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More upfront work now needed before water use licence applications may be lodged

14th May 2021

By: Natasha Odendaal

Creamer Media Senior Deputy Editor

     

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More early-stage upfront work to generate detailed engineering specifications will be needed before project developers can submit their water-use licence applications (WULAs) to the Department of Water and Sanitation (DWS).

All water-use applications involving engineering design work will now need to include a proof of concept, a design report with drawings to the required level and a construction quality assurance (CQA) plan.

However, the extra work will improve the efficiency of the process and reduce the time taken to obtain the WULA approval, assures SRK Consulting principal scientist Jacky Burke.

The new requirements followed the release by the DWS of a series of technical advisory notes (TANs) and design checklists to which applicants must adhere, as the department follows the global trend towards the sound engineering of all existing and proposed structures, including supporting facilities such as silt traps and water diversions.

“The higher level of detail is to assist DWS case officers in their initial assessment of submitted WULAs. “More importantly, the TANs and checklists also assist applicants in meeting engineering requirements upfront rather than after their WULA submission,” she continues.

The requirements, which are in line with regulations published in 2017 in Government Notice R267, reflect the shift in global best practice to integrate engineering aspects with environmental, social and governance issues and financial sustainability in all projects.

Constant Evolution

The underlying principles for this are water conservation and environmental protection, which are part of a constant evolution of practices towards ensuring that the proposed design will facilitate the efficient use of water and minimise pollution.

“In addition to the need for the protection of our water resources, there is a need to protect against the failure of structures – to save lives and to reduce the related impacts on the affected environment, stakeholders and communities,” adds SRK Consulting partner and principal geotechnical engineer Adriaan Meintjes, commenting on the significance of the new requirements for the design of tailings storage facilities on mines.

Elaborating further, Burke explains that the proof-of-concept tasks may involve site-specific investigations, field and laboratory testing and the required engineering of all structures.

“The feasibility of the concept or design must be proven to give assurance to the DWS that the stability of the structure over its intended life is adequately engineered to minimise any potential risks of failure.”

Any review by another stakeholder should then come to the same conclusions.

“In terms of WULA submissions, this means that structural risk must be assessed and mitigated by suitable engineering works and incorporated into the designs and CQA plan submitted with the WULA,” Burke says.

The design level acceptable to the DWS is outlined in the TANs and is based on the Engineering Council of South Africa Board Notice 138 of 2015, which defines various stages of a project.

The notice states that the Stage 2 level of design is generally inadequate for regulations requiring a quantified performance, but may be adequate in some projects, while Stage 3 is the basis of quantified performance assessment and subject to review by authorities.

“Here, the concept must be developed to finalise the design and to outline specifications; the submission must incorporate a cost plan and define both the financial viability and a programme for the project.

“It is at this stage that the regulatory requirements must be built into the design and reflected in the design drawings, including draft technical details and specifications,” Burke points out.

The Stage 4 project elements, such as the tender documentation and procurement of construction services, can be done after the WULA has been approved and a water-use licence has been issued.

“The CQA plan, now also required in the WULA submission, establishes the procedures to verify that construction is in accordance with the construction drawings and specifications,” she says.

Edited by Martin Zhuwakinyu
Creamer Media Senior Deputy Editor

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