Civil Engineering June 2021 | Vol 29 No 5

Civil Engineering June 2021 17 water uses in terms of the National Water Act, and the second specifying the re- quirements for waste licence applications in terms of the 2013 Waste Regulations under the National Environmental Management Waste Act. The new requirements include a proof of concept in the WULA, which may involve site-specific investigations, field and laboratory testing, other relevant as- sessments, and the required engineering of all structures. This too aligns with the new global approach towards the construction of earthworks and engineering structures – where the technical aspects are considered alongside the ESG requirements. What is required here is for the ap- plicant to prove the holistic feasibility of the concept or design, to assure the DWS that the stability of the structure over the intended life of the facility is adequately engineered. As mentioned above, the approach taken by the DWS is in line with that of global organisations like ICOLD, which has updated water dam and tailings dam standards. These standards recognise the need not only to protect our water resources, but also to prevent the failure of structures – to save lives and to reduce the related impacts on the affected environ- ment, stakeholders, and communities. In terms of this approach, the structural risk must be assessed, and the identi- fied risks must be mitigated by suitable engineering works – which are to be incorporated into the designs and the CQA plan submitted with the WULA. The design level that is acceptable under the new ar- rangements is described in the DWS’s TAN, based on the Board Notice 138 of 2015 from the Engineering Council of South Africa. This provides the various stages of a project in Regulation 3(2) of the notice. DESIGN STAGES Although Stage 2 is a level of design that is generally inadequate for regulations requiring a quantified performance, it may be adequate in some projects. At this level, the concept design criteria would be established, and a preliminary concept de- sign would be prepared. In terms of how we work at SRK, the client would be ad- vised regarding further surveys, analyses, tests, and investigations – including the establishment of regulatory requirements – which need to be incorporated into the design. The concept would be refined to ensure conformance, and the deliverables would include a preliminary design. At the next level, a Stage 3 design is the basis of quantified performance assessment and is subject to review by authorities. In this stage, the concept would be developed to finalise the design and outline specifications, which would incorporate a cost plan and define the financial viability of the project, as well as a programme for implementing the project. The regulatory requirements are to have been built into the Stage 3 design, which is to be reflected in design draw- ings including draft technical details and specifications. The fourth stage comprises documen- tation and procurement, which is essen- tially the preparation of tender documenta- tion and the procurement of construction services. This can be done once the WULA is approved, and a water use licence (WUL) is issued. Stage 5 addresses the general con- dition in an issued WUL requiring as-built drawings to be submitted on completion of construction. This is the implementation phase, which culminates in the issuing of certificates of completion and submission of reports to authorities. QUALITY ASSURANCE The other important element that the DWS now requires in a WULA submis- sion is the CQA plan. This document establishes the procedures that will verify that construction is in accordance with the applicant’s construction drawings and construction specifications. The CQA plan must show that the planned proce- dures will meet the appropriate regulatory requirements and will lead to the develop- ment of the documentation that needs to be provided to the regulatory authority. This plan provides evidence of independent third-party verification and testing. It must demonstrate that the contractors and installers have met their obligations in the supply and installation of components and materials according to all the requirements of the construction drawings, the construction specifications, and the regulatory requirements. CONCLUSION The principles underlying the procedural changes by the DWS are water conserva- tion and environmental protection. As such, the changes represent an important contribution towards the constant evolu- tion of practices toward ensuring that the proposed design of engineering projects will facilitate efficient use of water and minimise pollution. While the new DWS requirements for the submission of WULAs will undoubt- edly demand a greater investment of time and resources at an earlier stage of a project, the overall result will be a positive one. Developers will be more prepared for their project implementation, and the interests of safety, water conservation and environmental protection are more likely to be served.  Applicants must prove holistic feasibility of a concept or design, to assure the DWS that the stability of the structure over the intended life of the facility is adequately engineered