Environmental Assessment for the Proposed Police Fuel Depot in Ncaute Scoping Report – Public Review

SEPTEMBER 2014

ENVIRONMENTAL ASSESSMENT FOR THE PROPOSED POLICE FUEL DEPOT IN NCAUTE SCOPING REPORT – PUBLIC REVIEW

MINISTRY OF SAFETY AND SECURITY ENVIRO DYNAMICS CC

PROJECT NAME Proposed Police Fuel Depot in Ncaute

STAGE OF REPORT Draft Scoping Report for Public Review

CLIENT Meyer Consulting Engineers Enquires: Henk Meyer Tel: (061) 258 708 E-Mail: [email protected]

LEAD CONSULTANT Enviro Dynamics CC Enquires: Sheldon Husselmann Tel: (061) 223-336 E-Mail: [email protected]

DATE OF RELEASE September 2014

CONTRIBUTORS TO Sheldon Husselmann, Quzette Bosman, Eddy Kuliwoye THIS REPORT Internal Reviewer: Norman van Zyl

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DECLARATION

I hereby declare that I:

 have knowledge of and experience in conducting assessments, including knowledge of the Environmental Management Act (7 of 2007), its regulations and guidelines that have relevance to the proposed activity;

 have performed the work relating to the application in an objective manner, regardless of whether or not the views and findings were favourable to the applicant;

 have complied with the Act, and its regulations, guidelines and other applicable laws.

I also declare that there is, to my knowledge, no information in my possession that reasonably has or may have the potential of influencing –

 any decision to be taken with respect to the application in terms of the Act and its regulations; or

 the objectivity of this report, plan or document prepared in terms of the Act and its regulations.

Norman van Zyl Environmental Assessment Practitioner (EAP)

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EXECUTIVE SUMMARY

INTRODUCTION

The Ministry of Safety and Security (MSS) intends to construct a fuel depot as part of a police station in the Ncaute Village, located 60 km south of Rundu. This fuel depot will assist the Namibian Police Force to better serve and protect the people located in and around the Ncaute Village.

A Desktop Groundwater Impact Assessment was conducted at a Scoping level by Mr P. Botha

PROJECT DESCRIPTION

In order to help the local police force to serve the community and fight crime a fuel depot needs to be developed in the Ncaute Village. The nearest fuel station is located in Rundu, approximately 60 km north of the police station.

The construction of the depot involves the following:

 The installation of two 23 m3 Underground Storage Tanks (USTs). The storage tanks will be constructed according to the applicable South African National Standards (SANS) and will be housed in a concrete bunker. The bunker will have a capacity of 101 m3 and will be lined with a fuel resistant sheeting;  One tank will store 95 octane petrol and the other diesel;  Installation of one suction dispenser pump with 2 hoses – 1 for unleaded petrol and 1 for automotive gas oil (diesel);  A leak-proof filler box with the capacity to contain the contents of a bulk fuel delivery vehicle discharge hose and no less than 35 ℓ.  All underground fuel lines will be installed in sleeves that start and end in sealed manholes;  The dispenser pumps will be located at the centre of a 9 m X 9 m concrete platform with a canopy covering the area of the platform. The platform will be contoured to channel all spilled hydrocarbons to wastewater drains;  Installation of a 100 kVA back‐up generator.

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Alternatives considered were the ‘no-go’ alternative and Underground Storage Tank (UST) design alternatives. If the proposed project is not implemented fuel needs will most probably be met through the storage of fuel in two 2200 litre above ground steel storage tanks. The police station will then most probably need to downscale its operations owing to lack of available fuel. An increase in negligent behaviour is likely owing to the nature of the rudimentary fuel store. This alternative is therefore not recommended. In terms of UST design the Glass-Reinforced Plastic (GRP) coated steel UST is the preferred alternative because it is has a higher resistance to corrosion than the double-walled steel UST alternative

The MSS will be responsible for the operation and maintenance of the fuel depot and will accordingly be responsible for training all those who utilise the fuel depot.

LEGISLATION AND RECEIVING ENVIRONMENT

Various national legal instruments have provisions applicable to the proposed project. The most important provisions are those pertaining to the EIA Regulations, the Petroleum Products Regulations, the Health and Safety Regulations and the Water Act.

The proposed project will have an impact on sensitive aspects of the receiving environment, both biophysical and socio-economic. The key environmental sensitivities include those pertaining to groundwater and health and safety.

PUBLIC CONSULTATION

Public participation was carried out in accordance with the EIA Regulations. Various stakeholders at national, regional and local level were identified and their input solicited. Particular effort was exerted to involve stakeholders at a local level – those living in the Ncaute Village.

Based on the comments received during the public meeting held in Ncaute on Wednesday, 28 May 2014, the main concerns were:

 Perceived exclusion from state-funded provision of fuel, expressed by community members, regarding the fact that the fuel depot was not open to the public; and  Concerns regarding employment once the fuel depot becomes operational.

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IMPACT ASSESSMENT

The issues identified by Enviro Dynamics and along with those identified during the public consultation process are assessed using a range of assessment criteria. The application of these criteria involves a balanced consideration of duration, extent, and intensity/magnitude, modified by probability, cumulative effects, and confidence in order to determine significance. Mitigation measures are outlined for each impact.

CONCLUSIONS AND RECOMMENDATIONS

The key impact – Impact on groundwater, and its mitigation measures are outlined below:

The pollution of the groundwater in the area is considered an impact with a high significance rating. The main areas of concern are the total failure of the Underground Storage Tanks (USTs) (improbable), oil-water separator soakaway, the need for training of all personnel utilising the fuel depot, sewage management during construction and monitoring and maintenance of the fuel depot. The latter four concerns are linked to highly probable impacts. The mitigation measures prescribed in this report and the EMP are however, sufficient to address this potential impact.

It is the opinion of Enviro Dynamics that sufficient information is available to address all impacts identified during this Scoping-Level Environmental Assessment through the recommended mitigation and management actions for the construction, operation and decommissioning phases of the proposed project. Should the recommendations included in this report and the EMP be implemented, the significance of the impacts can be reduced to reasonably acceptable standards and durations.

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It is therefore recommended that the proposed project and the following associated activities receive Environmental Clearance with it, provided that the recommendations above and the EMPs are implemented:

 The construction of a facility for the underground storage of petrol and diesel; and  The storage handling of petrol and diesel with a combined capacity of 46 m3.

Furthermore the training of applicable MSS personnel should be a condition of approval.

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Table of Contents

EXECUTIVE SUMMARY ...... iv

LIST OF FIGURES AND TABLE ...... x

LIST OF ABBREVIATIONS ...... xi

LIST OF APPENDICES ...... xii

1 INTRODUCTION ...... 1

1.1 BACKGROUND ...... 1

1.2 TERMS OF REFERENCE ...... 2

1.3 ADDITIONAL STUDIES ...... 2

2 PROJECT DESCRIPTION ...... 3

2.1 NEED FOR THE PROJECT ...... 3

2.2 FUEL DEPOT ...... 3

2.3 CONSTRUCTION ...... 5

2.3.1 WASTE MATERIALS ...... 5

2.3.2 EMPLOYMENT CREATION ...... 5

2.4 OPERATION AND MAINTENANCE ...... 5

2.5 DECOMMISSIONING ...... 6

2.6 ALTERNATIVES ...... 7

3 LEGISLATION, POLICIES AND GUIDELINES ...... 9

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4 RECEIVING ENVIRONMENT ...... 11

4.1 BIOPHYSICAL ENVIRONMENT ...... 11

4.1.1 VEGETATION ...... 11

4.1.2 GROUNDWATER ...... 11

4.2 SOCIAL ENVIRONMENT ...... 12

5 PUBLIC CONSULTATION ...... 14

5.1 INTERESTED AND AFFECTED PARTIES (I&APs) ...... 14

5.2 COMMUNICATION WITH I&APs ...... 15

6 IMPACT ASSESSMENT ...... 17

6.1 METHODOLOGY EMPLOYED FOR THE IMPACT ASSESSMENT ...... 17

6.2 ASSESSMENT OF IMPACTS ...... 22

6.3 DISCUSSION ...... 24

7 CONCLUSIONS AND RECOMMENDATIONS ...... 26

8 REFERENCES ...... 28

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LIST OF FIGURES AND TABLE

Figure 1: Regional context of the proposed project ...... 1

Figure 2: Glass-Reinforced Plastic Steel UST ...... 4

Figure 3: Fuel depot platform and canopy ...... 4

Figure 4: 2200 ℓ fuel storage tank ...... 7

Figure 5: Location of the fuel depot ...... 8

Figure 6: Public meeting held in Ncaute on 28 May 2014 ...... 15

Figure 7: Screening process to determine key issues ...... 18

Table 1: Comparison of two Underground Storage Tank (UST) designs ...... 7

Table 2: Water related sensitivities ...... 12

Table 3: Sensitivities related to social aspects ...... 13

Table 4: Identification of Interested and Affected Parties ...... 15

Table 5: Definitions of each of the criteria used to determine the significance of impacts ...... 19

Table 6: Definitions of the various significance ratings ...... 22

Table 7: Assessment of impacts ...... 23

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LIST OF ABBREVIATIONS

AIDS Acquired Immune Deficiency Syndrome

BID Background Information Document

CV Curriculum Vitae

DEA Directorate of Environmental Affairs

EA Environmental Assessment

ECC Environmental Clearance Certificate

EIA Environmental Impact Assessment

EMP Environmental Management Plan

GG Government Gazette

GN Government Notice ha Hectare

HIV Human Immunodeficiency Virus

I&APs Interested and Affected Parties km Kilometre kVA Kilo Volt Ampere

ℓ Litre m Metre

MET Ministry of Environment and Tourism

MSS Ministry of Safety and Security

RN Republic of Namibia

UST Underground Storage Tank

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LIST OF APPENDICES

Appendix A CV – Stephanie van Zyl

Appendix B Environmental Management Plan

Appendix C Groundwater Impact Assessment Report

Appendix D Issues and Responses Trail

Appendix E Newspaper Notices

Appendix F Stakeholders List

Appendix G Background Information Document

Appendix H Public Meeting Minutes

Proposed Police Fuel Depot in Ncaute Draft Scoping Report for Public Review September 2014

1 INTRODUCTION

1.1 BACKGROUND

The “[C]onstruction of filling stations or any other facility for the underground or aboveground storage of dangerous goods, including petrol, diesel, liquid petroleum…” is an activity that requires an Environmental Clearance Certificate (ECC) before it may be undertaken (Republic of Namibia (RN): Ministry of Environment and Tourism (MET), 2012: s9.5). Consequently Meyer Consulting Engineers (on behalf of the MSS) appointed Enviro Dynamics CC to conduct an Environmental Assessment (EA) for the proposed project.

This Scoping Report is the culmination of the first stage of this EA process. During this Scoping Stage, information was gathered concerning potential impacts whether positive or negative in nature and their relative significance was determined. This document provides information regarding whether detailed investigation is required or not. If all issues/impacts can be addressed without further investigation, this document will be submitted to the Directorate of Environmental Affairs (DEA) along with the Environmental Management Plan (EMP). Sheldon Husselmann is the Environmental Assessment Practitioner (in training) who conducted the EA under the supervision of Norman van Zyl who is a qualified and a recognised Environmental Assessment Practitioner (see Appendix A for CV).

Figure 1: Regional context of the proposed project 2

1.2 TERMS OF REFERENCE

The Terms of Reference for the proposed project is based on the requirements set out by the Environmental Management Act (2007) and its Regulations (2012). The process covered the following steps, which are reported on in this document as follows:

 Provide a detailed description of the proposed activity (Chapter 2);  Identify all legislation, policies and guidelines that have reference to the proposed project (Chapter 3);  Identify existing environmental (both ecological and socio-economic) conditions of the receiving environment in order to determine environmental sensitivities (Chapter 4);  Inform Interested and Affected Parties (I&APs) and relevant authorities of the details of the proposed development and provide them with a reasonable opportunity to participate during the process (Chapter 5);  Consider the potential environmental impacts of the development, and assess the significance of the identified impacts (Chapter 6).  Outline management and mitigation measures in an EMP (Appendix B) to minimise and/or mitigate potentially negative impacts, which cannot be avoided.

1.3 ADDITIONAL STUDIES

The following specialist study was conducted at a scoping level. Sufficient information has been generated for the impacts identified to date within the specialist’s field of study to warrant a Scoping-Level investigation:

 Groundwater Impact Study – Mr P. Botha (Appendix C).

The following section provides a detailed description of the proposed project and its components.

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2 PROJECT DESCRIPTION

2.1 NEED FOR THE PROJECT

The Ministry of Safety and Security (MSS) has commissioned the construction of a fuel depot to service the needs of a police station located within the Ncaute village, south of Rundu (Figure 5). This fuel depot will enable the local police force to serve the community and fight crime. The nearest fuel station is located in Rundu, approximately 60 km north of the police station. In addition the bulk storage of fuel will enable cost effective transfer, storage and distribution of fuel for police-related endeavours in the areas surrounding Ncaute.

2.2 FUEL DEPOT

The depot will be constructed in the Ncaute village, which is located approximately 60 km south of Rundu (Figure 5). The construction of the depot involves the following:

 The installation of two 23 m3 Underground Storage Tanks (USTs) (Figure 2) and fitted with leak detectors and observation wells. The storage tanks will be constructed according to the applicable South African National Standards (SANS) and will be housed in a concrete bunker. The bunker will have a capacity of 101 m3 (6.7 m X 6.3 m X 2.4 m) and will be lined with a fuel resistant (High Density Polyethylene) sheeting;  One tank will store 95 octane petrol and the other diesel;  Installation of one suction dispenser pump with 2 hoses – 1 for unleaded petrol and 1 for automotive gas oil (diesel);  A leak-proof filler box with the capacity to contain the contents of a bulk fuel delivery vehicle discharge hose and no less than 35 ℓ.  All underground fuel lines will be installed in sleeves that start and end in sealed manholes;  The dispenser pumps will be located at the centre of a 9 m X 9 m concrete platform with a canopy covering the whole area of the platform (see Figure 3 for example). The platform will be contoured to channel all spilled hydrocarbons to wastewater drains;  Installation of a 100 kVA back‐up generator.

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Figure 3: Fuel depot platform and canopy Figure 2: Glass-Reinforced Plastic Steel UST

The bulk services and infrastructure requirements are as follows:

Road access: The site is accessible from the district road D3400 (Figure 5) which links up with the B8 (a main road) to the north, which links Rundu with Grootfontein.

Water supply: Water will be supplied by a borehole, which has been sunk for the police station and fuel depot.

Electricity reticulation: The Northern Regional Electricity Distributor (NORED) will supply the depot and associated infrastructure with electricity.

Wastewater disposal: Wastewater drains and associated pipelines will be installed on site. The drains will discharge into a three-chamber oil-water separator system to be installed on site. The capacity of the system is 2.4 m3. Wastewater, which passes through the system will discharge into a wastewater treatment plant installed on-site. This treatment plant is currently (at the time of writing this report) in the design phase.

Fire Protection: Once operational the fuel depot will be equipped with the following:

 Two 9 kg dry chemical powder type fire extinguishers;  Hydraulic hose reel with 30 m of 25 mm rubber hose and 5 mm shut off nozzle and 50 mm supply leading with pressure gauge; and  Appropriate safety signage.

All the abovementioned equipment should be positioned according to the applicable SANS.

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2.3 CONSTRUCTION

The estimated time for construction is approximately 3 months.

2.3.1 WASTE MATERIALS

Besides left-over concrete and various other residual building material, normal domestic waste such as plastic bags, tins, bottles, paper, and packaging waste will be generated. Waste generation is an obvious impact of any project and needs to be managed in an appropriate manner in order to minimise the proposed project’s ecological footprint. Waste management is addressed in the EMP for the proposed project.

2.3.2 EMPLOYMENT CREATION

Approximately 25 labourers will be used during the construction of the Fuel Depot of which approximately 8 workers (30%) will be housed at a temporary campsite located within close proximity to the site (0.5-1 km).

2.4 OPERATION AND MAINTENANCE

In keeping with the applicable SANS and in an effort to prevent groundwater pollution, fail-safe devices have been incorporated into the design of the USTs. One such device is a leak detection system, which includes ventilation pipes and an automatic pipe leak detector. “Each submersible pumping system shall have a leak detector that automatically checks the integrity of the pipework on the pressure side of the pump at a minimum leak rate of 11.5 ℓ per hour at 70 kPa” (South African Bureau of Standards (SABS), 2010: 18). In the event of tank leakage into the bunker, the ventilation pipes allow fuel odours to be detected during routine inspections. The automatic pipe leak detector is linked to the submersible pumping system and will shut down pumping operations in the event of a leak.

Once operational the fuel depot will provide fuel to police vehicles servicing the area. The two USTs will be filled by standard fuel tanker trucks as and when required. The MSS will be responsible for the operation and maintenance of the fuel depot. The MSS will accordingly be responsible for training the relevant staff members who will be responsible for:

 Filling of the USTs and dispensing of fuel;  Monitoring fuel levels and leak detection; and  Monitoring and maintenance of 3-chamber oil-water separator.

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Hazardous substances will be stored and handled and produced on-site during the operation phase these include hydrocarbons, tank sludge and waste water contaminated with hydrocarbons. The 2.4 m3 three-chamber oil-water separator system will be cleaned daily to ensure optimal functioning of the system.

Emergency procedures are essential to the operation of a Fuel Depot and a qualified occupational health and safety professional will train all MSS personnel utilising the Fuel Depot.

2.5 DECOMMISSIONING

It is envisaged that the proposed project will continue as long as the settlement exists, hence decommissioning is not expected. However measures will be prescribed in the EMP (Appendix B) in the event that the proposed project needs to be decommissioned.

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2.6 ALTERNATIVES

The ‘no-go’ alternative depicts the scenario where the proposed project is not implemented. If the proposed project is not implemented fuel needs will most probably be met through the storage of fuel in two 2200 litre above ground steel storage tanks (Figure 4). This scenario will require more frequent bulk transport of fuel to refill the tanks. The police station will most probably need to downscale its operations Figure 4: 2200 ℓ fuel storage tank owing to lack of available fuel. In addition it is likely that less stringent health and safety procedures will be necessary for this scenario and this may potentially lead to an increase in negligent behaviour. For these reasons the “no-go” alternative is not recommended.

Two alternatives were considered in terms of UST design. The main differences between these two designs are displayed in Table 1 below.

Table 1: Comparison of two Underground Storage Tank (UST) designs

UST ALTERNATIVE 1 UST ALTERNATIVE 2

Tank Wall layers Single Double

Material Glass-Reinforced Polyester-coated (GRP) Steel Steel

Resistance to Excellent Good corrosion

Life expectancy 100 years 100 years (in non-corrosive conditions)

Type of welds Nupigeco Nupigeco

Life expectancy 100 years 100 years of welds

The GRP tank was developed subsequent to the Double-Walled Steel Tank (DWST) due to the limitations associated with the design of the DWST. The double-walled steel tank is protected by keeping the volume between the two walls under pressure. In the event that the pressure between the two walls falls, the system shuts down because a leak is expected. The main risk factor for the DWST is the limited lifespan of the steel when exposed to corrosive substances contained to varying degrees in different soils. The GRP coated steel addresses the issue of corrosion, evidenced by its 100 year (unlimited) expected lifespan.

Proposed Police Fuel Depot in Ncaute Draft Scoping Report for Public Review September 2014

Figure 5: Location of the fuel depot

3 LEGISLATION, POLICIES AND GUIDELINES

The pursuit of sustainability, with respect to any project, is guided by a sound legislative and policy framework. This section provides a review of applicable and relevant Namibian legislation, policies and guidelines. This review serves to inform the Developer of the requirements and expectations, as laid out in terms of these instruments, to be fulfilled before the proposed project may commence. The findings of the abovementioned review are summarised below.

LEGISLATION/ RELEVANT PROVISIONS IMPLICATIONS FOR THIS POLICY/ GUIDELINE PROJECT

Namibian Chapter 11 Article 95: Promotion of the Welfare of Ecological sustainability Constitution First the People. should inform and guide Amendment Act 34 this project. of 1998

Environmental  Requires that projects with significant The EMA and its Management Act environmental impact are subject to an regulations should inform EMA (No 7 of 2007) environmental assessment process (Section 27). and guide this EA  Details principles which are to guide all EAs. process.

Environmental  Details requirements for public consultation Impact Assessment within a given environmental assessment (EIA) Regulations GN process (GN 30 S21). 28-30 (GG 4878)  Details the requirements for what should be included in a Scoping Report (GN 30 S8) and an Assessment Report (GN 30 S15).

Labour Act 11 of Details requirements regarding minimum wage The MSS should ensure 2007 and working conditions (S39-47). that all contractors involved during the Health and Safety Details various requirements regarding health and construction, operation Regulations GN safety of labourers. and maintenance of the 156/1997 (GG 1617) proposed project comply Public Health Act 36 Section 119 states that “no person shall cause a with the provisions of of 1919 nuisance or shall suffer to exist on any land or these legal instruments. premises owned or occupied by him or of which he is in charge any nuisance or other condition liable to be injurious or dangerous to health.”

Water Act 54 of 1956 The Water Resources Management Act 24 of 2004 The protection of ground is presently without regulations; therefore the Water and surface water Act No 54 of 1956 is still in force: resources should be a  Prohibits the pollution of underground and priority. The main threats surface water bodies (S23(1)). will most likely be  Liability of clean-up costs after closure/ concrete and abandonment of an activity (S23(2)). hydrocarbon spills during construction and hydrocarbon spills during operation and

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LEGISLATION/ RELEVANT PROVISIONS IMPLICATIONS FOR THIS POLICY/ GUIDELINE PROJECT

maintenance.

Petroleum Products  “No person shall… operate a consumer  Proponent needs to and Energy Act 13 of installation, unless authorised to do so under a apply to MME for a 1990 and the certificate” (PPR: S 3(1)(b)). consumer installation Petroleum Products  “No person shall possess or store any fuel except certificate. Regulations (PPR) under authority of a licence or a certificate”  Proponent needs to (PPR: S 3(2)). comply with conditions  Chapter 2, Part IV (Sections 16-24) of the PPR applicable to the details various provisions relating to certificates Consumer Installation with respect to consumer installations. Certificate.  “The Minister may… apply… any specification or  Proponent need to standard of the South African Bureau of submit an annual Standards… which… pertains to the handling, report with respect to storage, distribution and composition of the underground petroleum products…” (PPR: S 44(1)). storage tanks.  “Every…certificate-holder shall with regard to any replacement or installation of a storage tank, or a remaining storage tank… annually not later than 28 February, duly complete Form PP/10 as set out in Annexure B…” (PPR: S46(2)).  Par IV of Chapter 3 (Sections 47&48) deals with duties regarding fires and explosions, while (S 4) details measures to be taken in the event of product spills.  Section 50 details provisions related to cost recovery in respect of incidents involving product spills.

The provisions most important, in terms of guiding this EA process from those listed above are those contained in:

 The EIA Regulations;  The Petroleum Products Regulations;  The Health and Safety Regulations; and  The Water Act.

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4 RECEIVING ENVIRONMENT

This chapter provides an overview of the baseline biophysical and social environmental conditions, with which the proposed project will interact. This information has been sourced from the specialist desktop study, observations made during a site visit and existing literature from previous research conducted in the area. This chapter also identifies sensitivities pertaining to key environmental features as well as potential impacts resulting from the proposed project in relation to these sensitivities.

4.1 BIOPHYSICAL ENVIRONMENT

4.1.1 VEGETATION

The project area is located in within the North-eastern Kalahari Woodland Biome which in turn is a subset of the larger Tree-and-shrub Savanna Biome. This North- eastern Kalahari Woodland biome is characterised by relatively high plant diversity with approximately 300-400 plant species (Mendelsohn, et al., 2009), which include several high use-value and protected species including Acacia erioloba (Camel thorn) and Philenoptera nelsii (Kalahari Apple leaf). These species have been observed in the areas surrounding the proposed site, but the site itself is totally void of vegetation.

4.1.2 GROUNDWATER

The summary provided below has be sourced primarily from the desktop groundwater impact assessment conducted by Botha (2014) as part of this Scoping- Level EA process (see Appendix C).

The proposed site is located within the Omatako groundwater basin, which is not located within a state-controlled Water Control Area. Groundwater within the project area is hosted in Kalahari Group aquifers. These aquifers are porous and by definition hold water in intergranular pore spaces (Christelis & Struckmeier, 2001). This means that these aquifers due to their high permeability behave like a sponge and water thus enters these aquifers very easily and rapidly. This makes the groundwater vulnerable to impacts associated with pollution.

Based on existing data obtained from the Ministry of Agriculture, Water and Forestry (MAWF) there are currently 9 known boreholes within a 10 km radius of the proposed site. It should be noted that owing to data gaps there may be more boreholes present. Water has been intersected within area at depths of less than 10 m below

Proposed Police Fuel Depot in Ncaute Draft Scoping Report for Public Review September 2014 12 the surface and at 5 m below the surface on-site. Boreholes in the area produce good quality water at yields of between 5 and 25 m3/hr. The primary water source for the Ncaute Village is abstracted from this groundwater resource. It should be noted that Ncaute does not have any formal domestic sewerage system or surface runoff reticulation system.

The sensitivities and potential associated impacts pertaining to groundwater are outlined in Table 2 below.

Table 2: Water related sensitivities

ENVIRONMENTAL DESCRIPTION SENSITIVITY POTENTIAL FEATURE IMPACTS

Groundwater The project area is underlain by a Presence of a Groundwater porous aquifer, which hosts water of shallow, Class A pollution and Class A quality. This water serves the water quality compromising of potable water needs of the porous aquifer community water community source

4.2 SOCIAL ENVIRONMENT

According to the Namibia Statistics Agency (NSA) (2012), the total population for the Kavango Region (now divided and renamed as Kavango West and Kavango East) is estimated at 223 352 people. The population density is estimated at 4.6 people per km2. About 50% of the population are between the ages of 15 and 59 years, which is the main labour force. Approximately 50% of the main labour force are unemployed, which is substantially higher than the national average unemployment rate, which was estimated at 37% (NSA, 2012).

According to the NSA (2012), the main sources of income per household are: 43% farming, 22% wages and salaries, 12% business operations (non-farming), 6% cash remittance and 13% state pensions.

No statistics pertaining to HIV/AIDS are available for Ncaute, however, the HIV prevalence rate for the Kavango Region is estimated between 26-40% (Ministry of Health and Social Services, 2012), which is one of the highest in Namibia. The national HIV prevalence for Namibia is currently estimated at 13.3%.

The sensitivities and potential associated impacts pertaining to the social environmental features are outlined in Table 3 below.

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Table 3: Sensitivities related to social aspects

ENVIRONMENTAL DESCRIPTION SENSITIVITY POTENTIAL IMPACTS FEATURE

Unemployment Unemployment, estimated at Construction activities Positive: Creation of a 50%, is a concern in the associated with the small number of jobs Kavango Region. proposed project will during construction. require labourers.

Nuisances Construction activity will result The proposed project is  Dust impacts due in the generation of dust and located near to construction noise. residential areas. works and vehicles  Noise impact due to operation of construction vehicles machinery.

Health and safety Hazardous and highly Negligent behaviour or Injury or loss of life due flammable substances will be inadequate health to fires or explosions. handled on-site once the and safety procedures. project is operational.

Some of the construction Potential increase in Increase in HIV/AIDS labour force will be employed HIV/AIDS infection rate infection rate. from beyond the project area owing to risky sexual and this may lead to risky behaviour during sexual behaviour. construction phase in the event of an influx of migrant labour.

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5 PUBLIC CONSULTATION

Public consultation forms an important component of an Environmental Assessment (EA) as it provides potential interested and affected parties (I&APs) with a platform whereby they can raise any issues or concerns relevant to the proposed project. This assists the environmental consultant in considering the full spectrum of potential impacts and to what extent further investigations are needed.

In addition, the public consultation process also grants I&APs an opportunity to review and comment on all the documents produced throughout the EA process. This is done in accordance with both the Environmental Management Act’s EIA Regulations, as well as international best practice principles.

This Chapter details:

 The identified I&APs for the proposed project;  The means of communicating with them; and  A summary of the issues raised during the public consultation process.

A list of all issues and concerns that have been raised during the public consultation process is provided in the Issues and Responses Trail (Appendix D).

5.1 INTERESTED AND AFFECTED PARTIES (I&APs)

Specific I&APs, whom Enviro Dynamics deemed interested in and/or affected by the proposed project, from the broader project area, all tiers of government, and the private (non-state) sector were identified, contacted and registered as I&APs. In addition, notices regarding the project were placed in widely circulated national newspapers (Appendix E) for two consecutive weeks inviting members of the public to register as I&APs. A summary of the stakeholder groups, consisting of authorities and interest groups at national, regional and local level, are presented in Table 4. The complete stakeholders list can be viewed in Appendix F.

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Table 4: Identification of Interested and Affected Parties

LEVEL DESCRIPTION

National Ministry of Environment and Tourism

Ministry of Mines and Energy Ministry of Water, Agriculture and Forestry

Non-Governmental Organisations

SUMMARY Regional Kavango West Regional Council

TAKEHOLDER DATABASE Local Traditional Authorities

S Ncuncuni Constituency

5.2 COMMUNICATION WITH I&APs

Section 21 of the EIA Regulations (RN: MET, 2012) details steps to be taken during a given public consultation process and these have been used in guiding this process. Communication with stakeholders about this proposed development was facilitated through the following means:

 A Background Information Document (BID) was compiled that contained essential information about the project (Appendix G). The BID was sent to all registered I&APs;  Notices were placed in the press, briefly explaining the development and its locality, inviting the public to register as I&APs (Appendix E); and  All I&APs living within close proximity of the project area as well as key community representatives (e.g. traditional authorities) were invited to attend a meeting held in the Catholic Church hall (Figure 6) in Ncaute at 11h00 on Wednesday, 28 May 2014.

Figure 6: Public meeting held in Ncaute on 28 May 2014

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During the public meeting (Figure 6), a description of the project was presented and opportunity given for those present to give their comments and concerns. Those present actively engaged once the floor was open for discussion. The minutes for this meeting are available for review (see Appendix H).

Based on the comments received during the public meeting the main concerns were:

These comments have been recorded in an Issues and Responses Trail (Appendix D). These issues as well as those identified in Chapter 4 are addressed in the following chapter.

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6 IMPACT ASSESSMENT

6.1 METHODOLOGY EMPLOYED FOR THE IMPACT ASSESSMENT

The EIA Regulations (RN: MET, 2012) require “a description of the significance of any significant effects, including cumulative effects, that may occur as a result of the undertaking of the activity”. In order to determine significance each of the potential impacts identified have been subjected to the following questions displayed graphically (steps 1 and 2 - Figure 7) and in tabular form (Table 8) below. These questions form the methodology for assessing the significance of the effects or impacts identified through this EIA process:

1. The first step is to screen out (set aside) all issues/potential impacts, which do not fall within the scope of the proposed project and responsibility of the Ministry of Safety and Security (MSS);

2. The next step is to determine whether sufficient information exists to assess the potential impacts of those that remain. If insufficient information is available to assess (with a high degree of confidence) and recommend mitigation measures to address a given impact further investigation will be required. However, if sufficient information is available to assess (with a high degree of confidence) and recommend mitigation measures to address a given impact, no further investigation will be required and the impact will be addressed in the EMP. Table 6 depicts this process; and

3. To fully understand the significance of each of the potential impacts, it is necessary to subject each to a range of assessment criteria. The application of these criteria, in determining the significance of potential impacts, uses a balanced combination of duration, extent, and intensity/magnitude, modified by probability, cumulative effects, and confidence. The definitions of each of the criteria are contained in Table 5.

Finally based on the answers obtained after applying steps 1-3 a decision can be made regarding the significance of the impact based on three categories – low, medium or high (Table 7).

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Does the issue/potential impact fall within the scope of this EA and the responsibility of the Developer?

YES NO

Sufficient information Insufficient information Issue communicated to assess the impact to assess the impact to applicable authority

No further Further investigation investigation required required

Addressed in Scoping Key impacts identified Report and EMP and addressed in Assessment Report

Figure 7: Screening process to determine key issues

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Table 5: Definitions of each of the criteria used to determine the significance of impacts

DESCRIPTION

NATURE Reviews the type of effect that the proposed activity will have on the relevant component of the environment and includes “what will be affected and how?”

EXTENT Geographic area. Indicates whether the impact will be within a limited area (on site where construction is to take place); local (limited to within 15 km of the area); regional (limited to ~100 km radius); national (limited to the national borders); or international (extending beyond Namibia’s borders).

DURATION Whether the impact will be temporary (during construction only), short term (1-5 years), medium term (5-10 years), long term (longer than 10 years, but will cease after operation) or permanent.

INTENSITY Establishes whether the magnitude of the impact is destructive or innocuous and whether or not it exceeds set standards, and is described as none (no impact); low (where natural/ social environmental functions and processes are negligibly affected); medium (where the environment continues to function but in a noticeably modified manner); or high (where environmental functions and processes are altered such that they temporarily or permanently cease and/or exceed legal standards/requirements).

PROBABILITY Considers the likelihood of the impact occurring and is described as uncertain, improbable (low likelihood), probable (distinct possibility), highly probable (most likely) or definite (impact will occur regardless of prevention measures).

SIGNIFICANCE Significance is given before and after mitigation. Low if the impact will not have an influence on the decision or require to be significantly accommodated in the project design, Medium if the impact could have an influence on the environment which will require modification of the project design or alternative mitigation (the route can be used, but with deviations or mitigation) High where it could have a “no-go” implication regardless of any possible mitigation (an alternative route should be used).

STATUS OF THE A statement of whether the impact is positive (a benefit), negative (a cost), or neutral. Indicate in each case who is likely to benefit and who is likely to IMPACT bear the costs of each impact.

DEGREE OF Is based on the availability of specialist knowledge and other information. CONFIDENCE IN PREDICTIONS

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Table 6: Screening of impacts

POTENTIAL IMPACT STATUS/ NATURE EXTENT DURATION INTENSITY CONFIDENCE/ SIGNIFICANCE SIGNIFICANT NEXT STEP SUFFICIENT /RISK MITIGATION INFORMATION ASSESSMENT DEEMED AVAILABLE? POSSIBLE? Y/N Y/N

CONSTRUCTION PHASE

Soil contamination Hazardous substances utilised Local Temporary Low Yes Low Yes EMP during construction may spill on the ground and contaminate the soil.

Surface and Hazardous substances utilised Local Temporary Low Yes Low Yes EMP groundwater pollution during construction may pollute to short- local groundwater and/or be term transported via local watercourses and contaminate nearby dams.

Increased HIV/ AIDS The potential increase in risky sexual Local Long-term Medium Yes Low Yes EMP infection rate. behaviour associated with non- local contract construction labours may increase the local HIV/AIDS infection rate.

Dust and noise impacts Construction activity will generate Local Temporary Low Yes Low Yes EMP dust and noise which will affect nearby residents.

Limited job Temporary creation of unskilled jobs Local Temporary Medium Yes Low Yes EMP opportunities. during construction of project components and services infrastructure.

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POTENTIAL IMPACT STATUS/ NATURE EXTENT DURATION INTENSITY CONFIDENCE/ SIGNIFICANCE SIGNIFICANT NEXT STEP SUFFICIENT /RISK MITIGATION INFORMATION ASSESSMENT DEEMED AVAILABLE? POSSIBLE? Y/N Y/N

OPERATION AND MAINTENENCE PHASE

Groundwater pollution The local groundwater may be Site- Long-term High No High No Desktop and compromising of polluted by hydrocarbon spills. The specific Groundwater community water local community’s water source in to Local Impact source such an instance would be Assessment compromised.

Injury or loss of life due Negligent behaviour might lead to Site Long-term High Yes High Yes EMP to fires or explosions. fires or even explosions associated specific to with hydrocarbons. Injuries or loss of permanent life could occur in these instances.

Theft Members of the community may Site Temporary Low Yes Low Yes EMP seek to obtain fuel from the fuel specific depot through dishonest means – soliciting favours from MSS personnel or by stealing.

DECOMMISSIONING PHASE

Groundwater pollution In the event that the fuel in the Site- Medium Medium Yes Medium Yes EMP pipelines are not drained before specific term decoupling groundwater will be polluted.

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Table 7: Definitions of the various significance ratings

SIGNIFICANCE RATING CRITERIA

LOW Where the impact will have a negligible influence on the environment and no modifications or mitigations are necessary for the given development description. This would be allocated to impacts of any severity/ magnitude, if at a local scale/ extent and of temporary duration/time.

MEDIUM Where the impact could have an influence on the environment, which will require modification of the development design and/or alternative mitigation. This would be allocated to impacts of medium intensity/magnitude, locally to regionally, and in the short term.

HIGH Where the impact could have a significant influence on the environment and, in the event of a negative impact the activity(ies) causing it, should not be permitted (i.e. there could be a ‘no-go’ implication for the development, regardless of any possible mitigation). This would be allocated to impacts of high magnitude, locally for longer than a month, and/or of high magnitude regionally and beyond.

6.2 ASSESSMENT OF IMPACTS

All impacts included in the table below fall within the scope of this project and responsibility of the Ministry of Safety and Security. By subjecting each of the potential impacts to the criteria stipulated above, it is possible to establish the significance of each. Impacts concerning water have been addressed in greater detail, in Appendix C.

A brief description of the mitigation measures is stated in the table below but detailed descriptions of management actions are contained in the EMP (Appendix B).

Impacts with a “high” significance rating are discussed at the end of this section.

The process of assessing the significance of each of the possible impacts is contained in the table below.

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Table 8: Assessment of impacts

POTENTIAL STATUS/ NATURE EXTENT DURATION INTENSITY PROBABILITY DEGREE OF SIGNIFICANCE

IMPACT CONFIDENCE PRE- MITIGATION/ POST- MITIGATION ENHANCEMENT MITIGATION

OPERATION AND MAINTENENCE PHASE

Groundwater The local groundwater Local Long-term High Probable High High  Oil-water separator Medium pollution and may be polluted by soakaway should compromising hydrocarbon spills. The take place on of community local community’s surface water source water source in such an  All personnel utilising instance would be the fuel depot should compromised. be trained by an independent third party  Regular monitoring of key elements on the fuel depot need be carried out in accordance with the EMP

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6.3 DISCUSSION

Having screened all potential impacts and having subjected those applicable to the criteria outlined in Table 5 the following should be noted regarding the impact on groundwater and its corresponding mitigation measures:

The total failure of the USTs will result in the pollution of the local groundwater and if not remedied will affect groundwater for a few kilometres beyond the project area. In this event the primary water source of the local community will be compromised and water will need to be sourced from beyond the village area. It will take decades to remedy the effects of the pollution. This particular aspect of the total range of impacts on groundwater constitutes a high impact intensity. However, it is improbable that this event should take place.

The maintenance of the oil-water separator is considered to be the main concern in terms of groundwater pollution. The soakaway should take place on the surface so that any hydrocarbon staining can be clearly visible and attended to immediately.

All personnel utilising the fuel depot need to be adequately trained, especially those responsible for the monitoring and maintenance of the depot. The training should as a minimum cover all the provisions contained in the Operation and Maintenance chapter of the EMP (Appendix B). This training should be outsourced to an independent and qualified third party. All new staff are to receive training. Refresher training should be offered at least annually by the same independent and qualified third party.

Sewage volumes generated during the construction period may pollute the local groundwater if not managed appropriately, particularly when it rains. Measures contained in the EMP (Appendix B) pertaining to waste management should be strictly adhered to.

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In terms of regular monitoring and maintenance of the fuel depot the following measures are required:

 The oil-water separator must be inspected and cleaned daily;  The soakaway must be inspected daily for signs of staining;  Inspection holes around the tanks must be inspected daily; and  Tank volume reconciliation bust be conducted twice a day.

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7 CONCLUSIONS AND RECOMMENDATIONS

The negative impacts with a high or medium significance rating have been identified. Mitigation measures have been devised and outlined above (Chapter 6.3) to address these so as to ensure that this project (if granted Environmental Clearance) is implemented in the most sustainable way possible. All impacts discussed above will be addressed in the EMP (Appendix B). The key impacts and their mitigation measures are summarised below:

 Impacts on health and safety: The consequences of negligent behaviour in terms of the management of highly flammable substances on-site are potentially disastrous – resulting in significant injury or loss of life. The mitigation measures prescribed in Chapter 6.3 and the EMP (Appendix B) are however, sufficient to address this potential impact.  Impact on groundwater: The pollution of the groundwater in the area is considered an impact with a high significance rating. The main areas of concern are the total failure of the Underground Storage Tanks (USTs) (improbable), maintenance of the oil-water separator, the need for training of all personnel utilising the fuel depot, sewage management during construction and monitoring and maintenance of the fuel depot. The latter four concerns are linked to highly probable impacts. The mitigation measures prescribed in Chapter 6.3 and the EMP (Appendix B) are however, sufficient to address this potential impact.

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 The construction of a facility for the underground storage of petrol and diesel; and  The storage handling of petrol and diesel with a combined capacity of 46 m3.

Furthermore the training of applicable MSS personnel should be a condition of approval.

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8 REFERENCES

Christelis, G. & Struckmeier, W., 2001. Groundwater in Namibia. 1st ed. Cape Town: Formset (Pty) Ltd.

Mendelsohn, J., Jarvis, A., Roberts, C. & Robertson, T., 2009. Atlas of Namibia. 3rd ed. Cape Town: Sunbird Publishers.

Republic of Namibia: Ministry of Environment and Tourism, 2012. Environmental Impact Assessment Regulations, GG 4878, GN 29, Windhoek: MET.

Republic of Namibia: Ministry of Health and Social Services, 2012. National HIV Sentinel Survey, Windhoek: MoHSS.

Republic of Namibia: Namibia Statistics Agency, 2012. Population and Housing Census Main Report, Windhoek: NSA.

Proposed Police Fuel Depot in Ncaute Draft Scoping Report for Public Review September 2014