mining licence 219 - gov

Mining Licence 219

Environmental Impact Assessment

Cape Cross, Erongo Region

Project Name

Mining Licence 219 Cape Cross Salt Pan

Arandis Electoral Constituency Erongo Region

ENVIRONMENTAL MANAGEMENT PLAN (EMP)

Report Status Final

Project Reference Number

APP -00688

Prepared For

Cape Cross Salt (Pty) Ltd Farm 143, Cape Cross

P O Box 25021 WINDHOEK

Namibia

Prepared By

EKWAO CONSULTING

4350 Lommel Street Ongwediva

Namibia Cell: 081 418 3125

Fax2Mail: 088645026 Email: [email protected]

Date Prepared October 2019

Contributors Joel Shafashike & Takatu Shafashike

mailto:[email protected]

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Abbreviations and Acronyms

BAT Best Available Technology BID Background Information Document BSR Baseline Scoping Report CO Carbon Monoxide CO2 Carbon Dioxide EIA Environmental Impact Assessment

EMP Environmental Management Plan HES Health Environmental and Safety HPP The Harambee Prosperity Plan IAPs Interested and Affected Parties ISO International Organization for Standardization M

2 Square meters

M3 Cubic meters

MAWF Ministry of Agriculture, Water and Forestry MET Ministry of Environment and Tourism MME Ministry of Mines and Energy

MTISMED Ministry of Trade, Industry and SME Development NAAQS National Ambient Air Quality Standards

NAMPOWER Namibia Power Corporation Pty Ltd NAMWATER Namibia Water Corporation Ltd

NHC National Heritage Council NO2 Nitrogen Dioxide NSI Namibia Standards Institute PM Particulate Matter PPE Personal Protective Equipment

SABS South African Bureau of Standards SHE Safety, Health & Environment SME Small and Medium Enterprises SO2 Sulphur Dioxide TLV Threshold Limit Value

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Table of Contents

Section Description Page

1.0 Environmental Management Plan 1

1.1 Introduction 1

1.2 Purpose of the EMP 1

1.3 Acceptance of the EMP 1

1.4 Environmental Policy 2

2.0 Environmental Management Objectives 2

2.1 Roles and Responsibilities 2

3.0 Regulatory Framework 4

3.1 Environmental Legislations and Standards 4

3.2 Standards and Guidelines 5

3.2.1 Air Quality 5

3.2.2 Health Screening Criteria 5

3.2.3 Water Quality Guidelines 6

3.2.4 Proposed Inspections 7

4.0 Aspects Related to Environmental Compliance 8

4.1 Environmental Monitoring, Auditing and Review 8

4.2 Environmental Induction and Awareness Training 8

5.0 Proposed Environmental Management Plan 8

5.1 The Physical Environment 9

5.2 The Natural Environment 24

5.3 The Human Environment 26

6.0 Compliance with the Environment 30

6.1 Introduction 30

6.2 Non-compliance of the EMP 30

6.3 Penalties for Environmental Violations 30

6.4 Emergency Preparedness 31

6.5 Reporting 31

6.5.1 Good Housekeeping 32

6.5.2 Documentation Control 32

7.0 Conceptual Closure Plan 33

7.1 Objectives 33

7.2 Closure Planning 33

7.3 Socio-economic Considerations 34

7.4 Mechanisms to Manage Socio-economic Effects 34

7.5 Financial Provision for Closure 35

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7.5.1 Employee costs 35

7.5.2 Social Aspects 35

7.5.3 Physical Rehabilitation 35

7.6 Post Closure Monitoring 35

7.7 Financial Provisions for Rehabilitation 36

7.8 Conclusions on the Closure Plan 36

8.0 Conclusions 36

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Tables

Table 1 Roles and Responsibilities - MET (Regulator) 2

Table 2 Roles and Responsibilities - Promoter 3

Table 3 Legislative Framework 4

Table 4 Ambient Air Quality 5

Table 5 Reference Exposure for NOx, Dust, etc. 6

Table 6 Namibia Water Quality Guidelines 6

Table 7 List of Inspection Schedule 7

Table 8 Environmental Aspects on Topography & Land Use 9

Table 9 Environmental Aspects on Hydrology : Surface Water 10

Table 10 Environmental Aspects on Hydrology: Potable Water 11

Table 11 Environmental Aspects on hydrology: Underground Water 12

Table 12 Environmental Aspects on Brine Effluent Discharge 13

Table 13 Environmental Aspects on Ambient Air Quality 14

Table 14 Environmental Aspects on Noise Disturbance 15

Table 15 Environmental Aspects on Dust Disturbances 16

Table 16 Environmental Aspects on Waste Management 17

Table 17 Environmental Aspects on Visual Intrusions 18

Table 18 Environmental Aspects on Archaeological Interests 19

Table 19 Environmental Aspects on Traffic on National Road D2301 20

Table 20 Environmental Aspects on Public Roads : C34 and MR44 21

Table 21 Environmental Aspects on Fuel Storage & Handling 23

Table 22 Environmental Aspects on Natural Vegetation 24

Table 23 Environmental Aspects on Fauna (Wildlife) 25

Table 24 Environmental Aspects on Employment Impact 26

Table 25 Environmental Aspects on Labour & Employment Conditions 27

Table 26 Environmental Aspects on Social & Community Impacts 28

Table 27 Environmental Aspects on Safety and Health Impacts 29

Environmental Management Plan

1. ENVIRONMENTAL MANAGEMENT PLAN

1.1 Introduction

This Environmental Management Plan (EMP) is compiled for Cape Cross Salt

(Pty) Ltd hereafter (CCS) to serve as a standalone plan, to manage and

safeguard the environmental impacts associated with the revival of its salt mining

activities at the Cape Cross saltfield, about 42 km north of Henties Bay in the

Arandis Electoral Constituency of the Erongo Region.

In this EMP, recommendations and guidelines have been provided according to

which compliance monitoring can be done during all three phases of the

development: Construction, Operational and Decommissioning of the salt works.

It should be noted that the EMP is a working document; changes may be made

with regards to future extensions of the salt operation as well as giving due

consideration of Best Available Technology (BAT).

1.2 Purpose of the EMP

The purpose of this EMP is to ensure that the Environmental Impacts

associated with the salt operation conducted by CCS are managed, mitigated and

kept to a minimum. This includes ensuring that the mitigation measures as

described in the Baseline Scoping Report (BSR) are implemented and complied

with.

It is the aim of this EMP to provide clearly defined actions that should be

implemented during the lifespan of the salt operation. The EMP is a dynamic

document, flexible and responsive to new and changing circumstances i.e. it

should be updated as and when required. Any substantive changes to the EMP

will require authorization and endorsement of MET.

This EMP is binding on CCS Management, to all its future employees as well as

to any contractors or third parties who may be hired to carry out certain works on

the salt mine from time to time.

Copies of this EMP must be kept at the office and all prospective employees of

the company are expected as part of their employment contracts to be

acquainted with the content and provisions of this EMP.

1.3 Acceptance of EMP

The acceptance of the EMP by the Environmental Commissioner will confer a

legal obligation to CCS Management to comply with the provisions of the EMP.

Should the proponent fail to comply with the requirements of this EMP, it is

deemed to be a contravention in terms of the Environmental Management Act

(Act No. 2 of 2007) and as such is criminally prosecutable.

This EMP includes all relevant documentation contained in it or referred to within

it, along with any amendments, appendices or annexure to this document. Any

substantial changes, updates or revisions to the EMP must be submitted to and

approved by MET.

Environmental Management Plan for ML 219 - Cape Cross Salt (Pty) Ltd

ML 219 – Environmental Management Plan Page 2

1.4 Environmental Policy

Based on the criteria provided in this EMP, CCS is to establish an overarching,

specific policy that defines the objectives of its salt operation that will ensure

sound environmental and social performance (IFC, 2012). This policy obligates

the proponent to comply with the applicable laws and regulations related to

environmental and social assessment and management processes.

2. ENVIRONMENTAL MANAGEMENT OBJECTIVES

The implementation of this EMP is a recurring process that converts mitigation

measures into actions and through monitoring, auditing, review and corrective

action, ensures conformance with the overall aims and objectives. These

objectives are provided below:

ensure compliance with the conditions of the Environmental Clearance

Certificate (ECC) once granted by the Environmental Commissioner

propose adverse practical measures to prevent, minimize, mitigate or

rehabilitate areas impacted by the operation;

conserve significant aspects of the biophysical and social environments;

protect human health and ensure safety of workers and the public;

propose a plan to monitor and manage the operational aspects of the salt

mining activities in such a way that the operation is carried out in manner

which is technically acceptable, economically feasible and environmentally

sustainable

2.1 Roles and Responsibilities

Throughout the lifespan of the salt operation, a number of individuals and entities

are expected to fulfill various roles and responsibilities to ensure the effective

implementation of the EMP.

In the table below are the roles and responsibilities that various parties will play

with respect to the implementation of this EMP:

TABLE 1: ROLES AND RESPONSIBILITIES - MET

The Environmental Management Act (EMA) is implemented by MET and the

Environmental Commissioner is a statutory office responsible for enforcing compliance of

EMA. Amongst the roles and responsibilities of MET are:

granting of ECC (Environmental Clearance Certificate)

ensuring overall compliance with the terms of the ECC & EMP

reviewing this document and any revisions thereof

undertaking site audits at their discretion

reviewing Audit Reports

enforcing legal mechanisms for contraventions of the EMP and ECC



TABLE 2: ROLES AND RESPONSIBILITIES OF THE PROJECT PROPONENT

During the operational (business phase) and decommissioning phases of the salt

operation, the overall management and responsibilities of the operation will be vested in

the General Manager who should be suitably qualified, skilled and experienced. Amongst

the roles and responsibilities of the General Manager are to:

manage the day-to-day activities of the salt operation and to ensure that such

activities are executed in compliance with relevant legislation and in terms of the

EMP

ensure that the necessary environmental authorizations and permits are obtained

and kept on file at the salt mine office

maintain the general communications with stakeholders, authorities and affiliated

associations

report any significant environmental incidents, accidents and or emergencies to the

relevant local authority

facilitate the appointment of a Safety, Health Environmental (SHE) Officer for the salt

operation

Amongst the roles and responsibilities of an SHE Officer are to:

provide induction training to all personnel who are hired such that the environmental

values, potential impacts, management measures and emergency responses are

understood and implemented

undertake monthly inspections to ensure on-site implementation and to check the

effectiveness of the prescribed mitigation measures

investigate environmental incidents and report to the General Manager and to take

corrective actions including ongoing monitoring activities

perform annual internal audits of EMP implementation

conduct annual internal reviews and update of the EMP

The induction training on the EMP should, as a minimum, cover the following aspects:

the importance of complying with the EMP

employees‟ roles and responsibilities, including emergency preparedness

how to deal with Health and Safety aspects

the management of wastes both solid and liquid at the salt mine

the importance of conducting daily pre-start checks of earthmoving machines

the importance of keeping equipment in good working condition including spill kits

and fire extinguishers



3. REGULATIVE FRAMEWORK

3.1 Environmental Legislations and Standards

In the Table below, some of the laws and regulations applicable to the envisaged

salt operation are indicated:

TABLE 3 : LEGISLATIVE FRAMEWORK

Legislation Requirements

Minerals

(Prospecting and

Mining) Act, Act 33

of 1992

The Act provides for reconnaissance, prospecting and mining,

and disposal of, and the exercise of control over minerals in

Namibia, and all matters incidental thereto.

Mining Licence: means a Mining Licence issued under Section

98 of the Minerals Act and includes the renewal of any such

license.

Mining Area: means the area of land to which a Mining Licence

relates.

Mining Operations: means any operations carried on in

connection with mining

Mine: when used as noun means any place where mining

operations are or have been carried on, including any

excavations or accessory works, which is or are necessary for, or

incidental to such mining operations

Mine: when used as a verb means any operations calculated to

win any mineral or group of minerals, from a mine or from any ore

won from a mine and includes any operations which are

necessary for or incidental to such any operation.

Petroleum Product

Act

The Act provides for the Storage and Handling of Petroleum

Products. Proponent needs to apply to MME for a consumer

installation certificate.

Roads Traffic and

Transport Act 22

of 1999 as

Amended

The Act provides for the control of traffic on public roads, the

licensing of drivers, the registration and licensing of vehicles and

the control and regulation of road transport on Namibia public

roads and for matters incidental thereto.

Labour Act as

Amended

Regulations relating to the health and safety of employees at

work are contained in GN 156/1997 (GG 1617). Must be complied

with on this project.

National Heritage

Act No. 27 of 2004

No archaeological/heritage site or cultural remains may be

removed, damaged, altered or excavated.

Section 48 sets out the procedure for application and

granting of permits, such as the permit required in the event

of damage to a protected site occurring as an inevitable

result of development. Section 51 (3) sets out the

requirements for impact assessment.

Part VI Section 55 Paragraphs 3 and 4 require that any

person who discovers an archaeological site should notify

the National Heritage Council



3.2 Standards and Guidelines

3.2.1 Air Quality

The Namibian Atmospheric Pollution Prevention Ordinance (No. 11 of 1976) does

not include any ambient air standards to comply with. Typically, when no such

local criteria exists, or are in the process of being developed, reference is made

to international criteria.

TABLE 4: AMBIENT AIR QUALITY GUIDELINES

Pollutant Averaging

Period

WHO Guidelines

Value (ug/m3)

EC Directive Limits

(ug/m 3)

US NAAQS (ug/m

3)

RSA NAAQS (ug/m

3)

Sulphur Dioxide SO2

1 Year - 20 50

24 Hours 125 (IT-1) 125 125

50 (IT-2)

20 (guideline)

1 Hour 350 196 350

10 Minute 500 (guideline) 500

Carbon Monoxide (CO)

1 Hour 30 0000

(guideline) - 40 000 30 000

Nitrogen Dioxide (NO2)

1 Year 40 (guideline) 100 40

1 Hour 200 guideline 40 188 200

Particulate Matter (PM10)

1 Year

70 (IT-1) 20 50

50 (IT-2) 40

30 (IT-3)

20 guideline

24 Hour

150 (IT-1) 50 150 120

100 (IT-2) 75

75 (IT-3)

50 guideline

Particulate Matter (PM2.5)

1 Year

35 (IT-1)

25 (IT-2) 25

15 (IT-3) 15 20

10 guideline 15

24-Hour 75 (IT-1)

50 (IT-2) 65

37.5 (IT-3) 35 40

25 guideline 20 s)

Note: Sourced from various International Organization as accepted by the World Bank (Airshed Planning Professionals 2014)



3.2.2 Health Screening Criteria

For the purpose of the health risk assessment, proposed evaluation criteria taken from the various international criteria are provided in Table 5 below

Note: Airshed Planning Professionals 2014)

3.2.3 Water Quality Guidelines

In Table 6 below are guidelines for the Water Quality of Namibia (MAWF 1988):

TABLE 6: NAMIBIAN WATER QUALITY GUIDELINES

Recommended Maximum Limits Human Consumption Livestock

Consumption

Parameters Group A Group B Group C

Water PH 6-9 5.5-9.5 4.11 4.11

Electrical Conductivity (MS/M) 150 300 400

Turbidity (NTU) 1 5 10

Total Dissolved Solids (mg/l) 600

Total Hardness as mg/l CaCo3 300 650 1300

CA-Hardness as mg/l mg/l CaCo3 375 500 1000 2500

MG-Hardness as mg/l CaCo3 290 420 840 2057

Chloride as Cl mg/l 250 600 1200 3000

Fluoride as F mg/l 1.5 2.0 3.0 6.0

Sulphate as SO4 mg/l 200 600 1200 1500

Nitrate as N mg/l 10 20 30 100

Nitrite as N mg/l 10

Sodium as Na mg/l 100 400 800 2000

Potassium as K mg/l 200 400 800

Magnesium as Mg ml/g 70 100 200 500

Calcium as Ca mg/l 150 200 400 1000

Manganese as Mn mg/l 0.005 1.0 2.0 10

Iron as Fe mg/l 0.1 1.0 2.0 10

TABLE 5 : REFERENCE EXPOSURE FOR SO2, NO2, PM10 & DUST

Pollutant Averaging Period Selected Criteria

(ug/m3)

Source

SO2

1- Hour Mean 350 EC Limit & SA Standards

660 California OEHHA RfC

8-Hour TWA

5 640 Nam Occupational Exposure Limit

1 410 European Community (EC)

24-Houe Mean 125

WHO IT1, SA, Botswana and EC Limit

20 WHO AQG

Annual Mean 50 SA standard

NO2 1 Hour

200 (a) EC limit & SA Standards

470 California OEHHA RFC

Annual Mean 40 WHO AQG

PM10

8-Hour TWA 10 000 Nam Occupational Exposure

limit

24-hour Mean 75(a) WHO IT3 & SA Standard

50 WHO AQG

Annual Mean 30 WHO IT3

Dust 8-hour TLV 2 ACGIH TLV



3.2.4 Proposed Inspections

Table 7 below provides a list of inspections that should be undertaken as part of this EMP:

TABLE 7: LIST OF INSPECTION SCHEDULE

Inspections Frequency Responsibility

Compliance with the provisions of the EMP At all times during the salt operation

CCS Management

Earthmoving Plants, Road Trucks & LDVs: Alcohol check for each employee Pre-start checks General conditions & cleanliness No overloading No spills from loaded trucks

Daily Daily Daily Daily

Operators

Littering : Access to the salt works Salt mine internal routes Workshop/administrative block areas Salt stockpiles All around ML 219 premises Areas around D2301

Weekly Weekly Daily

Weekly Weekly

Biweekly

SHE Officer

General conditions Boundary fence Crystalliser‟ areas Product stockpiles Salt mine internal haul road Wearing of PPE

Biweekly Weekly Weekly Weekly

Once weekly

SHE Officer

Hazardous spills: Oil Fuel Lubricants Paints

When reported SHE Officer

Waste Disposal: plastics, bottles, cans, etc.)

Weekly SHE Officer

Noise nuisance: idling revving hooting loud music from vehicles, etc.

Daily SHE Officer

Good housekeeping practices Administrative Office Workshop Section Wash Plant Section Stockpile Areas Mine routes

Daily SHE Officer

Internal Environmental Reporting Monthly SHE Officer

Overall Operational Environmental Audit Annually General Manager



4. ASPECTS RELATED TO ENVIRONMENTAL COMPLIANCE

4.1 Environmental Monitoring, Auditing & Review

Environmental monitoring is essential to assess the effectiveness of the recommended management strategies. According to IFC (2012) monitoring should include keeping records of specific outcomes and then comparing it to the benchmarks established during the onset of the EIA. Should corrective action be required, it needs to be documented to reflect not only the corrections that were made, but also preventative measures considered to avoid future recurrence. This should be followed up on, in all future monitoring endeavours to ensure the effectiveness.

In addition to keeping records of monitoring actions and outcomes, the implementation of this EMP should be internally audited on an annual basis after which the document will be updated or revised (as required) to address the issues and mitigation measures identified during the audit. During the annual audit, the appropriateness of the EMP to current activities, monitoring studies and legislation should be reviewed. This will enhance the relevance of the document and verify compliance and progress towards the desired outcomes.

4.2 Environmental Induction and Awareness Training

It is proposed that an environmental compliance workshop on the EIA and on the provisions of the EMP be provided to all the employees who will be involved with the salt operation. The agenda for such a workshop should amongst others include the following:

the importance of complying with the EMP,

the importance of complying with the salt mining plan

discussion of the potential environmental impacts of salt mining activities

the benefits of improved personal performance;

employees‟ roles and responsibilities, including emergency procedures

aspects related to Safety and Health Standards

explanation of the management structure of individuals responsible for matters pertaining to the EMP



5. PROPOSED ENVIRONMENTAL MANAGEMENT PLAN

The EMP is divided into three environmental aspects which are: the Physical Environment the Natural Environment, and the Human and/or Socio-economic Environment

5.1 The Physical Environment

The physical environment aspects are described in the table below:

TABLE 8: ENVIRONMENTAL ASPECT - TOPOGRAPHY & LAND USE

POTENTIAL IMPACTS

The whole of ML 219 is on saline pan which does not support any form of noticeable life, however there can be loss of habitat for micro-organism which have adapted to living in conditions of high salt content. Land surface disturbances through excavations will occur, but this is limited to the footprint of approximately 35% of ML 219

ENVIRONMENTAL OBJECTIVE

Limit land disturbances and maintain the aesthetic values of the area

POSSIBLE MITIGATION MEASURES

Mining Footprint:

Limit the development of new Salt Crystallisers on the saline pan and within the confines of ML 219. Salt Works Internal Routes:

All internal routes must be well planned and clearly demarcated. Movements of trucks within the salt works should be restricted to such routes. Off-road driving should be discouraged and drivers found driving off-road should be reprimanded.

Raised Crystallisers:

Salt Crystallisers developed on the southeastern of ML 219 should be slightly raised to prevent incidences of possibly flooding of the Owarab River. There are, however no records of the river flow having reached the Cape Cross saltfield in the last 30 years.

Aesthetic Appeal:

Areas temporarily disturbed during the construction of Salt Crystallisers, Salt Wash Plant and access routes that are not required for salt operation should be identified, graded and rehabilitated to improve the visual and aesthetic appeals of the area. This is important because D2301 is close to the salt works and is used by many tourists visiting the Cape Cross Seal Colony and Skeleton Coasts.



TABLE 9: ENVIRONMENTAL ASPECT ON HYDROLOGY - SURFACE WATER

DESCRIPTION AND POTENTIAL IMPACTS

The Lagoon along the beach is the only section of the Cape Cross Saltfield containing standing surface water and is home to thousands of marine birds, breeding and roosting on man-made structures - guano platforms from which guano has been harvested for well over one hundred (100) years. The Lagoon and guano platforms are about 5 km away and outside the boundaries of ML 219. As such the salt operation is not expected to have any negative impacts on the Lagoon. On average the project receives approximately 50 mm of rain annually, but it is not uncommon for the area to go for years without receiving a single drop of rain.


Potable water is a scarce commodity in Namibia and should be used sparingly

RECOMMENDED MITIGATION MEASURES

Lagoon:

The salt operation does not have any significant impact on the water in the Lagoon. It is believed that the Lagoon is being recharged through tidal overflows and seepage of seawater through the sand barrier. The salt works will pump brine from the aquifer underneath the Rock Salt layer (Halite) and this is not expected to have any impact on the recharge of the Lagoon. Contaminated Water:

Water used to clean machinery, plant and equipment is likely to contain amounts of oil and grease and should not be discharged into the natural ground. Washing of vehicles should be done on a dedicated well-designed area with an impervious floor which allows used water to drain through a well-constructed oil interceptor device. Sewage System:

Onsite sewerage systems should be designed and installed by professionals according to tested local standards to ensure that there are no leaks into the ground. Good housekeeping should be maintained to ensure that any leaks of sewerage system and or water storage facilities are detected early and repair work carried out immediately to avoid wastage.



TABLE 10: ENVIRONMENTAL ASPECT ON HYDROLOGY - POTABLE WATER


The washing process for salt does not require the use of potable water. There are no known sources of potable water in the Cape Cross saltfield area. Limited potable water will be required for human use and cleaning purposes only. A mobile tanker will be used to track water from the Omdel Water Scheme at Henties Bay. This is the practice used by other salt miners and commercial establishments in the area. The alternative to lay a pipeline from the Omdel Water Scheme has not been considered by the promoter. At this stage, the requirement for potable water and scale of the salt operation do not seem to justify a capital expenditure of that magnitude. Potential impacts are: Contamination from lubricants, oil and fuels from machinery and vehicles and

refueling installations Poor management and containment of solids or liquid waste systems Poor housekeeping


Ensure water is used wisely and not wasted because it is a scarce resource


Onsite Water Storage Facilities:

Store water on site in suitable PVC tanks which are secured, well installed and leak-free. Inspection of water storage facilities should be done on a regular basis so that defects and leaks are detected early and repairs effected timeously. Good Housekeeping:

Maintain a high standard of housekeeping which includes regular inspections of surface water installations and storage facilities (tanks and containers) on the salt mine. Recycling:

Try to recycle water used for cleaning purposes for watering of plants around the administrative offices of the salt works.



TABLE 11: ENVIRONMENTAL ASPECT ON HYDROLOGY -UNDERGROUND WATER


Drilling conducted in the area by several exploring companies to locate sources of

underground water for their activities has disappointing outcomes in that the water was of

poor quality with high levels of salt and the yield was poor.

There was no attempt made by the promoter to drill for underground water sources in the

vicinity of the project site – the scale of the envisaged operation does not justify that.

Generally, the groundwater quality can be contaminated from sources such as:

fuelling installations

poor storage and handling of hazardous products

overflow or leakage from sewerage and domestic wastewater systems

fuel spills


Ensure no leaks of fuel, oil and lubricants to the soil


Contaminated Water

No mitigation is considered necessary with regard to underground water sources provided measures proposed for surface water installations are implemented.

Fuel Installations

Fuel installations on the salt works should be properly designed and installed by professional experts in full compliance of the Petroleum Products and Energy Act. Daily inspections of fuel installations should be performed by a staff member specifically assigned to handle and manage fuel supply and handling on the mine. Adequate suitable signage should be provided around the fuel installation facility. Sewage in Installation

The design and management of facilities for treatment and disposal of sewage should make use of technologies that are tried and proven in Namibian conditions. Maintenance of such systems should be to a very high standard. Treated water should be recycled via a small processing plant. No water may be disposed of to the environment. This is to ensure that leakages do not occur.



TABLE 12: ENVIRONMENTAL ASPECT ON BITTERNS DISCHARGE


At approximately 29% of salinity, almost 75% of Sodium Chloride would have crystallized out of the original brine solution leaving other undesirable salts such as Magnesium, Potassium and Bromine. The spent brine containing these salts has to be pumped out of the crystallisers before the unwanted salts start to precipitate out to contaminate Sodium Chloride already in the pond. The effluent or bitterns from several Salt Crystallisers is pumped into a separate common pond with a sealed floor. Here the bittern is diluted with some seawater prior to pumping the same to the sea over a distance of 2 km via a 110 mm diameter PVC pipe. The volume involved is very little and pumping will most likely be done once per year or in the worst case scenario twice per year. The discharge pipeline will be buried and not exposed to the element. Discharging the Magnesium rich bitterns and other high iron on the saline pan is risky in that the brine in the entire saltfield could be contaminated. A section of the piping will be outside ML 219.


Ensure bitterns from the salt operation is disposed of in a responsible manner


Bitterns Discharge Management Plan:

Develop a holistic effluent (bitterns) discharge management plan which looks into securing markets for Magnesium salt so that the effluent is turned into commercial use in the long term. Underground Discharge Pipe:

The piping conveying the spent brine to the sea should be buried and not exposed to the elements resulting into a visual nuisance. Inspection should be done from exposed manholes at equal intervals over the length of the pipeline. Leakage:

Ensure that the piping conveying the bitterns to the sea is of good quality and the installation is well executed to avoid leakages and associated high maintenance costs. Inspection A single track route on one side of the underground pipeline should be allowed for purposes of carrying out regular inspections and any repairs which may be required from time to time.



TABLE 13: ENVIRONMENTAL ASPECT - AMBIENT AIR QUALITY


The ambient air quality is often negatively impacted when developments are located in areas where there are heavy industries such as Walvis Bay. There are no industries around the project site. The high moisture content of the soil and salt road has the effects that no dust is actually generated. The salt operation will generate emissions that are likely to impact the ambient air quality through: noxious emissions from earthmoving machines, trucks and equipment used in the

salt operation PM10 concentrations as a result of wind brown dust from coastal „berg-wind‟ bouts possible dust released during the construction of crystallisers (handling of gypsum,

sand, cement, etc.) health hazard noxious emissions from traffic using D2301 and machinery from other salt works in

the area


Ensure the impact on the ambient air quality is minimized such that social amenity and health values are maintained.


Personal Protective Equipment:

Employees working in areas where gaseous emissions are generated should be provided with suitable PPE. Wearing of such PPE should be compulsory and enforced.

Maintenance Of Plant & Machinery:

Earthmoving machinery, salt haul trucks and LDVs should be properly maintained, regularly serviced and idling times limited, so as to minimize NO2 emissions. Speed Limits:

Speed limits on the salt mine internal routes should be adhered to and enforced at all times - 20 km/hour on all internal routes and 80 km for all trucks driven on public roads. Limit Harmful Emissions:

Where possible diesel with low sulphur content (50 ppm) should be used. Use seawater to combat dust emissions by spraying sources of dust especially when handling dry materials. Ensure that emissions are kept within allowed threshold limits. Complaints:

All complaints related to air quality pollution received from the community/stakeholders should be recorded, investigated and corrective action taken.



TABLE 14: ENVIRONMENTAL ASPECT - NOISE DISTURBANCES


Noise is unwanted/undesirable sound that can affect job performance, safety and health of humans. Psychological effects of noise include annoyance and disruption of concentration. Physical effects of noise are: loss of hearing irritation and pain nausea, and interference with communications when the exposure is severe

ENVIRONMENTAL OBJECTIVES

Protect amenity values by ensuring that noise levels are minimised. Ensure noise levels are within the statutory parameters and allowed standards.

PROPOSED MITIGATION MEASURES

MAINTENANCE OF MACHINERY & EQUIPMENT:

Ensure machineries and equipment used in the salt operation are properly maintained and regularly serviced (defective silencers should be replaced, etc. Where applicable, equipment should be operated at the minimal ratings to undertake required tasks. Machineries must be switched off when not in use and unnecessary hooting, idling & revving should be avoided. Personal Protective Equipment:

People working in areas where noise levels are high should be provided with suitable PPE. Wearing of such devices should be enforced. Training:

Employees should be trained on the importance of wearing PPE and on all the provisions of the EMP. Complaints:

Any complaints related to noise disturbances received from stakeholders/community should recorded, investigated immediately and corrective action taken



TABLE 15: ENVIRONMENTAL ASPECT - DUST DISTURBANCES


The salt operation is not associated with dust generation largely because of the high moisture content of the soil and humidity in the atmosphere. Construction activities involving the handling of dry materials, i.e. gypsum, sand, cement, sandblasting, etc. are likely to generate some dusts. The negative effects of dust to the employees: eye and noise irritation health hazard amenity nuisance airborne dust particles The nature of the operation especially during the Operational Phase, is that incidents of dust emissions are almost negligible


Enhance and protect amenity values by ensuring that dust levels (if any) from the salt operation is minimized


Product Stockpiles:

Where possible salt stockpiles should be located in sheltered areas outside the common direction of „berg winds‟ or „east wind‟ or where they are not exposed to erosive effects of the east wind. Personal Protective Equipment (Ppe):

People working in areas of the operation where dust is generated (if any) should be provided with suitable PPE. Wearing of such PPEs should be enforced at all times.

Equipment Maintenance:

Earthmoving machinery, trucks and LDVs used in the salt operation should be properly maintained and regularly serviced. Limit idling times to minimize NO2 emissions and associated impacts. Speed Limits:

Speed limits within the working areas should be adhered to and enforced at all times - 20 km/hour on internal routes. Complaints:

Any complaints or claims related to any form of dust should immediately be investigated and corrective action taken



TABLE 16: ENVIRONMENTAL ASPECT - WASTE MANAGEMENT


The salt operation is located within the Dorob National Park which makes all disposal of waste in the Park unacceptable. Waste could attract scavengers resulting in conflict with humans or injury or even fatalities to animals. Waste could also result in the these nuisances: visual nuisance odour nuisance health hazard amenity nuisance


Protect amenity values by ensuring a hygienic and waste-free salt operation.


Waste Management Plan:

Develop a Waste Management Plan which includes details of waste types, procedures to be followed and facilities available for disposal.

Hazardous Waste:

All vehicles should be inspected daily for oil leakages. Service and wash trucks at designated areas with impervious floors fitted with oil-water separators. Store oil filters in a marked container that allows oil to drain through but without escaping.

Trained Personnel:

Hazardous waste should be handled by trained personnel only. Spill management kits, PPEs and relevant emergency procedures should be available at the workshop and storage facilities. Any spills should be contained and cleaned up.

General Waste:

All domestic and workshop wastes should be cleaned and contained daily. Small quantities of papers and plastics may be burned at a designated site. Liquid Waste:

Determine annual quantities of liquid wastes generated, store in sealed containers and transport once or twice annually to a licensed waste landfill at Walvis Bay. Waste Bins:

Provide separate containers/bins for household and general workshop wastes. Waste bins should be clearly marked and all employees trained and sensitized on waste disposal. Littering should be avoided. Dispose waste at designated waste landfill sites (Henties Bay for general waste and Walvis Bay hazardous waste). Fire Control:

All fire-fighting equipment should be readily accessible and kept in a good working order. No smoking should be allowed in areas where there is a fire hazard, i.e. near fuel storage areas.



TABLE 17: ENVIRONMENTAL ASPECT - VISUAL INTRUSION


There are permanent man-made structures visible all along the D2301 salt road in the form of guano platforms, dilapidated buildings, land disturbances from previous salt mining operations and stalls displaying salt crystals. The following visual intrusions are likely to be associated with this salt operation: support infrastructures (wash plant & workshop buildings) product stockpiles light pollution


Ensure the salt operation infrastructures do not alter the existing views of surrounding areas but are made to blend in well and enhance the sight.

MITIGATION MEASURES

Permanent Structures:

Reduce visual impacts of permanent structures by locating such structures away from sensitive and elevated areas. This will particularly apply to the wash plant and harvesting equipment. Salt stockpiles are naturally white and therefore very pleasing to the eye to see. Lighting:

Ensure that security light at night does not offend the traffic using the D2301 road. The lighting layout should direct lights inwards towards the workshop areas and not outwards to D2301 road. This should apply to the lighting installed at the D2301 T-junction to enhance safety. Waste:

Wind-blown papers and plastics around the salt premises should be regularly picked up to avoid visual nuisance. Housekeeping:

Maintain a high standard of housekeeping. Maintenance of Structures:

Buildings on the operational site should be well maintained and regularly painted to avoid visual decay.



TABLE 18: ENVIRONMENTAL ASPECT - ARCHAEOLOGICAL & CULTURAL HERITAGE

DESCRIPTION OF POTENTIAL IMPACTS

The Cape Cross saltfield is a brownfield area which had a fair share of environmental

disturbances spanning over a hundred years. Guano production, whales processing and

seal curling have been conducted at Cape Cross since 1895. The Cape Cross Bay was

also used as a loading facility.

The area is therefore endowed with items of archaeological and cultural heritage

interests.


Safeguard and protect any findings of an Archaeological or Cultural Heritage


Heritage & Archaeological Sites:

Should a Cultural Heritage site or an Archaeological site of interest be uncovered or discovered during the construction of crystallisers, i.e. a “chance find” the following procedure should be applied: if operating machinery or equipment, stop work immediately; demarcate the site with plastic warning tape; cease any works in the immediate vicinity if possible determine GPS position of the site report findings, site location and actions taken to the Project Manager site location and details to be added to the Geographic Information System (GIS) for

field confirmation by archaeologist; invite officials from the National Heritage Council (NHC) from Windhoek to visit the

site or request written permission to remove findings from work area; and recover, pack and label findings for transfer to the National Museum as guided by

officials of NHC Human Remains:

Should human remains be unearthed, the following actions will be required: apply the chance find procedure as described above; schedule a field inspection with an archaeologist to confirm that remains are human; inform and liaise with the NHC and the Namibian Police; and remains will be recovered and removed by the police either to the National Museum

or the National Forensic Laboratory work should only continue once all clear is given by officials of NHC or the Namibian

Police



TABLE 19: ENVIRONMENTAL ASPECT - TRAFFIC IMPACTS ON NATIONAL ROAD D2301

The trucking of salt from the Cape Cross to the Walvis Bay Port will be done over three national roads: D2301 (Cape Cross & Henties Bay), C34 (Henties Bay & Swakopmund) and MR44 (Swakopmund & Walvis Bay).

POTENTIAL IMPACTS ON D2301

Certain sections of this road present safety challenges in that the cross section is narrow making it difficult for two heavy vehicles to pass each other. The road shoulders also tend to fail when a fully loaded heavy truck drive over it. Intersections along this road could also pose safety risks. Potential impacts associated with this road are: overturning due to slippery road head-on collisions accidents and incidents

Intersection Of The Salt Mine Access Road With D2301:

The horizontal sight distance to the south of the intersection is impeded with slight undulations and a slight curve which hide approaching vehicles. Turning Lane: Turning lanes should be added to both sides of the road (D2301) to facilitate smooth merging of traffic onto D2301. Lighting: Adequate lighting, preferably amber flushing lights should be installed at the junction to improve safety, increase visibility at night especially when foggy conditions prevail. Signage: Provide adequate and prominent signage on either side of D2301 to warn other road users of heavy vehicles entering and exiting the road. Ensure that road signs are cleaned on a regular basis to serve the purpose for which they are installed.

Intersection of MR76 With D2301

The horizontal sight distance when approaching this junction from south or north is clear and unimpeded. The traffic flow on this Uis road is low, but this is due to change once the planned upgrade to bitumen is complete. Turning Lane: It is recommended for the intersection area to be widened to provide an area where three lanes of traffic are accommodated so that the north bound heavy vehicles do not have to slow down to allow traffic turning right onto MR76.

Lighting:

Provide adequate lighting preferably with amber flushing lights to enhance safety and increase visibility especially during foggy conditions. Adequate signage is provided, however the promoter should liaise with the Roads Authority to have the road signs cleaned on a regular basis at least twice a week


Same measures as recommended for C34 and MR44 roads



TABLE 20: TRAFFIC IMPACTS ON NATIONAL ROADS C34 AND MR44

At the time of the EIA, contractors were still busy upgrading both roads to bitumen. C34 between Henties Bay and Swakopmund is almost complete and the contractor was only working on the bridge, across the Omaruru River and the section of the road leading to the Uis turnoff (MR76). MR44 is a new dual carriageway road being constructed between Swakopmund and Walvis Bay running behind the dunes. Completion is expected during the second half of 2020. Total distance from MR76 to the Walvis Bay Harbour is approximately 123 km.

POTENTIAL IMPACTS ON NATIONAL ROADS C34 AND MR44

Both roads are in good condition and the number of vehicles involved in the trucking of salt to the port is not expected to increase the traffic on these roads. Potential impacts are: overloading over speeding accidents and incidents unlicensed and non-roadworthy vehicles being operated on the roads litter thrown from vehicles by drivers racing


Enhance and protect amenity values by ensuring that traffic regulations are maintained and complied with at all times


Speed Limit:

All drivers should adhere to the speed limits of 80 km/hr for trucks on all public roads including the salt road D2301. Trucking Device:

Trucks should be fitted with trucking devices and permanent staff assigned to man a control room on a 24 hour basis monitoring movements of all trucks. Drivers found speeding or not complying with road regulations should be disciplined. Weighbridge:

Trucks leaving the salt works should pass over the weighbridge to have their payloads weighted and recorded. Overloading will cause undue wear and tear on national public roads. Staff in the control room should keep all loading data. Road Regulations:

All company vehicles operated on public roads must be licensed, roadworthy, supplied with Mass Distance Logbooks and operated by licensed drivers with valid public driver‟s permits. All road signs should be respected and complied with. Log books should be completed. Overloading:

Trucks hauling salt to the port should not be loaded such that salt falls out of the tipper edges becoming a safety hazard to other road users. Training On The Employee:

All truck operators should be given a training workshop on the EMP. To ensure that the provisions of the EMP are well understood, it is advisable for the training to be presented in a language understood by the operators.



Defensive Driving:

It is recommended that all truck operators undergo a defensive driving training periodically to enhance their driving skills, safety awareness and their responsibilities when driving on public roads.

Alcohol Testing:

All drivers reporting for duty must be tested for alcohol and any driver who tests positive for alcohol should not be allowed to drive out of the premises and should be disciplined.

Pre-Start Checks:

All drivers should perform pre-start checks on their vehicles in the morning before they start operating the trucks, checking any oil leaks, water levels, coolant levels, cleanliness of the vehicle, tyre pressure, lights, etc. Completed pre-start checks for each vehicle should be given to the supervisor for review and filing. Maintenance Of Vehicles:

Any faults on the trucks as reported by the drivers should be repaired immediately and drivers should refuse to drive trucks which are defective. Regular servicing of vehicle should be done to ensure a safe and hazardous free operation. Accidents/Incidents:

All incident and/or accidents involving a company vehicle should be thoroughly investigated and corrective measures taken to prevent a re-occurrence. Truck operators who violet company policies on traffic should be reprimanded. Lights:

All trucks hauling salt to the port should be driven with their headlights switched on at all times. In addition all trucks should be fitted with amber flushing lights at the front and the rear. The housing of such lights should be cleaned on a regular basis. Complaints:

Any complaint(s) received from any stakeholder with respect to traffic violations should be recorded, promptly investigated and corrective action taken.



TABLE 21: ENVIRONMENTAL ASPECT - FUEL STORAGE AND FUEL MANAGEMENT

Large volumes of fuel (diesel) will be required for the fleet of trucks hauling the salt to port and for the earthmoving machinery and plants used in the salt operation. This fuel will be stored on the mine premises in accordance with the provisions of the Petroleum Product Act.

POTENTIAL IMPACTS

Potential impacts involved in fuel handling are amongst others: Leakage (groundwater contamination) Fire hazard Safety hazard


Ensure that a high standard of safety is maintained for the fuel storage and handling


Designated Storage Area:

The fuel storage area must be approved by CCS Management in consultation with the bulk fuel supplier. The diesel tank must be situated on a smooth impermeable surface (plastic or concrete) base with an earth bund. The floor of the bund must be sloped towards an oil trap or sump to enable any spilled fuel and or fuel-soaked water to be removed, or the bunded area must be covered. Fuel Security:

The fuel tank must be fitted with lids which are kept firmly shut at all times. The Operations Manager must keep the fuel under lock at all times and the key kept in the safe. Smoking and naked flames must not be allowed in the vicinity of the fuel storage area. Signage:

Symbolic signage clearly depicting “No Smoking” “Danger” & “No Naked Lights” must be clearly displayed and must conform to local standards. The volume capacity of the fuel tank must also be displayed. Fire Safety:

The areas of fuel storage and any other flammable materials must comply with fire safety regulations. Any fuel dispensing pump (electrical or fuel-driven) must be equipped and positioned so as not to cause danger of ignition of the product. Suitable and adequate firefighting equipment should be provided at the site.

Fuelling:

Earthmoving and equipment fuelling should be undertaken on a hard impermeable surface or over drip pans to ensure spilled fuel is captured and cleaned up. Defective hoses, valves and containment structures should be promptly repaired. Refueling of earthmoving machines working on the saltfield should be done from a suitable mobile diesel bowser.



5.2 The Natural Environmental Impacts

Possible mitigations of environmental aspects related to the ecosystem are

described in the table below.

TABLE 22: ENVIRONMENTAL ASPECT ON NATURAL VEGETATION

POSSIBLE IMPACTS

ML 219 is located on the saline pan of the Cape Cross saltfield which does not support vegetation. Impact on vegetation is therefore not applicable for this operation. There are however vegetation on the delta of the Owarab River but this is outside the confines of ML 219.


Ensure the salt operation does not impact negatively on the vegetation in the surroundings. RECOMMENDED MITIGATION MEASURES

Training Workshop:

All employees should be given an environmental induction specifically dealing with aspects related to the ecosystem (flora aspects) and the importance thereof. Salt Mine Internal Routes:

Earthmoving machinery should be operated on dedicated internal routes only. Such routes should be well planned and well maintained. Off-road driving should be discouraged and drivers found driving off-road should be reprimanded. Rehabilitation:

Areas disturbed during the construction of salt crystallisers and roadways should be rehabilitated.



TABLE 23: ENVIRONMENTAL ASPECT ON FAUNA (WILD ANIMALS)

DESCRIPTION OF POSSIBLE IMPACTS

The Lagoon to the southwest of ML 219 is home to hundreds of marine bird species. To the northwest of ML 219 is the Cape Fur Seal Colony with over 100 000 seals at any given time. Whilst these locations are quite far and outside the confines of ML 219, they visited by scavengers moving in from inland looking for preys. Potential impacts are likely to include the following aspects: Loss of habitat to saline adapted species Road kills of slow moving animals and birds Poaching of wild animals (Oryx are often seen in the Owarab River delta) Killing of snakes Illegal fishing Killing of Seals (often wounded seal bulls are encountered on the salt pans) Honey bees are often attracted to water in the desert and this could lead to

confrontation with human


Upheld the integrity of the ecosystem with respect to the fauna in the area


Training Workshop:

An environmental induction specifically dealing with aspects related to the ecosystem (fauna) and the importance thereof should be offered to all employees of CCS. Salt Mine Internal Routes:

Earthmoving machinery should be operated on dedicated internal routes only. Off-road driving will destroy the habitat of saline adapted species and should be discouraged and drivers found driving off-road should be reprimanded. Wild Animals:

Illegal hunting, killing of snakes and fishing without a permit are unlawful activities punishable by law and are not allowed. The same applies to reptiles and small insects. Waste Handling:

Food leftover should be placed in bins with secured lids. Wild animals (jackals) should not be allowed access to leftover food. Hyenas allowed access to human food have turned into problem animals often leading to conflict between the parties. Hazardous Products:

Waste products of a hazardous nature such as fuel, lubricants, etc can be harmful to fauna when stored in unsecure containers.



5.3 The Human (Socio-economic) Environment

In the table below are possible mitigations of environmental aspects related to socio-economic impacts.

TABLE 24: ENVIORNMENTAL ASPECT - EMPLOYMENT IMPACT

POTENTIAL IMPACTS

Poverty eradication Improved standard of living Good income /salary Support to family/relatives Dignified life


Ensure employment is offered in compliance of applicable labour laws and regulations


Hiring Of Employees:

Adopt a „local first policy‟ when hiring workers for non-skilled positions at the salt operation.

Hire employees from the local communities without discrimination on the basis of gender, race, language, background, religion or political affiliations

People from marginalized communities (i.e. Sun people) should also be considered and offered employment

People with disabilities should likewise be considered for suitable employment opportunities.

Ensure that the recruitment of employees at the salt operation is done in a transparent manner. The recruitment process should be gender and disability inclusive, i.e. qualified women should be given an equal opportunity where possible. The recruitment process must be formal and organized. Preference should be given to residents of Henties Bay.

Employees’ Wellbeing:

Develop a policy on social ills to deal with aspects related to drug and alcohol abuse by the employees. Initiatives should also be made with regard to raising awareness on the danger of unsafe sex practices which lead to HIV/AIDS and other sexual transmitted diseases. Training:

All employees should be given an induction workshop on this EMP Provide and offer on-the-job training opportunities for employees to improve their

skills level which ultimately leads to high productivity and efficiencies.



TABLE 25: ENVIRONMENTAL ASPECT - LABOUR & WORKING CONDITIONS

POTENTIAL IMPACTS

unsafe working environments bias recruitment practices poor standard of hygiene & cleanliness


Ensure and maintain a safe and hazardous-free working environment Employment Contract:

The terms and conditions of each employee should be clearly spelled out in a written contract with a copy held on the file at the office and one copy given to the employee. The contract should amongst other things spell out job specifications, working hours, remuneration, etc.

Employee Transport:

Employees should reside in the town of Henties Bay with the company providing free transport to and from work. Only security personnel working rotational shifts are allowed to reside on the company premises during working hours only. Trade Unions:

Allow the employees to exercise their rights to join and belong to a trade union of their choice. Allow each employee charged with a misconduct the right to be represented during a disciplinary hearing Records:

Proper records should be kept with respect to the number of people employed whether fulltime or part-time, contractors hired, payments made to contractors, salaries and wages paid to full-time and part-time employees, number of non-locals hired and the salaries paid to non-Namibians, etc. The amount spent on salaries will be an indication of the amount of money that will be spent in the local and regional economy by the employees.



TABLE 26: ENVIRONMENTAL ASPECT - SOCIAL AND COMMUNITY IMPACTS

POTENTIAL IMPACTS

Increased local economic activities (Henties Bay, Swakopmund and Walvis Bay) Injection of income into the local community Creation of employment Increased regional trading opportunities Community support – support a good course


Extend economic opportunities to local businesses, promote industrial relations, and contribute to socio-economic stability.


Goods & Services:

Source and procure goods and services required for the salt operation from local suppliers (spare parts, fuel, PPEs, stationery, etc.) where applicable. Contribution to the regional and national economy should be monitored and reported on through annual reviews where applicable.

Workers:

Try as much as possible, to hire and recruit people for manual and unskilled labour from within the constituency with preference given to those already having accommodation in the town of Henties Bay. Complains From The Community:

Engage with the community and provide information in a transparent and open manner so as to manage their expectations. Any complain and or grievance received from the community should be addressed timeously. Corporate Social Responsibility:

Contributions made by the salt company to the community should be reported on in the media so as to enhance the profile of the company to the general public. Membership of the Chamber of Mines or the Namibia Chamber of Commerce and Industry (NCCI) is recommended.

Logbook:

A logbook should be kept at the gate of the salt operation where all vehicles visiting the operation are recorded, the time of entry, exit, the type of vehicle, and its destination. This will give an indication of the number of vehicles visiting the operation.

Tourists:

Tourists wishing to view the salt operation should be allowed and given the space to do so, provided prior arrangements have been made or when such visits do not inter with the operation.



TABLE 27: ENVIRONMENTAL ASPECT - HEALTH AND SAFETY IMPACTS

POTENTIAL IMPACTS

Incidents & accidents Injuries Loss of life Loss of assets/properties Unhygienic conditions

ENVIRONMENTAL OBJECTIVES

Protect amenity values and business efficiency by ensuring that a high standard of health and safety is maintained.


Health & Safety Plan:

Develop a Health and Safety Plan which makes provision for raising of awareness, sharing of information as well as access to health care services. The health and safety of workers should be protected and safeguarded at all times.

Emergency Response:

Develop an Emergency Response and Procedures Framework for the salt operation to deal with any safety incidents or accidents occurring such as : accidentally Spill of hazardous materials, accidents involving personnel on the work sites, and fire or major landslide or structural failure, etc

The basic principles to be included are: preventive and responsive actions responsible person to coordinate such actions reporting procedures for incidents on site corrective measures to flawed methods of response

Personal Protective Equipment (PPE):

Provide and supply suitable PPE to all employees working on the salt operation and enforce wearing of such PPE. Good Housekeeping Practice:

maintain good housekeeping comply with the guidelines in the EMP limit speed to 20 km/hour on internal routes enforce good housekeeping and ensure proper handling of all waste products ensure adherence to the relevant health and safety legislation



6.0 COMPLIANCE WITH THE EMP

6.1 Introduction

This EMP becomes a legally binding document once approved and written confirmation to this effect has been given through the issuance of an Environmental Clearance Certificate by the Ministry of Environment and Tourism. The provisions and mitigation details given in this EMP must be strictly adhered to and complied with by the proponent.

6.2 Non-compliance of the EMP

CCS Management should act immediately when notices of non-compliance of the provisions of the EMP are received and take corrective action. Complaints received regarding activities on the salt operation pertaining to the environment must be recorded in a dedicated registry book and the response noted with the date and action taken. Management must be made aware of any complaints received from stakeholders. The provisions of the EMP are deemed to have been violated in the following instances: there is evidence of contravention of the EMP specifications within and or

outside of the ML 219

environmental damage ensues due to negligence

salt mining activities taking place outside the defined boundaries of ML 219 t

CCS Management fails to adequately address complaints from the public

6.3 Penalties for Environmental Violations

It is recommended that CCS Management, in its employees‟ code of conducts, institutes penalties for the following less serious environmental violations and others determined during the course of the work as detailed here below: willful littering on site

persistent or unrepaired fuel and oil leaks

non completion of pre-start checks for machinery & equipment

any person or vehicle found within an area designated as a „no-go‟ area

possession or use of intoxicating substances (drugs or liquor) whilst on duty

possession of a firearm whilst on duty or on the company premises

coming to work under the influence of alcohol

any vehicle being driven in excess of designated speed limits

failure of wearing PPE when working in areas where wearing of PPE is mandatory

failure to wear a seatbelt when driving an earthmoving machinery, salt haul

trucks or LDVs

removal and or damages to any cultural heritage objects on site

urination and defecation anywhere other than using designated facilities on site



6.4 Emergency Preparedness

CCS Management should compile and maintain an Environmental Emergency Producers to ensure that there will be an appropriate response to unexpected or accidental actions or incidents that will cause environmental impacts throughout the operational period of the salt works. Such procedures must include inter alia the following: accidental exposure of employees to hazardous substances

accidental fires

accidental spillage of hazardous substances

The emergency plan should, as minimum include the following: list of key personnel and contact numbers (police, ambulance, fire, etc.)

details of emergency services available (fire department, spill clean-up services, etc.)

internal and external communication plans including reporting procedures

incident and accident recording, progress reporting procedures, etc.

information on hazardous materials including potential impacts associated with each and measures to be taken in the event of accidental release

training plans, testing exercises and schedule for effectiveness

6.5 Reporting

6.5.1 Good Housekeeping

CCS Management must ensure that „good housekeeping‟ is practiced during the salt operation. This will help to avoid disputes on responsibilities and allow for the smooth running of the operation as a whole. It should be noted that good housekeeping extends beyond the wise practice of mining, washing and trucking to the Walvis Bay Port to include aspects related to care and preservation of the environment within which the operation is located.

6.5.2 Record Keeping

Management should record all incidents related to the environment including violations, accidents and incidents. Action taken to address the situation should also be recorded for future references.

6.5.3 Documentation Control

Management must be responsible for establishing a procedure for document control. The document control must comply with following requirements: all documents must be dated and provided with a reference number, filed

systematically and must be retained for at least three years

management must ensure that documents are periodically reviewed and revised by the SHE Officer prior to conduct annual audit

to quantify nuisance risk to the surrounding environment



7. CONCEPTUAL CLOSURE PLAN

The purpose of this section in the EMP is to provide a conceptual closure plan for the salt operation, including restoration objectives and potential suggestions. Salt is renewable resource and salt mining at the Cape Cross saltfield can go on for an indefinite period into the future, as long there is demand for salt, however provision for restoration has to be made in the event of project failure, bankruptcy or unfavourable economic factors beyond the control of the promoter such as recession. The structure of this plan is in accordance with the Namibian Mine Closure Framework (The Chamber of Mines of Namibia, 2010).

7.1 Objectives

The objectives for the closure and rehabilitation of disturbed areas are: to ensure that the site is made safe for both humans and wildlife to manage all residual impacts to acceptable levels and without deterioration

over time to ensure that the closure is achieved with minimal socio-economic upheaval to safeguard and protect the biodiversity and the environment of the site

7.2 Closure Planning

Ideally, the plan for closure and rehabilitation should be an on-going process which is periodically updated and refined during the Operational Phase of the operation. The plan should reflect changes in the salt mining development, operational parameters, environmental and social conditions. The promoter is required to undertake a detailed closure and rehabilitation process during the Operational Phase. At this stage it is not possible to provide exact details as to how this process will take place, because technology, science and legislative requirements may well have changed by the time the salt operation begins its decommissioning process. However, a thorough closure development strategy has to be formulated now which should be reviewed and improved throughout the remaining lifecycle of the operation. Ideally, the final closure strategy should include and provide for a continuous rehabilitation and final closure. Although planning for the pre-mature closure cannot be done in much detail, being prepared for such unforeseen circumstances relies on having an updated detailed closure plan, which gives the promoter the flexibility to rapidly evaluate the remaining unknowns and risks associated with closure and to develop an appropriate decommissioning plan.

7.3 Socio-Economic Considerations

It is important to identify and engage key stakeholders in the formulation of a successful Mine Closure Plan. The mining operation which had been in operation for a number of years can often be responsible for substantial changes in both the community and the environment in which it operates (The Chamber of Mines of Namibia, 2010).

Engagement will enable stakeholders to have their interests considered as part of closure planning process, whilst creating an understanding for their views and expectations and formulating a balanced, realistic and achievable closure outcome.



Stakeholder engagement is an ongoing process that should start in the planning phase, and continue throughout the operation and salt mine closure phases. It should include consultations and providing feedback to all affected parties and stakeholders. The parties that should be consulted are divided into those that are directly affected: employees of the salt operation

Regional Authority (Erongo)

Local Authorities (Henties Bay)

service providers (Namwater, fuel companies, etc)

GRN institutions (MME, MET, Inland Revenue, etc)

product end-users (local buyers, livestock farmers, etc)

7.4 Mechanism to Manage Socio-economic Effects

Various mechanisms are available to manage post closure social issues. The following mechanisms are highlighted herewith for interest only. establishment of a Future Forum

mechanisms to Save Jobs and avoid Job Losses and a Decline in

Employment

mechanisms to provide alternative solutions and procedures for creating job security where job losses cannot be avoided; and

mechanisms to improve the social and economic impact on individuals, regions and economies when retrenchment or closure of the salt works is certain

At this stage, no financial provision is made for the above mentioned mechanisms and the promoter will need to ensure that sufficient provision is made for the management of such issues within the future iterations of the Salt Mine Closure Plan.

7.5 Financial Provisions for Closure

The financial provision for socio-economic effects should be structured to include:

7.5.1 Employee Costs:

provision for retrenchment (i.e. severance, leave days, etc)

new employment opportunities

retraining costs

7.5.2 Social Aspects

Social aspect deals with the sustainability of associated communities:

exit strategy (i.e. process by which the salt operation will cease to support

local initiatives)

social transition (i.e. support that will be provided to the community to transition to new economic activities)



7.5.3 Physical Rehabilitation

The infrastructure components that will be decommissioned and rehabilitation are: the salt crystallisers

all salt mine internal routes, dykes, walkways, etc

all fixed structures, i.e. wash plant, conveyor belts, etc

workshop, administrative office and ancillary support facilities

the effluent (bitterns) discharge piping

electrical connections (generator sets, containers, etc)

weighbridge & security office

scrap yard, access road, etc.

7.6 Post Closure Monitoring

Post-Closure monitoring and management should account for monitoring and management of pollution control. Depending on anticipated risks, post-closure monitoring should continue for a minimum period of at least five years.

7.7 Financial Provisions for Rehabilitation

The Minerals Policy of Namibia (1999) endorses the „polluter pays‟ principle

which places responsibility for pollution mitigation on the party that caused the

pollution. This principle is strengthened by the Mine Closure Framework (The

Chamber of Mines of Namibia, 2010) and IFC (IFC, 2007). It aims to ensure that

environmental liabilities do not remain with the government but that mechanisms

are put in place by mining companies to make sure that adequate financial

resources have accrued at the time of closure to cover these costs at a time

when revenue is no longer being generated.

CCS Management should review the closure plan on an annual basis and set

aside sufficient funds for the implementation of the closure plan. The costs

associated with the decommissioning strategies and the monitoring and

management program up to a period of five years post-closure (as prescribed by

IFC (2007) have been estimated.

7.8 Conclusions on the Closure Plan

This Closure Plan cannot anticipate all of the issues that will arise during the

projected life of the operation and therefore, it is not intended to be a definitive

closure prescription. This document does, however, provide an outline of the

closure process that may be undertaken. A detailed closure plan will be prepared

closer to the actual closure date, when the date of closure has been confirmed.



8.0 CONCLUSIONS

Although all possible actions and potential mitigation or management actions are

contained in this document, the EMP should be considered as a day-to-day

management tool. The EMP therefore sets out minimum environmental and

social standards that are required to minimise the negative impacts and maximize

the positive benefits of the salt operation proposed by CCS.

The EMP should be reviewed on an on-going basis and any changes or

amendments made communicated to MET. Based on the observations made

during the site inspections and issues raised by interested and affected parties

during the EIA process, CCS Management should be able to assess whether any

modifications to the procedures as proposed in this EMP may be required to

improve the overall efficiency and applicability of the EMP to its salt mining

operation.

mining licence 219 - gov

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