savanna marble cc - goveia.met.gov.na/screening/148_savanna environmental report final.… ·...

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ENVIRONMENTAL SCOPING AND MANAGEMENT PLAN FOR THE MINING AND

UPGRADING OF GRANITE VALUE ADDITION PLANT – RENEWAL OF MINING

LICENCE 152 IN ARANDIS, ERONGO REGION.

FOR

SAVANNA MARBLE CC

Prepared by

P. O. Box 70822, Khomasdal, Windhoek, Namibia.

+264 812 683 578

[email protected]

mailto:[email protected]

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PROJECT DETAILS

TITLE Environmental Scoping And Management Plan For

The Mining And Upgrading of Granite Value Addition

Plant – Renewal of Mining Licence 152 In Arandis,

Erongo Region.

TERMS OF REFERENCE

AND SCOPE OF THE PROJECT Savanna Marble CC

AUTHORS Outrun Consultants CC

CLIENT Savanna Marble CC

REPORT STATUS Final Report

DATE 11 February 2019

AUTHORISED SIGNATURE:

JOSIAH T. MUKUTIRI

EIA PRACTITIONER

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Table of Contents LIST OF ABBREVIATIONS .................................................................................................................... 8

EXECUTIVE SUMMARY ....................................................................................................................... 9

1. INTRODUCTION ........................................................................................................................ 11

1.1. Background ....................................................................................................................... 11

1.2. Benefits of the Proposed Project........................................................................................ 11

1.3. Terms of Reference and / or Scope of Work ....................................................................... 12

1.3.1. Activities carried out during the scoping phase ........................................................... 13

1.3.2. Activities carried out during the EIA process ............................................................... 13

1.4. Description of the Proposed Project .................................................................................. 14

1.4.1. Additions and Modifications to Upgrade the Granite Processing Facility ..................... 14

1.4.2. Construction of other Facilities for the well-being of Staff Members on Site................ 14

1.4.3. The Proposed Technology / Mining and Processing Methods .......................................... 16

2. METHODOLOGY ....................................................................................................................... 19

2.1. The Consultancy Team / Practitioner’s Details ................................................................... 19

2.2. Public Consultation and Stakeholder Engagement ............................................................. 20

2.2.1. Purpose of the Public Participation Process ................................................................. 20

2.2.2. Identification of Key Stakeholders ............................................................................... 20

2.2.3. Initiation of the Scoping Process ................................................................................. 21

2.2.4. Public Consultation ..................................................................................................... 21

2.2.5. Issues and Concerns Raised and Responses ................................................................. 22

2.2.6. Review Draft Scoping and Environmental Management Plan ...................................... 24

2.2.7. Public Participation: Way Forward .............................................................................. 24

2.2.8. Historical Stakeholder Engagement ............................................................................. 24

2.2.9. Stakeholder Engagement during the EIA Study ............................................................ 25

3. DESCRIPTION OF THE ENVIRONMENT ....................................................................................... 26

3.1. Project Location ................................................................................................................. 26

3.2. Climate .............................................................................................................................. 26

3.3. Wind Field ......................................................................................................................... 27

3.4. Topography ....................................................................................................................... 28

3.5. Soils and geology ............................................................................................................... 30

3.6. Radiation (safety issues) .................................................................................................... 30

3.7. Flora and Fauna ................................................................................................................. 31

3.8. Culture and Heritage ......................................................................................................... 34

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3.9. Existing Mine Infrastructure and Operational Activities as already in Existence .................. 35

3.10. Water .............................................................................................................................. 36

3.11. Energy ............................................................................................................................. 36

3.11.1. Potential Challenge ................................................................................................... 36

3.12. Accommodation and toilet facilities ................................................................................. 37

3.13. Current Land use, Stakeholder infrastructure / No go zones and the Unimpacted areas in

ML 152. ....................................................................................................................................... 37

4. ANALYSIS OF PROJECT ALTERNATIVES ...................................................................................... 39

4.1. The ‘No – Go’ Option ......................................................................................................... 39

4.2. Alternative Sites ................................................................................................................ 39

4.3. Strategic Alternatives......................................................................................................... 39

4.3.1. Road ........................................................................................................................... 39

4.3.2. Water ......................................................................................................................... 39

4.3.3. Electricity .................................................................................................................... 39

5. LEGAL AND POLICY REVIEW ...................................................................................................... 40

5.1. Summary of Regulatory Authorities and Permits Applicable to the Proposed Project ......... 44

6. IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES ................................................ 45

6.1. Hierarchy of hazards control measures .............................................................................. 45

6.1.1. Habitat Loss ................................................................................................................ 45

6.1.2. Visual Impacts ............................................................................................................. 46

6.1.3. Solid Waste ..................................................................................................................... 46

6.1.4. Occupational Health – Exposure to Dust ..................................................................... 46

6.1.5. Occupational Health and Safety – Incidents, Accidents / Injuries / Loss of Life ............. 48

7. ENVIRONMENTAL MANAGEMENT PLAN ................................................................................... 50

8. CONCLUSION, RECOMMENDATIONS AND WAY FORWARD ....................................................... 57

8.1. Conclusion ......................................................................................................................... 57

8.2. Recommendation .............................................................................................................. 57

8.3. Way Forward ..................................................................................................................... 58

8.4. History of stakeholder interactions (i.e. proof of good working relations) .......................... 60

8.5. Background Information and Invitation to Participate Document ....................................... 61

8.6. Advertisements ...................................................................... Error! Bookmark not defined.

8.7. List of IAPs .............................................................................. Error! Bookmark not defined.

8.8. Correspondence with IAPs ...................................................... Error! Bookmark not defined.

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8.9. Proponent’s Identification Documents, Founding Statement and Mining Licence ......... Error!

Bookmark not defined.

8.10. Consultant’s CV .................................................................... Error! Bookmark not defined.

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Figure 1: The EIA process followed during the study. ............................ Error! Bookmark not defined.

Figure 2: Block cutter used in the value addition facility. ................................................................. 14

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Table 1. Team of experts and their areas of responsibility in the EIA process. .................................. 19

Table 2: Applicable Legal Instruments, Permitting Authority and Current Status / ............................ 44

Table 3: Environmental Management Plan ...................................................................................... 51

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LIST OF ABBREVIATIONS Full name Acronym

Background Information Document BID

Environmental Impact Assessment EIA

Environmental Management Plan EMP

Interested & Affected Party IAP

Ministry of Environment & Tourism MET

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EXECUTIVE SUMMARY

The applicant, Savanna Marble CC is the mining licence holder of ML 152 granted for

a period running from the 5th of June in 2009 to 4th June 2019. At the time of the

granting of the licence only an internal EIA was done as all such projects were cleared

based on an environmental questionnaire submitted to the Ministry of Environment

and Tourism (MET) who would then issue an environmental contract. Over the years

Savanna Marble CC (Proponent) has been involved in mining and exporting of granite

blocks and partially processing slabs and tiles for further value addition. Slabs were

mostly transformed into table tops through further value addition in Windhoek. It is the

Proponent’s plan to prioritise production at the on site value addition plant and make

finished products such as tiles, slabs, curbstones, windowsills etc., which would form

the basis for the expansion of existing stone manufacturers, as well as for the

development of various new downstream businesses that can add further value to

Savanna Marble CC’s products.

Most significantly this processing activity will enable the Proponent to make use of a

large number of blocks that were rendered waste due to inconsistent colour or cracks

or any other reason that compromised the overall quality of the blocks. In a nutshell

this EIA study has been necessitated by the application for renewal of mining licence

ML 152 (due in June 2019) and the addition of Processing and Manufacturing

equipment on the existing facilities. This was enough to motivate for a comprehensive

Environmental Management Plan in compliance with the Environmental Management

Act (2007) which covers both the mining operations and value addition activities.

Outrun Consultants CC an independent consulting company, conducted the EIA

process for Savanna Marble CC. The EIA was conducted in 2 phases, the Scoping

Phase during which interested and affected parties were given the opportunity to

comment on the granite mining and processing activities. Comments received during

the scoping exercise were incorporated. The second phase gave rise to the draft

environmental scoping and management report which was shared with stakeholders

for their inputs. The mining and processing activities in Erongo Region pose potential

environmental damage in the form of destruction of the landscape and aesthetic view

of the desert and disturbance of the natural environment. There are indigenous plants

of interest which the Namibia Botanical Garden could relocate and propagate if the

need arise, however at this stage none of the sensitive areas containing protected

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plants or of historical, cultural & heritage significance fall within the target zones for

mining or processing activities. The predicted environmental impacts can be managed

resulting in minimal or insignificant residual effects through the successful

implementation of the proposed Environmental Management Plan. Specific

instructions have been formulated as part of the EMP.

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1. INTRODUCTION

1.1. Background


a period running from the 5th of June in 2009 to June 2019. At the time of the granting

of the mining licence only an internal EIA was done as all such projects were cleared

based on an environmental questionnaire submitted to the Ministry of Environment

and Tourism (MET) who would then issue an environmental contract. Over the years



mostly transformed into table tops through further value addition in Windhoek. It is in

the Proponent’s plans to upgrade the value addition plant and make finished products

such as tiles, slabs, curbstones, windowsills etc., which would form the basis for the

expansion of existing stone manufacturers, as well as for the development of various

new downstream businesses that can add further value to Savanna Marble CC’s

products.




this EIA study has been necessitated by the following:

a. Renewal of mining licence ML 152.

b. Change of operations due to the inclusion of Processing and Manufacturing

activities for the purpose of local value addition and reduction of waste.

c. Development of a comprehensive Environmental Management Plan in

compliance with the Environmental Management Act (2007) which covers both

the mining operations and value addition activities.

1.2. Benefits of the Proposed Project

The benefits of the renewal of ML 152 and the proposed expansion and upgrading of

the granite manufacturing and processing facility can be summarised as follows:

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• Employment creation, subject to full capacity being reached, up to 30

permanent work postitions can be created considering that manpower will be

required to mine the granite blocks, processing of granite blocks into finished

products (cutting and polishing plant), packing, despatch and transportation.

• Downstream industries will also benefit from the availability of raw material

(granite blocks) and finished products for use in the construction industry.

• Environmentally, all the blocks on site which were rendered waste due to quality

inconsistencies will be processed into finished products.

1.3. Terms of Reference and / or Scope of Work

Savanna Marble CC appointed Outrun Consultants cc to conduct the Environmental

Impact Assessment. The EIA was carried out in 2 phases, the scoping phase and the

full EIA study.

The EIA study took consideration of:

• Due consultation with the applicant and interested and affected parties.

• Reviewed current development / activity at the local level.

• Identification of legal framework governing assessment.

• Identification of the nature of site.

• Identification through scoping and on – site evaluation of issues relating to the

proposed development and its potential impacts on site.

• Methodology of assessing potential impacts.

• Information relating to public participation process.

• Plan of study for assessment of impacts / issues.

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Bio physical, social and economic aspects formed part of the EIA study and guided

the Consultants during the study. Mitigation strategies and a complete environmental

management plan were developed as part of the EIA study. Alternatives including the

“no go” option were explored. The following activities were undertaken during the

scoping and detailed EIA phases:

1.3.1. Activities carried out during the scoping phase

The scoping process undertaken includes the following activities:

• Policy and legislation relevant to the establishment of a quarry and crusher.

• Description of the proposed project

• Description of the affected environment

• The public participation process

• A detailed description of the potential impacts associated with the proposed

project

• Evaluation of the significance of the potential impacts.

• Evaluation of whether a full EIA is required or an Environmental Management

Plan only.

• Submission of the final scoping report to MET: DEA for consideration and

decision making.

1.3.2. Activities carried out during the EIA process

The EIA study covered the following areas in detail:

• Detailed project description

• Public consultation and a register of issues raised

• Identification of the possible and known impacts of the project

• Detailed analysis of the impacts

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• Review of relevant policies and legislation and the development of a legislative

framework compliance plan

• Development of an Environmental Management Plan (EMP) with workable

mitigation measures for adoption.

1.4. Description of the Proposed Project

1.4.1. Additions and Modifications to Upgrade the Granite Processing Facility

The project is focused on upgrading and operating the granite cutting and polishing

facility. This entails extending the floor line for the various product lines as well as a

packing and dispatch area. Associated planned activities include the construction of

the ablutions, showers and canteen.

1.4.2. Construction of other Facilities for the well-being of Staff Members on Site

Staff canteen:

The staff canteen will comprise of a pantry for storing food stocks, a kitchen and

seating hall.

Figure 1: Existing Block cutter used in the value addition process.

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Ablutions and showers:

Dixy toilets catering for twenty people will be used and serviced by an external

contractor. Showers will be installed to serve the same number of people but the grey

water will be used to feed a syphon growing melons and other vegetables.

• Description of a Toi Toi Dixi toilet, Operation and Maintenance

The facility comprises of a 5 m3 waste water tank fitted with a sanitary cabin mounted

on top. The waste water tank can be drained when full and the waste disposed of at a

municipal facility (Arandis). The Proponent is advised to negotiate with Arandis Town

Council to obtain a permit authorizing the Proponent to use Town Council facilities for

waste disposal.

Figure 2: A typical Toi Toi Dixi toilet cabin.

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Figure 3: Container toilet type mounted on a ten cubic meter waste water tank.

Operational and / or Working Hours

The Proponent has planned to operate both the mining and the cutting and polishing

plant during normal working hours of the day, (excludes night shift).

Refurbishment and plant adaptations

Existing processing equipment was imported in 2012 and was kept under maintenance

until 2016. Trial production and run-in of the plant commenced after assembly in 2016.

Rehabilitation and mine closure:

Rehabilitation and mine closure plans will only be developed in the future based on

the status quo at the time. Crafting a rehabilitation and closure plan based on predicted

scenario will be inaccurate.

1.4.3. The Proposed Technology / Mining and Processing Methods

Dimension stone mining involves purely physical processes of cutting the granite

blocks, sorting and dispatch to the on-site processing plant for local value addition or

to Walvis Bay for export. The process can be described by the following key

processes:

• Granite block delineation

• Mining

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• Product sorting by Quality

• Product handling and Despatch

1.4.3.1. Granite block delineation

Granite blocks are marked on the ground by distinct parallel lines. A jack hammer is

used to drill 0.5m holes along the lines for a permanent demarcation of the blocks.

Currently the blocks are marked strip by strip moving down and also away from

recently mined out areas.

1.4.3.2. Mining

The mining process follows on the demarcated blocks. A Circular saw is placed on

tracks along the marked lines, it cuts vertically following the marked lines moving along

a track that is rigged on-site as the cutting progresses. The horizontal cutting of the

block is done by a rubberised diamond wire that is powered by a generator. The wire

cuts at the base of the block in a horizontal manner. The cut out block is then uplifted

by a forklift to the sorting area. The mine has a capacity to produce 100 granite blocks

per month with each block weighing and average of 15 tonnes.

1.4.3.3. Product Sorting by Quality

The blocks are then sorted out by quality; this is done merely by visual inspection of

the colour of the blocks by trained and experienced personnel. The quality sorting is

dependent on the market demand of the time which is driven by a desire for a specific

colour. The block that do not meet the market colour requirements are put aside in

anticipation of a future demand for that colour. All the blocks are marked using an in-

house numbering system that allows for block inventory and tracking of the blocks

through the processing chain.

1.4.3.4. Processing

The mine blocks are processed to various specifications as dictated by the clients’

needs:

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• Processing – Semi processed slabs (Material strips of various lengths and

thicknesses) for supply to local processors for further value addition;

• Project specific products that are cut to size according to requirements and;

• Finished products – Tiles and cladding

1.4.3.5. Product handling and despatch

The blocks that do not meet current market demands are stockpiled onsite and the

blocks that are meant for the market are processed as required and transported to the

loading bay where they are loaded onto trucks before transporting to destination

markets.

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2. METHODOLOGY

2.1. The Consultancy Team / Practitioner’s Details

Outrun Consultants CC is a privately owned consultancy company doing various

projects in Southern Africa Development Community (SADC) countries. Our core

services are:

• Environmental Impact Assessment

• Environmental Investigations

• Research and Training

• Feasibility Studies

• Agronomy

• Monitoring and Evaluation

Outrun draws its experts from regional and international universities such as University

of Zimbabwe (Zimbabwe), National University of Science and Technology (Zimbabwe,

Namibia), University of Namibia (Namibia) and other specialized consulting

companies and / or individuals. Outrun declares that we have no interests in this

project and are independent and acted as such during the EIA process as required by

the EIA regulations. The key team members who carried out this EIA are presented in

Table 1 below.

Table 1. Team of experts and their areas of responsibility in the EIA process.

ORGANIZATION AREA OF

RESPONSIBILITY /

FIELD OF EXPERTISE

TEAM MEMBERS

OUTRUN Project management

EIA coordination

Josiah T. Mukutiri

OUTRUN EIA process Josiah T. Mukutiri

Savanna Marble CC Development of the

business concept

Mark Hoffmann

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OUTRUN Literature review / Desk

study

Emmerencia Montzinger

OUTRUN Legislation & Policy

Review


OUTRUN Biodiversity Study Josiah T. Mukutiri,


OUTRUN Development of

Environmental

Management Plan (EMP)

Josiah T. Mukutiri

OUTRUN Public Consultation and

Facilitation

Phillip Hooks, Josiah T.

Mukutiri, and Mark

Hoffmann

N.B. Abridged CVs of key Team Members are annexed at end of the report.

2.2. Public Consultation and Stakeholder Engagement

2.2.1. Purpose of the Public Participation Process

The purpose of the public participation process is to:

• Provide information to IAPs and other stakeholders about the project

background, proposed site, project concept and predicted potential impacts.

• Establish the public’s interests, concerns and expectations regarding the

proposed project.

• Obtain input from IAPs, the public and other key stakeholders.

2.2.2. Identification of Key Stakeholders

The following key stakeholders were identified for consultation purposes:

• Namibia Botanical Gardens CC

• Goanikontes Oasis Rest Camp

• Ministry of Mines & Energy

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• Ministry of Environment & Tourism

• Civil Society Organisation

• Other members with interest or affected by the project.

2.2.3. Initiation of the Scoping Process

The scoping process was initiated by publicising it through the local media in which

we published legal notices informing readers of the EIA. The legal notices announced

the beginning of the scoping process and invited stakeholders and members of the

public to register as IAP as well as participation in public meetings. The legal notice

was also made into A3 posters displayed in public and popular gathering places such

as the school, shops and along the highway next to the site etc. See Annexure 2 for

the advertisements and poster. A Background Information Document (BID), see

attached copy in Annexure 3, was forwarded to I&APs who responded. The BID

contained the relevant information about the proposed project and promoted

stakeholders and public participation in the scoping process. A comment sheet was

provided at the end of the BID report inviting comments on issues of interest and

importance to the stakeholders.

2.2.4. Public Consultation

A meeting was held at Swakopmund High School Hall on the of….and . The meeting

was designed to give the stakeholders details regarding the project and the EIA

process being followed. Phillip Hooks facilitated the meeting.

The members present were given the chance to say their interests or concerns

regarding the project. Communication was interactive and two languages used

(English and Afrikaans). All the factors identified during the environmental scoping

phase were studied during the EIA and used to generate the draft Environmental

Scoping and Management Plan. The draft report was publicised and shared with

registered I&APs. All the issues and concerns raised are presented below. Records of

all consultations are also attached as annexures for this report.

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2.2.5. Issues and Concerns Raised and Responses

Records of all registered IAPs and stakeholders and the issues, concerns and

comments on the proposed project were compiled and are attached as annexure in

this report. Below is a summary of issues raised during the meeting and interviews:

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Table 2: Issues and / or concerns raised during consultations by category.

Subject Issues and / or Concerns raised

EIA PROCESS • Attendance at the public meeting was very poor but issues raised were genuine and

were considered in shaping the study in order to keep environmental damage under

control, (attendance register annexed).

CULTURE AND

HERITAGE

• Destruction of the old Germany railway line passing through the area.

BIODIVERSITY • Extensive flora is expected to occur in the targeted area, especially the dolerite ridge.

POTENTIAL NEGATIVE

IMPACTS

• Air pollution from dust generated by various activities ranging from mining blocks,

cutting and polishing blocks, vehicle movements on gravel

POSITIVE IMPACTS • Reduction and partial elimination of granite waste.

• Employment creation and thus improve the well-being of the local people. Employment

preference will be afforded to previously disadvantaged Namibians.

• Supply of raw materials and processed materials to downstream industry for economic

growth. Such industries include but are not limited to the construction industries etc.

• A contribution to the balance of payments through exports.

• Local Value addition allowing for the processing of blocks (waste) that cannot be sold

as complete blocks.

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2.2.6. Review Draft Scoping and Environmental Management Plan

The draft reports availability was published din the local media inviting reviewing and

commenting.

2.2.7. Public Participation: Way Forward

The comments on the reports were incorporated into the final Scoping Report and the

final Environmental Report respectively before submission to the MET: DEA. MET:

DEA’s decision regarding the EIA report will be made available to all IAPs.

2.2.8. Historical Stakeholder Engagement

Organisation Activity / Issue Status Quo

Erongo Red Connection to the grid On going relationship for

future connection although

the Proponent uses diesel

powered generators at the

moment

NAMWATER Connection to the

water pipeline

Completed

MET Environmental contract Environmental Pro-forma

Contract submitted to MET

MET EMA Act 2007,

Compliance

Environmental Scoping &

Management Plan will be

submitted to MET to renew

the existing Mining License.

MET Mad Marx movie

making

Joint effort with Swakop

Uranium to concertize MET

on the impact resulting from

the movie making activities.

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2.2.9. Stakeholder Engagement during the EIA Study

Only two key stakeholders were engaged and their comments incorporated:

• Namibia Botanical Gardens CC represented by Mr Frank Lohnert.

• Ministry of Environment & Tourism represented by Parks Warden - Mr Siegfried

Gawiseb.

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3. DESCRIPTION OF THE ENVIRONMENT

3.1. Project Location

The project site is located in the Arandis area running adjacent and parallel to the B2

Highway with the D1991 gravel connecting from the B2 and cutting through the SW

side of the site.

Figure 4: The location of the project site (ML 152) in relation to existing infrastructure, protected areas and other mines. Source: Map by Outrun Consultants CC.

3.2. Climate

Climate refers to the meteorological or weather elements measured in a particular

region or area over a long period of time of 20 to 30 years. The climate of an area is

generally affected by the latitude, terrain, altitude and distance or proximity to water

bodies. Climatic knowledge about an area is important because it shapes human

activities of the people inhabiting the area. This is because climatic factors such as

rainfall and temperature affects geomorphology, weathering and soil formation,

transport of materials, flora and fauna and the use of natural resources, (Bertram and

Broman, 1999). Erongo region climate is predominantly arid and characterized by:

• Very low rainfall, averaging about 300mm in the north eastern parts of the

region and less than 15mm to the coast;

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• Very high variability in total annual rainfall;

• A steep rainfall gradient from the coast towards the eastern parts of the region

(wetter / receives more rainfall).

3.3. Wind Field

The wind regimes are characterized by southerly and south westerly winds during

summer, and the north easterly winds during winter. The data was obtained from the

weather station: Coastal Met (Station ID: E7631) comprised of the following

specifications:

Table 3: Coastal Met weather station specifications.

Parameter Sensor Type Height

Temperature/Humidity Campbell CS 215 2 m

Wind Young Model 05103 Wind Monitor 9 m

Radiation Campbell NR-Lite 2 m

Ground Temperature and Moisture Campbell CS 655 n.a.

Barometric Pressure Setra 100 n.a.

Leaf Wetness Campbell CS 237 0.1 m

Rain Young Model 52202 Tipping Bucket Rain Gauge 1.5 m

Data Logger Campbell CR1000 n.a.

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Figure 5: Wind directions and speeds from the nearest weather station in Erongo Region.

3.4. Topography

The topography rises from the sea level in the western coast line of the country towards

the east and north eastern parts of the region. The study area lies in the Namib Desert

which is characterized by open sandy plains and rising mountains and dry river beds

heavily silted with sand. Soils become coarser into gravel in the foot of the hills. The

variability in plant substrates in chemical composition and texture dictates the

occurrence of differing plants in these areas.

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Figure 6: The Rossing Mountain view to the North West of ML 152.

Figure 7: The Eastern entrance to ML 152 using D1992.

Figure 8: Goanekontes road, South West view from ML 152.

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3.5. Soils and geology

The Swakop Group in the southern part of the study area (Central Zone) is subdivided

into the Rössing, Chuos, Arandis, Karibib and Kuiseb Formations. The marble-

dominated Karibib Formation is widely distributed in the study area and underlies large

parts of the flat, poorly exposed coastal region.

Figure 9: An eroded dolerite ridge passing through the study area.

3.6. Radiation (safety issues)

Ionising radiation on the other hand is associated with high-energy x-rays and gamma

rays, and the various types of radiation emitted by radioactive elements. Ionising

radiation has sufficient energy to strip electrons from atoms, resulting in electrically

charged particles which are called ions. It has long been recognised that large doses

of ionising radiation can damage human cells and tissue: free-roaming ions created at

the cellular level are highly reactive and may trigger or participate in chemical

reactions, some of which may bring about molecular bonds which are harmful to the

cell. For example, chemical reactions that are activated by ions generated by ionising

radiation can alter the chemical balance of natural processes, which may give rise to

undesirable chemical products and thereby negatively affect living cells. In addition,

ionising radiation can change the make-up of cells by changing the genetic building

blocks of cells and in this way bring about cancerous cell multiplication and growth.

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Not all atomic nuclei found in nature are stable. When unstable nuclei undergo a

process of nuclear rearrangement they emit particles and radiation. The process

whereby radiation is emitted from atomic nuclei as a result of nuclear instability is

called radioactivity. The most common types of sub-atomic particles and radiation

emitted during radioactive decays of atomic nuclei are alpha particles, beta particles

and gamma radiation. Radioactivity is a natural phenomenon, and elements such as

uranium, thorium and potassium are naturally occurring radioactive substances.

Radioactivity and the effects of ionising radiation on living tissue have been studied

for many decades. Today it is well recognised that an exposure to large doses of

ionising radiation may have potentially damaging effects on humans. Natural sources

of ionising radiation include radiation of extra-terrestrial origin, i.e. cosmic radiation,

and radiation emitted by soils, rocks and groundwater, i.e. terrestrial radiation, as well

as radiation from radioactive dust and radioactive gases such as radon and thoron.

Humans are continuously exposed to ionising radiation of natural and man-made

origin. Such exposure is location- and time-dependent, and any potential effects

depend on the exposure dose received by an individual person. To quantify the total

exposure to ionising radiation that members of the public are exposed to one has to

determine the magnitude of the exposure to the prevailing natural background

radiation and add to it the incremental contribution of additional sources, such as a

uranium mine.

3.7. Flora and Fauna

Plant communities in the study area are influenced by numerous factors: soil type,

climate, topography etc. Main habitats visible on ML512 are gravel plains, flood or

drainage plains and watershed dolerites. One ephemeral river drains through the study

area.

One ridge was identified and it cuts through at a SW to NE orientation with visible

weathered dolerite boulders. Plants of conservation importance are the aloes (Aloe

sperrfolia and Aloe namibensis), stone plants (Lithops gracilidelimeata and Lithops

ruschiorum). The Trichocaulou peclicellatum is also common in these grounds. It is

not surprising to find lichens on the weathered dolerite ridges being the pioneer

colonizers in newly available habitats. These are an ecologically important group of

species: food for the beetles and springboks, protection to insects and mites though

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they are very sensitive to damage and climatic changes. Over and above they offer

very unique aesthetics.

Table 4: Some of the plant species observed in the study site.

Image Name

Caloplaca spp Lichens

Aloe asiperifolia

Zygophyllum stapffii

Zygophyllum sp.

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Pencil bush

Acacia sp.

Euphorbia gregaria

Zygophyllum sp.

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Table 5: Some of the plant species expected to occur in the study area and their conservation status.

Scientific name Common name Status

Heliotropium curassavicum Seaside heliotrope DD

Aristida adscensionis Sixweeks threeawn DD

Cyperus marginatus Desert sedge DD

Sarcocornia natalensis No known common name DD

Zygophyllum simplex Brakkies DD

Acacia reficiens Red bark acacia / Red thorn DD

Citrullus ecirrhosus Desert gourd / Wild melon DD

Orthanthera albida Sandmelketou DD

Blepharis grossa Little desert thistle NE

Stipagrostis obtusa growwe twa LC

Stipagrotis ciliata Tall bushman’s grass DD

Adenolobus pechuellii Namib neat’s foot DD

Pechuel – Loeschea leubnitziae

Wild sage DD

Hermannia amabilis

Dream catcher DD

Tribulus zeyheri Large – flowered devil thorns /

Calthrop

DD

Heliotropium tubulosum Erysipela plant DD

Acacia erioloba Camelthorn Protected (F)

Acacia albida , White thorn Protected (F)

Faidherbia albida Apple ring acacia Protected (F)

Acanthosicyos horrida Nara bush DD

Commiphora saxicola Rock cockwood E

Commiphora virgata Slender cockwood E

Sarcocaulon marlothii Bushman’s candle DD

Schmidtia kalihariensis Kalahari sour grass LC

Aloe asperifolia E, P, LC, C2

Ipomea adenioides Morning Glory DD

Parkinsonia Africana Green hair thorn DD

Ophioglussum polyphyllum Large adderstongue DD

3.8. Culture and Heritage

Cultural heritage refers to the legacy of phsical artifacts and intangible attributes of the

Namibian society that are inherited from past generations, maintained in the present

and bestowed for the benefit of future generations. Cultural heritage includes tangible

culture (such as buildings, monuments, landscapes, books, works of art, and artifacts),

35

intangible culture (such as folklore, traditions, language, and knowledge), and natural

heritage (including culturally-significant landscapes, and biodiversity).

Cultural heritage is often unique and irreplaceable, which places the responsibility of

preservation on the current generation. Smaller objects such as artworks and other

cultural masterpieces are collected in museums and art galleries. One such piece of

history that is of cultural and heritage importance is the old railway line that cuts

through parts of the mining licence area.

Figure 10: Remains of the 100 year old "staats lyn" or railway line route and mound that runs through ML 152. Source: Own photographs.

3.9. Existing Mine Infrastructure and Operational Activities as already

in Existence

There is an existing mine pit from which granite blocks were extracted over the years.

In addition there is a granite cutting and polishing plant mounted on concrete

foundations and shaded under a roof constructed from corrugated iron sheets fixed on

iron beams. Concrete floors serve as storage, value addition and general maintenance

areas. Water and electricity are available onsite as detailed under sections 3.10 and

3.11 below.

36

3.10. Water

Water is tapped from the main pipeline supplying the Uranium mines in the area. Daily

water consumption during full production would be ten cubic meters per day. However,

most of this water is recycled, and up to 80 % of the water used for cutting can be

retained, so that water consumption is reduced significantly. Water is mainly used for

the cutting process with diamond cutting blades and diamond wires. It is also used to

completely suppress any dust development during the cutting process. Water loss is

predominantly through evaporation, no infiltration is expected since the pond was cut

out from the solid granite formation.

Figure 11: Stakeholders infrastructure, NAMWATER pipeline running through ML 152 and NAMPOWER substation adjacent to the site.

3.11. Energy

All the electrical equipment at the mine is powered by diesel generated electricity.

Diesel is stored on-site using an above ground storage tank from which other mobile

equipment also fuels. Should there be need to get electricity connection to the national

grid in the future then the necessary procedures will have to be followed. It is an option

that cannot be ruled out if there is need and the powerline is within reach. The

Proponent does not plan a connection to the grid at the moment.

3.11.1. Potential Challenge

37

The EIA study will investigate the suitability of the fuel storage site in relation to other

mining operations taking into consideration the environment, occupational health and

safety. Spills and leaks of hydrocarbons impact negatively on the environment.

3.12. Accommodation and toilet facilities

Mine and processing plant workers will be accommodated in Arandis and

Swakopmund. Accommodation facilities in the form of movable containers on the mine

site are solely for accommodating security personnel and site managers if required.

The following facilities will be erected on the mine site for the well-being of the

employees:

a. Staff canteen: The staff canteen will comprise of a pantry for storing food

stocks, a kitchen and seating hall.

b. Ablutions and showers: Dixy toilets catering for twenty people will be used and

serviced by an external contractor. Showers will be installed to serve the same

number of people but the grey water will be used to feed a sypon growing

melons and other vegetables.

3.13. Current Land use, Stakeholder infrastructure / No go zones and

the Unimpacted areas in ML 152.

As can be shown on the map below: areas containing NAMWATER and NAMPOWER

infrastructure will not be disturbed in any way during mining and / or associated

activities. In addition the dolerite ridges are weathered and for that reason are not

suitable mining target and as a result will not be affected.

38

Figure 12: Mining target area, long -term future mining reserve and areas and no-go areas.

39

4. ANALYSIS OF PROJECT ALTERNATIVES

4.1. The ‘No – Go’ Option

The “no-go” option means maintaining the status quo were neither the mining licence

is renewed nor upgrading of the cutting and polishing facility takes place. This would

mean decommissioning the mine and stopping operations. Such a situation is not

favoured as it means no development and lack of employment opportunities for the

local people. All the blocks that were rendered waste would remain as an eyesore to

passers-by. As a result this is not in favour of the environment. This option was also

not studied more since the mine was commissioned and has been kept active in the

market during the past 9 years with a strong focus on developing the market interest

for future processed goods.

4.2. Alternative Sites

No alternative mining sites were considered in this study except for the current site

where ML152 was issued and contains the existing facilities.

4.3. Strategic Alternatives

4.3.1. Road

The proposed site is very accessible through a gravel road branching off from the B2

Highway. The site is accessible using this existing road and as a result no new access

road will be built.

4.3.2. Water

The site is connected to the main pipeline supplying water to the Uranium Mines.

4.3.3. Electricity

The Proponent uses diesel generators, but there is an electricity sub-station close-by

that brings electricity to the Uranium mines. In the event that the Proponent decides

to use this source to complement the generators in-future, then relevant permits

should be obtained from MME as well as from NAMPOWER.

40

5. LEGAL AND POLICY REVIEW Describes Legal and Policy Instruments Regulating the Proposed Project Activities.

41

LEGAL / POLICY INSTRUMENT INTERPRETATION

Constitution of the Republic of Namibia, 1990.

The Constitution is the supreme law in Namibia, providing for the establishment of the main

organs of state as well as guaranteeing various fundamental rights and freedoms. Provisions

relating to the environment are contained in Chapter 11, article 95, which is entitled “promotion

of the Welfare of the People”. This article states that the Republic of Namibia shall – “actively

promote and maintain the welfare of the people by adopting, inter alia, policies aimed at …

maintenance of ecosystems, essential ecological processes and biological diversity of Namibia

and utilisation of living natural resources on a sustainable basis for all Namibians, both present

and future; in particular, the Government shall provide measures against the dumping or recycling

of foreign nuclear waste on Namibian territory.”

Minerals (Prospecting and Mining) Act, 1992.

The Minerals Act governs minerals prospecting and mining. The Act provides for the

reconnaissance, prospecting and mining for, and disposal of, and the exercise of control over

minerals in Namibia; and to provide for matters incidental thereto. A new Minerals Bills is

currently under preparation.

Minerals Policy 2004. The Minerals Policy is developed to ensure long-term sustainable growth in the mining sector of

Namibia. One of the objectives of the Policy, relevant to EIAs is to ensure compliance with

national environmental policy and other relevant policies to develop a sustainable mining

industry.

Environmental Management Act (2007)

The purpose of the Act is to give effect to Article 95(l) and 91(c) of the Namibian Constitution by

establishing general principles for the management of the environment and natural resources;

to promote the co-ordinated and integrated management of the environment; to give statutory

42

effect to Namibia’s Environmental Assessment Policy; to enable the Minister of Environment

and Tourism to give effect to Namibia’s obligations under international conventions. In terms of

the legislation it will be possible to exercise control over certain listed development activities

and activities within defined sensitive areas. The listed activities in sensitive areas require an

Environmental Assessment to be completed before a decision to permit development can be

taken. The legislation describes the circumstances requiring Environmental Assessments.

Hazardous Substance Ordinance 14 of 1974.

Provisions for hazardous waste are amended in this act as it provides “for the control of

substances which may cause injury or ill-health to or death of human beings by reason of their

toxic, corrosive, irritant, strongly sensitizing or flammable nature or the generation of pressure

thereby in certain circumstances; to provide for the prohibition and control of the importation,

sale, use, operation, application, modification, disposal or dumping of such substance; and to

provide for matters connected therewith”

Atmospheric Pollution Prevention Ordinance

11 of 1976.

This regulation sets out principles for the prevention of the pollution of the atmosphere and for

matters incidental thereto. Preventative measures for dust atmospheric pollution are outlined in

Part IV and Part V outlines provisions for Atmospheric pollution by gases emitted by vehicles.

The Nature Conservation Ordinance,

Ordinance 4 of 1975.

This Ordinance covers game parks and nature reserves, the hunting and protection of wild

animals (including game birds), problem animals, fish and the protection of indigenous plants.

Parks and Wildlife Management Bill of 2006.

The act enacts the legal framework, to provide for and promote the maintenance of ecosystems,

essential ecological processes and the biological diversity of Namibia, and the utilisation of living

natural resources on a sustainable basis for the benefit of Namibians, both present and future,

43

and to promote harmonious and mutually beneficial co-existence of humans with wildlife, to give

effect to Namibian’s obligations under relevant international legal instruments including the

Convention of Biological Diversity. Provisions with regard to declaration of protected areas, entry

into and residence are made in chapter V. Regulations on the protection of species of wildlife and

plants are provided in Chapter VII of the Act.

The Labour Act, 2007 (Act No. 11 of 2007)

The labour Act gives effect to the constitutional commitment of Article 95 (11), to promote and

maintain the welfare of the people. This Act is aimed at establishing a comprehensive labour

law for all employees; to entrench fundamental labour rights and protections; to regulate basic

terms and conditions of employment; to ensure the health, safety and welfare of employees

under which provisions are made in chapter 4. Chapter 5 of the act improvises on the protection

of employees from unfair labour practice.

Petroleum (Exploration and Production) Act

1991 (Act 2 of 1991)

This Act provides provisions for possible petroleum exploration as to provide for the

reconnaissance, exploration, production and disposal of, and the exercise of control over storage

of refined petroleum products; and to provide for matters incidental thereto.

Pollution Control and Waste Management Bill

The purpose of this Bill is to regulate and prevent discharge of pollutants to the air, water and

land in Namibia, and to enable the country to fulfil its international obligations in the regard. The

draft Bill forbids any person from discharging or disposing of pollutants into any water or water

course without a water pollution licence (aside from the discharge of domestic waste from a

private dwelling or the discharge of pollutants or waste to a sewer or sewage treatment works).

44

5.1. Summary of Regulatory Authorities and Permits Applicable to the

Proposed Project

The environmental regulatory authorities responsible for environmental protection and

management in relation to marble mining including their role in regulating

environmental protection are presented below. The table shows an extract from the

legal instruments of the regulating authorities with respect to relevant permits and / or

licences required for the renewal of the mining licence and the upgrading of the cutting

and polishing facility.

Table 6: Applicable Legal Instruments, Permitting Authority and Current Status /

Legal Instrument Authority Status

Ministry of Mines &

Energy (MME)

To apply for renewal of Mining

Licence when the

Environmental Clearance

Certificate has been issued.

Forestry Act, 12 of 2001. Ministry of Agriculture,

Water & Forestry

(MAWF).

Removal, disturbance of

Protected plants. Not

anticipated since the targeted

areas have no plant cover.

Petroleum (Exploration &

Production) Act 1991 (Act

2 of 1991).

Ministry of Mines and

Energy (MME).

Discarding or

disposing of used oil.

To Apply when

Required

Regulation 16 (2001)

Petroleum Regulations.

Operating a petroleum

consumer installation.

To apply when EIA clearance

certificate is issued.

45

6. IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES

6.1. Hierarchy of hazards control measures

Hazard controls should be applied in this order:

a. Elimination— remove the hazard, or the need to perform the hazardous activity;

b. Substitution— substitute with a safer alternative;

c. Separation/isolation— isolate or separate people from the hazard by use of

barriers, distance or time;

d. Engineering controls— redesign or modify tools or equipment and / or process

flow;.

e. Administrative controls— se training, rules, procedures to reduce the risk of the

hazard and;

f. Personal protective equipment— provide fit-for-purpose protective equipment.

More than one control may need to be used to adequately control the hazard. Controls

used must be maintained to ensure they continue to remain effective.

6.1.1. Habitat Loss

If the entire current project area is developed, combined with land preparation

destructive methods there would be a very high loss, which virtually guarantees some

extinction.

Proposed Mitigation Measures

However, if plans are built to prevent substrate / habitat destruction, the direct habitat

loss will be greatly reduced. Destruction is avoidable since the targeted mining area

and the extension of the processing area is on a previously disturbed area, that

comprises mainly of barren solid stone outcrops.. This impact is rated as High

negative, which can be mitigated to low negative. Importantly the mining targets intact

dimension stone and the weathered dolerite which are the primary lichen habitats are

not suitable for mining, see fig. 12, above.

46

6.1.2. Visual Impacts

Although the mining facility is located on a fairly flat land it is not intrusively visible from

the B 2 and Goanekontes road due to distance.


The colour of the cut stone blends well with the local environment to reduce contrast.

Over time the processing of all blocks that are not exported as well as waste blocks

will eliminate the visual impact permanently.

6.1.3. Solid Waste

Major composition of solid waste generated from the mining process is blocks that fail

to meet the quality due to inconsistent strength arising from cracks and inconsistent

colour etc.


Process all the blocks that could not sold during the previous mining operations and

was rendered waste due to quality inconsistencies.

Perform test cuts before cutting out entire blocks in order to avoid mining unusable

rock material.

6.1.4. Occupational Health – Exposure to Dust


6.1.4.1. Elimination

• Adopt production processes that generate less dust (any wet method is

likely to generate less dust than a dry one).

• Treat the dust at its point of generation, as this is more effective than

capturing airborne dust.

• Treat the dust on its transmission path using dust suppression techniques

(e.g. water sprays, chemical additives, local exhaust ventilation (LEV),

vacuum).

47

6.1.4.2. Engineering controls

• Choose appropriate equipment (e.g. correct cutting blades for ore body).

• Replace and maintain equipment regularly to ensure cutting blades and

picks remain sharp.

• Suppress dust by using water sprays on work area, roads, and when using

machinery and cutting equipment. Use additive in water sprays to suppress

dust and adjust the droplet size of the spray according to dust particle size.

• Use enclosures (e.g. covered conveyors, enclosed cabs on vehicles, plant

and equipment).

• Rehabilitate exposed mine land to reduce environmental dust load.

• Enclose cabins where possible, ensure seals are well-maintained, provide

inlet air filtration for respirable particles, and use positive pressure air inside

cabs to prevent dust penetration.

• Cover product conveyors.

• Cover loads for road haulage where practicable.

6.1.4.3. Administrative controls

• Ensure regular maintenance and housekeeping of vehicles and mine

workings.

• Position personnel away from dust-generating activity by establishing

exclusion zones.

• Maintain unmade roads and ensure ground conditions throughout sites are

appropriate to the machines using them.

• Provide training and information to workers on the hazards, risks and

controls of dusty tasks, as well as supervision for workers.

• Limit the duration and magnitude of exposure to dust (e.g. worker rotation,

job task changes).

• Ensure work schedules have adequate rest periods to limit exposure.

• Change the location of dumping operations or modify blasting programs to

suit weather conditions.

• Provide adequate signage.

48

6.1.4.4. Personal protective equipment (PPE)

• Ensure higher-order controls are adopted before resorting to PPE.

• Select the most appropriate respiratory protection for the task (e.g. full face,

half face, powered air, purifying).

• Ensure training, comfort and fit testing is provided before use. Respirators

should not be shared.

• Maintain and store respiratory protective equipment properly.

6.1.5. Occupational Health and Safety – Incidents, Accidents / Injuries / Loss of Life


There are multiple factors that influence the effectiveness of your work health and

safety and injury management systems, including:

• your employees;

• your organisation's safety culture and safety management systems;

• the type of hazards in your workplace;

• How your organisation manages risks.

6.1.5.1. Consultation with employees and other participatory action methods

Consultation between employer and workers is a legal requirement under the Labour

Act (2012), and an essential part of managing health and safety risks. A safe

workplace is more easily achieved when everyone involved communicates with each

other to identify hazards and risks, talks about health and safety concerns and works

together to find solutions. By enabling workers to share their knowledge and

experience, better informed decisions can be made about work safety.

Other benefits from worker health and safety involvement / consultations are:

• greater awareness and commitment – workers who have been actively involved

in how health and safety decisions are made understand the decisions better.

• positive relationships – understanding the views of others leads to greater

cooperation and trust.

6.1.5.2. Safety culture

49

Safety culture embodies the value placed on safety and the extent to which people

take personal responsibility for safety in an organisation. A positive safety culture

means a safer, healthier and more productive workplace. Like any aspect of an

effective organisation, growing a positive safety culture requires a commitment of time,

resources and focused actions from the Proponents / Management and the employees

too. The Proponent should champion the importance and in-still rich value in

workplace occupational health and safety.

50

7. ENVIRONMENTAL MANAGEMENT PLAN

The Environmental Management Plan (EMP) presents a summary of management initiatives

that will be required to ensure the identified negative and positive impacts are mitigated and

maximized respectively. However, this EMP will be focussing on negative impacts presented

earlier. Indicators are suggested for each identified impact, and this is followed by the assigned

responsible implementing agent and the monitoring frequency. Where there are budgetary

implications besides the common project costs, they will be indicated specifically.

The chapter also lays down the plan for monitoring the impacts during project life cycle stages.

The EMP is also aimed at ensuring continued compliance even after the duration of project.

In some cases the implementing agencies would need the assistance of the consultant to

adequately formulate local area and more specific implementation strategies. It is important

that the proponent implements this EMP with reference to the impact analysis and evaluation

chapters which have more detail on the impacts and the suggested mitigation measures. The

EMP summarized the impacts and configured them into objectives that can be pursued

sustainably.

51

Table 7: Environmental Management Plan

ACTIVITY ENVIRONMENTAL

ASPECT

IDENTIFIED

IMPACT

POSITIVE

\NEGATIVE

SOURCE MITIGATION INDICATOR(S) IMPLEMENTING

AGENT

RESPONSIBLE

AGENT

MONITORING

AGENT

MONITORING

FREQUENCY

DESIGN AND PLANNING PHASE

Inadequate

mining

design

Noise Noise pollution -ve Mining

operation /

running

equipment

Incorporating low-

noise equipment

in the mine

design.

Maintaining trees

around the plant

to serve as

barriers.

Acoustic levels

measured in

decibels

Design Engineer Savanna Marble

CC

DEA

Ministry of

Labour

At the design

stage and

commissioning

phase.

Occupational hazards Injuries / loss

of life

-ve Plant

operation /

running

equipment.

Rock falls

during

mining

Carrying standard

hazard

assessment and

operation

procedures at the

commissioning

stage.

Occupational

health and safety

training of the

operators.

Employ qualified

Miner with the

ability to use

Uncovered moving

parts, lack of

safety or warning

signs.

Dangerous

unsupported rocks

and walls

Design Engineer Savanna Marble

CC

Ministry of

Labour and

Social Welfare

Ministry of Mines

& Energy

At commissioning

stage and

thereafter

Monthly

52


ASPECT

IDENTIFIED

IMPACT

POSITIVE

\NEGATIVE


AGENT

RESPONSIBLE

AGENT

MONITORING

AGENT

MONITORING

FREQUENCY

support

effectively.


ASPECT

IDENTIFIED

IMPACT

POSITIVE

\NEGATIVE


AGENT

RESPONSIBLE

AGENT

MONITORING

AGENT

MONITORING FREQUENCY

DESIGN AND PLANNING PHASE

Inadequate mining design

Noise Noise

pollution

-ve Mining

operation /

running

equipment

Incorporating

low-noise

equipment in

the mine

design.

Maintaining

trees around

the plant to

serve as

barriers.

Acoustic levels

measured in

decibels

Design Engineer Savanna

Marble CC

DEA

Ministry of

Labour

At the design stage and

commissioning phase.

Occupational

hazards

Injuries /

loss of life

-ve Plant

operation /

running

equipment.

Carrying

standard

hazard

assessment

and operation

procedures at

the

Uncovered

moving parts,

lack of safety

or warning

signs.

Design Engineer Savanna

Marble CC

Ministry of

Labour and

Social Welfare

Ministry of

Mines &

Energy

At commissioning stage and

thereafter Monthly

53


ASPECT

IDENTIFIED

IMPACT

POSITIVE

\NEGATIVE


AGENT

RESPONSIBLE

AGENT

MONITORING

AGENT


Rock falls

during

mining

commissioning

stage.

Occupational

health and

safety training

of the

operators.

Employ

qualified Miner

with the ability

to use support

effectively.

Dangerous

unsupported

rocks and walls


ASPECT

IMPACT POSITIVE

\NEGATIV

E

SOURCE MITIGATION INDICATOR IMPLEMENTIN

G AGENT

RESPONSIBLE

AGENT

MONITORING

AGENT


OPERATIONAL PHASE (Mining)

Dimension stone cutting Safety hazards Accidents -ve Rock falls Put supports and rocks

should be well

balanced on the

ground or well secured

on the trailer or on the

fork lift.

No. of block fall

incidents and

accidents

Mine Manager

Occupational

Health & Safety

Officer

Savanna

Marble CC

Ministry of

Labour

Daily

54


ASPECT

IMPACT POSITIVE

\NEGATIV

E


G AGENT

RESPONSIBLE

AGENT

MONITORING

AGENT


Mining operation Occupational

health

Diseases such as

diarrhoea

-ve Poor and

inadequate

sanitation

facilities

Build on-site sanitation

facilities.

Provide on-site clean

drinking water and

promote hygienic

practices.

Number of

people falling

sick due to

unhygienic

practices

Mine Manager

Occupational

Health & Safety

Savanna

Marble CC

Ministry of

Labour

Ministry of

Health &

Social Services

Quarterly

Blocks conveyance Safety hazards Accidents -ve Rock falls from

fork lift or

truck

Loads should be well

secured on the moving

fork lift or truck.

Rock fall

accidents

Mine Manager

Occupational

Health & Safety

Officer

Savanna

Marble CC

Ministry of

Labour

Daily when the plant is in

operation

Mining operation Health and safety

hazards

Occupational

accidents.

-ve Machinery and

moving

equipment;

Workers should be

provided with personal

protective equipment

and be trained on

safety and health

issues. Warning signs

to be posted to

indicate dangerous

areas and risks

associated.

Number of

incidences and

accidents

Mine Manager

Occupational

Health & Safety

Officer

Savanna

Marble CC

Ministry of

Labour

Every six months

Mining operation Noise pollution

(See detailed

analysis below)

Noise is a

nuisance and

long exposure

times can cause

hearing

impairment.

-ve Plant

operations

Workers should be

provided with personal

protective equipment

and be trained on safety

and health issues.

Warning signs to be

posted to indicate

dangerous areas and

risks associated.

Noise exposure

measurement in

decibels

Mine Manager

Occupational

Health & Safety

Officer

Savanna

Marble CC

Ministry of

Labour

Daily during crusher operation

55


ASPECT

IMPACT POSITIVE

\NEGATIV

E


G AGENT

RESPONSIBLE

AGENT

MONITORING

AGENT


Mining operation Dust emissions Irritates and

causes lung

diseases

-ve Dust

generated

from the

cutting of

granite

blocks. Dust

generated

from the

movement of

trucks and

fork lifts on

the mine site

Provide workers with

appropriate protective

clothing and also use

water to suppress dust.

Dust deposition Mine Manager

Occupational

Health & Safety

Officer

Savanna

Marble CC

Ministry of

Labour

Hourly during mining

operations.

Mining operation Air pollution Irritates and

causes lung

diseases over

long exposure

periods

-ve Vehicle and

machinery

exhaust

fumes

Use efficient vehicles

and machinery and

ensure they are well

serviced and

maintained

Carbon

monoxide and

SO2

Mine Manager

Occupational

Health & Safety

Officer

Savanna

Marble CC

Ministry of

Labour

Quarterly

Mining operation Accidents Injuries to

domestic

animals and

passers by

-ve Livestock

being

trapped in

mine water

ponds.

Fence off the mining

area to restrict

entrance.

Number of

accidents

Mine Manager

Occupational

Health & Safety

Officer

Savanna

Marble CC

Ministry of

Labour

Quarterly

ENVIRONMENTAL ASPECT IMPACT POSITIVE

\NEGATIVE

SOURCE MITIGATION INDICATOR IMPLEMENTING

AGENT

RESPONSIBLE

AGENT

MONITORIN

G AGENT


DECOMMISSIONING PHASE

56


ASPECT

IMPACT POSITIVE

\NEGATIV

E


G AGENT

RESPONSIBLE

AGENT

MONITORING

AGENT


Land degradation Scarred earth and bare

ground

-ve Destruction and

removal of overburden

and rocks during

mining

Make sure the pit walls are not

steep to allow wildlife to drink

water collected with easy.

Number of un-

rehabilitated pits

Mine Manager Savanna

Marble CC

DEA Twice / once a

year

Land degradation Solid waste and loss of

aesthetic value

-ve Indiscriminate

dumping of waste rock

and poor grade blocks

as well as domestic

waste.

Waste rock should be kept

properly for rehabilitation

exercise.

Reusable or recyclable

materials should be separated

and treated as such.

Area of un-

rehabilitated

land surface, and

waste dumps


Marble CC

DEA Twice / once a

year

DECOMMISSIONING PHASE

Land degradation Scarred earth and bare

ground

-ve Destruction of trees

and removal of

overburden and rocks

during mining

Refill all dug out pits and

replace topsoil.

This should be followed by

planting of trees and grass.

Borehole water can be used to

water them until they have

established well.

Land cover, tree

population and

number of un-

rehabilitated pits


Marble CC

DEA Twice / once a

year

Land degradation Solid waste and loss of

aesthetic value

-ve Indiscriminate

dumping of waste rock

and poor grade blocks

as well as domestic

waste.

Waste rock should be kept

properly for rehabilitation

exercise.

Reusable or recyclable

materials should be separated

and treated as such.

Area of un-

rehabilitated

land surface, and

waste dumps


Marble CC

DEA Twice / once a

year

57

8. CONCLUSION, RECOMMENDATIONS AND WAY FORWARD

8.1. Conclusion

The mining of granite / dimension stone at ML 152 has negative environmental

impacts. The EIA study findings showed negative environmental impacts to the

environment to varying degrees depending on the nature of the activity and impacts

arising thereof. Management and corrective measures were formulated and

implementation timelines proposed depending on the gravity of threat to human life

and the environment.

The identified impacts, mitigation and monitoring activities, indicators, responsible

parties and monitoring frequency are indicated in the EMP. The EMP should form the

obligatory conditions upon which the EIA clearance certificates will be issued and non-

compliance attracts prosecution. The EMP should be implemented throughout the

project lifecycle and an Environmental Management System formulated and

implemented based on the EIA study findings. Environmental monitoring and

performance evaluations should be conducted and targets for environmental

improvement set and monitored throughout the project lifespan. It is also our

determination that the findings should be incorporated earlier and sound SHE policies

and supportive programmes implemented.

8.2. Recommendation

Recommendations were developed to guide the Proponent on the key activities that

should be done to effectively manage safety, health and environment:

• Develop SHE policies based on the study findings and use impacts evaluation

to formulate the objectives.

• Develop and implement Environmental Management Systems.

• Develop an occupational health and safety plan

• Adhere to the environmental management obligations upon which the EIA

clearance certificate will be issued by the MET: DEA.

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• The EIA clearance will not exempt the Proponent from obtaining other relevant

permits and should do as such.

• Provide relevant training to capacitate the workers with knowledge and skills to

manage safety, health and the environment.

8.3. Way Forward

The EIA will be submitted to MET: DEA. The decision made by MET: DEA will be made

known to the Proponent and I&APs.

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8.4. History of stakeholder interactions (i.e. proof of good working

relations)

All submissions to MET over the past 9 years of the mine's - at least the scanned

receipt proofs should go into an appendix. If the mine has not submitted 6 monthly

reports then this list and collated proofs will provide an alternative to the required

reporting that should have been done.

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8.5. Background Information and Invitation to Participate Document

BACKGROUND INFORMATION DOCUMENT AND INVITATION TO COMMENT.

ENVIRONMENTAL IMPACT ASSESSMENT (EIA) FOR THE MINING AND

UPGRADING OF GRANITE VALUE ADDITION PLANT – RENEWAL OF MINING

LICENCE 152 IN ARANDIS, ERONGO REGION.

FOR

SAVANNA MARBLE CC

Prepared by

P. O. Box 70822, Khomasdal, Windhoek, Namibia.

+264 812 683 578

[email protected]


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1. PURPOSE OF THE DOCUMENT AND CONTENTS

The purpose of this Background Information Document (BID) is to provide

stakeholders with the opportunity to register as Interested and Affected Parties

(I&APs) in the scoping exercise for the Environmental Impact Assessment (EIA) Study

for the mining and processing of granite on Mining Licence 152 held by Savanna

Marble CC. We will share with you the process being followed and also obtain your

initial comments on the granite mining project. The document also gives you

information on the benefits of the proposed project, potential impacts of the project

and proposed environmental studies needed. Further to that we advise you on how

you can become involved in the project, raise concerns which you may have or receive

information which may be of interest to you. This is the core of public participation

during the EIA process. Information sharing is the cornerstone of successful Public

Participation and your input will help ensure that all potential issues are taken into

consideration before critical decisions are made.

2. PROJECT DESCRIPTION


a period running from the 5th of June in 2009 to June 2019. At the time of the granting

of the licence only an internal EIA was done as all such projects were cleared based

on an environmental questionnaire submitted to the Ministry of Environment and

Tourism (MET) who would then issue an environmental contract. Over the years



mostly transformed into table tops through further value addition in Windhoek. It is in

the Proponent’s plans to upgrade the value addition plant and make finished products

such as tiles, slabs, curbstones, windowsills etc, which would form the basis for the

expansion of existing stone manufacturers, as well as for the development of various

new downstream businesses that can add further value to Savanna Marble CC’s

products.




this EIA study has been necessitated by the following:

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d. Renewal of mining licence ML 152.

e. Change of operations due to the inclusion of Processing and Manufacturing

activities for the purpose of local value addition and reduction of waste.

f. Development of a comprehensive Environmental Management Plan in

compliance with the Environmental Management Act (2007) which covers both

the mining operations and value addition activities.

Figure 13: The location of ML152 in relation to Swakopmund, Arandis, Namib Desert Nation Park and the existing water, road, rail and electricity infrastructure.

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3. DESCRIPTION OF THE ENVIRONMENT

3.1. Existing mine infrastructure

There is an existing mine pit from which granite blocks were extracted over the years.

In addition there is a granite cutting and polishing plant mounted on concrete

foundations and shaded under a roof constructed from corrugated iron sheets fixed on

iron beams. Concrete floors serve as storage, value addition and general maintenance

areas). Water and electricity are available onsite and details are presented below.

3.1.1. Water

Water is tapped from the main pipeline supplying the Uranium mines in the area. Daily

water consumption during full production would be ten cubic meters per day. However,

water is recycled retaining up to 80 % of the water used for cutting, so that water

consumption is reduced significantly. Water is mainly used for the cutting process with

diamond cutting blades and diamond wires. It also serves to completely suppress any

dust development during the cutting process. Water loss is predominantly through

evaporation, no infiltration is expected since the pond was cut out from the solid granite

formation.

3.1.2. Energy

All the electrical equipment at the mine is powered by diesel generated electricity.

Diesel is stored on-site using an above ground storage tank from which other mobile

equipment also fuels. Should there be need to get electricity connection to the national

grid in the future then the necessary procedures will have to be followed. It is an option

that cannot be ruled out if there is need and the powerline is within reach. The

Proponent does not plan a connection to the grid.

Potential Challenge

The EIA study will investigate the suitability of the fuel storage site in relation to other

mining operations taking into consideration the environment, occupational health and

safety. Spills and leaks of hydrocarbons impact negatively on the environment.

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3.1.3. Accommodation and toilet facilities

Mine and processing plant workers will be accommodated in Arandis and

Swakopmund. Accommodation facilities in the form of movable containers on the mine

site are solely for accommodating security personnel and site managers if required.

The following facilities will be erected on the mine site for the well-being of the

employees:

c. Staff canteen: The staff canteen will comprise of a pantry for storing food

stocks, a kitchen and eating / dining hall.

d. Ablutions and showers: Dixy toilets catering for twenty people will be used and

serviced by an external contractor. Showers will be installed to serve the same

number of people but the grey water will be used to feed a sypon growing

melons and other vegetables.

Potential Challenge

The ablutions and toilet facilities should be designed to the correct capacity and

appropriate technologies used to safeguard the environment and the health of the

employees.

3.2. The project

The project is focused on upgrading the granite cutting and polishing facility. This

entails extending the floor line for the various product lines as well as a packing and

dispatch area. Associated activities will be of course the construction of the ablutions,

showers and canteen described earlier.

Figure 14: Block cutter used in the value addition facility.

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3.3. The need for the project

The benefits of upgrading the granite cutting and polishing plant are among others:

• Reduction and partial elimination of granite waste

• Employment creation and thus improve the well being of the local people.

Employment preference will be afforded to previously disadvantaged

Namibians.

• Supply of raw materials and processed materials to downstream industry for

economic growth. Such industries include but are not limited to the construction

industries etc.

• A contribution to the balance of payments through exports.

• Local Value addition allowing for the processing of blocks (waste) that cannot

be sold as complete blocks.

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4. PROPOSED STUDIES

A baseline environmental study will be done covering the following aspects:

4.1. Biodiversity Scoping study

A flora and faunal study is proposed given the likelihood of vegetation destruction

during mining operations and land clearing during construction activities. A baseline

map showing area covered by protected flora will be generated indicating no go areas

as well.

4.2. Culture and Heritage Scoping

A culture and heritage scoping will be done to investigate the occurrence and

significance of historical heritage sites.

4.3. Assessment Of Alternatives

4.3.1. No-Go Option

The “no-go” option means maintaining the status quo. This option will be explored to

assess the implications of not implementing the project.

4.3.2. Sites

Sites within the mining licence that pose minimal impact on the environment will be

chosen for mining. Similarly access routes will be assessed and those with minimal

environmental impacts chosen. The same will be done with the fencing of the mining

area.

4.3.3. Strategic Alternatives

Strategic alternatives will be explored to see the best way to exploit the targeted

mineral reserves in terms of mining techniques, transportation and marketing.

4.3.4. Technological Alternatives

There are different technologies available that are used in the mining and

environmental monitoring. The various options will be explored and appropriate

recommendations made to enhance sustainability.

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5. THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

An EIA is the process of identifying, predicting, evaluating and mitigating the

biophysical, social, health and other relevant effects of development projects prior to

major decisions being taken and commitments made.

The objectives of the EIA will be to:

• Provide you with adequate information to understand the potential

environmental and socio-economic impacts of the proposed project and

opportunities to comment on the project and the process.

• Provide information that will assist the consultants to incorporate effective

mitigatory measures into the design and implementation of the project.

• Provide the regulatory authorities with sufficient information to serve as a basis

for sound decision making.

5.1. Project elements to be covered by the EMP.

The EIA will cover the following elements:

• Operation and maintenance of the mine and processing plant.

• Decommissioning

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PHASE 1: SCOPING

• Determine scoping of EIA

• Policy, regulatory review

• Desk review of previous studies

• Reconnaissance site visit

• Scoping workshop

• Draft scoping report with terms of reference & work plan for phase 2

•

PHASE 2: Environmental Impact Aseessment

• Biophysical, Socio-economic and Specialist Studies

• Impact Assessment

• Mitigation Plan

• Draft EIA Report

Decision making

Implementation

On-going consultations

Including Public Meetings

Public Consultation & Disclosure

• Includes community

consultation & Public Meeting

• Draft Public Consultation &

Disclosure Plan (PCDP)

Development not approved

Environmental Impact Aseessment

Development not approved

Development approved

Figure 15: The EIA process that will be followed. Figure 16: The EIA process to be followed.

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5.2. Scope Of The Work

The Environmental Impact Assessment scope will focus on the issues related to fauna

with respect to land clearing, waste management (solid and liquid), operation and

management of the mine and processing area, construction of the canteen, ablution

and toilets, sites of national heritage significance and policy and legislation review.

The EIA will be done in 2 phases (See Figure.2).

PHASE 1 – SCOPING

It is a formal requirement during the EIA process to carry out a scoping study and this

is in-line with the Namibian Environmental Management Act (2007). The purpose of

this study is to direct the assessment on the key issues for assessment and at the

same time eliminate those that do not require detailed intensive studies.

5.3. Scoping Activities

• Consultations with key stakeholders, government departments etc.

• Advertising and carrying out public meetings.

• Distribution of project information to the public.

• Producing draft scoping report.

• Gathering public comments on draft scoping report.

• Submission of final scoping report to Ministry of Environment & Tourism

(MET).

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PHASE 2

Issues that are raised during the scoping study will be used to develop terms of

reference for specialist studies. Experts within the Consultancy Team will be assigned

to carry out the specialist studies. The results from the specialist studies will be

incorporated into the Draft EIA report.

5.4. Draft EIA Report

The draft EIA report will reflect all the identified issues, mitigation measures and the

proposed environmental management plan. The draft EIA document will be made

available to the public for comments on issues of interest and can also raise any

concerns they may feel require further attention.

5.5. Legal Framework

The Namibian Government gazzeted the Environmental Management Act in 2007 and

is supported by a set of guidelines and regulations. The EIA process will follow the EIA

Policy and the Environmental Management Act & its regulations. The EIA will also take

cognizance of applicable international standards and guidelines, conventions and

treaties.

6. PUBLIC CONSULTATION AND DISCLOSURE PLAN

According to the Environmental Management Act (2007), public participation forms an

integral part of the EIA process. Adequate public consultation is important to identify

issues relevant to the project, evaluating their significance and deciding measures to

mitigate these impacts. A public consultation plan has been developed in line with the

Environmental Management Act (2007) and seeks to achieve the following objectives:

• To ensure all stakeholders are included in the consultation and disclosure

process;

• To ensure initial information disclosure about the project is appropriate and

understandable to the non-technical stakeholders and the local population;

• To ensure that adequate and timely information is provided to the public;

• To ensure that all stakeholders are given sufficient opportunity to express their

issues, concerns and opinions;

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• To ensure that stakeholders’ opinions and concerns influence project decisions;

• To ensure regular feedback is given to the public;

• To ensure that effective communication will continue during the construction

and operational phases of the project;

Savanna Marble CC and the Outrun Team are committed to active and ongoing

communication and consultation of all members of the public with regards to the

granite mining project at ML 152 in the Arandis Area.

6.1. How you can be involved?

• Attend public meetings that will be advertised in the local media.

• Contact the EIA consultants for further information.

• Review the draft reports when you are invited to do so within the timeframes

provided.

Please ensure that you are registered on the project database by providing your

contact details to the EIA Consultants. Registration will ensure that you receive on-

going communication about the EIA process, meeting invitations, project updates and

invitations to review the draft reports.

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SAVANNA MARBLE CC

REGISTRATION AND COMMENTS FORM

Please register me as an Interested and Affected Party (I&AP) to

receive ongoing communication about the EIA process and the

proposed project.

NAME: TELEPHONE:

ORGANIZATION: FAX:

DESIGNATION: E-MAIL:

ADDRESS:

COMMENTS AND ISSUES OF CONCERNS

PLEASE SUBMIT REGISTRATION AND COMMENTS TO:

JOSIAH T. MUKUTIRI AND PHILLIP HOOKS

P. O. Box 70822

Khomasdal

Windhoek

Namibia

Mobile: +264 – 812 683 578.

E-Mail: [email protected]


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EXISTING ENVIRONMENT IN PICTURES

Figure 17: Dolerite ridge. Figure 18: Granite blocks awaiting processing.

Figure 19: Eroded dolerite forming microhabitat for Caloplaca spp Lichens.

Figure 20: Aloe Asperifolia

Figure 21: Remains of the 100 years old railway line damaged during movie production of Mad Max.