select route that curtails impacts enhances benefits, whilst being technical feasible affordable 2) In adjudicating the preferred routing careful consideration must be given to in particular the visual aesthetics lowners (especially with respect to continued l-use) Objective: To ensure selection of BPEO for transmission tower configuration 1) Select tower configuration that curtails impacts enhances benefits, whilst being technical feasible affordable. 2) In adjudicating the preferred tower configuration, careful consideration must be given to in particular the visual aesthetics Routing meets objective. Selected route minimises any negative impacts maximises any benefits. Tower configuration meets objective. Selected tower design(s) minimises any negative impacts maximises any benefits. (due to schedule) (due to schedule) Prior to submission of Prior to submission of 4

5 4. ENVIRONMENTAL MANAGEMENT OF THE CONSTRUCTION PHASE xiv OCGT xv associated (including substation, fuel pipeline, water source conveyance access road) Monitoring enforcement of specified requirements Communication with his during of OCGT associated Inability to communicate effectively with the regarding their obligations Objective: To ensure that the of the OCGT associated does not result in avoidable the, that any impacts that do occur are anticipated managed 1) Appoint an Control Officer is (either independent or inhouse) 2) Develop implement an auditing system for the 3) Audit the compliance with the requirements of the specification contained within the relevant Objective: To ensure that there is effective communication with the on issues 1) Include considerations as an item on the agenda of the monthly meetings for each 2) Include considerations in the s programme (where relevant) 3) Appoint a senior manager on the s as the designated Officer, empowered to managed compliance with the requirements on behalf of the 4) Compile implement the necessary Method Statements 5) Undertake awareness training of all impacts effectively monitored managed during the with no residual the Comprehensive record of compliance remedial actions available to the authorities requirements are proactively communicated with the reflected in a more responsible approach to consultant/ inhouse consultant/ inhouse Programme Meetings to to DEAT/ DEA&DP xvi 5

6 Communication with public ~ Access ~ structures Inability to deal with public queries complaints Hazards to lowners public, security of materials that degrades the visual aesthetics of the area, unnecessarily exacerbates consequences of leads to public complaint Objective: To ensure that the public has a mechanism to contact a responsible individual in order to obtain information or report complaints Mechanism 1) Provide a contact number of someone responsible for the on the signage 2) Maintain a complaints register on to allow public complaints to be recorded. Complaints should be noted signed off at meetings Objective: To secure the against unauthorised entry to protect members of the public/ lowners 1) Secure in an appropriate manner 2) Where necessary to control access, fence secure s camp 3) Provide alternative access/ detours for public/ lowners Objective: To minimise the consequences associated with the of the 1) Locate key in ly acceptable area limit its extent 2) Position so as to limit visual intrusion on neighbours or greater 3) Select materials for that limit reflection blend in with the 4) Accommodate temporary services underground within the same trench were possible Public are able to communicate effectively with the relevant members of the project team either to obtain information or lodge complaints is secure there is no unauthorised entry No members of the public/ lowners injured has limited impact on the visual aesthetics of the area does not result in unnecessary degradation to 6

7 ~ Protection or topsoil sensitive areas/ artefacts ~ Surface groundwater ~ Solid waste Destruction or loss of topsoil, sensitive areas/ artefacts (which could include indigenous vegetation, fauna or heritage resources) Pollution of water resources by effluents Pollution of with solid waste materials Objective: To retain topsoil for later use in closure to ensure that disturbance to sensitive areas or artefacts is minimised 1) Locate key in ly acceptable area limit its extent 2) Remove topsoil approximately 150 mm deep from, working area stockpile areas, stockpile for later use 3) Protect topsoil stockpiles against erosion contamination 4) Provide containment settlement facilities for effluents from concrete mixing facilities 5) Provide spill containment facilities for hazardous materials like fuel oil 6) Minimise the extent of areas cleared 7) Identify sensitive areas or artefacts demarcate these as no-go areas 8) Develop contingency plans to address heritage resource discoveries during Objective: To avoid pollution of water resources 1) Establish contaminated water system 2) Provide suitable sufficient ablution facilities that are serviced regularly 3) Provide containment settlement facilities for effluents from concrete mixing facilities 4) Provide spill containment facilities for hazardous materials like fuel oil Objective: To avoid pollution of with solid waste materials 1) Provide adequate waste bins 2) Set up system for regular waste removal to approved facility 3) Minimise waste by sorting wastes into recyclable non recyclable wastes 4) Prohibit burying or burning of waste on Limited extent of vegetation destroyed during activities Sufficient topsoil for closure available No topsoil contaminated with cement materials, fuel, oil or other undesirable compounds No sensitive s or artefacts damaged or destroyed Effluents managed effectively No pollution of water resources Appropriate of solid wastes No complaints from public 7 to to

8 ~ Fire Increased fire risk to surrounding areas Objective: To decrease fire risk 1) Provide adequate cooking heating facilities for 2) Prohibit open fires 3) Develop emergency protocols for dealing with fires No occurrence of fires on or on surrounding areas to ~ Materials Risk of contamination or safety incident to public/ resulting from inappropriate treatment of materials Objective: To ensure that materials are hled, used stored in a manner that limits the risk of contamination or a safety hazard 1) Inform delivery drivers re requirements of the specifications 2) Secure materials during transport 3) Identify appropriate storage areas for stockpiling of materials, storage of hydrocarbons storage of hazardous substances ensure that these areas are appropriately prepared for their purpose 4) Dispose of hazardous substances in terms of the relevant legal requirements 5) Limit spillage of hazardous substances or substances with the potential to cause contamination of the 6) Develop emergency protocols for dealing with spillages particularly where these pose a pollution risk or involve hazardous substances 7) Compile implement the necessary Method Statements 8) Undertake awareness training of all Correct hling, use storage of materials, including hazardous materials No incidents of contamination No accidents or incidents related to the hling of materials No public complaints to 8

9 ~ Equipment maintenance storage ~ Surface water /or existing stormwater systems ~ Dust Present of plant on which exacerbates impact including pollution nuisance Contamination of stormwater runoff with suspended solids Dust nuisance from the excavated stockpiled materials Objective: Ensure that all plant on is well maintained serviced in the appropriate manner 1) Ensure that all plant is in good working order 2) Undertake maintenance within specified area (workshop) 3) Use drip trays for all stationary or parked plant when servicing equipment away from designated areas Objective: Contain soils materials within defined areas prevent contamination of stormwater runoff 1) Identify predetermined stockpile areas for topsoil, materials excavated material 2) Dispose of waste excavated material at appropriate waste disposal s 3) Rehabilitate to prevent soil erosion, including temporary revegetation of areas that will remain exposed for extended periods 4) Undertake concrete mixing away from sensitive areas on impermeable surfaces 5) Store fuels in storage area that is appropriately bunded drains to a sump 6) Ensure that substances that pose a risk of water contamination are appropriately stored disposed of 7) Develop implement water monitoring programme where work abuts aquatic systems Objective: To avoid dust nuisance from excavated materials or materials 1) Implement dust suppression measures e.g. regular watering 2) Concrete mixing to be carried out away from sensitive areas 3) Develop implement dust monitoring programme All plant in good working order Maintenance of plant does not result in degradation No public complaints Correct stockpiling of excavated material on No waste material left on No erosion on No pollution of water courses Appropriate of dust No complaints from public No complaints from 9 to to to

10 ~ Noise ~ Public health safety Closure ~ integrity Noise nuisance from equipment Hazardous conditions to lowners members of the public integrity of undermined resulting in reduced visual aesthetics, erosion, compromised l capability on-going intervention Objective: To avoid noise nuisance from equipment 1) Limit working hours of noisy equipment to daylight hours 2) Fit silencers to equipments 3) Develop implement noise monitoring programme Objective: Provide adequate warning to lowners/ public regarding potential hazards ensure safe access where required 1) Ensure adequate signboards to lowners/ public about the work, particularly where work abuts major public thoroughfares like the N2 2) Implement requi traffic safety measures were abutting roads 3) Ensure adequate accessibility to lowners/ public where required for safe access Objective: To ensure that the is appropriate rehabilitated following the execution of the works, such that residual impacts are remediated or curtailed 1) Remove all temporary facilities waste materials 2) Replace stockpiled topsoil 3) Install necessary drainage works anti-erosion measures 4) Lscape revegetate disturbed areas with appropriate vegetation 5) Ensure that the is required to maintain revegetated areas until an acceptable cover has been achieved Appropriate of noisy activities No complaints from public No complaints from Safe conditions for public No members of the public/ lowners injured Signboards put up before commences Provision of safe access routes for lowners/ public, which are clearly demarcated visible All portions of, including camp working areas, cleared of equipment temporary facilities Topsoil replaced on all areas, stabilised Disturbed areas rehabilitated Acceptable cover achieved on closed Closed free of erosion to to Following execution of the works consultant/ in house DEAT/ DEA&DP 10

11 Transmission line substation xvii Implementation of general requirements, monitoring/ enforcement of said implementation Implementation of project specific requirements, monitoring/ enforcement of said implementation during of transmission line substation during of transmission line substation Objective: To ensure that the of the transmission line substation do not result in avoidable the, that any impacts that do occur are anticipated managed 1) Appoint an Control Officer (either independent or in-house) 2) Develop implement an auditing system for the 3) Audit the compliance with the requirements of the in-house EMPs for Line Substation / Refurbishment Work Objective: To ensure that the transmission line substation do not result in avoidable the, that any impacts that do occur are anticipated managed 1) Appoint an Control Officer (either independent or in-house) 2) Develop implement an auditing system for the 3) Audit the compliance with the project specifications produced to augment the in-house EMPs impacts effectively monitored managed during the with no residual the Comprehensive record of compliance available to authorities proponent impacts effectively monitored managed during the with no residual the Comprehensive record of compliance available to authorities proponent (implementation) & consultant/ inhouse (monitoring enforcement) (implementation) & consultant/ inhouse (monitoring enforcement) document In-house EMPs (i.e. for Line Substation / Refurbishment Work) to to consultant/ in house DEAT/ DEA&DP consultant/ in house DEAT/ DEA&DP 11

12 Communication with his Communication with public Inability to communicate effectively with the regarding their obligations Inability to deal with public queries complaints Objective: To ensure that there is effective communication with the on issues 1) Include considerations as an item on the agenda of the monthly meetings for each 2) Include considerations in the s programme (where relevant) 3) Appoint a senior manager on the s as the designated Officer, empowered to managed compliance with the requirements on behalf of the 4) Compile implement the necessary Method Statements 5) Undertake awareness training of all Objective: To ensure that the public has a mechanism to contact a responsible individual in order to obtain information or report complaints Mechanism 1) Provide a contact number of someone responsible for the on the signage 2) Maintain a complaints register on to allow public complaints to be recorded. Complaints should be noted signed off at meetings. requirements are proactively communicated with the reflected in a more responsible approach to Public are able to communicate effectively with the relevant members of the project team either to obtain information or lodge complaints consultant/ inhouse Programme Meetings to to 12

13 5. ENVIRONMENTAL MANAGEMENT OF THE OPERATIONAL AND DECOMMISSIONING xviii PHASES OCGT xix associated (including substation, fuel pipeline, water source conveyance access road) procedures of the operational No framework within which to locate the of the operational decom. s No procedures against which to assess performance during the operational decom. s thus no measure of compliance during operation Objective: To develop procedures which are consistent with the existing Management Procedures will ensure the effective proactive of the operational decom. s 1) Use the Peaking Business Unit Management Procedure as the basis to develop specific procedures for the Mossel Bay OCGT its associated 2) Ensure that Management Procedures provide specific policies plans that comply with s EMS 3) Ensure that the procedures are practical implementable on the Objective: To ensure that the operation of the OCGT associated does not result in avoidable the, that any impacts that do occur are anticipated managed 1) Implement the operational procedures outlined in the Management Procedure Management Procedure for the MB OCGT associated which is consistent with the Business Units existing documents, complies with s EMS requirements will ensure effective of the operational decom. s impacts effectively monitored managed during the operational with no residual the Comprehensive record of compliance remedial actions available to the authorities (in-house ) In-house procedures (i.e. Peaking Business Unit Management Procedure) EMS Management Procedure EMS Prior to the onset of operation operation of the decom. during decom. Objective: To ensure that the decom. of the OCGT associated does not result in avoidable the, that any impacts that do occur are anticipated managed 1) Implement the decom. procedures outlined in the Management Procedure impacts effectively monitored managed during the decom. with no residual the Comprehensive record of compliance remedial actions available to the authorities (in-house ) Management Procedure EMS decom. 13

14 Transmission line substation No policies or procedures to guide of activities associated with the maintenance, decom. of the transmission lines substation Objective: To ensure that the requi policies procedures are implemented to ensure the effective proactive of the maintenance, operation decom. of the transmission lines associated substation 1) Revise the existing transmission policies procedures (were necessary) to ensure that they adequately cater for the specific issues associated with the current 2) Ensure that Management Procedures provide specific policies plans that comply with s EMS 3) Ensure that the procedures are practical implementable on the policies procedure for the transmission line that complies with s EMS requirements will ensure effective of the operational decom. s In-house procedures (i.e. those developed by transmission, including access to farms, bird collision, nesting perching, erosion, fire protection, gate, vegetation etc.) Prior to the onset of operation EMS of the operational during maintenance operation Objective: To ensure that the maintenance operation of the transmission does not result in avoidable the, that any impacts that do occur are anticipated managed 1) Implement the maintenance operation procedures impacts effectively monitored managed during maintenance operation with no residual the Comprehensive record of compliance remedial actions available to the authorities (in-house ) Transmission policies procedure EMS maintenance operation 14

15 of the decom. during decom. Objective: To ensure that the decom. of the transmission does not result in avoidable the, that any impacts that do occur are anticipated managed. 1) Implement the decom. procedures impacts effectively monitored managed during decom. with no residual the Comprehensive record of compliance remedial actions available to the authorities (in-house ) Transmission policies procedure EMS decom. i = Impact Assessment ii RoD = Record of Decision iii DEAT = Department of Affairs Tourism iv ECA = Conservation Act v HWC = Heritage Western Cape vi SAHRA = South African Heritage Resources Agency vii NEM = National Management (as is National Management Act, the umbrella Act under which the Air Quality Act is promulgated) viii APPA = Air Pollution Prevention Act ix NEMAQA = National Management Air Quality Act x DWAF = Department of Water Affairs Forestry xi The in-house EMPs may need to be augmented with project specific project specifications to ensure that the issues are comprehensively addressed in the Tender. xii Within this context BPEO, or Best Practicable Option, is defined as for a given set of objectives, the option that provides the most benefits or least damage to the as a whole, at acceptable cost, in the long term as well as in the short term (Royal Commission on Pollution, 1988). Here includes both the social biophysical components. xiii It is assumed that the source of water would have been resolved as part of the process as highlighted under Section 1 of the femp xiv It is understood that effect will be given to the requirements listed here by ensure that they are integrated as specifications (where appropriate) in the Tender, as highlighted under Section 2. xv More detail is provided on the OCGT related since has no stard in-house procedures in this regard. xvi DEA&DP = Department of Affairs Development Planning xvii This section is intentionally less detail than the preceding section as has in-house EMPs to address the transmission line aspects of this project these should be implemented during the. xviii Abbreviated to decom. xix More detail is provided on the OCGT related since has no stard in-house procedures in this regard. 15