ENVIRONMENTAL MANAGEMENT PLAN Erongo Desalination...

ENVIRONMENTAL MANAGEMENT PLAN Erongo Desalination Plant

Date: February 2019

Erongo Desalination Plant Environmental Management Plan 2019

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Contents

1 Introduction.............................................................................................................................................................. 5

1.1 AIM OF THE EMP ............................................................................................................................................. 5

1.2 BACKGROUND.................................................................................................................................................. 5

1.3 ENVIRONMENTAL APPROVALS ........................................................................................................................ 7

1.4 LEGAL FRAMEWORK ........................................................................................................................................ 7

2 Project Overview ...................................................................................................................................................... 8

2.1 CARE AND MAINTENANCE ............................................................................................................................... 8

2.2 OPERATIONS .................................................................................................................................................... 8

2.3 CLOSURE .......................................................................................................................................................... 9

3 Environmental Management ................................................................................................................................... 9

3.1 ENVIRONMENT POLICY .................................................................................................................................... 9

3.2 LEGAL COMPLIANCE ...................................................................................................................................... 12

3.3 ENVIRONMENTAL MANAGEMENT SYSTEM .................................................................................................. 12

4 Mitigation Tables .................................................................................................................................................... 14

Appendix A – Environmental Clearance Certificate

Figures Figure 1 – Locality Map for Trekkopje Mine Figure 2 – Locality Map for Erongo Desalination Plant Figure 3 – Environment Policy

Tables Table 4.1 – General mitigation measures to be applied throughout the life-of-operations Table 4.2 – Mitigation measures relating to social activities to be applied throughout life-of-operations Table 4.3 – Mitigation measures to be applied during closure operations

DOCUMENT COMPILED AND APPROVED BY:

Werner Petrick Namisun Environmental Projects and Development PO Box 8127 Swakopmund, Namibia

Sandra Müller, QHSE Consultant Orano Mining Namibia

25 Mandume ya Ndemufayo Street

P O Box 585, Swakopmund, Namibia

Acronyms

ECC Environmental Clearance Certificate EDP Erongo Desalination Plant ESIA Environmental and Social Impact Assessment EMP Environmental Management Plan HSE Health, Safety and Environment km Kilometre km/h Kilometre per hour km2 Square kilometre m Metre mm Millimetre Mm3 Million cubic metres MAWF Ministry of Agriculture, Water & Forestry MET:DEA Ministry of Environment and Tourism: Directorate of Environmental Assessment Orano Orano Mining Namibia PPE Personal Protection Equipment STP Sewage Treatment Plant


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1 Introduction

1.1 AIM OF THE EMP The purpose of this Environmental Management Plan (EMP) for the Erongo Desalination Plant and water pipeline to the Trekkopje Mine is to list the actions that will both mitigate and monitor the impacts relating to the operation and closure phases of the plant. Currently, the company AVENG Water Treatment runs the desalination plant on behalf of Orano Mining Namibia (formerly known as AREVA Resources Namibia). While Orano carries the overall legal responsibility for EMP compliance, AVENG is contractually obliged to meet all the requirements. This EMP has been developed within the framework of an Environment Policy and is based on the original approved EMP of 2008, the amended 2013 EMP and the second amended EMP (2016) that is currently in force at the Erongo Desalination Plant. Both amendments were approved by the Ministry of Environment and Tourism: Directorate of Environmental Assessment. Once approved by MET, this (third) Amendment to the EMP will supersede the 2016 EMP that will expire in September 2019. The 2013 amendment replaced the construction-specific mitigation measures in the 2008 EMP with measures that are more applicable to the operational phase. The 2016 amendments mainly concerned some socio-economic mitigation measures that had not been updated in 2013. The main objective of the 2018 amendment was to incorporate the additional management and mitigation measures associated with the proposed new on-site Sewage Treatment Plant (STP). However, further amendments / additions to the operational phase mitigation measures of the EMP were also deemed necessary to ensure key issues assessed during the original EIA for the desalination plant are better addressed, in the spirit of continuous improvement. All changes / additions to the EMP are highlighted, for ease of reference.

1.2 BACKGROUND The French nuclear energy concern AREVA (now Orano) purchased the Trekkopje uranium project in 2007 and established the local subsidiary AREVA Resources Namibia. Areva Resources Namibia changed its name to Orano Mining Namibia in 2018. The Trekkopje project site is located within the Erongo region of Namibia, 70 kilometres (km) north-east of Swakopmund (Figure 1). Once in operation the mine will exploit a large, low-grade uranium resource using an alkaline heap leaching process. In order to supply the large volumes of water required by the heap leach process, Orano decided to construct the Erongo Desalination Plant to minimise the mine’s impact on the region’s limited groundwater reserves and guarantee the mine’s water supply. The desalination plant is close to Wlotzkasbaken, 30 km north of Swakopmund (Figure 2). It can produce up to 20 million cubic metres (Mm3) of potable water per year at current capacity and could be upgraded to 26 Mm3 within the existing buildings. There is a second seawater intake pipe and sufficient space to build another 20 Mm3-desalination plant on the same premises. In October 2012 due to economic uncertainties, Orano decided to postpone the start-up of the mine and place the Trekkopje project under a ‘care and maintenance’ programme, which is aimed at maintaining the already constructed facilities in operating condition. Given that the project is well advanced and installations are ready in place, Orano intends to start up the mine as soon as there is an upturn in the market. The economics of the project will be reassessed annually while implementing this programme.

Figure 1 - Location of the Trekkopje project site

Figure 2 - Location of the Erongo Desalination Plant and Related NamWater Infrastructure


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As there is a shortage of groundwater in the coastal region, the Erongo Desalination Plant did not go into ‘care and maintenance’. Orano concluded an agreement with NamWater in August 2013 and has been producing up to 10 Mm3 of water per annum to supply other uranium mines as needed. In the meantime, Trekkopje Mine has been using very little water for care and maintenance.

1.3 ENVIRONMENTAL APPROVALS In 2008, an Environmental and Social Impact Assessment (ESIA)1 was completed for the construction, operation and ultimately decommissioning of the Erongo Desalination Plant. The ESIA, including an EMP report, was approved by the MET:DEA and a clearance certificate was issued on 13 June 2008. During the same month, the environmental clearance certificate for the Trekkopje Mine was similarly issued by the MET:DEA based on an approved EIA and EMP. The 2008 EMP was amended and a new clearance certificate was issued in April 2013, which was valid for three years. The 2016 amended EMP was submitted to MET:DEA and approved on the 12th of September 2016 (see Appendix A). Once approved by the MET:DEA, the 2019 amended EMP will supersede the 2016 EMP.

1.4 LEGAL FRAMEWORK To ensure continuous improvement Orano made further amendments to the EMP in 2019, partly based on the EIA Amendment Report for the activities associated with the proposed new STP, partly on good practice established elsewhere in the mining industry. According to Section 39 of the Act existing EMPs can be amended under the following conditions:

1) The Environmental Commissioner may amend a condition of an environmental clearance certificate - a) if the certificate holder consents to or requests for the amendment; or b) at the initiative of the Environmental Commissioner, by giving written notice to the holder of the

certificate.

2) The Environmental Commissioner may require the holder of the environmental clearance certificate to make an application in the prescribed form and manner to the Environment Commissioner for the proposed amendment.

3) In considering an application to amend an environmental clearance certificate the Environmental Commissioner must have regard to the same matters which he or she was required to consider when deciding the initial application for that environmental clearance certificate.

4) The Environmental Commissioner may only amend a condition of the environmental clearance certificate under this section if he or she is satisfied that the - a) amendment will not have a significant effect on the environment; and b) the interests of any other person are not adversely affected.

5) In amending an environmental clearance certificate the Environmental Commissioner must follow the

consultative process referred to in section 44. To obtain approval for the updated EMP, an application for an amendment to the ECC for the proposed new STP, as stipulated under Section 39 1(a) of the EMA 2007 and Section 19 of the Regulations is required. This updated EMP reflects these changes and will be submitted as part of an application for an amendment to the ECC.

1 Environmental and Social Impact Assessment Plan for the proposed Trekkopje Uranium Project Desalination Plant, Turgis

Consulting, 2008

2 Project Overview

The desalination plant at Wlotzkasbaken was inaugurated on 16 April 2010. It is the largest reverse-osmosis seawater desalination plant in Southern Africa. The plant is owned by Orano Mining Namibia, and operated and maintained by AVENG Water Treatment. At full capacity the plant is able to produce 20 million cubic metres of potable water per year. This is made possible through the adoption of state-of-the-art technology including screen filtration, ultrafiltration, reverse osmosis, limestone contact and chlorination. The first and second phases of the desalination process entail seawater passing through screens that remove coarse debris from the water and ultrafiltration membranes that filter out even the finest particles and plankton. The process of reverse osmosis separates the seawater into two streams—a pure, mineral-enriched potable water of excellent quality and a brine stream, which is fed back by gravity-flow and dispersed into the ocean. The potable water is conveyed to Trekkopje mine via a 40 km long, 800 mm diameter pipeline, supported by three pump stations. To be able to use the excess capacity of the plant to supply other consumers the pipeline from the desalination plant to Trekkopje Mine had to be interconnected with NamWater’s pipeline from Henties Bay to Swakopmund. Omaruru River groundwater and desalinated water are thus mixed in the pipeline, which results in a lower salinity and hardness of the water supplied to all users. The volume to be produced is determined by contract with NamWater according to the demand of other mines. The addition of desalinated water has helped to alleviate the over-abstraction of NamWater’s groundwater resources and contributed to further economic development in the Erongo region.

2.1 CARE AND MAINTENANCE From the middle of 2013, the Trekkopje project was put under care and maintenance. The mine’s infrastructure is being maintained in good working order so that the mine will be able to start production when economic conditions become more favourable. The Erongo Desalination Plant continues to supply the mine with water, albeit at a reduced amount of approximately 15 000 cubic metres per annum. Once the economic conditions on the uranium market become favourable, Trekkopje Mine will begin full-scale operations. Most of the water being produced by the desalination plant will then be used by the mine. It is anticipated that by this stage either the current plant has been extended to meet the expected demand or NamWater will have built their own desalination plant.

2.2 OPERATIONS The seawater desalination process consists of screen filtration, ultrafiltration, reverse osmosis, limestone contact and chlorination. The first step in the process is the intake of seawater through a pipeline anchored 1000 metres off the coast, at a depth of 10 metres. At the intake, a 40 millimetre diameter screen keeps out all larger aquatic organisms such as fish. The water is disinfected with chlorine and passes through screens that eliminate micro-organisms and particles larger than 60 micrometres in diameter, and then ultrafiltration removes all remaining particles so that only dissolved salts remain in the clear water. The next step is reverse osmosis which separates the water into two streams, namely pure drinking water and a brine stream that is returned to the ocean. The reverse osmosis process forces the water through semi-permeable membranes under high pressure. These membranes allow only water molecules to pass through, thus producing clean water, while the salts remain in the brine. After the reverse osmosis step the brine is still at very high pressure. This pressure is exchanged with the incoming seawater, directly recovering 98% of the energy that would otherwise be lost and thereby reducing the plant’s electricity consumption by approximately 40%. The final steps in the desalination process are limestone contact and chlorination. Water produced at the Erongo Desalination Plant is replenished with all the minerals the body needs and is safe for human consumption. Regular independent tests are conducted and the client, NamWater, constantly monitors the plant’s water output to ensure that it is compliant with its quality standards. The Erongo Desalination Plant’s entire operation is subject to Namibia’s national legislation and standards in terms of health, safety and the environment. The ESIA predicted no major effects of the brine on marine life around the outlet. This has since been confirmed by monitoring.


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It should be noted that seawater desalination is an advanced and innovative process and thus more expensive than groundwater. This may have an impact on water tariffs of coastal towns in future. The major cost items are electricity consumption for reverse osmosis and replacement of ultrafiltration and reverse osmosis membranes. The membranes are prone to clogging during sulphur outbreaks, meaning that the plant has to be stopped under these conditions and NamWater will have to meet the water demand from its groundwater sources.

2.3 CLOSURE Desalination plants typically have a life span of about 30 years, while Trekkopje Mine is only expected to operate for a maximum of 10 years. Orano is currently in negotiations with government about the sale of the desalination plant. Should this come to pass it would mean that the plant would remain in operation indefinitely, long after the mine has closed. Should the plant have to be closed, Orano will follow the usual closure process that commenced before the start of operations and will involve multi-stakeholder cooperation to find optimised post-closure environmental and social targets to work towards. Closure plans will be supported by regular risk assessments and reviews. The closure strategy for the Erongo Desalination Plant includes the following goals:

To maximise rehabilitation;

To have no liabilities at the end of life-of-operations; and

To achieve cost estimates for closure within a 15% accuracy, five years before closure. The plant is situated on land that falls within the Wlotzkasbaken settlement area. The plant infrastructure, i.e. plant, pipeline, pump stations and service track belong to Orano, while NamPower owns the 132 kV power line from the mine to the desalination plant via two substations. The objective of the closure programme will be to ensure the long-term safety of the former plant site by demolishing all the infrastructure built and owned, which will not be required by a future land owner. Before commencement of the closure programme, public consultation will take place and a closure impact assessment will be carried out. Rehabilitation and clean-up activities will take place over an extended period until completed. This will be followed by ongoing monitoring activities until the land can be relinquished.

3 Environmental Management

3.1 ENVIRONMENT POLICY Environmental management at the Erongo Desalination Plant is guided by the Orano environmental policy and the AVENG environment policy (Figure 3).


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3.2 LEGAL COMPLIANCE The following acts, policies and draft policies are applicable to environmental management at Erongo Desalination

Plant:

National Land Policy and Land Use Planning Policy

Regional Councils Act (No. 22 of 1992) and Amendment No. 17 of 1997

Environmental Management Act 7 of 2007

12 Point Plan for Integrated and Sustainable Environmental Management

Parks and Wildlife Management Bill, 2004

Nature Conservation Ordinance No.4 of 1975

Nature Conservation Amendment Act (No. 5 of 1996)

Soil Conservation Act (No. 70 of 1969)

Water Act (No. 54 of 1956)

Water Resources Management Act, 2004 (No. 24 of 2004, not commenced)

Namibian Water Corporation Act (No. 12 of 1997)

Water and Sanitation Policy

Integrated Water Resource Management and Water Demand Management Policy

Pollution Control and Waste Management Bill, 1999

Prevention and Combating of Pollution of the Sea by Oil Act 6 of 1981,

Marine Resources Act (No. 27 of 2000)

Air Quality Act (No. 39 of 2004)

Atmospheric Pollution Prevention Act (No. 45 of 1965)

Labour Act (No. 11 of 2004) – Health & Safety Regulations

The Erongo Desalination plant’s permit for seawater abstraction (number 10535) was extended in 2017 for three years until 31 August 2020. The quota was at the same time increased to 60 Mm3 per annum so that the plant will be able to produce the contracted volume of 12 Mm3 for NamWater. A domestic and industrial effluent disposal exemption permit (number 687) was issued on 24 May 2016 and will be valid until 31 May 2021. An important condition of this permit is that “the quality of brine from the desalination plant that will be disposed into the marine environment should not have an effect and impact on the marine ecosystem and therefore the fishing industry.”

3.3 ENVIRONMENTAL MANAGEMENT SYSTEM A set of policies, strategies and procedures have been developed to facilitate the on-site implementation of the environmental policies. The documents were drawn up based on the Environmental and Social Impact Assessment for the proposed Trekkopje Uranium Project Desalination Plant (Turgis, 2008) and company guidelines. Mitigation actions and monitoring are carried out by the Orano QHSE team in cooperation with AVENG and the details of these management measures and monitoring results are reported annually. The environmental aspects which are monitored at the desalination plant include the following:

Land surface (including soil pollution and land use)

Marine environment (water quality, flora and fauna) The original EMP for the construction phase included a requirement for dust fallout monitoring. Three dust buckets were included in the Trekkopje Mine monitoring network and monthly analyses were done until the end of 2018. The data collected during this time has shown conclusively that the operation of the desalination plant did not cause additional dust emissions. Further monitoring is therefore not necessary. Monitoring of social impacts including traffic, noise and visual aspects was also required during the construction phase and the first few years of operation. No further monitoring of these aspects is required during the operational phase because: 1) traffic safety has been taken into account in the recent upgrading of the Henties Bay road to bitumen standard by constructing turning lanes to the desalination plant; 2) noise from the plant cannot be heard from the road which passes close-by and has no effect on the residents of Wlotzkasbaken; and 3) visual impact has


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been avoided by designing the buildings to blend well into the desert landscape. The only exception is the electrical substation that unfortunately had to be built according to NamPower’s standard design. AVENG Water is ISO 9002-certified and has its own policies, strategies and procedures related to health, safety and environmental management. In case any procedures should be missing they will use the relevant documents of Orano. All the environmental mitigation and monitoring actions as described in the ESIA and this updated EMP will continue to be carried out in accordance with the applicable procedures.


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4 Mitigation Tables

The mitigation tables describe the mitigation measures that are implemented to address the environmental and social impacts during operations and closure, as well as monitoring and aftercare. Table 4.1 General mitigation measures to be applied throughout the operational phase

Activity / facility

Aspect Impact Mitigation Responsibility Frequency

Operating the plant

Environmental awareness

Various impacts on the environmental and third parties

All site personnel will be inducted prior to commencing work and sign acknowledgement of the induction. In addition to health and safety the induction will include the main points of this EMP to ensure that all workers are trained in good environmental practices and made aware that the plant is operating close to the Dorob National Park. Therefore all activities are confined to within the fenced plant area and along the service track.

AVENG Plant Manager

Ongoing (prior to new personnel commencing work)

All employees are familiar with the emergency response plans and trained in emergency response through formal training sessions, toolbox talks, and regular drills.

Once off training Ad hoc talks Quarterly drills

Third party access

Strict access control is maintained and no visitors are allowed on site without the express permission of the Plant Manager.

Ongoing

Water use Resource use Wastage of water Ensure that the ‘reduce, reuse and recycle’ philosophy is applied to minimise wastage of water resources.

Product Water

Final product water quality

Impact on third party water users and human health

Conduct regular water quality tests to confirm that the plant continues to operate at its design specification. Undertake routine monitoring with in-line probes to ensure that water exiting the plant is fit for human consumption in accordance with the NamWater relevant drinking water standards. Aveng Management shall notify NamWater immediately of any transgressions in terms of the water quality standards, discontinue distribution, and institute measures to correct the problem.

Maintenance Routine maintenance and repairs to be carried out to ensure that the desalination plant continues to operate in accordance with the approved design.

AVENG Plant Manager

Ongoing

Handling, storage and disposal of waste

Waste management

Incorrect management of waste and effluent causing visual impact (littering), soil and water pollution

Apply the waste hierarchy in order of preference, i.e. waste avoidance, waste reuse, waste recycling or reclamation, waste treatment and waste disposal.

Littering, burying or burning of waste on site is prohibited. Domestic waste disposal bins are used and emptied at appropriate intervals. Waste is disposed of at the Swakopmund landfill. Use of the Wlotzkasbaken landfill is prohibited.

Handling, treatment and discharge of domestic effluent

Current sewage system to be used until new STP is in place: Discharge all effluent into the existing conservation tanks, pump out tanks as required to prevent overflow and transport effluent to the municipal treatment plant at Swakopmund or Walvis Bay.

As required to avoid overflow

Pump the collected sludge from the conservation tanks by honeysucker and transport it to the municipal treatment plant at Swakopmund.

At least 6 monthly (or as required to avoid overflow)


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Activity / facility


New sewage system: Install and operate the STP according to design specifications. Ongoing

Route the treated effluent to the desalination plant outlet stream, i.e. mixing this with the brine from the desalination plant being discharged into the sea.

Ongoing

Monitor effluent quality from STP to ensure it meets Namibian environmental standards for discharge to the environment (refer to Appendix B of the 2019 EIA Amendment Report for the proposed new STP).

6 monthly or as stated in the permit

The required domestic and industrial effluent disposal exemption permit will be applied for and kept up to date.

Orano QHSE Specialist

Ongoing

Sewage spills Contamination of soil, surface water due to spills, leakages, inadequately operating plant etc.

Pollution will be prevented through basic infrastructure design and regular maintenance of equipment.

Constant monitoring must take place so that any spills or leakages can be contained and cleaned up immediately.

AVENG Plant Manager

Ongoing

The STP operation and associated infrastructure will be monitored on a weekly basis to ensure no spillages occur.

AVENG HSE Officer

Weekly

Hydrocarbons used on site

Hazardous

substances

management

Hydrocarbon pollution of soil and water

Store hydrocarbons in bunded areas and check tanks for leaks. Vehicles to be regularly serviced to reduce oil leaks. Used solvents, oils and grease to be kept in sealed containers and recycled or disposed of at the Walvis Bay hazardous waste site.

Spill kits will be readily available on site. Employees and/or contractors will be shown how to use the spill kits to enable containment and remediation of hydrocarbon pollution incidents.

Contaminated soil or absorbent must be taken to a registered hazardous waste site and disposal certificates must be kept on file.

AVENG Plant Manager

Ongoing

Handling and storage of chemicals used at the desalination plant

Chemical pollution of soil and water

Chemicals used for conditioning seawater for membrane treatment and for cleaning the membrane elements (antiscalant Vitec SR, hydrochloric acid, sulphuric acid, chlorine gas, caustic soda, sodium hypochlorite and sodium metabisulphite) are stored securely in dedicated areas and handled in accordance with standards and legislation.

Pollution will be prevented through basic infrastructure design and through maintenance of equipment.

MSDS are readily available and employees are aware of their content, especially first aid and spill response measures. Periodic checks for leaks from storage tanks or containers are carried out.

Disposal of empty chemical containers

Dispose of empty containers as per the MSDS. Empty containers (hazardous) to must be taken to a registered hazardous waste site and disposal certificates must be kept on file.

Plant infrastructure

Visual management

Visual intrusion Keep buildings well maintained to ensure that visual intrusion is kept to a minimum. Fencing will be inspected and maintained to ensure that it remains intact. Lighting to be maintained so that directionality is not affected by wear and tear and that adequate lighting is available at all times.

AVENG Plant Manager

New STP to blend in with the existing desalination plant infrastructure. Orano / AVENG Management

Design and construction phase

All materials should be stockpiled in a neat and orderly fashion in designated areas. AVENG Plant Manager

Ongoing


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Activity / facility


Operating the plant, vehicle movement and general site activities

Air quality – dust

Soil, flora and fauna impacts

Keep a complaints register. In the event of complaints received from third parties, carry out further dust and/or noise monitoring and compare results with those obtained from monitoring in 2009-2018.

Orano QHSE Specialist and Communication Consultant

When complaints are received.

Noise Public nuisance

Seawater intake

Biodiversity (fauna and flora)

Impact on marine fauna and flora

The peak velocity at the intake should not exceed ~0.15 m/s, so as to ensure that fish and other organisms can escape the intake current.

Orano / AVENG Management

Design phase

Continue using Vitec SR antiscalant because it has been specially developed for sea water application where biodegradability is important.

AVENG Plant Manager

Design phase and ongoing

Ensure a water abstraction permit is in place and comply with its conditions. Orano / AVENG Management

Ongoing

To reduce the consumption of chlorine as a marine growth inhibitor, pigging of intake and discharge pipelines should be regularly undertaken.

AVENG Plant Manager

At least annually

Brine discharge

Ensure discharge permit is in place and comply with its conditions. Orano QHSE Specialist

Ongoing

Discharge brine into open tank to ensure aeration when sodium metabisulphite is used as a neutralizing agent for chlorine.

AVENG Plant Manager

Ongoing

Maintain the brine discharge system that is installed with diffusers to achieve the dilution of brine concentration to the seawater background concentration within 30 metres of the point of discharge.

Annually

Consumption of treatment chemicals per cubic metre of water treated should be within 10% of the design standard on average for the year. Discharge all used chemicals into the brine tank for neutralisation and dilution.

Ongoing

Effluent quality monitoring

Seawater quality

Deterioration of quality due to brine salinity and discharged pollutants

Physiochemical monitoring of the brine: Real-time monitoring instruments / probes are positioned on the seawater intake and the brine discharge streams. These instruments provide data on volumes, electrical conductivity, dissolved oxygen, and other relevant parameters. Where anomalous readings are detected in these indicator readings, an investigation is initiated, and additional water samples are taken for laboratory testing to determine the underlying cause and identify corrective actions.

AVENG Plant Manager

Ongoing

Every six months, samples have to be taken from the brine discharge system and sent for external laboratory analysis to confirm that the plant is operating within its expected design parameters and to confirm that the chemical profile of the discharge matches the expected values.

Six-monthly

Marine environment monitoring

Biodiversity (fauna and flora)

Impact on marine fauna and flora

Monitor the salinity and iron concentration of seawater quality at the edge of the mixing zone (i.e. 30 m from the discharge point). Comply with the ANZECC 2000 limits relevant to the Namibian seawater background quality): Salinity “Low-risk trigger concentrations for salinity are that the median (or mean) salinity should lie within the 20%ile and 80%ile of the ambient salinity distribution in the reference system(s). The old salinity guideline (ANZECC 1992) was that the salinity change should be <5% of the ambient salinity”.


Annually


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Activity / facility


Iron “Insufficient data to derive a reliable trigger value. The current Canadian guideline level is 300 μg/ℓ”.

The oceanic water quality monitoring programme will be maintained throughout the desalination plant operation period on an annual basis. This will include ad hoc monitoring of the marine environment for changes whenever divers inspect the intake and outlet facilities. Results will be reported on an annual basis and action taken if negative impacts are detected.

AVENG Plant Manager

Annual and ad hoc

Operation of desalination plant and pipeline to the mine

Impact on terrestrial fauna and flora

Avoid the presence of open water as this could attract wildlife and insects. Fix water leaks (including leaks from the water pipeline to the mine) promptly.

Ongoing

Managing employees, contractors and visitors

Poaching and setting of traps is strictly prohibited and anyone found poaching will be prosecuted.

Snakes, scorpions and bees are not to be killed, unless they pose an immediate and unavoidable danger to human safety. The area must be vacated until the wildlife has been moved to a safe place

and released. Vehicle movement along the pipeline track to the mine

Traffic management

Impact on land surface, fauna and flora

Only the designated service track along the pipeline may be used for inspection of the pipe and power lines. Enforce the speed limit of 70 km/h.

Traffic safety and access control

Signage will be inspected periodically and maintained to ensure that it is visible and legible.

Table 4.2 Mitigation measures relating to socio-economic activities to be applied throughout the operational phase

Activity Aspect Impact Mitigation Responsibility Frequency

Employment and retrenchment

Local employment Benefits for local communities

Give preference to locals when filling vacancies. Abide by the conditions stipulated in the Labour Act (No. 6 of 1992) and newer versions and the Affirmative Action (Employment) Act No. 29 of 1998.

AVENG Plant Manager

When employing new people

Capacity and quality of labour

Promote development of the workforce through training. Make programmes for skills development available to all workers.

Ongoing

Economic, psychological and social impacts of retrenchment

Develop a retrenchment policy to deal with these impacts. If possible provide counselling services three months before departure, assess training needs, and provide voluntary after-hours training programmes in appropriate alternative fields of employment.

During closure plan preparation

Local economic development

Sustainability of local economy

Dependence Implement mechanisms to promote local procurement and give preference to local service providers.

Ongoing

Health and wellness

Health awareness Spread of disease Implement wellness programmes to ensure comprehensive HIV/AIDS and TB awareness and testing, toolbox talks or peer educator initiatives, maternal health awareness.

Ongoing


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Community and stakeholder relations

Promote transparency and build relationships

Stakeholder concerns and misperceptions about desalination impacts

Implement a stakeholder engagement strategy to monitor relations with stakeholders, record grievances and partnerships, keep regular contact with all stakeholder groups.

Orano Communication Consultant

Ongoing

Keep a register of public complaints, address and follow up complaints and give feedback to members of the public. Any grievances raised should be responded to promptly. The register for the desalination plant is kept at the Orano office in Swakopmund.

Ongoing

Table 4.3 Mitigation measures to be applied during closure


Closure vision Sustainable operation

Socio-economic impact The preferred option at mine closure is for the desalination plant to be handed over to the national water supplier or another operator who will continue using it to supply water to the region.

Orano Managing Director

5 years before mine closure

Infrastructure removal and site rehabilitation

Land surface disturbance

Habitat loss All infrastructure i.e. desalination plant, inlet and outfall pipes, desalinated water pipeline, booster pump stations and service track should be removed unless an alternative use has been identified.


During closure plan preparation

Cut-and-fill areas must be backfilled and graded to resemble the original landscape forms. Compacted areas and roads are to be ripped before smoothing out the surface. Restore hydrological drainage patterns as far as possible.

Air quality – dust Soil, flora, fauna impact Dust control measures must be applied during demolition and restoration work.

Non-hazardous waste management

Pollution Steel and reusable non-hazardous material to be salvaged and sold. Non-hazardous waste that cannot be recycled to be taken to municipal landfills. Concrete foundations and buried pipes to be removed. Building rubble to be backfilled into the excavation to restore the original site profile.

Demolition contractor

During closure

Hazardous waste management

Pollution Demolition sites to be inspected for hydrocarbons and chemicals. Any hazardous materials and chemicals to be returned to suppliers or taken to the hazardous waste facility in Walvis Bay. Remediate all soil pollution.

Socio-economic

Workforce retrenchment

Socio-economic impact A detailed closure management plan must be developed. Ensure that AVENG has a plan to address retrenchment impacts, e.g. alternative livelihood options. Early engagement with workforce, labour union and authorities to be undertaken to determine the most appropriate management measures.

AVENG Management

1 year before closure

Aftercare Land surface and biodiversity

Effective restoration Monitor site stability and effectiveness of restoration measures, as well as ecological functioning over several years after closure.


3 years after closure


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Appendix A –Environmental Clearance Certificate

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