audit period: july december 2019 - goveia.met.gov.na/screening/187_208_mine audit_january 2019...

Environmental Audit of Environmental Management Plan of RPZC

ENVIRONMENTAL PERFORMANCE AUDIT FOR

ROSH PINAH ZINC CORPORATION ON MINING LICENCE ML 39

Audit Period: July – December 2019

Compiled for:

Rosh Pinah Zinc Corporation (Pty) Ltd

Private Bag 2001

Rosh Pinah

Namibia

Compiled by:

A. Speiser Environmental Consultants cc

PO Box 40386

Windhoek

Namibia

Environmental Audit of Environmental Management Plan of RPZC January 2019 1

TABLE OF CONTENT

1 Introduction..................................................................................................................... 2

2 Findings of the Recertification Audit – May 2018 ......................................................... 2

3 Objectives and Scope .................................................................................................... 4

4 Methodology ................................................................................................................... 5

5 ISO 14001 ........................................................................................................................ 5

5 Applicable Namibian Legislation ................................................................................... 5

6 Observations and Findings, Assessment Performance and recommendations ........ 5

6.1 Sewage disposal (Rosh Pinah Mine) ......................................................................... 6

6.2 Waste Disposal at Rosh Pinah Mine and Bioremediation Site ................................... 6

6.3 Tutungeni, water usage in Rosh Pinah & Sewage facility .......................................... 7

6.4 General mining operation .......................................................................................... 9

6.5 Ore processing operation ........................................................................................ 11

6.6 Chemicals used during ore process – storage and handling ................................... 12

6.7 Laboratory & Chemical Storage .............................................................................. 13

6.8 Supply Chain ................................................................................................................ 13

6.9 Workshop – current procedures, disposal of hazardous waste ................................ 13

6.10 Road maintenance within ML 39 ............................................................................. 14

6.11 Geological surface exploration ................................................................................ 14

6.12 Bulk fuel storage & dispensing on ML 39 ................................................................ 15

6.13 Tailings dam operation ............................................................................................ 16

6.14 Storage and loading facility at Lüderitz harbour ...................................................... 16

7 Summary of findings and Recommendations ............................................................ 17


JANUARY 2019

ENVIRONMENTAL PERFORMANCE AUDIT FOR

ROSH PINAH ZINC CORPORATION ON MINING LICENCE ML 39

1 INTRODUCTION

On 23 to 25 January 2019 the 26th environmental performance audit was conducted at Rosh Pinah Zinc Cooperation (RPZC) assessing the current implementation of the aspects identified in the Environmental Audit & Environmental Management Plans (EA & EMPs) for the Mine (A. Speiser Environmental Consultants (ASEC), 2003; revised November 2008). The previous audits were conducted annually (or bi-annually on request of RPZC) starting February 2004. All environmental performance audits were carried out using the findings and recommendations provided in the EA and EMPs for RPZC and partly internationally accepted ISO 14001 standards, as RPZC obtained ISO 14001 accreditation in November 2005. During the years additional scopes were included in the audit. Recertification audits are carried out by DQS every two years. The next DQS audit is due in May 2020.

As stipulated in the Environmental Management Act No. 7 of 2007 RPZC has an Environmental Clearance Certificate. The Environmental Clearance Certificate has been granted by the Department of Environmental Affairs and is valid until 26 September 2019.

End July 2017 RPZC mine was bought by Trevali a Canadian company.

2 FINDINGS OF THE RECERTIFICATION AUDIT – MAY 2018

Seven environmental findings were reported, see table below. The numbering refers to the DQS report.

No. Description Immediate action (to minimize impact)

Status July 2018

Status January 2019

1 Polluted water or tailings which poured into external environment from the tailings dam, pollution dam or pipeline is considered by RPZC as an environmental emergency condition. A breakage in a pipeline at the west section of the tailings facility was not addressed.

Repair leakages and clean-up tailings which poured into external environment immediately.

Rectifying action have been taken.



Status July 2018

Status January 2019

2 Replacement valves and piping that were replaced are left on the tailings facility and do not from part of RPZC waste management process.

Dispose of redundant valves and piping as per waste management procedure.

Rectifying action has been taken.

3 The lining on the return water dam at the northern side of the tailings facility is torn and causing pollution to the soil.

Repair lining on the return water dam at the northern side of the tailings facility as soon as possible.

Rectifying actions have been taken shortly after the audit, but no holes and opening of glued sheets have occurred. This needs to be rectified.

Still needs to be addressed.

5 The management of chemicals is posing a danger to health and safety of the workers and to the environment. The following issues have been observed:

1. Hazardous chemicals are stored on bare ground

2. Available bunding and secondary containment is insufficient

3. Batteries are stored without any secondary containment

4. Various chemicals, known and unknown, have been dumped in the scrap yard

5. Two gas cylinders (small medial oxygen) were observed in the main store.

6. A number of chemicals spills (including hydrocarbon and innocuous chemicals) have been observed

7. Phials, marked dangerous and harmful to the environment, but the name has been left illegible, have been dumped at the scrap yard

8. Incompatible chemicals (granulated chlorine) are stored in the paint store

Situation regarding the storing and disposing of hazardous chemicals, as mentioned above will be attend to immediately.

A contractor has been appointed and the chemicals will be taken to the hazardous waste site at Kupferberg in Windhoek.

According to the Mrs. J. Yisa the chemicals have been disposed at the hazardous waste site at Kupferberg in Windhoek.

8 An old Bell low profile truck number 7 was observed to be parked on bare soil with a drip tray that was overflowing with oil resulting in contamination of approximately 2m x 2m of soil at the Transport workshop parking bay of old machinery.

At different parking bays of Load and Haul workshop, different kinds of trackless mobile machinery was observed parking on bare soil contaminating the soil. A lowbed truck number AD 15 had a hydraulic pipe removed resulting in oil leaking and contaminating an area of approximately 5m x 5m.

Prevent spillages from sources mentioned above and clean-up hydrocarbon spillages and dispose of as per the waste management programme.

Situation rectified, but other trucks are standing on bare soil and contaminating the soil.

Observation during the January 2019 audit shows that the situation gets worth.



Status July 2018

Status January 2019

9 A dam on the southern side of the tailings facility, within the mine’s mining area is used for the storage of water by a pipeline, origin unknown. No management of change / impact assessment or any documentation or records were available regarding use of the dam.

Find source and seize unauthroised flow/use immediately.

Comments from ASEC:

The dam was created during the construction of the tar road to Oranjemund. After the roadworks were finalized RoshSkor is utilizing the dam to discharging treated waste water from the Rosh Pinah sewage plant.

No permit

available from Roshskor.

Dam within ML, follow up re legal implications.

rectified

11 The bio-remediation site is not being used as intended and is now the source of pollution, rather than to prevent it. While the infrastructure is available to remediate hydrocarbon polluted soil, the polluted soil is now stored on bare ground and the rest of the area is being used as a compost manufacturing area.

If the remediation cells are not used with immediate effect, the contaminated soil must be taken to a hazardous waste area.

Contaminated soil will removed and stored on isolating material and disposed of as hazardous waste.

No rectifying action taken.

Quotes have been obtained to remove the soil to an authorized site.

No action taken during the audit period.

3 OBJECTIVES AND SCOPE

Prior to the site visit the objective and scope was discussed with Ms J. Yisa (Head of Safety). The objective of the environmental performance audit is to establish in how far mitigation measures stated in the EA & EMPs for the Mine (ASEC, 2008) and from previous environmental audits are implemented and to compile a priority list for future environmental activities. In addition the legal compliance with Namibian law was checked regarding compliance of ‘environmental’ aspects.

In 11 November 2014 the new ‘water discharge and effluent permit’ (No. 658) from the Department of Water Affairs was received. The new permit is valid until 30 November 2019 and needs to be renewed well in advance before the expiry date.

The findings of the environmental performance audit report will help to draw up an action list to ensure that at the next ISO 14001 audit most environmental aspects are addressed.

The scope entails the following work area of the Mine and Mining Licences:

1. Sewage disposal;

2. Waste disposal at Rosh Pinah Mine & Bioremediation site;

3. Environmental behavior of Tutengeni;

4. General mining operation;

5. Ore processing operation;


6. Chemicals used during ore process;

7. Laboratory;

8. Workshop;

9. Road maintenance within ML 39;

10. Geological exploration;

11. Bulk fuel storage & dispensing;

12. Tailings dam operation;

13. Storage & loading at Lüderitz harbour.

The current audit was conducted with Ms J. Yisa (Head of Safety) and Mr. B. Feris (SHE officer).

4 METHODOLOGY

The following steps were followed to conduct the environmental performance audit:

(1) Initially environmental aspects/activities and performance were identified using the priority list of identified impacts from the mine operation and related works (see Chapter 8.3.2, EA & EMPs, ASEC, 2003 & 2008) and measure also against legal compliance (Namibian law). However, environmental aspects were added and amended during the past environmental audits.

(2) Site inspection of scope areas as indicated;

(3) Compilation of the bi-annual environmental performance audit report.

(4) Feedback to RPZC mine to rectify shortcomings.

5 ISO 14001

In November 2005 RPZC was accredited ISO 14001 status. Storage and loading at NamPort in Lüderitz harbour started in November 2013 and the operation has been included in the August 2014, January 2015, January 2017, January 2018 and January 2019 audits. The Environmental Clearance Certificate (ECC) for the storage and loading facility at Lüderitz is valid until August 2020.

5 APPLICABLE NAMIBIAN LEGISLATION

See legal register

6 OBSERVATIONS AND FINDINGS, ASSESSMENT PERFORMANCE AND RECOMMENDATIONS

In the following the observations and findings of the environmental performance audit are summarized according to the respective scope areas. Further the assessment performance and recommendations are given in each section / table of the scope areas.

Standards used in the environmental performance audit were professional knowledge and experience, meetings with Ms J. Yisa and Mr. B. Feris (SHE officer) and some of the departmental heads. The audit starts stating the findings of each scope area using the priority list of identified impacts (only medium and high significant impacts are included) in the EA & EMPs (ASEC, 2008) and continues to list additional aspects identified during the environmental performance audits since February 2004.

In the following only the findings of the current environmental performance audit are listed. Findings of the previous audits are accessible at the Head of Safety office at Rosh Pinah Zinc Mine (see Bi-annual Environmental Performance Audit for Rosh Pinah Zinc Corporation on Mining Licence ML 39, February and August 2005, January and July 2006, March and September 2007, October 2009, January and August 2010, January, May and November 2011, April and August 2012, January and July 2013, January and August 2014, January and July


2015 and February and July 2016, January and July 2017, January and July 2018 and January 2019).

The following symbols indicate the respective priority ranking regarding significance of impact and importance to address the aspect:

√ = satisfying finding, no action to be taken or action implemented to be followed up

+++ = mitigation measures and/or standards not met, high priority, action to be taken as soon as possible

++ = mitigation measures and/or standards not met, medium priority (risk of impact occurring), action taken within the next 6 months

6.1 Sewage disposal (Rosh Pinah Mine)

No. 1 Management of oxidation ponds

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Additional rehabilitation measures to be taken.

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No action was taken since the January 2013 audit. Further clean up and rehabilitation are recommended:

Smoothening of the heavy equipment tracks.

Removal of the invasive alien vegetation. Collect and burned.

Clean up of rubbish of the site.

SHE department informed ASEC that mine management indicated that all rehabilitation measures will only be conducted with mine closure.

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+++

6.2 Waste Disposal at Rosh Pinah Mine and Bioremediation Site

Disposal of waste (Rosh Pinah Mine) - Responsible person: SHE Department

No. 1 Waste disposal system

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No rehabilitation plan has been developed for the old waste site.

Waste management within the mine has been taken over by the SHE Department. Domestic waste (paper, plastic and domestic waste) are disposed in one skip and separated at the Roshkor waste site. Hydrocarbon contaminated waste, e.g. oil lappies are disposed of at the Rosh Pinah waste site. Some skips show both types of waste, non-hazardous and hydrocarbon contaminated waste.

Also a decision was taken to treat the oil lappies at the bioremediation site, no action has been taken.

Garden refuse is dumped at the bioremediation site where it is used in the bioremediation process of hydrocarbon contaminated soil. Since end 2017 the management of the bioremediation plant lies again with the SHE Department. All treatment pads have been cleaned and fixed. One pad is filled.

The overall housekeeping within the ML area is poor.

Building rubble and plastic is dumped at the site.

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ASEC recommends that a rehabilitation plan of the old waste site needs to be established. Mine management indicated that final rehabilitation will only be conducted at mine closure.

Improve management of the bioremediation site.


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++

No. 2 Management of hydrocarbon waste

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Fuel drums and grease tins are collected at the designated storage area (adjacent to the diesel filling station). Since the last audit the site has been cleaned and all drums are inside the designated area. The padlock at the entrance gate is broken.

The oil drum drain rack is in working condition.

Drains maintained at Load & Haul and the Drilling & Blasting workshop need to be cleaned.

Contaminated soil from the wash bay, workshop drains and mine is stored downstream of the wash bay area. A concrete lip has been erected to contain the soil. Ensure that the site is only used for contaminated soil. The site is currently overflowing and the contaminated soil needs to be taken to the bio-remediation site.

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++

No. 3 Bioremediation Facility (SHE Department)

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Access to the site is managed (gate).

Contaminated soil is not stored on PVC sheets and no containment of the soil is provided. Potential run-off containment from contaminated water is not provided. (Same finding as during the last 10 audits)

Money for final rehabilitation will be put into the Mine Closure Plan.

The project to wash oil filters and other contaminated materials at the bioremediation site to be finally disposed at the scrap yard has been approved in January 2014 and has still not been implemented. The machine has arrived, but cleaning has still not started.

Some household waste and building rubble has been dumped at the bioremediation plant.

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during rain events.

The storage area for the contaminated site needs to be lined (PVC or concrete).

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++

6.3 Tutungeni, water usage in Rosh Pinah & Sewage facility

Environmental behaviour at Tutungeni

No. 1 Rehabilitation of informal settlement ‘Sand Hotel’

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gs All previous infrastructures at the former Sand Hotel site have been bulldozed. However final rehabilitation actions of the previous informal settlement site have still to be established and implemented.


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Final rehabilitation criteria and measures for the site need to be established and implemented.

No action since the last audits. SHE department mentioned that mine management decided that the site is only rehabilitated at mine closure.

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No. 2 Establishment of infrastructure within the ML

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1. RPZC’s Mining Licence has been clearly demarcated on the ground.

2. Inhabitants from Tutengeni enter the ML area frequently for firewood collection, waste dumping, etc.

3. Littering, dumping and defecating in the ML area adjacent to Tutengeni continues. At the July 2017 meeting with RoshSkor is was agreed that a skip will be placed at the eastern border of Tutengeni to discourage people of littering. This did still not happen.

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1. A sign has been erected between the border of Tutengeni and the ML area.

2. Clean up of area driven by RoshSkor.

3. No skip has been placed at the eastern border of Tutengeni to discourage people of littering.

All actions were agreed on during the meeting with RoshSkor and RPZC mine on 24 July 2017.

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++

No. 3 Usage of run-off water from Danie se Dam

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Danie se Dam has been cleaned and relined. The dam is fully operational.

A level switch has been installed to prevent overflow of the dam. A sediment trap is installed.

Water to the Golf Course is only pumped 2 days per week for a few hours. No overflow at the back of the golf course occurred since the last audit.

The areas were previously and currently water was overflown at the end of the golf course needs to be cleaned up and rehabilitated.

The water from Danie se Dam water is used in the mine.

Water is released into the environment to the east of Danise Dam. It looks like that the water overflows from the water trucks when refilling with water. SHE Department needs to investigate and action taken to prevent overflow in future.

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Clean up and rehabilitation of the area were water has and is overflowing at the end of the golf course.

SHE Department needs to investigate and action taken to prevent overflow while refilling water trucks at Danie se Dam in future.

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+++

No. 4 Water discharge from the RoshSkor Sewage plant

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At present the released water allows alien vegetation to grow in the area, e.g. wild tobacco (from Mexico, which is one of the nine main alien invasive plants in Namibia). In the July 2018 audit RoshSkor promised to remove alien vegetation. No action was taken.

The water is currently contained in the dam, which was established during the construction of the tar road to Oranjemund.


The fence has been fenced in to prevent unauthorized access.

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RoshSkor to remove alien vegetation.

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++

6.4 General mining operation

General mining operation - Responsible person: Acting Head of Safety, Senior Production Geologist

No. 1 OH&AP Consulting survey

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The RPZC has appointed an Occupational Health & Hygiene Officer (Mr. R. Mujende), who will also be responsible for all environmental monitoring at the mine and surroundings. This will include noise and PM 10 sampling and monitoring. The samples are send to RSA for analysis. OH & AP Consulting are compiling the report and mentoring Mr. R. Mujende.

For the auditing period all measurements were within their limits, except some dust samples at the plant.

Multiple directional dust monitoring buckets have been installed in November 2018 around the tailings dam. The results will be available at the next audit.

At the Lüderitz shed dust buckets are erected and samples are taken monthly and send to RSA for analysis for total dust fallout and lead percentage. Lead percentage lies at all results below the international and RSA legislation. The results can be obtained from the mine.

From 2019 PM 2.5 dust monitoring will be included. Currently the mine is waiting for the filters.

Dust suppression at all crushers have been installed. In July 2018 it was planned to install netting around the ore stockpile and other areas within the plant area. Dust suppression at all crushers have been installed. As these were not sufficient, netting around the ore stockpile and other areas within the plant area will be installed within the next months. No action has been taken.

In July 2018 it was planned that the road from the ore concentrate to the gate will be graveled every six months to minimize dust. No action has been taken.

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Follow up on proposed actions.

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++

No. 2 Water monitoring


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Two water monitoring activities are currently management by the Residential Engineering department:

(1) The installation of water flow meters within the mine area has been completed, and the Engineering Department is monitoring the flow meters on a monthly basis. Results are monthly compiled and can be obtained from the Engineering Department.

(2) Water samples from boreholes located around the tailings dam and within the mine area are taken and analyzed on a quarterly basis. The water samples are analysed at the NamWater lab in WHK. All monitoring borehole samples from the third quarter 2018 are within the limits, except for two lead analysis (tailings return 0.18 mg/l : allowed 0.1 mg/l and the WOF outflow 0.12 mg/l : allowed 0.1 mg/l) and the cadmium analysis at the WBH05 (0.17 mg/l : allowed 0.05 mg/l), which is located downstream from the tailings dam. Results from the fourth quarter are outstanding.

(3) Quarterly water samples are taken from Danie se Dam

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Investigate why the lead is elevated at the sampling point tailings return and the WOF outflow; and cadmium at WBH05.

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√

No. 3 Run-off water management

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Run-off water from the mine is used for dust suppression underground and collected in Danie se dam.

Where possible water is recycled and reused at the mine.

The water from Danie se Dam is used for dust suppression within the Mine.

Water run off from the filling area at Danie se Dam.

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Investigate run of at the filling area at Danie se Dam.

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+++

No. 4 Heavy vehicle parking area & vehicles taken out of production

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gs Heavy vehicle from the Load & Haul workshop are parked in the area. According to Engineering

(Mr. Andre Bergh) the area was supposed to be lined, but this has not been implemented.

The number of vehicles park in the area has increased and numerous spillage can be observed.

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s Investigate depth of contaminated soil. Ensure that the area is lined.

Money for final rehabilitation will be put into the Mine Closure Plan.

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+++


6.5 Ore processing operation

Ore processing operation - Responsible Person: Plant Operations

No. 1 Flora survey re impact of dust on plant growth

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gs The potential of negative impacts on plant growth from dust generated by the ore material &

concentrate downwind of the processing plant has not further been investigated.

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It is recommended that an initial plant survey should be conducted to establish a baseline survey, comparing the area with parts of the mountain not affected by dust.

The survey should be repeated annually during the growing season to establish if an impact occurs.

Proposal to conduct such a survey should be invited to start a plant-monitoring programme.

No action has been taken.

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+++

No. 2 Dust suppression at tailings dam

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The top of the tailings facility is constantly kept wet to minimize dust.

The top berm will be sprayed with dust suppression agent.

Rock cladding continued and is ongoing when a truck is available.

The northern and eastern water retention dam have been lined. As the water return to the plant decreased during December 2018, water overflow occurred at the eastern retention dam.

Invasive plants need to be removed from the tailings dam area, e.g. wild tobacco.

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s Line all water retention dams at the tailings dam.

Invasive plants will be removed within the tailings dam area. To avoid any further spreading of the seeds the removed plants need to be burnt.

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++

No. 3 Dust monitoring programme at tailings dam

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A dust monitoring programme was set up by Fraser Alexander in August 2006 and is ongoing. The initial programme has been extended to measure dust also within the mine and Rosh Pinah village. Dust samples are taken monthly. Analytical results are available at the Processing Plant Department.

A PM10 sampling programme is in place, the first measurements were taken in December 2015.

Data can be obtained from Fraser Alexander.

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s In place for fallout dust, ensure that analytical data are obtained and interpreted to take action

accordingly.

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√

No. 4 Dust suppression at ore concentrate shoot


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gs A dust monitoring programme (personal inhalable dust and nuisance dust) has been implemented

in August 2015.

Dust levels in Lüderitz are generally high due to the high wind occurrences, however, lead levels are all within the limits.

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No. 6 Storage of lead and zinc concentrate

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gs The concentrate storage area has been upgraded to accommodate more ore concentrate.

The area next to bulk diesel area has been concreted and bunding has been erected to avoid ore concentrate wash off.

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6.6 Chemicals used during ore process – storage and handling

Not audit during this site audit.

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The plant Department installed dust suppression at all crushers.

In July 2018 further actions to minimize dust at the ore shoot had been investigated, but no action has been taken.

Dust netting around the ore stockpile has been approved and it was anticipated to be implemented before end of 2018. No action has been taken.

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No. 5 Dust monitoring at Lüderitz harbour storage and loading facility


6.7 Laboratory & Chemical Storage

Chemical Storeroom – Responsible person: Materials Management

No. 1 Layout of storeroom

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The chemical store is well managed.

MSDS sheets are available in the storeroom. The wall display of MSDSs has been updated.

Inspection records of emergency shower, eye wash area and other emergency equipment are available.

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6.8 Supply Chain

Storage area– Responsible person: Materials Management

No. 1 Storage area

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Bunded areas for batteries and transformers need to be repaired.

Different chemicals and dust suppression chemicals are stored in the sun in a non-bunded area.

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6.9 Workshop – current procedures, disposal of hazardous waste

Workshop – Responsible Person: Resident Engineer

No. 1 Washing bay – oil-water separator

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The oil-water separator is in working condition.

A rope separator at the wash bay oil-water-separator has been installed.

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No. 2 Sludge from washing bay

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At present sludge is dried at the wash bay and transported to the bioremediation plant for treatment.

The area is very full and needs urgently be cleaned.

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s The contaminated sludge should be taken to the bio-remediation site.

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No. 3 Oil drum drainage area

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Drain rack for used 210l oil drums is in working condition.

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No. 4 Oil drum storage site

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The area has been cleaned.

All drums are placed within the designated fenced area.

Padlock at the gate is broken.

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6.10 Road maintenance within ML 39

No negative observations are to be reported.

6.11 Geological surface exploration

Findings of the environmental performance regarding the geological surface exploration can be obtained in the bi-annual reports, until January 2016 the reports were compiled by ASEC for submission to the Department of Environmental Affairs (DEA/MET) as stipulated in the Environmental Clearance Certificate. The last audit of surface exploration by ASEC was


conducted on 29 January 2016 and the bi-annual report covered the period July – December 2015.

The Environmental Clearance Certificate (ECC) from Ministry of Environment and Tourism (MET) : Department of Environmental Affairs (DEA) is valid until April 2019.

Since 2016 all bi-annual reports are compiled by the Geology Department of Rosh Pinah Mine.

6.12 Bulk fuel storage & dispensing on ML 39

Operation and maintenance of the bulk fuel storage area lies with Engen Namibia. However, RPZC should ensure that the operation meets all legal aspects (safety, health and environmentally), as the tanks is located within the mining area.

A responsible person to check and maintain the bulk fuel storage area has been allocated.

Old oil is collected in a designated tank next to the wash bay and removal is managed by Engen Namibia. Engen Namibia also organizes the transport of old oil to a registered disposal facility in South Africa.

Fuel pump / storage area - Responsible Person: Materials Manager

No. 1 Diesel filling facility - surface

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Maintenance at the diesel filling facility has improved. However, spills during refueling still occur.

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No. 2 Diesel storage - surface

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s Cracks of the concrete are visible at the in- and outlet pipe area of the tank and at the floor of the

pumps. The cracks were repaired with fiberglass, but already comes off from the repaired areas.

Numerous cracks are observed in the diesel tank bund area.

Although it was stated in January 2018, that engineering is busy to put a project together to erect a new bund around the diesel bulk storage area and the pumps, no action has been taken.

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changed immediately.

Ensure that the project is carried out as soon as possible.

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No. 3 Diesel filling facility and maintenance bay - underground

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The diesel storage facility is clean. Less overfilling occurs which results in less spillages.

A proper nozzle hook has been installed at the diesel filling station.

Management of the oil-water separator is good.

Sludge and oil needs to be removed from the maintenance bay.

The lights in the trench to work on the trucks are very dirty and 2 are not working.


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It is recommended that a maintenance / management protocol is developed to keep a record of the pumping out and disposal of old oil at the surface old oil storage tank.

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No.4 Oil-water separator at diesel filling facility

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Management of the oil-water separator is in working condition.

Sludge is taken to the bioremediation site.

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6.13 Tailings dam operation

The management and operation of the tailings dam has been outsourced to Fraser Alexander in August 2005. The plant operation is responsible to ensure that Fraser Alexander meets their contract objectives. The scope of work entails the management of the tailings dam. RPZC mine decided to conduct own trials regarding rehabilitation of the tailings dam since mid-2013.

The trial to erect netting at the northern area of the tailings dam has been finalised and regarding re-vegetation by planting and self-seeding has occurred. The areas are no longer watered.

End 2017 all penstocks reached the same height. From now one penstock will be raised while the other one will be kept wet.

Rock cladding continuous and the top berm gets twice a year sprayed with a dust suppression reagent.

A significant saving in water has been achieved by reusing water from the tailings dam at the plant. The northern and eastern water retention dam have been lined. Due to decrease in water usage at the plant during December 2018 the eastern dam overflow into the two adjacent non lined dams and into the environment.

Tears in the lining of the southern retention dam are visible and need repair.

6.14 Storage and loading facility at Lüderitz harbour

In November 2013 storage and loading at Lüderitz Harbour commenced.

The last audit of the loading and storage facility at Lüderitz harbour was conducted on 23 January 2019.

A dust monitoring programme (personal inhalable dust and nuisance dust) has been implemented in August 2015. Samples are taken monthly and send to RSA for analyses for total dust fall out and the percentage of lead. Both are compared to the international acceptable

standards (The American Society for Testing and Materials (ASTM) D 1739-70 and SANS 1929:2004 – Ambient air quality – Limits for common pollutants / South Africa Air Quality Act). The results can be obtained from the SHE office.

The management of the operation is carried out by Access Freight.


The main finding of the January 2018 audit was the insufficient illumination of the shed. In March

2018 the Mr. Ronald Mujende (Occupational health and hygiene coordinator) conducted an occupational hygiene illumination survey on behalf of Rosh Pinah Zinc Corporation (Part of Trevali Group) to assess and assist the warehouse in complying with the Namibian legislation. The illumination of the shed was changed according to the recommendation of the report. A follow up survey was conducted end of December 2018. The findings show, that

although the previous lights were replaced with linear fluorescent lights, the illumination of the shed is still not sufficient. Rectifying actions will be taken within the next months.

The recommendation of the January 2018 audit have not been put into place. Access Freight approached NamPort to discuss heavy vehicle traffic on the quay, the final decision to implement these is lying with NAmPort.

lane demarcation

erect a stop sign at the turn off to the Skoprion shed when coming from the Rosh Pinah shed

The next audit at the Lüderitz Harbour storage facility will be conducted in January 2020.

7 SUMMARY OF FINDINGS AND RECOMMENDATIONS

It is recommended that negative findings stated in Sections 6.1 to 6.14 are used in management meetings including the operational manager of each audited scope area to discuss and agree to the way forward.

Possible mitigation measures and changes to current activities at the mine need to be discussed and agreed to, especially in the light of ensuring ISO 14001 compliance.

The following aspects were identified in previous bi-annual reports and the current audit report and needed to be addressed prior to the next audit. The findings of the January 2019 audit are stated in green (positive) and red (negative) behind each aspect. If no action has been taken over the past audits the negative findings will remain red.

Develop rehabilitation plan and an implementation schedule for the:

o Oxidation pond – Mine management decided that this will be conducted in the final rehabilitation of the mine.

o Old waste disposal site - Mine management decided that this will be conducted in the final rehabilitation of the mine.

o Sand Hotel - Mine management decided that this will be conducted in the final rehabilitation of the mine.

Bioremediation site:

o Construct a concrete floor and storm water berms around the contaminated soil storage site – No action has been taken.

o Money for final rehabilitation will be put into the Mine Closure Plan budget.

o Currently the SHE Department is busy to get money approved to construct a proper storage area for the contaminated soil. No action has been taken.

Waste disposal at the Mine

o All domestic waste (paper, plastic and domestic waste) are collected together in skips and brought to the RoshSkor waste disposal site.

o Recycling at the RoshSkor waste site is not managed very well. Investigate with RoshSkor.

o General housekeeping can improve at the mine.

Tutengeni / Southern entrance to Rosh Pinah (agreed actions have to be implemented):

o RPZC and RoshSkor will remove the existing rubble and erect a properly design storm water run-off berm – This was recommended in all bi-annuals since August 2012 and no


action has been taken. Dumping at the storm water run-off berm should be discouraged and skips put up next to the ML boundary. Although this was agreed upon in a meeting between RPZC and RoshSkor on 24 January 2017 and July 2018, no action has been taken from RoshSkor’s site.

o The waste dumped at the site has increased since the last audit.

o Signs to be erected to show people that they enter private land – One sign has been erected and at the meeting it was agreed to put a berm from waste rock boulders at the border between Tutengeni and RPZC ML area. No action taken.

o A gate has been installed at the Obib Training Center to discourage people entering the mine area from the bioremediation site.

Waste dumping South of Rosh Pinah

o Illegal dumping of waste and garden refuse south of Rosh Pinah continues. Roshkor to investigate and to take action. Same findings for the last audits.

Tailings Dam Facility

o The northern and eastern water retention dams have been lined.

o At the eastern water retention dam some of the lining has opened, where sheets had been glued together. Repair lining of the eastern retention dam.

Danie se Dam, water channel to Golf course and southern run-off from the Golf course:

o Danie se Dam has been newly lined and is operational.

o Overflow from the golf course has stopped. The area needs to be rehabilitated.

o Water has flown into the environment while filling the water trucks at Danie se Dam. This is not a once off. Investigate and rectify the situation.

Load and Haul heavy vehicle parking area: o The area needs to be cleaned and lined with a polyliner or concreted to avoid any soil

contamination. No action has been taken. o Lots of vehicle are parked in the area and numerous spills could be observed. o Money will be allocated for the final rehabilitation in the Mine Closure

Dust suppression at ore stockpile:

o ‘Dry mist sprinklers’ are in working condition. o In July 2018 it was mentioned that wind breakers will be installed around the ore stock

piles within the next months. No action has been taken.

Flora Survey:

o Ensure funding to conduct an initial plant survey to develop a baseline survey, comparing plant growth in areas not affected by ore dust and affected by ore dust - No action has been taken

Storage of lead concentrate next to bulk diesel storage area:

o Area is relatively well managed.

Diesel filling facility and maintenance bay – underground

o Management of the oil-water separator is good.

o The bulk diesel storage area is clean.

o At the maintenance bay the contaminated sludge and oil needs to be cleaned out of the working trench.

Cracks in bunding walls and floor of bulk diesel storage - surface:

o Cracks of the concrete floor and bunding at the diesel storage tank (surface) are visible at the in- and outlet pipe area at the tank and the tank bunding. The cracks have been sealed with fiberglass, but already coming off again. Investigate new method to seal the cracks or build new bunding. In July 2018. Engineering was busy to draw up plans to build a new bunding wall around the bulk diesel storage area. No action has been taken since the last audit.


Old oil drum storage area:

o The oil drum storage area has been cleaned and all oil drums are stored within the area.

o Drums are very full and it is not easy to move them without potential spillage.

o Investigate bird fatalities on one of the oil drums. No bird fatalities have been observed during the audit period.

o The padlock at the gate is broken.

Load & Haul workshop

o All drainage are blocked with sludge.

A. Speiser MSc MPhil

audit period: july december 2019 - goveia.met.gov.na/screening/187_208_mine audit_january 2019...

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