Bokpoort CSP Groundwater Management Plan - WSP

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Bokpoort CSP Groundwater ManagementPlan

Document Revision and Approval

Developer Nonkanyiso May EO 06 September 2018

Reviewer Marthinus Engelbrecht HSE Manager 06 September 2018

Approver Bheki Majola PGM 06 September 2018

Name Title Date Signature

Proc. No: NBKP/HSE/PL-002

Proc Title: Groundwater Management Plan

Revision Date Description

00 06 September 2018 Bokpoort CSP Groundwater Management plan – First review

Groundwater Management Plan

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1. Background.......................................................................................................................................... 32. Groundwater Management Plan .......................................................................................................... 33. Purpose ............................................................................................................................................... 44. Scope ................................................................................................................................................... 45. Roles and Responsibilities .................................................................................................................... 46. Equipment/Software ........................................................................................................................... 57. Terminology......................................................................................................................................... 58. Procedure ............................................................................................................................................ 79 Records:............................................................................................................................................. 1610 Legal Requirements and References: ................................................................................................. 17



1. Background

Bokpoort is in a portion of Farm Bokpoort 390 located in the Northern Cape; South Africa. BokpoortConcentrated Solar Plant (CSP), employs parabolic trough concentrated solar thermal technology. Thetechnology generates electricity in a similar way to conventional power stations by using steam to drive a steamTurbine generator. The fundamental principle of the technology is to collect the energy carried by sunraysthrough very precise parabolic shaped, sun-tracking mirrors to concentrate and collect sunlight on thermallyefficient receiver tubes running through the optical focal line of the parabolic mirror troughs. The parabolictroughs, orientated along the north-south directional plane, are designed to track the sun along one axis as itmoves from east to west. A heat transfer fluid (HTF) is heated by the focused sunlight as it circulates throughthe receivers to absorb the collected energy and then converting the thermal energy first into steam then intomechanical power then ultimately into electrical energy.

The capacity of the Bokpoort CSP project is 50 MW (net). The power plant includes a 1 300 MWht molten saltthermal energy storage system capable of delivering up to 9 hours of stored energy. The heat of the molten saltis then released again to the steam cycle during transitory periods (i.e. clouds passing) and in the evenings whenthe solar irradiation is lower. This helps to maintain a more constant load in the steam Turbine having a moreefficient power generation process and produce electricity during the evenings.

The Generator output voltage is 15kV. It feeds through a 15kV to 6.6kV auxiliary transformer. From the 6.6 kVbus, the power station is connected via a step-up transformer to 132kV to the Eskom Garona Substation.

This type of technology is clean, safe, sound and environmentally friendly. The power plant meets all health,safety, and labor standards.

2. Groundwater Management Plan

Nomac operation & maintenance company agree that groundwater and surface water in Bokpoort CSP arevitally important resources that provide the foundation for maintaining current and future water needs.



Preservation of these resources is essential to maintaining the operations of the site. It is the overall goalof NOMAC operations & maintenance that groundwater will continue to be a reliable, safe, efficient, andcost-effective water supply to surrounding community. This Groundwater Management Plan includestargets to guide the groundwater management actions of Bokpoort CSP. The targets described in thisGroundwater Management Plan include:

· Maintain an adequate water level in the groundwater basin.· Protect groundwater quality and implement measures, where feasible, to reduce the potential

movement of existing contaminants.· Support and encourage water conservation.· Monitor potential pollution to groundwater by the Bokpoort CSP activities.· Develop and support alternate water supplies and educate users on the benefits of water recycling.· Continue coordination and cooperation between NOMAC members and customers.

3. Purpose

To ensure compliance of Water License use and requirements in Bokpoort CPS as the per the abstract belowfrom Water Use License no. 14/D73D/ABCIH/2128.

SECTION 4. MONITORING

Detection wells must be drilled south and south-west of the ponds to monitor if any pollution isoccurring. If contamination occurs it can be detected before it reaches the groundwater systemsouth and the Orange River south-west of the site. Monthly samples should be taken.

SECTION 5. WATER RESOURCE PROTECTION

The impact of the activities of the thermal plant on the ground water shall not exceed the in-stream water quality objectives detailed in the water quality reserve for the area

SECTION 13. GENERAL CONDITION

The applicant must ensure in advance that alternative water supply for external water users isprovided to these users should groundwater resources be impacted

A proper ground water monitoring network should be established to monitor the quality ofgroundwater as per the report recommendation and ensuring that water used by other waterusers are safeguarded in accordance to Chapter 14 of the National Water Act, 1998

The evaporation pond and septic tank system must be designed in such a manner that anyspillage can be contained and reclaimed without any impact on the surrounding environment

4. Scope

Scope of this plan covers the overall groundwater management at Bokpoort CSP.

5. Roles and Responsibilities

Position Responsible for

Operation Manager(OM)

1. Overall responsibility for the implementation of groundwatermanagement on site. Ensure to implement & update OperationalEnvironmental Management Plan (OEMP) & Environmental MonitoringPlan (EMP).



Maintenance Manager(MM)

1. Ensure Preventive Maintenance site Plan / Program shall be effectiverelated to maintenance of all equipments which defects may lead togroundwater contamination.

Environmental Officer (EO)

1. Provide proper guidance and advice about the implementation ofgroundwater pollution monitoring and OEMP & EMP on site.

2. Ensure that groundwater quality is maintained by monitoring anyexceedance to DWS limits.

3. Environmental monitoring is carried out as per site EnvironmentalMonitoring Plan.

4. Report any exceedance to the limits to relevant competent authority toprevent further exceedance if any.

5. Maintain records of third party analysis.

Shift Supervisor (SS)

1. Controlling levels of the evaporation ponds to prevent overflowing intothe surrounding environment, chemical and oil spill control on site,pump halfway house and Orange River abstraction point.

Plant Chemist (PC)

1. Laboratory analysis of groundwater and maintain the records.2. Raise purchase request and get approval from PGM/OM for conducting

environmental parameters analysis by third party as per siteEnvironmental Monitoring Plan.

3. Maintain records of third party analysis.Environmental Officerand Health, & SafetyEngineer Officer (HSE/O)

1. Develop and implement of plant specific groundwater managementplan.

Health, & SafetyEngineer /Officer(HSE/O) &Environmental Officer (EO)

1. Shall be provided training on spill response, environmental awarenessprogram etc. from outsource.

6. Equipment/Software

Borehole sampling equipment

7. Terminology

BOD : Biological Oxygen DemandCOD : Chemical Oxygen DemandDEA : Department of Environmental AffairsDO : Dissolved OxygenDWS : Department of Water and SanitationEA : Environmental AuthorizationEIA : Environmental Impact AssessmentEIR : Environmental Impact ReportEMP : Environmental Monitoring PlanEO : Environmental OfficerHSE/O : Health and Safety Engineer/ OfficerMM : Maintenance ManagerMS : Maintenance SupervisorsNEMA : National Environmental Management Act no. 107 of 1998OEMP : Operational Environmental Management PlanPM : Particulate Matter



PC : Plant ChemistPE : Plant EngineerRef. : ReferenceSS : Shift SupervisorWML : Waste Management LicenseWULA : Waste Management Officer

Groundwater management plan

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8. Procedure

- Process Map

No

Compliance monitoring Remediation monitoring

2 Monitoring boreholes(located next to West &

East and West Evaporationponds)

Post-closuremonitoring

Any exceedance

Strengthen & Maintain Preventive Maintenance byMM and operation control measures shall be taken by

SS / OMYesChemist

Assessmentmonitoring

Notify toPGM/OM/MM &

HSE/O

Maintain

Monthly Water Analysis ReportNBKP/HSE/SP-004/FM-002



8.1 Groundwater monthly monitoring in Bokpoort shall be conducted in the following:

The results must be recorded and submitted to Project company on monthly basis. Project company willthen report to DWA. The below results show the analysis from June 2017 to May 2018.

- Borehole no.1- Borehole no.2- Process water discharged into evaporation pond1 (East)- Process water discharged into evaporation pond2 (West)- Homogenization pit composite- Camp potable water- Orange River raw water



8.1.1 Compliance MonitoringRelates to the conditions of the WUL & OEMP compliance. Bokpoort CSP is in possession of WUL whichrequires groundwater monitoring through two boreholes located in the solar field next to East and Westevaporation ponds. Compliance monitoring is conducted to determine if groundwater has beenimpacted by an unauthorized release. Compliance monitoring is through a combination of evaporationponds and/or groundwater sampling. Evaporation pond water monitoring is important. The possiblecause of groundwater pollution can be through seepage of waste water in the evaporation ponds(damaged liner) and overflow of evaporation ponds waste water.

Picture 1: level logger

On the picture above, it shows the level logger that was installed to measure the volume of water onthe evaporation ponds. It helps to monitor the 0.8 meters freeboard. Level logger will ensure that wemaintain the 0.8 freeboard and when to raise a flag.

In-case waste water reaches above 0.8 meters free board· Reverse Osmosis Plant (RO) plant will be installed. This RO plant will assist to treat waste water

from evaporation ponds and send back to regulation ponds for re-use in the plant. This processwill therefore decrease the level of waste water in the evaporation ponds.

· Trucks will be used to pump out waste water to dispose in a registered treatment plant by aregistered service provider.

· O & M will ensure minimum cooling tower blowdowns i.e. not discharging waste water to theevaporation ponds.

· O & M will ensure the discharging of waste water to one evaporation pond, using the secondevaporation pond as safeguard.

8.1.2 Assessment MonitoringRelates to documentation of groundwater pollution or compliance monitoring results which indicatepotential groundwater pollution from the limits from DWS.Bokpoort CSP conducts monthly monitoring on two boreholes and the samples are analysed by externalaccredited laboratory for the following parameters:

· pH,· Conductivity,



· Sodium (Na),· Magnesium (Mg),· Calcium (Ca),· Chlorides (Cl),· Sulphates (SO42-· Nitrates(NO3),· Fluorides(F),· Iron(Fe) and· Manganese (Mn).

The parameters are assessed against the limits and if there are any deviations the relevant Competent Authorityis notified. In case of water parameters exceedance, a specialist or competent authority will be contacted toassess, advise or recommend measures to be put in place. Recommendations from a specialist will beimplemented accordingly.

Remediation monitoring relates to determination of effectiveness of groundwater clean-up activities.Clean-up activities will be conducted upon any instruction from the Competent Authority.

Post-closure monitoring relates to determination of levels of contaminants at time of cessation ofBokpoort activities. Upon requirement by the Competent Authority if any groundwater pollutionrequire further monitoring, Bokpoort CSP project will comply with the WUL monitoring requirements asper appendix V section 4.1, 4.2. & 4.3.

All samples will be analysed by external accredited laboratory (Test-It-Lab) on monthly basis. Frequency mayincrease if required by events which could cause breach to allowable legislative limits. Sampling and analysis ofground water from the site will be carried out as per legislation and/or WUL, WML and EIA requirements.

Monitoring results will be communicated to competent authority on quarterly basis by the Project Company(Bokpoort CSP) as per requirement of the WUL. Engagement with the competent authority will be initiated ifthere is any exceedance from the licence’s allowable limits.

8.2 Reporting Strategy and Corrective Actions

8.2.1 Monitoring results for all water resources will be reported to the Competent Authority (DWS) on

quarterly basis as per requirement of the Water Use License.

8.2.2 If any of the parameter’s measured values are exceeding above the specified limits or breached, full

details, including causes, remedial actions and measures taken to prevent recurrence, will immediately

be notified to Operations Manager and HSE department. The site HSEO, EO, Plant Chemist and Shift

Supervisors are responsible for this notification and related corrective actions to be taken through

NOMAC IAE NCR procedure (ref. NBKP/IMS/SP-004). All corrective actions should be recorded in the

form NBKP/IMS/SP-004/FM-003 that should be kept with HSEO, Plant Chemist and Plant IMS

coordinator with a copy to MR, DC, PGM, and site HSE Department, OM, MM.

8.2.3 After internal reporting and investigation with all mitigation measures, Department will be notified with

all the recorded corrective measures taken to rectify the exceedance within 24 hours.



8.2.4 Monthly Environmental Monitoring Report will be submitted to the Project Company by OM/PGM which

includes the groundwater monitoring. Referring to section 5 of the Water Use License No.

14/D73D/ABCIH/2128 “The impact of the activities of the thermal plant on the ground water shall not

exceed the stream water quality objective detailed in the water quality reserve for the area as indicated

on the table below (6)”:

Table 6: Water resource quality objectives

License No.14/D73D/ABCIH/2128File No. 27f2/2/D73D/0/F390/1/2/3/4/8

Variable RQOPH 5.0-9.5Electric Conductivity 146.74Sodium (mg/l) 118.47Magnesium (mg/l) 45.34Calcium (mg/l) 61.37Chloride (mg/l) 106.26Sulphate (mg/l) 104.01Nitrate (mg/l) 11.26Fluoride (mg/l) 0.65

Quality of waste water to be disposed into waste water facilities shall not exceed the following limits as specifiedin table 5 of the licence 14/D73D/ABCIH/2128.

8.3 Emergency Incidents Reporting

According to NEMA Act No. 107, 1998 Section 30. (1) “incident” means an unexpected sudden occurrence. including a major emission, fireor explosion leading to serious danger to the public or 5 potentially serious pollution of or detriment to the environment. whetherimmediate or delayed.

According to NWA 36 OF 1998-chapter 3, part 4 pollution prevention, the person who owns, controls, occupies or uses the land in questionis responsible for taking measures to prevent pollution of water resources. If these measures are not taken, the catchment managementagency concerned may itself do whatever is necessary to prevent the pollution or to remedy its effects, and to recover all reasonable costsfrom the person responsible for the pollution.

According to NWA 36 OF 1998-chapter 3, part 5 Emergency incidents, such as an accident involving the spilling of a harmful substancethat finds or may find its way into a water resource. The responsibility for remedying the situation rests with the person responsible for theincident or the substance involved. If there is a failure to act, the relevant catchment management agency may take the necessary stepsand recover the costs from every responsible person. All environmental incident that has a potential to pollute or cause harm to theenvironment shall be reported to Water Affairs immediately by the licensee.



It is referenced to the above three quotes, the licensee (Bokpoort CSP / O&M) will ensure the prevention ofpollution of surface and groundwater by ensuring that all environmental spillages are prevented if occurredcleaned immediately. Spillage on site, halfway house and in the abstraction river point will be prevented ormitigated. This will ensure that spillage on the ground is not eroded nor penetrated to the river and groundwateror any water resource. All environmental incident will be reported immediately according the below structure.Failing to report to Project company by O&M will results in monetary penalties or license revoked. Projectcompany must inform the DWA / DEA within speculated time frame to avoid any penalties to be imposed. Everyincident must be reported to Project company & DEA / DWA regardless of the incident classification matrix, theywill determine if there is a need for further investigation.

O & M Incident Classification

Incident Classification Matrix (ICM)Incident Type Class A “Major” Class B “Significant” Class C “Moderate” Class D “Minor”

Environmental • Required to regulatory /governmental agency withamount ≥ 50000 US$.; or

• Oil spill ≥ 50 m3 (Coastal);≥ 10 m3 (Inland); or

• Chemical spill ≥ 400 L.

• Required to report toregulatory / governmentalagency with amount <50,000 but ≥ 25,000 US$;or

• Oil spill < 50 but ≥ 25 m3(Coastal); < 10 but ≥ 5m3(Inland); or

• Chemical spill < 400 but ≥200 L.

• Spillage fromcontainment areawith amount <25,000 but ≥ 5000US$; or

• Oil spill < 25 but ≥ 5m3 (Coastal); < 5 but≥ 1m3 (Inland); or

• Chemical spill <200 L but ≥ 50

• Spillage fromcontainment area withamount < 5000 US$; or

• Oil spill < 5 m3(Coastal); < 1 m3(Inland); or

• Chemical spill < 50 L



9 Emergency PlanIn case of ground water pollution due to O & M activities, all affected and impacted parties in thesurrounding area will be provided with water for consumption from local municipality. An agreementwith local municipality will be in place to ensure enough water is available. The provision ofconsumption to the affected and impacted parties will continue until the ground water is deemedclean and safe for consumption. Water analysis will be conducted to ensure that there is nocontamination in the ground water and surface water. Water will be delivered to all I&A parties at theirconvenient times of the day. All communication will be liaised with the community leaders throughthe engagement meetings, emails and telephonic. The community will be informed immediately bythe Project company and O & M in case there is contamination on the ground water. Affectedcommunity members due to contamination of ground water as a result of Bokpoort activities will begiven the necessary health care.

10 O & M Maintenance

O&M maintenance will ensure the following to prevent any possibilities of spillage on site:

· Abstraction point: Inspect for tightness of all clamps on discharge line to make sure that there is noleaks. We will ensure diesel generator have no leaks that might cause any spillage and impact groundwater. Diesel generator will be inspected on daily basis by Operation department and regular checkswill be done by maintained department. Any spillage will be attended immediately to prevent anyimpact on ground water. Ensure drip trays are used to contain any leaks and spillage on the dieselgenerator.

· Halfway house: Inspection of leaks on sand filters, check glands on discharge pumps, check and verifythe integrity of the backwash system to make sure that there is no continuous water flowing to thefarmers dam. Check the balance of the incoming water from the abstraction against the discharge (Inletto the regulation ponds) to avoid overflow. We will ensure diesel generator have no leaks that mightcause any spillage and impact ground water. Diesel generator will be inspected on daily basis byOperation department and regular checks will be done by maintained department. Any spillage will beattended immediately to prevent any impact on ground water.

· At the camp: Water levels at raw water tank coming from the regulation ponds, the pump is startedmanually so it must be monitored and switched off once the tank is full. Inspection of water leaks shouldbe done. Fat trap at the kitchen will be cleaned regularly to ensure its efficient.

· On site: All emergency showers will be inspected, or all leaks will be fixed. Drain and steam trap valvesthat are leaking will be repaired. We will ensure diesel generator have no leaks that might cause anyspillage and impact ground water. Diesel generator will be inspected on daily basis by Operationdepartment and regular checks will be done by maintained department. Any spillage will be attendedimmediately to prevent any impact on ground water. HTF & Salt leaks and spillages will be attendedimmediately.

· At the Ponds: Inspection of inlet and discharge pipes for water leaks. Will ensure that no seepage ordamages on the sump lining that might be high environmental risk.

· Sewage / Pit: The sewage system needs be serviced to avoid the pit to be overflowing now and again.Scarab should be consulted. Will ensure that no seepage or damages on the sump lining that might behigh environmental risk.



11 Auditing

Daily, weekly and monthly visual inspection must be conducted by the plant chemist and environmental officer.Results of the inspections must be recorded and reported to O&M and Project company, then to theDepartment of Environmental affairs / Department of Water and Sanitation will be formally informed if there isa need.

12 Records

Record Number Record TitleRecord RetentionResponsibility

RetentionPeriod

NK/HSE/SP-004/FM-002Monthly Water AnalysisReport

Plant Chemist 5 years

NK/HSE/SP-004/RP-001Environmental ComplianceInspection Report

Plant Chemist / EO 5 years

13 Legal Requirements and References:- WUL No. 14/D73D/ABCIH/2128- National Environmental Management Act EIA Regulations- !Kheis Local Municipality by-laws- National Environmental Management Act no. 107 of 1998- National Environmental Management Air Quality Act no. 39 of 2004- National Water Act no. 36 of 1998- South African water quality guidelines- National Environmental Management Waste Act no. 59 of 2008- Environmental Social Impact Assessment- ACWA Power O&M Standards & Guidelines – section 6.3.1 Environmental Practices and Procedures- Bokpoort OEMP

TABLE-IEVAPORATION PONDS WASTE WATER DWS LIMITS

Sl.No. Parameter Unit DWSStandards

Physical Chemistry1 Temperature D °C Limit2 pH pH

units6.0 -9.0

3 Turbidity NTU 704 Conductivity uS 50005 Total Dissolved Solids (TDS) mg/l 3000

Indicators6 BOD mg/l 30-407 Magnessium (Mg) mg/l 1008 Calcium mg/l 2509 Chlorides mg/l 350



10 Sodium (Na) mg/l 30011 Sulphates(SO4) mg/l 1100

12 Calcium(Ca) mg/l 250

13 Bicarbonate (HC32-) mg/L 85014 Chlorides(Cl) mg/L 350

MONITORING BOREHOLES DWS LIMITS

Sl.No. Parameter Unit DWSStandards

Physical Chemistry1 Temperature D °C Limit2 pH pH

units≥ 5 - ≤ 9.5

3 Conductivity mS/m ≤ 147 Indicators4 Magnessium (Mg) mg/l ≤ 455 Sodium (Na) mg/l6 Sulphates(SO4) mg/l ≤ 104

7 Calcium(Ca) mg/l ≤ 61

8 Chlorides(Cl) mg/L ≤ 106

9 Fluoride(F) mg/L ≤ 0.6510 Sodium (Na) mg/L ≤ 11811 Nitrates (NO3) mg/L ≤ 11

· It is important to understand that Bokpoort CSP comply with mitigation measures of its respectiveEnvironmental Impact Assessments, which have been established upon the plant design in the EIR – bestpractice would suggest adopting the most stringent limit contained in the South African water qualityguidelines (DWS) for compliance.

Bokpoort CSP Groundwater Management Plan - WSP

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