Environmental Scoping Assessment

ENVIRONMENTAL IMPACT ASSESSMENT FOR A TYRE PYROLYSIS PLANT FOR THE RECYCLING OF END OF LIFE/USED TYRES TO PRODUCE FUEL OIL, CARBON BLACK, GAS AND STEEL ON A PORTION (PORTION A) OF PORTION 15 OF THE FARM OTJIWARONGO TOWNLANDS SOUTH NO. 308, OTJOZONDJUPA REGION

JUNE 2019

GREEN EARTH Environmental Consultants 1

ENVIRONMENTAL IMPACT ASSESSMENT FOR A TYRE PYROLYSIS PLANT FOR THE RECYCLING OF END OF LIFE/USED TYRES TO PRODUCE FUEL OIL, CARBON BLACK, GAS AND STEEL ON Project Name: A PORTION (PORTION A) OF PORTION 15 OF THE FARM OTJIWARONGO TOWNLANDS SOUTH NO. 308, OTJOZONDJUPA REGION

Pneumatic Green Energy CC The Proponent: P.O. Box 41005 Windhoek

Prepared by:

Release Date: June 2019

C. Du Toit C. Van Der Walt Consultant: Cell: 081 127 3145 Fax: 061 248 608 Email: [email protected]

GREEN EARTH Environmental Consultants 2 EXECUTIVE SUMMARY

Green Earth Environmental Consultants were appointed by the proponent, Pneumatic Green Energy CC, to conduct an Environmental Impact Assessment to obtain an Environmental Clearance for the construction and operation of a tyre pyrolysis plant for the recycling of end of life tyres for the production of fuel oil, carbon black, gas and steel on a Portion of Portion 15 of Farm Otjiwarongo Townlands South No. 308, Otjozondjupa Region. The land within the immediate vicinity of the project site is predominately characterized by residential, industrial, farming and business activities. In terms of the Regulations of the Environmental Management Act (No 7 of 2007), an Environmental Impact Assessment has to be done to address the following ‘Listed Activities’:

WASTE MANAGEMENT, TREATMENT, HANDLING AND DISPOSAL ACTIVITIES 2.1 The construction of facilities for waste sites, treatment of waste and disposal of waste. 2.2 Any activity entailing a scheduled process referred to in the Atmospheric Pollution Prevention Ordinance, 1976. 2.3 The import, processing, use and recycling, temporary storage, transit or export of waste.

HAZARDOUS SUBSTANCE TREATMENT, HANDLING AND STORAGE 9.1 The manufacturing, storage, handling or processing of a hazardous substance defined in the Hazardous Substances Ordinance, 1974. 9.2 Any process or activity which requires a permit, licence or other form of authorisation, or the modification of or changes to existing facilities for any process or activity which requires an amendment of an existing permit, licence or authorisation or which requires a new permit, licence or authorisation in terms of a law governing the generation or release of emissions, pollution, effluent or waste.

The main positive impacts to be derived from this project are that opportunities will be created from the recycling of tyres and to reduce the impact of end of life tyres on the Namibian Environment in general but specifically on the landfill sites around the country. Employment opportunities will be created during construction and operation of the plant.

The negative impacts associated with the proposed project are the impact on the vegetation, trees, bushes, the natural drainage systems, noise and dust during, the transmission of diseases from people or to people involved in construction and the loss of land during the construction of the bulk municipal services (roads, sewer, electrical and water reticulation). The plant will be constructed and operated on a disturbed natural environment with most of the vegetation removed; therefore, the impacts will not be severe. However, the project will put further pressure on water supply resources and infrastructure. Mitigation measures will be provided that can control the extent, intensity and frequency of these named impacts in order not to have substantial negative effects or results.

GREEN EARTH Environmental Consultants 3 The type of activities that will be carried out on the site will not negatively affect the amenity of the locality and the activities do not adversely affect the environmental quality of the neighbouring portions or areas. None of the potential impacts identified are regarded as having a significant impact to the extent that the proposed project should not be allowed. However, the construction and operational activities further on need to be controlled and monitored by the assigned subcontractors and the proponent.

The Environmental Impact Assessment which follows upon this paragraph was conducted in accordance with the guidelines and stipulations of the Environmental Management Act (No 7 of 2007) meaning that all possible impacts have been considered and the details are presented in the report.

Based upon the conclusions and recommendations of the Environmental Impact Assessment Report and Environmental Management Plan following this paragraph the Environmental Commissioner of the Ministry of Environment and Tourism is herewith requested to:

1. Accept the Environmental Impact Assessment; 2. Approve the Environmental Management Plan; 3. Issue an Environmental Clearance for the construction and operation of the tyre pyrolysis plant for the recycling of end of life tyres for the production of fuel oil, carbon black, gas and steel on Portion 15 of Farm Otjiwarongo Townlands South No. 308, Otjozondjupa Region and for the following “listed activities”:

GREEN EARTH Environmental Consultants 4 TABLE OF CONTENTS

LIST OF FIGURES ...... 7 LIST OF ABBREVIATIONS ...... 8 LIST OF APPENDIXES ...... 9 1. INTRODUCTION ...... 10 2. BACKGROUND INFORMATION ON PROJECT ...... 11 2.1. LOCALITY AND DESCRIPTION ...... 11 2.2. LAND OWNERSHIP, SIZE AND ZONING...... 14 2.3. CURRENT UTILIZATION OF SITE ...... 14 2.4. PROPOSED DEVELOPMENT ...... 16 3. BULK SERVICES AND INFRASTRUCTURE ...... 21 3.1. ACCESS AND INTERNAL ROADS ...... 21 3.2. RAIL FACILITIES ...... 24 3.3. WATER SUPPLY ...... 24 3.4. ELECTRICITY SUPPLY ...... 24 3.5. SEWAGE DISPOSAL ...... 24 3.6. SOLID WASTE DISPOSAL ...... 25 4. TERMS OF REFERENCE ...... 25 5. APPROACH TO THE STUDY ...... 26 6. ASSUMPTIONS AND LIMITATIONS ...... 27 7. ADMINISTRATIVE, LEGAL AND POLICY REQUIREMENTS ...... 27 8. AFFECTED RECEIVING ENVIRONMENT ...... 37 8.1. BIODIVERSITY AND VEGETATION ...... 37 8.2. GEOLOGY AND SOILS ...... 40 8.3. PREVAILING HYDROGEOLOGY ...... 41 8.4. SURFACE WATER ...... 43 8.5. THE SOCIO-ECONOMIC ENVIRONMENT ...... 44 8.6. CLIMATE ...... 44 8.7. HYDROLOGICAL COMPONENT ...... 45 8.8. CULTURAL HERITAGE ...... 46 9. IMPACT ASSESSMENT AND EVALUATION ...... 46 10. POSSIBLE IMPACTS ON RECEIVING ENVIRONMENT ...... 47 11. SUMMARY OF ENVIRONMENTAL ASSESSMENT ...... 48 11.1. IMPACTS DURING CONSTRUCTION PHASE ...... 49 11.1.1. ENERGY CONSUMPTION AND REQUIREMENTS ...... 49 11.1.2. SOCIAL AND CULTURAL ISSUES ...... 49 11.1.3. WATER USAGE AND REQUIREMENTS ...... 50 GREEN EARTH Environmental Consultants 5 11.1.4. ECOLOGICAL IMPACTS ...... 50 11.1.5. DUST POLLUTION AND AIR QUALITY ...... 50 11.1.6. NOISE IMPACT ...... 51 11.1.7. HEALTH, SAFETY AND SECURITY...... 51 11.1.8. CONTAMINATION OF GROUNDWATER ...... 52 11.1.9. SEDIMENTATION AND EROSION ...... 53 11.1.10. GENERATION OF WASTE ...... 53 11.1.11. CONTAMINATION OF SURFACE WATER ...... 54 11.1.12. TRAFFIC AND ROAD SAFETY ...... 54 11.1.13. FIRES AND EXPLOTIONS ...... 54 11.1.14. SENSE OF PLACE AND GENERAL AMBIANCE...... 55 11.2. IMPACTS DURING OPERATIONAL PHASE ...... 55 11.2.1. FLUE AND GREENHOUSE GAS EMISSIONS ...... 55 11.2.2. WASTEWATER GENERATION ...... 57 11.2.3. ECOLOGICAL IMPACTS ...... 57 11.2.4. DUST POLLUTION, ODOUR AND AIR QUALITY ...... 57 11.2.5. CONTAMINATION OF GROUNDWATER ...... 58 11.2.6. GENERATION AND MANAGEMENT OF SOLID WASTE ...... 58 11.2.7. FAILURE IN RETICULATION PIPELINES ...... 59 11.2.8. FIRES AND EXPLOSIONS ...... 59 11.2.9. HEALTH, SAFETY AND SECURITY...... 59 11.2.10. STORAGE OF TYRES AND HARMFUL SUBSTANCES ...... 60 11.3. CUMMULATIVE IMPACTS ...... 60 12. ENVIRONMENTAL MANAGEMENT PLAN ...... 61 13. CONCLUSION ...... 61 14. RECOMMENDATION ...... 62

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LIST OF FIGURES

Figure 1: Locality of Project Site ...... 11 Figure 2: Project Site ...... 12 Figure 3: Site plan...... 13 Figure 4: Floor/site plan ...... 13 Figure 5: Buildings on the site (1) ...... 14 Figure 6: Buildings on the site (2) ...... 15 Figure 7: Buildings on the site (3) ...... 15 Figure 8: Buildings on the site (4) ...... 15 Figure 9: Buildings on the site (5) ...... 16 Figure 10: Buildings on the site (6) ...... 16 Figure 11: Component of Tyre (Evens, 2006) ...... 17 Figure 12: Basic setup of plant ...... 19 Figure 13: Fuel oil ...... 20 Figure 14: Recovered Carbon Black ...... 20 Figure 15: Steel ...... 20 Figure 16: Current Access to Project Site ...... 21 Figure 17: Current Access not supported by Roads Authority ...... 22 Figure 18: Future Access supported by Roads Authority ...... 22 Figure 19: Future Access as per Structure Plan (1) ...... 23 Figure 20: Future Road as per Structure Plan (2) ...... 23 Figure 21: Siding 9000 ...... 24 Figure 22: Flowchart of the Impact Process ...... 36 Figure 23: Biomes in Namibia (Atlas of Namibia, 2002) ...... 37 Figure 24: Trees on the Project Site ...... 40 Figure 25: Geology of Namibia ...... 41 Figure 26: Groundwater basin & rock types ...... 41 Figure 27: Hydrogeological Map of Namibia (Geological Survey of Namibia, 2015) ...... 43 Figure 28: Average annual temperatures in Namibia ...... 45 Figure 29: Wet Scrubber Image ...... 56 Figure 30: Noise Exposure Limits and Times ...... 58

GREEN EARTH Environmental Consultants 7 LIST OF ABBREVIATIONS

CAN Central Area of Namibia EC Environmental Clearance ECO Environment Control Officer EIA Environmental Impact Assessment ELT’s End of life/used tyres EMP Environmental Management Plan I&APs Interested and Affected Parties MET Ministry of Environment and Tourism SQM Square Meters

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LIST OF APPENDIXES

APPENDIX A: NEWSPAPER NOTICES APPENDIX B: BACKGROUND INFORMATION DOCUMENT APPENDIX C: LIST OF I&APS APPENDIX D: COMMENTS FROM I&APS APPENDIX E: DEED OF TRANSFER APPENDIX F: LEASE AGREEMENT APPENDIX G: CURRICULUM VITAE OF CHARLIE DU TOIT APPENDIX H: CHARLIE DU TOIT IDENTIFICATION DOCUMENT APPENDIX I: CURRICULUM VITAE OF CARIEN VAN DER WALT APPENDIX J: CARIEN VAN DER WALT IDENTIFICATION DOCUMENT APPENDIX K: ENVIRONMENTAL MANAGEMENT PLAN

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1. INTRODUCTION

The Proponent, Pneumatic Green Energy CC, appointed Green Earth Environmental Consultants to conduct an Environmental Impact Assessment and develop an Environmental Management Plan to obtain an Environmental Clearance for the construction and operation of a tyre pyrolysis plant for the recycling of end of life/used tyres for the production of oil/diesel, carbon black, gas and steel on Portion A (±2ha) of Portion 15 of Farm Otjiwarongo Townlands South No. 308, Otjozondjupa Region.

The Environmental Management Act (No. 7 of 2007) and the Environmental Impact Assessment Regulations (GN 30 in GG 4878 of 6 February 2012) stipulates that an Environmental Impact Assessment (EIA) report and management plan is required as the following 'Listed Activities' are involved:

The Environmental Impact Assessment below contains information on the proposed project and the surrounding areas, the proposed development and activities, the applicable legislation to the study conducted, the methodology that was followed, the public consultation that was conducted, and the receiving environment’s sensitivity and any potential ecological, environmental and social impacts.

GREEN EARTH Environmental Consultants 10 2. BACKGROUND INFORMATION ON PROJECT

2.1. LOCALITY AND DESCRIPTION

Portion 15 of Farm Otjiwarongo Townlands South No. 308 (the old cement factory site) is located ±3km to the north-east of Otjiwarongo east of the B1 National Road leading to the town of Otavi. See below plans to show the locality of Portion 15:

Figure 1: Locality of Project Site

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Figure 2: Project Site

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Figure 3: Site plan

Figure 4: Floor/site plan

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2.2. LAND OWNERSHIP, SIZE AND ZONING

Portion 15 of Farm Otjiwarongo Townlands South No. 308 is registered in the name of Namibia Development Corporation which is now part of NIDA (Namibia Industrial Development Agency). The Portion is 12, 3108 hectares in extent and zoned ‘general industrial’. The proposed plant can be accommodated under the zoning ‘general industrial’ on condition the Otjwarongo Municipality grant consent for a ‘noxious industry’. It is the intension to use ±2 hectares for the construction and operation of the tyre pyrolysis plant.

2.3. CURRENT UTILIZATION OF SITE

Various buildings are present on the site. The bulk of these buildings have been vandalized (roof sheets and doors have been removed and windows are broken). The site is used for the dumping of household and industrial waste. It was observed that the site is used for the storage and handling of charcoal and people residing (loitering and squatting on the site).

Figure 5: Buildings on the site (1)

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Figure 6: Buildings on the site (2)

Figure 7: Buildings on the site (3)

Figure 8: Buildings on the site (4)

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Figure 9: Buildings on the site (5)

Figure 10: Buildings on the site (6)

2.4. PROPOSED DEVELOPMENT

It is the intention of the proponent to establish a tyre pyrolysis plant for the recycling of ELT’s (end of life/used tyres) into fuel oil, carbon black, gas and steel. From info obtained from City of Windhoek, 2000 to 2500 tyres are received per month at the Kupferberg Landfill site outside Windhoek. It is estimated that the same amount can be sourced from the coastal and the northern towns of Namibia. Some of the mines have also indicated that they have large volumes of used tyres which are currently a problem to dispose of. These tyres take up space and shorten the lifespan of landfill sites. It is the intension to refund or put incentives in place to motivate members of the general public and businesses to supply tyres to the plant. It is expected to employ 15 workers in the project process. The following image demonstrates the components of a tyre:

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Figure 11: Component of Tyre (Evens, 2006)

Pyrolysis is a thermochemical process used to decompose organic material, namely heat treatment in the absence of oxygen. In the recycling industry, tyre pyrolysis works the same way: heat is applied to feedstock in vacuum or at atmospheric pressure to decompose whole or shredded tires into marketable materials. Four main materials derived from end-of-life tyres by weight/volume in descending order are fuel oil, carbon char, steel wire and gas. The table below shows the materials as a percentage of weight from which a tyre is made:

Table 1: Composition of a Tyre Passenger Car Tire, % Truck Tire, % of total Material of total weight weight Rubber 48 45 Carbon Black 22 22 Metal 15 25 Textile 5 – Zinc Oxide 1 2 Sulphur 1 1 Other Additives 8 5

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During the pyrolysis process, ELTs are heated in an oxygen free environment most commonly in a reactor vessel to temperatures ranging between 300 and 800 degrees Celsius. Once heat is applied to feedstock, it begins to soften, and tire polymers break down. Products of this process can be divided into three basic categories - vapors, liquids and solid remainder. Smaller molecules exit the reactor in the form of vapor. A bigger part of the vapors is collected and condensed into an oily liquid, while another fraction of vapors is collected as gas outside the vessel and is then burnt for energy generation. The heavier minerals originally present in tyres remain in the reactor as a solid residual and consist of carbon char - referred to as carbon black - and steel. Roughly, output shares are:

These values may vary depending on technology and processing temperature equipment. The quantity and quality of each product depends on several variables such as feedstock quality, processing temperature, pressure, and processing time. For instance, higher processing temperatures are associated with higher yields of gas. Thus, the share of gas among other outputs may vary from 10% to 15%. The set up of the proposed pyrolysis plant will in principle be as follows:

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Figure 12: Basic setup of plant

Nowadays, there are different types of equipment available on the market for a good- quality tire pyrolysis. Apart from treatment temperature, there are batch and continuous feed systems available. A pyrolysis pant is normally set up as follows:

1 Hopper, 2 Input sluice, 3 Thermolysis coke hot, 4 Thermolysis coke cold, 5 Thermolysis raw gas, 6 Permanent gas, 7 Permanent gas, cleaned, 8 GPL / natural gas, 10 Rotary kiln unit, 20 Condensation, 21 Cooler, 22 Bypass filter. The products derived from the pyrolysis process will be used as follows:

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Fuel oil

Figure 13: Fuel oil

The main fields of application are:

 maritime fuel  fuel for vehicular engines  fuel for stationary engines (generators)  furnace fuel used by local (community) heating companies

Carbon Black

Figure 14: Recovered Carbon Black

Recovered carbon black is a mixture of carbon, ash, zinc and sulphur. It is the intension to press the carbon black through a briquetting process into sticks or blocks with large diameter and different shapes to be used as industrial fuel. NamPower has shown interest in this product for the Van Eck Powerplant as the recovered carbon fibre has a high calorific value. Cement plants are also users of the product.

Steel

Figure 15: Steel

GREEN EARTH Environmental Consultants 20 Recovered steel will be further recycled to be sold as a commodity or it as scrap metal without applying additional treatment.

Gas

Gas output makes up the smallest fraction of tire pyrolysis output. Gas released during thermal decomposition of ELT has sufficiently high calorific value to power the operation and it is the intension to use it as such in the proposed plant.

3. BULK SERVICES AND INFRASTRUCTURE

The bulk services that will be provided will be as follows:

3.1. ACCESS AND INTERNAL ROADS

Portion 15 of Farm Otjiwarongo Townlands South No. 308 is currently accessed from a private/municipal road that runs south-eastwards towards the town and joins the D2440 from which the B1 and the Town can be accessed in a south-westerly direction. This private/municipal road also link up with the Main Road B1, crossing the railway line, directly northwest of the site. See current access in Figure below.

As this section of Main Road B1 falls under the jurisdiction of the Roads Authority, their comments were requested. The Roads Authority indicated that:

“The access point of the private/municipal road onto the B1 is for the Roads Authority problematic as this creates with the D2430 a cross intersection that is potentially very dangerous for users of the B1 and should be closed”. See attached a copy of the email from Roads Authority regarding the access. Therefore, this access is not supported and will probably be closed by Roads Authority.

Figure 16: Current Access to Project Site

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Figure 17: Current Access not supported by Roads Authority

The Otjiwarongo Structure Plan provides for a future access to Portion 15 of Farm Otjiwarongo Townlands South No. 308 from the eastern side via a road still to be constructed which will link up with District Road D2440 in the south from where the B1 and the Town can be accessed. This road will also provide access to developments planned to the north of Portion 15. See Google Image and Structure Plan below for the alignment of the future road.

Figure 18: Future Access supported by Roads Authority

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Figure 19: Future Access as per Structure Plan (1)

New Road

Figure 20: Future Road as per Structure Plan (2)

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This will thus be the future access to the plant once constructed. The positioning of the plant and layout of the site is also done in such way as to take access from this road once constructed.

3.2. RAIL FACILITIES

The site has access to the TransNamib Rail Network via siding No. 9000. TransNamib confirmed that the siding can still be used although some upgrading work is required.

Figure 21: Siding 9000

3.3. WATER SUPPLY

Water is supplied to the site from the existing municipal water reticulation system.

3.4. ELECTRICITY SUPPLY

Electricity is supplied to the site from the Cenored network. The plant will be gas driven from the gas generated through the process.

3.5. SEWAGE DISPOSAL

Currently no sewer infrastructure is available for this development. The site will thus be serviced by an enclosed waterborne sewer system which will treat the effluent for reuse

GREEN EARTH Environmental Consultants 24 on site. The proposed systems will be designed and constructed according to Municipal standards and with their approval.

3.6. SOLID WASTE DISPOSAL

Household and other waste generated from the activity should be collected by the Municipality under their normal waste management and collection services. If the Municipality cannot render this service at this site it is proposed that the normal household waste and industrial waste which will be generated on the site be sorted into glass, paper, metal, plastics, noxious materials and others and stored in a dedicated area on the site from which it is collected by a professional waste management and recycling company like Rent-A-Drum.

4. TERMS OF REFERENCE

To be able to implement the proposed project, an Environmental Impact Assessment and Environmental Clearance is required. For this environmental impact exercise Green Earth Environmental Consultants followed the terms of reference as stipulated under the Environmental Management Act.

The aim of the environmental impact assessment was:

- To comply with Namibia’s Environmental Management Act (2007) and its regulations (2012); - To ascertain existing environmental conditions on the site in order to determine its environmental sensitivity; - To inform I&APs and relevant authorities of the details of the proposed development and to provide them with an opportunity to raise issues and concerns; - To assess the significance of issues and concerns raised; - To compile a report detailing all identified issues and possible impacts, stipulating the way forward and identify specialist investigations required; - To outline management guidelines in an Environmental Management Plan (EMP) to minimize and/or mitigate potentially negative impacts.

The tasks that were undertaken for the Environmental Impact Assessment included the evaluation of the following: climate, water (hydrology), vegetation, geology, soils, socio economic impact, cultural heritage, groundwater, sedimentation, erosion, biodiversity, sense of place, socio-economic environment, health, safety and traffic.

The EIA and EMP from the assessment will be submitted to the Environmental Commissioner for consideration. The Environmental Clearance will only be obtained (from the DEA) once the EIA and EMP has been examined and approved for the listed activity.

The public consultation process as per the guidelines of the Act has been followed. The methods that were used to assess the environmental issues and alternatives included the collection of data on the project site and surrounding area, info obtained from the GREEN EARTH Environmental Consultants 25 proponent and the professional team appointed for planning and construction and the Ministry of Environment and Tourism and identified and affected stakeholders. Consequences of impacts were determined in five categories: nature of impact, expected duration of impact, geographical extent of the event, probability of occurring and the expected intensity.

Interested and affected parties were invited to register in terms of the assessment process to give input, comments and opinions regarding the proposed project. All other permits, licenses or certificates that are further on required for the operation of the proposed project still needs to be applied for by the proponent.

5. APPROACH TO THE STUDY

The assessment included the following activities: a) Desktop sensitivity assessment

Literature, legislation and guidance documents related to the natural environment and land use activities available on the portion and area in general were reviewed in order to determine potential environmental issues and concerns. b) Site assessment (site visit)

The proposed project site and the immediate neighbourhood and surrounding area were assessed through several site visits to investigate the environmental parameters on site to enable further understanding of the potential impacts on site. c) Public participation

The public were invited to give input, comments and opinions regarding the proposed project. Notices were placed in two local newspapers namely The Namibian and New Era (see Appendix) on 25 April and 2 May 2019 inviting public participation and comments on the proposed project. The closing date for questions, comments, inputs or information on the proposed Newspaper Notice was 24 May 2019. Background Information Documents have been sent to Interested and Affected Parties (I&APs) and to relevant authorities. The closing date for questions, comments, inputs or information on the Background Information Document was also 24 May 2019. See Appendix for comments received from the Interested and Affected Parties and from the Public. d) Scoping

Based on the desk top study, site visit and public participation, the environmental impacts were determined in five categories: nature of project, expected duration of impact, geographical extent of the event, probability of occurring and the expected intensity. The findings of the scoping have been incorporated in the environmental impact assessment report below.

GREEN EARTH Environmental Consultants 26 e) Environmental Management Plan (EMP)

To minimize the impact on the environment, mitigation measures have been identified to be implemented during planning, construction and implementation. These measures have been included in the Environmental Management Plan to guide the planning, construction and operation of the project/development which can also be used by the relevant authorities to ensure that the project is planned, developed and operated with the minimum impact on the environment.

6. ASSUMPTIONS AND LIMITATIONS

It is assumed that the information provided by the proponent (Pneumatic Green Energy CC) is accurate. Alternative sites namely the Remainder of Portion 56, Brakwater Stand No. 9 were evaluated but it has no access to bulk municipal services and is also located next to a residential area. The zoning of the Portion is residential which does not allow industrial use. The proposed site (Portion 15 of Farm Otjiwarongo Townlands South No. 308) for the development was chosen because of the location, zoning, size of the portion and proximity to the main road leading through Namibia (B1). The site was visited several times and any happenings after this are not mentioned in this report. (The assessment was based on the prevailing environmental conditions and not on future happenings on the site.) However, it is assumed that there will be no significant changes to the proposed project, and the environment will not adversely be affected between the compilation of the assessment and the implementation of the proposed activities.

7. ADMINISTRATIVE, LEGAL AND POLICY REQUIREMENTS

To protect the environment and achieve sustainable development, all projects, plans, programs and policies deemed to have adverse impacts on the environment require an EIA according to Namibian legislation. The administrative, legal and policy requirements to be considered during the Environmental Assessment for the tyre pyrolysis plant on Portion 15 of Farm Otjiwarongo Townlands South No. 308, Otjozondjupa Region are the following:

 The Namibian Constitution  The Environmental Management Act (No. 7 of 2007)  The Otjiwarongo Town Planning Scheme  Other Laws, Acts, Regulations and Policies

THE NAMIBIAN CONSTITUTION

Article 95 of Namibia’s constitution provides that:

“The State shall actively promote and maintain the welfare of the people by adopting, inter alia, policies aimed at the following:

Management of ecosystems, essential ecological processes and biological diversity of Namibia and utilization of living natural resources on a sustainable basis for the benefit GREEN EARTH Environmental Consultants 27 of all Namibians, both present and future; in particular, the Government shall provide measures against the dumping or recycling of foreign nuclear and toxic waste on Namibian territory.” This article recommends that a relatively high level of environmental protection is called for in respect of pollution control and waste management.

Article 144 of the Namibian Constitution deals with environmental law and it states:

“Unless otherwise provided by this Constitution or Act of Parliament, the general rules of public international agreements binding upon Namibia under this Constitution shall form part of the law of Namibia”. This article incorporates international law, if it conforms to the Constitution, automatically as “law of the land”. These include international agreements, conventions, protocols, covenants, charters, statutes, acts, declarations, concords, exchanges of notes, agreed minutes, memoranda of understanding, and agreements (Ruppel & Ruppel-Schlichting, 2013). It is therefore important that the international agreements and conventions are considered (see section 4.9).

In considering these environmental rights, the Proponent should consider the following in devising an action plan in response to these articles:

 Implement a “zero-harm” policy that would guide decisions.  Ensure that no management practice or decision result in the degradation of future natural resources.  Take a decision on how this part of the Constitution will be implemented as part of the Environmental Control System (ECS).

ENVIRONMENTAL MANAGEMENT ACT (NO. 7 OF 2007)

The Environmental Impact Assessment Regulations (GN 30 in GG 4878 of 6 February 2012) of the Environmental Management Act (No. 7 of 2007) that came into effect in 2012 requires/recommends that an Environmental Impact Assessment and an Environmental Management Plan (EMP) be conducted for the following listed activities in order to obtain an Environmental Clearance Certificate:

HAZARDOUS SUBSTANCE TREATMENT, HANDLING AND STORAGE 9.1 The manufacturing, storage, handling or processing of a hazardous substance defined in the Hazardous Substances Ordinance, 1974. 9.2 Any process or activity which requires a permit, licence or other form of authorisation, or the modification of or changes to existing facilities for any process or activity which requires an amendment of an existing permit, licence or authorisation or which requires a new permit, licence or authorisation in terms of GREEN EARTH Environmental Consultants 28 a law governing the generation or release of emissions, pollution, effluent or waste.

Cumulative impacts associated with the development must be included as well as public consultation. The Act further requires all major industries and mines to prepare waste management plans and present these to the local authorities for approval.

The Act, Regulations, Procedures and Guidelines have integrated the following sustainability principles. They need to be given due consideration, particularly to achieve proper waste management and pollution control:

Cradle to Grave Responsibility

This principle provides that those who handle or manufacture potentially harmful products must be liable for their safe production, use and disposal and that those who initiate potentially polluting activities must be liable for their commissioning, operation and decommissioning.

Precautionary Principle

It provides that if there is any doubt about the effects of a potentially polluting activity, a cautious approach must be adopted.

The Polluter Pays Principle

A person who generates waste or causes pollution must, in theory, pay the full costs of its treatment or of the harm, which it causes to the environment.

Public Participation and Access to Information

In the context of environmental management, citizens must have access to information and the right to participate in decisions making.

CONCLUSION AND IMPACT

It can be concluded that Portion 15 of Farm Otjiwarongo Townlands South No. 308 was already used for ‘industrial’ purposes. Some of the site has been cleared from vegetation and structures have been constructed on them or are in the process of being constructed. The proposed activity will thus fit in with the surrounding activities and not have a negative impact on the prevailing environment. It will be ensured that protected trees and plant species will be retained where possible.

THE OTJIWARONGO TOWN PLANNING SCHEME

The Otjiwarongo Town Planning Scheme (as amended in Otjiwarongo Amendment Scheme No. 15 – approved 26 June 2015) applies to the area as indicated on the scheme maps and corresponds with the Townlands Diagram for Otjiwarongo Town and Townlands. Portion 15 of Farm Otjiwarongo Townlands South No. 308 falls within the area of the Scheme. GREEN EARTH Environmental Consultants 29

The general purpose of this Scheme is the coordinated and harmonious development of the area of Otjiwarongo (including, where necessary, the reconstruction and redevelopment of any part which has already been subdivided whether there are buildings on it or not) in such a way as will most effectively tend to promote health, safety, order, amenity, convenience and general welfare as well as efficiency and economy in the process of development and improvement of communications, and where it is expedient in order to promote proper planning or development, may provide for the suspending the operation of any provision of law or any bylaw or regulation made under such law, in so far as such provision is similar to or inconsistent with any of the provisions of the Scheme.

According to the Town Planning Scheme, Portion 15 of Farm Otjiwarongo Townlands South No. 308 is 12, 3108 hectares in extent and zoned ‘general industrial’. Clause 8.10 of the Town Planning Scheme allows the primary uses as is stipulated in the table below on an erf which is zoned ‘general industrial’:

It was confirmed with Mr Slabbert and Ms De Wet from Otjiwarongo Municipality that: “the nature of the business will be classified as a noxious trade and will require Council’s consent under the “general industrial” zoned property”. See below email received from Council in this regard.

GREEN EARTH Environmental Consultants 30 Email received from Council From: Charlie du Toit Sent: Thursday, 14 March 2019 3:17 PM To: Rene De Wet Subject: Die vorige sementfabriek

Hallo Rene

Kan jy my dalk help met die erf/porsie nommer van die perseel waarop die vorige sement fabriek geleë was. Ons het ‘n klient wat ‘n projek daarop wil doen en ek moet uitvind insake die gebruiksregte en dienste beskikbaarheid vir die gedeelte.

Die klient beplan om ‘n tyre recycling facility van die perseel af te bedryf. Dit is ‘n industriele aktiwitweit wat noxious van aard is. Die NDC het die grond aan hulle aangebied vir die projek.

Kan jy my help hiermee asb.

Dankie en groete

From: Rene De Wet Sent: Thursday, March 14, 2019 3:41 PM To: Charlie du Toit Subject: RE: Die vorige sementfabriek

Middag Charlie

Dis Portion 15 of Townlands South No 308 South. Sy sonering is General Industrial en hy is 12,3108 HA

Groete, Rene From: Charlie du Toit Sent: Friday, 5 April 2019 9:10 AM To: Rene De Wet Cc: [email protected]; 'Elmarie du Toit' Subject: RE: Die vorige sementfabriek

GREEN EARTH Environmental Consultants 31 Dear Rene

We have been appointed to attend to the Town Planning and Environmental Procedures for the construction and operation of Tyre Pyrolysis Plant on a 2ha portion of Portion 15 of Townlands South No 308 South, Otjiwarongo. Initially it was the intension to locate the plant in the Windhoek Municipal Area but a suitable site could not be found. See attached a BID prepared for the initial site which give some info on the proposed project. Although the plant has limited impact on the environment we are of the opinion that it is of a noxious nature and that it should thus be done with Council’s ‘consent’.

The Portion is zoned ‘General Industrial’ ant it is 12,3108 ha in extent. With this email I want to confirm the following:

If the proposed project will be classified as ‘noxious’ and if so; If Council’s consent must be obtained as a ‘noxious’ industry is a consent use under the zoning ‘general business ‘;

The implementation of the project is subject to obtaining an Environmental Clearance and Council’s ‘consent’(if required).

Your urgent feedback in this regard is highly appreciated as we need to inform the client and landlord on this.

Kind regards

Dear Charlie

I can confirm as follows:

The nature of the business will be classified as a noxious trade and will require Council’s consent under the “general industrial” zoned property.

Regards, Rene

GREEN EARTH Environmental Consultants 32 The Otjiwarongo Town Planning Scheme defines a ‘noxious industry’ as follows:

An application was therefore submitted to the Otjiwarongo Municipality by Du Toit Town Planning Consultants for:

 Consent to use Portion A (±2ha) of Portion 15 of the Farm Otjiwarongo Townlands South No 308, Otjozondjupa Region, for a tyre pyrolysis plant which is defined as a ‘noxious industry’

This application is currently awaiting Otjiwarongo Municipality’s approval. The approval of the consent to use Portion A of Portion 15 of Farm Otjiwarongo Townlands South No 308 for the tyre pyrolysis plant is subject to obtaining an environmental clearance from the Environmental Commissioner for the listed activities triggered by the proposed project.

GREEN EARTH Environmental Consultants 33 CONCLUSION AND IMPACT

It is believed that the proposed tyre pyrolysis plant on Portion A of Portion 15 of Farm Otjiwarongo Townlands South No 308 will not have a detrimental impact on the neighbourhood as the proposed development will fit in with the surrounding uses and complement the existing uses.

The proposed consent to use Portion A for a ‘noxious industry’ has been considered under the stipulations of the Otjiwarongo Town Planning Scheme and the Local Authorities Act. The proposed consent use will not have a negative impact on the public.

OTHER LAWS, ACTS, REGULATIONS AND POLICIES

The laws, acts, regulations and policies listed below have also been considered during the Environmental Assessment:

Table 1: Laws. Acts, Regulations and Policies Laws, Acts, Regulations & Policies consulted: Water The Water Resources Management Act (No 11 of 2013) stipulates Resources conditions that ensure effluent that is produced to be of a certain standard. Management There should also be controls on the disposal of sewage, the purification of Act effluent, measures should be taken to ensure the prevention of surface and groundwater pollution and water resources should be used in a sustainable manner. Nature The Nature Conservation Ordinance (No 4 of 1975) covers game parks and Conservation nature reserves, the hunting and protection of wild animals, problem animals, Ordinance fish and indigenous plant species. The Ministry of Environment and Tourism (MET) administer it and provides for the establishment of the Nature Conservation Board. Forestry Act The Forestry Act (No 12 of 2001) specifies that there be a general protection of the receiving and surrounding environment. The protection of natural vegetation is of great importance, the Forestry Act especially stipulates that no living tree, bush, shrub or indigenous plants within 100m from any river, stream or watercourse, may be removed without the necessary license. Soil The Soil Conservation Act (No 76 of 1969) stipulates that the combating and Conservation preventing of soil erosion should take place; the soil should also be conserved, Act protected and improved, vegetation and water sources and resources should also be preserved and maintained. When proper mitigation measures are followed along the construction and implementation phase of the project, the natural characteristics of the property is expected to have a moderate to low impact on the environment. Labour Act The Labour Act (No 11 of 2007) states regulations to ensure the health, safety and welfare of employees and to protect employees from unfair labour practices. The Act also states that the employees should be provided with a working environment that is without risk to their health.

GREEN EARTH Environmental Consultants 34 Local The purpose of the Local Authorities Act is to provide for the determination, for Authorities purposes of local government, of local authority councils; the establishment of Act (No. 23 of such local authority councils; and to define the powers, duties and functions of 1992) local authority councils; and to provide for incidental matters.

CONCLUSION AND IMPACT

Green Earth Environmental Consultants believe the above administrative, legal and policy requirements which specifically guides and governs the project had been followed and complied with in the assessment of the activity. A flowchart indicating the entire EIA process is shown in the Figure below.

GREEN EARTH Environmental Consultants 35

Figure 22: Flowchart of the Impact Process

GREEN EARTH Environmental Consultants 36

8. AFFECTED RECEIVING ENVIRONMENT

8.1. BIODIVERSITY AND VEGETATION

Portion 15 forms part of the Tree and Shrub Savannah Biome (specifically the Highland Savannah). The project site has previously accommodated a cement factory and has been cleared to construct and operate the factory and supporting infrastructure, roads, parking and storage areas, and boundary walls and is thus showing evidence of human interference where the vegetation was cleared on some areas of the Portion to provide for the placement of the buildings and roads. The trees that have been spared from the previous activities should be retained as far as possible.

Project Site

Figure 23: Biomes in Namibia (Atlas of Namibia, 2002)

According to Mannheimer and Curtis (2009), the area is home to Prosopis Trees especially near water courses namely small rivers/streams. Acacia Mellifera (Black Thorn), Acacia erioloba (Camelthorn), Boscia Albitrunce, Albicia antihelmintica, Aloe Littorallis, Commiphera spp. and Acacia erubescens are all located on the project site and are protected plant species and are listed under the Forest Ordinance of 1952.

Central Namibia is regarded as “average to high” in overall (all terrestrial species) diversity while the overall terrestrial endemism is “high” (Mendelsohn et al. 2002). Central Namibia has between 161-200 endemic vertebrates (all vertebrates included). The overall diversity and abundance of large herbivorous mammals (big game) is viewed as “high” with 7-8 species while the overall diversity of large carnivorous mammals (large predators) is determined at 3 species with Leopard and Cheetah being the most important with “high” densities (Mendelsohn et al. 2002).

It is estimated that at least 78 reptile, 9 amphibian, 73 mammal and 209 bird species (breeding residents) are known to or expected to occur in central Namibia of which a high proportion are endemics.

GREEN EARTH Environmental Consultants 37 Mountainous and rocky features in the Highland Savannah are viewed as unique and often critical habitat to a variety of vertebrate fauna of concern – e.g. Python anchietae & Verreaux’s Eagle (“Near Threatened”). Such habitats should be protected, especially isolated patches thereof, as these often have an “island” effect with a variety of rock and crevasse dwelling species dependent on these areas.

Ephemeral drainage lines with associated riparian habitat, especially bigger trees, and temporary pools (and/or perennial springs and seeps) are also viewed as important habitat for a variety of vertebrate fauna – e.g. bark roosting bats; South African Gallago; cavity nesting birds (Monteiros & Damara Hornbills and Rüppells Parrot), etc. Important habitats for vertebrate fauna identified during the site visits are viewed as the rocky, mainly schist outcrops and few ephemeral drainage lines.

It is estimated that at least 78 reptiles, 9 amphibian, 81 mammal and 209 bird species (breeding residents) are known to or expected to occur in the area of which a large proportion are endemics. Endemics include at least 36% of the reptiles, 33% of the amphibians, 9.9% of the mammals and 71% (10 of the 14 Namibian endemics) of all the breeding and/or resident birds known and/or expected to occur in the general area. Although these endemics are known to occur in the general area, it is currently not clear if any of these are associated with the proposed development area(s) or how exactly they will be affected by this development.

The Highland Savannah, although varied, is classified by Combretum apiculatum subsp. apiculatum and Acacia hereroensis, Acacia reficiens and Acacia erubescens amongst others and the climax grasses on undisturbed areas dominated by Anthephora pubescens, Brachiaria nigropedata and Digitaria eriantha (Giess 1971). The best palatable grasses have often been denuded in the general area over time due to over- and selective grazing practices (Giess 1971). The overall vegetation structure can be classified as “dense shrubland” and “shrubs and low trees” (Mendelsohn et al. 2002).

According to Curtis and Mannheimer (2005) and Mannheimer and Curtis (2009) between 66 and 83 species of larger trees and shrubs are known and/or expected to occur in the general area, respectively. Twenty-seven (32.5%) species of larger trees and shrubs have protected status in the general area. Five species (6.1%) are endemic, 3 species (3.7%) near-endemic, and 16 species (19.3%) protected by Forestry laws, 3 species (3.7%) protected by Nature Conservation laws.

During the site visit, various species of trees/shrubs were identified in the proposed development area. Of these, 6 species (Acacia erioloba, Albizia anthelmintica, Boscia albitrunca, Ozoroa crassinervia, Searsia lancea & Ziziphus mucronata) are protected under Forestry legislation with 1 species also being “near-endemic” (Ozoroa crassinervia).

The most important tree/shrub species expected from the general area are the various protected species and species of conservation concern and include Commiphora dinteri (endemic), Cyphostemma bainesii (endemic, NC), Cyphostemma currorii (NC) and Heteromorpha papillosa (endemic). All aloe species are protected in Namibia and other species potentially occurring in the general area are Aloe hereroensis and Aloe zebrina (Rothmann 2004). None of the species are exclusively associated with the area. GREEN EARTH Environmental Consultants 38

Up to 101 grasses are expected in the area of which 4 species are viewed as endemic (Eragrostis omahekensis, Eragrostis scopelophila, Pennisetum foermeranum and Setaria finite). Pennisetum foermeranum is associated with rocky mountainous terrain and consequently only expected is such suitable habitat. Eragrostis omahekensis is virtually only found on disturbed soils – e.g. close to watering points – while Eragrostis scopelophila is associated with mountainous areas under trees and shrubs. The endemic Setaria finita is associated with drainage lines in the general area; never very common and probably the grass species most likely to be affected most by development in the area. None of the species are exclusively associated with the area. The dominant grass throughout the proposed development area was Brachiaria nigropedata.

Due to the high priority and urgency of the project, as it forms part of the Harambee Prosperity Plan, the contractor cleared the site to be able to complete a detailed site survey for the civil works which will follow. The site will be landscaped, and platforms will be created on which the facilities will be constructed. During the clearance of the site, the contractor kept the protected tree species and plants although the rest of the vegetation was removed.

GREEN EARTH Environmental Consultants 39

Figure 24: Trees on the Project Site

The natural characteristics of the project site namely the vegetation clearance and the destruction of habitats is expected to further on have a low impact on the environment before the mitigation measures are taken and after the mitigation measures are taken, the impact will be very low.

8.2. GEOLOGY AND SOILS

Portion 15 of Farm Otjiwarongo Townlands South No. 308 is in the Khomas Trough on a geological area classified as Damara Supergroup and Gariep Complex. See Map below.

GREEN EARTH Environmental Consultants 40 Project Site

(Atlas of Namibia Project, 2002) Figure 25: Geology of Namibia

The Khomas Trough was formed during sedimentation of the Late Proterozoic Damara Sequence. The basin that was filled by a thick sequence, now preserved as metagreywackes and pelites of the Kuiseb Formation, which were subsequently multiply deformed and thrusted during the Damaran Orogeny. Minor lithologies included are graphite schists, calc-silicates and scapolite schists.

8.3. PREVAILING HYDROGEOLOGY

The bedrock geology of the area consists primarily of highly deformed rocks of the Kuiseb Formation rocks of the Swakop Group. The dominant lithologies are metagreywacke and mica schist.

Project Site

Figure 26: Groundwater basin & rock types

GREEN EARTH Environmental Consultants 41 Structures present in the larger area are mainly north-south faults and joint systems. The north-south fault systems are less developed in the micaceous lithologies of the Kuiseb Formation rocks, as the mica schist undergoes plastic deformation rather than brittle fracturing. No faults are mapped within the development area.

Some geological observations made during the field visit are:

- The schist is generally more massive and foliation is not very well developed. - Some north-west – south-east striking joints are cross-cutting the massive schist. - Quartz veins are present. - The area is largely covered by a thin “quartz-pebble mulch” covering much of the soil horizon.

To understand the occurrence of groundwater and the potential pollution impact of the development on groundwater, it is necessary to describe the prevailing geohydrological conditions, and to understand some of the fundamental geohydrological concepts. The predominant geology is the determining factor in the behaviour and characteristics of the geohydrological environment. The underlying geology is primarily schist, which is considered having a low groundwater potential and low risk of groundwater contamination.

Along drainage channels and rivers, alluvium may be found which have a moderate to high groundwater potential, with an associated higher risk of groundwater pollution. The main aquifer type found in the area is secondary fractured aquifers hosted in the mica schist of the Kuiseb Formation, with perceived limited (small) aquifers formed along the ephemeral river courses that are associated with river alluvials, or where groundwater recharge takes place during flood events.

Schist, being a naturally poor host of groundwater, acts as an aquiclude, or when hosting groundwater, at best as an aquatard. The weathering product of schist is clayey material, which also is not favourable for transmitting groundwater. The field observations made regarding some of characteristics of the schist, namely its massive nature together with cross-cutting joints, is important in that:

1. The massive schist will be even more impervious than well-foliated schist, thereby further reducing the potential for groundwater flow.

2. The joints, if open at depth, will have higher transmissivity in relation to the matrix rock transmissivity, thus resulting in higher percolation rates and flow rates of groundwater in the joints.

3. If the quartz veins are a result of quartz intrusion from depth, these veins can act as preferential flow paths, and it can also store significant quantities of groundwater, thus it can potentially act as good secondary aquifers.

It must however be borne in mind that, even if flow rates can be higher in certain parts of the schist, the rock type in general is at best an aquatard. Furthermore, the “geohydrologically better” portion of the schist in relation to the “geohydrologically poor”

GREEN EARTH Environmental Consultants 42 portion of the schist is most likely negligibly small. The most significant negative aspect of this higher transmissivity characteristic in joint zones is that pollutants can enter and disperse through such joint zones easier. At the same time however, it will be difficult to remove or abstract any pollutant from the schist due to its over-all poor transmissivity.

All information suggests that the area in general has poor groundwater potential and the predominant geology in the area results in very little risk of groundwater contamination, unless pollutants end up in geological structures acting as preferential groundwater flow paths (faults or open joints) or along the river courses where groundwater flow in the alluvial sediments will be higher. Under such conditions the transmissivity is higher; therefore, the potential to transmit pollutants can also be moderate to high.

The Hydrogeological Map of Namibia shows that the study area falls in a zone of rock bodies with little groundwater potential (generally low; locally moderate potential) in an area of metamorphic rocks.

PTN Re/56 Ongos

Figure 27: Hydrogeological Map of Namibia (Geological Survey of Namibia, 2015)

It can therefore be concluded that the geological and geohydrological settings: limit the flux of groundwater between different groundwater bodies or aquifers in the schist bedrock, thus limiting the movement of potential pollutants within this rock type; limit the probability that groundwater utilisation in one area will adversely affect groundwater availability in surrounding areas, and could result in higher flux within homogenous layers (Geological Survey of Namibia, 2015).

8.4. SURFACE WATER

Surface water flow in a catchment is largely determined by rainfall (quantity and intensity), potential evapotranspiration and catchment relief. A drainage system comprises all the elements of the landscape through which or over which water travels within that drainage basin. These elements include the soil, vegetation growing on it, geological materials underlying the soil, stream channels carrying surface water and the GREEN EARTH Environmental Consultants 43 zones where water is held in the soil and moves below the surface. It also includes constructed elements such as pipes and culverts, cleared and compacted land surfaces, and pavement and other impervious surfaces unable to absorb water. The hydrology of a region is thus characterised by the collection, movement and storage of water through a drainage basin.

Alteration of a natural drainage basin through for instance urbanisation can impose dramatic changes in the movement and storage of water. These changes can have negative impacts on other parties that use water for industrial, domestic and livestock watering purposes in the immediate vicinity or downstream.

According to Grunert (2003), the Geology of Namibia centrally is dominated by Damara Sequence. Pre-Cambrian aged metasedimentary strata of the Kuiseb Formation of the Damara Sequence are underlain on the project site. The Kuiseb Formation comprises of more than 6000m thick succession of mica schist, graphic schist, marble and quartzite. Biotite schist is the dominating rock type identified on the project site. Minor strata of micaceous quartzite, feldspathic schist and amphibole schist are also present (Grunert, 2003).

The project site is generally uneven with rock outcrops at places. Natural slopes are seen near natural drainage courses on the project site. The soil is suitable for development however the soil is also erodible and should not be used for building of infrastructure. Removing soil and using it for building purposes could cause erosion. Any additional filling material required for the creation of the platforms should be obtained from commercially approved suppliers.

8.5. THE SOCIO-ECONOMIC ENVIRONMENT

The character of the surrounding land is already of an industrial nature. Establishing the tyre pyrolysis plant on Portion 15 will thus not have further negative impacts on the neighbourhood as people are already used to the daily movement of construction vehicles, large trucks as well as the operations of manufacturing facilities in this area. The project site will be properly serviced by bulk services constructed to municipal standards and therefore be of limited nuisance to the surrounding landowners.

The tyre pyrolysis plant is expected to provide employment for ±15 people in the construction phase and in the operational phase for ±10 people. Some of the jobs to be created are drivers, tyre collectors, managers, operators, administrative officers and cleaners. Employment creation will have a positive impact.

8.6. CLIMATE

No specific climate data is available for Portion 15 of Farm Otjiwarongo Townlands South No 308, Otjozondjupa Region however in general the area is characterized with a semi-arid highland savannah climate typified as very hot in summer and moderate dry in winter. The highest temperatures are measured in December with an average daily temperature of maximum 31ºC and a minimum of 17ºC. The coldest temperatures,

GREEN EARTH Environmental Consultants 44 conversely, are measured in July with an average daily maximum of 20ºC and minimum 6ºC (Weather - the Climate in Namibia, 1998 – 2012). The area therefore has low frost potential.

Rainfall in the form of thunderstorms is experienced in the area during the summer months between October and April. The annual average rainfall is 350mm to 400mm however the average evaporation rate is 3 400mm a year (Weather - the Climate in Namibia, 1998 – 2012). Over 70% of the rainfall occurs in the in the summer months’ period between November and March. Rainfall in the area is typically sporadic and unpredictable however the average highest rainfall months are January to March.

The prevailing wind direction is expected to prevent the spread of any nuisance namely noise and smell. The predominant wind in the region is easterly with westerly winds from September to December (Weather - the Climate in Namibia, 1998 – 2012). Extreme winds are experienced in the months of August and September and thus significant wind erosion on disturbed areas is visible.

Project Site

(Atlas of Namibia Project, 2002) Figure 28: Average annual temperatures in Namibia

8.7. HYDROLOGICAL COMPONENT

The area where the project site is located has generally a low to average groundwater potential from a permeability and yield perspective (Grunert, 2003). However, groundwater is one of the important water sources and the protection thereof should be regarded as a high priority. The main uses of water in the area are for business, industrial and domestic purposes and agriculture and farming activities.

Although most of the surface water evaporates, runoff can be expected due to the impermeability of soils (Grunert, 2003). The storage and accumulation of substances, which might pollute river courses or basins because of surface water drainage, should be prevented. No potential pollutants should be channeled or directed towards any rivers.

GREEN EARTH Environmental Consultants 45 From the hydrological assessment perspective, no major geological structures that will enhance groundwater recharge or flow are evident on the proposed project site and the development that will take place will not pose any long-term negative effects on the hydrological cycle (Grunert, 2003).

8.8. CULTURAL HERITAGE

The proposed project site is not known to have any historical significance prior to or after Independence in 1990. The specific area does not have any National Monuments and the specific site has no record of any cultural or historical importance or on-site resemblance of any nature. No graveyard or related article was found on the site.

9. IMPACT ASSESSMENT AND EVALUATION

The Environmental Impact Assessment sets out potential positive and negative environmental impacts associated with the proposed project site which is located on Portion 15 of the Farm Otjiwarongo Townlands South No 308, Otjozondjupa Region. The following assessment methodology will be used to examine each impact identified, see Table below:

Impact Evaluation Criterion (DEAT 2006) Criteria Rating (Severity)

Impact Type +VE Positive

O No Impact

-VE Negative

Significance of L Low (Little or no impact) impact being either M Medium (Manageable impacts)

H High (Adverse impact)

Probability: Duration:

5 – Definite/don’t know 5 - Permanent

4 – Highly probable 4 – Long-term (impact ceases)

3 – Medium probability 3 – Medium term (5 – 15 years)

2 – Low probability 2 – Short-term (0 – 5 years)

1 – Improbable 1 - Immediate

0 - None

Scale: Magnitude:

GREEN EARTH Environmental Consultants 46 5 – International 10 – Very high/don’t know

4 – National 8 - High

3 – Regional 6 - Moderate

2 – Local 4 - Low

1 – Site only 2 - Minor

0 - None

10. POSSIBLE IMPACTS ON RECEIVING ENVIRONMENT

The Environmental Impact Assessment carried out identified the negative and positive impacts on the socio-economic environment especially relating to the long term health and safety of people involved in the operations and residing or working in the immediate surroundings of the site as well as the impacts on the bio-physical environment. The proposed project has been evaluated over the different stages of the project cycle namely:

- Planning - Construction - Operations - Decommissioning

During the EIA the following impacts were identified and evaluated:

 Flue and Greenhouse gas emissions  Energy consumption and requirements  Social and cultural issues  Water usage and requirements  Ecological impacts  Dust pollution and air quality  Noise impact  Health, safety and security  Contamination of groundwater  Sedimentation and erosion  Generation of and management of building, household and noxious waste  Contamination of surface water  Traffic and road safety  Fires and explosions  Storage of tyres and harmful substances  Sense of Place and general ambiance

GREEN EARTH Environmental Consultants 47

11. SUMMARY OF ENVIRONMENTAL ASSESSMENT

The overview/summary of the Environmental Impact Assess is presented in Table 2 below. The activities identified that could potentially have significant environmental impacts have been identified and is discussed in the section below Table 2. Mitigatory actions for activities with negative impacts are also included in these discussions.

Table 2: Summary of Impacts Phase Aspect/ Activity Impact Scale Duration Magnitude Probability Significance of Type Impact - Unmitigated - Mitigated Construction Energy O 3 3 4 3 - M consumption/ - L requirements Social and +VE 4 5 4 3 - L Cultural - L Water Usage -VE 3 4 6 4 - M - M Ecology -VE 3 4 6 4 - M - M Dust & Air -VE 3 4 6 4 - M Quality - M Noise -VE 2 4 6 3 - M - M Safety & Security -VE 2 4 6 3 - M - M Groundwater -VE 3 4 6 3 - M - M Erosion and -VE 1 3 4 2 - M Sedimentation - M Waste -VE 2 4 6 3 - M - M Surface water -VE 2 3 6 2 - M - M Traffic -VE 2 4 6 3 - M - M Fires and -VE 2 4 6 3 - M Explosions - M Nuisance -VE 1 4 6 3 - M Pollution - M

Operation Emissions -VE 3 4 6 3 - M - M Wastewater -VE 2 4 6 3 - M - M Ecology -VE 1 4 6 3 - M - M Dust & Air -VE 2 4 6 3 - M Quality - M -VE 2 4 6 3 - M  Groundwater - M contamination

GREEN EARTH Environmental Consultants 48 Waste -VE 1 4 6 3 - M Generation - M Failure of -VE 1 4 6 3 - M Reticulation - M Pipeline Fires and -VE 2 4 6 3 - M Explosions - M Safety & Security -VE 1 4 6 3 - M - M Storage -VE 1 4 6 3 - M - M Cumulative -VE 2 4 6 3 - M Impacts - M

The impacts on the receiving environment are discussed in the paragraphs below.

11.1. IMPACTS DURING CONSTRUCTION PHASE

Some of the impacts that the development has on the environment includes water will be used for the construction and operation activities, electricity will be used, a sewer system will be constructed, and wastewater will be produced on the site that will have to be handled.

11.1.1. ENERGY CONSUMPTION AND REQUIREMENTS

The electricity consumed during construction is expected to vary however the electricity consumed during operation has been estimated at 200 kWh daily. Energy/electricity usage is not expected to be an issue however it is recommended to use energy/electricity only when needed.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Energy O 3 3 4 3 M L

11.1.2. SOCIAL AND CULTURAL ISSUES

GREEN EARTH Environmental Consultants 49 Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Social and +VE 4 3 4 3 L L Cultural

11.1.3. WATER USAGE AND REQUIREMENTS

Water is a scarce resource in Namibia and therefore water usage should be monitored and limited in order to prevent unnecessary wastage. The proposed tyre pyrolysis plant will make use of water in its construction phase and operations however it is not anticipated that it will entirely be water-based operations. The emission control equipment (wet scrubber) will consume 0.7 m³ per day. All pipes and tanks should be checked and monitored in order to prevent water being lost due to leakages.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Water -VE 3 4 6 4 M M Usage

11.1.4. ECOLOGICAL IMPACTS

The proposed tyre pyrolysis plant will be constructed in a semi disturbed natural area which is sparsely covered with vegetation. Special care should be taken to limit the destruction or damage of the vegetation. However, impacts on fauna and flora are expected to be minimal. Disturbance of areas outside the designated working zone is not allowed.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Ecology -VE 3 4 6 4 M M

11.1.5. DUST POLLUTION AND AIR QUALITY

Dust generated during the transportation of building materials; construction and installation of bulk services, and problems thereof are expected to be low and site specific due to the sandy nature of the top soils. Dust is expected to be worse during the winter months when strong winds occur. Release of various particulates from the site GREEN EARTH Environmental Consultants 50 during the construction phase and exhaust fumes from vehicles and machinery related to the construction of bulk services are also expected to take place. Dust is regarded as a nuisance as it reduces visibility, affects the human health and retards plant growth.

It is recommended that regular dust suppression be included in the construction activities, when dust becomes an issue. No unnecessary revving of engines or operation of vehicles is allowed. In general, the servicing of these extensions is envisaged to have minimal impacts on the surrounding air quality.

Impact evaluation

 Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Dust & Air -VE 3 4 6 4 M M Quality

11.1.6. NOISE IMPACT

An increase of ambient noise levels at the proposed site is expected due to the construction activities. Noise pollution due to excavation, heavy-duty equipment and machinery will be generated.

It is not expected that the noise generated during construction will impact any third parties due to the distance of the neighbouring activities. Ensure all mufflers on vehicles are in full operational order; and any audio equipment should not be played at levels considered intrusive by others. Construction works should not be carried out during undue hours or at nighttime. The construction staff should be equipped with ear protection equipment.

In the operational phase of the plant, noise will be produced through a shredder, valves and pumps. The expected noise level at 500 m and 1000 m will be 58 dBA and 45 dBA respectively. The noise level will be inline within the prescribed limits of industrial noise.

Impact evaluation

 Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

Noise -VE 2 4 6 3 M M

11.1.7. HEALTH, SAFETY AND SECURITY

The safety, security and health of the labour force, employees and general public are of great importance. Workers should be orientated with the maintenance of safety and health procedures and they should be provided with PPE (Proper Protective Equipment).

GREEN EARTH Environmental Consultants 51 A health and safety officer should be employed to manage, coordinate and monitor risk and hazard and report all health and safety related issues in the workplace.

Safety issues could arise from the earthmoving equipment and tools that will be used on site during the construction phase. This increases the possibility of injuries and the contractor must ensure that all staff members are made aware of the potential risks of injuries on site. The presence of equipment lying around on site may also encourage criminal activities (theft).

Sensitize operators of earthmoving equipment and tools to switch off engines of vehicles or machinery not being used. The contractor is advised to ensure that the team is equipped with first aid kits and that they are available on site, always. Workers should be equipped with adequate personal protective gear and properly trained in first aid and safety awareness.

No open flames, smoking or any potential sources of ignition should be allowed at the project location. Signs such as ‘NO SMOKING’ must be prominently displayed in parts where inflammable materials are stored on the premises. Proper barricading and/or fencing around the site especially trenches for pipes and drains should be erected to avoid entrance of animals and/or unauthorized persons. Safety regulatory signs should be placed at strategic locations to ensure awareness. Adequate lighting within and around the construction locations should be erected, when visibility becomes an issue.

Impact evaluation

Aspect Impact Scale Duration Magnitude Probability Significance Type Unmitigated Mitigated

 Safety & -VE 2 4 6 3 M M Security

11.1.8. CONTAMINATION OF GROUNDWATER

Care must be taken to avoid contamination of soil and groundwater. Use drip trays when doing maintenance on machinery. Maintenance should be done on dedicated areas with linings or concrete flooring. The risk can be lowered further through proper training of staff. All spills must be cleaned up immediately. Excavations should be backfilled and sealed with appropriate material, if it is not to be used further. Fuel oil that is produced and handled can pollute ground and surface water if not handled and stored properly.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Groundwater -VE 3 4 6 3 M M

GREEN EARTH Environmental Consultants 52

11.1.9. SEDIMENTATION AND EROSION

Vegetation stabilizes the area against wind erosion. Vegetation clearance and creation of impermeable surfaces could result in erosion in areas across the proposed area. The clearance of vegetation will further reduce the capacity of the land surface to slow down the flow of surface water, thus decreasing infiltration, and increasing both the quantity and velocity of surface water runoff. The proposed construction activities will increase the number of impermeable surfaces and therefore decrease the amount of groundwater infiltration. As a result, the amount of storm water during rainfall events could increase. If proper storm water management measures are not implemented this will impact negatively on the water courses close to the site.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Erosion and -VE 1 3 4 2 M M Sedimentati on

11.1.10. GENERATION OF WASTE

This can be in a form of rubble, cement bags, pipe and electrical wire cuttings. This waste should be gathered and stored in enclosed containers to prevent it from being blown away by the wind. Contaminated soil due to oil leakages, lubricants and grease from the construction equipment and machinery may also be generated during the construction phase. It is expected that ±15 workers will be employed on site that will produce domestic waste.

The oil leakages, lubricants and grease must be addressed. Contaminated soil must be removed and disposed off at a hazardous waste landfill. The contractor must provide containers on-site, to store any hazardous waste produced. Regular inspection and housekeeping procedure monitoring should be maintained by the contractor. Waste should be stored, recycled and removed from site to a designated waste landfill site. Metal waste and other scrap should be sent to a recycling facility.

Impact Evaluation

 Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Waste -VE 2 4 6 3 M M

GREEN EARTH Environmental Consultants 53

11.1.11. CONTAMINATION OF SURFACE WATER

Contamination of surface water might occur through oil leakages, lubricants and grease from the equipment and machinery during the installation, construction and maintenance of bulk services at the site. Oil spills may form a film on water surfaces in the nearby streams causing physical damage to water-borne organisms.

Machinery should not be serviced at the construction site to avoid spills. All spills should be cleaned up as soon as possible. Hydrocarbon contaminated clothing or equipments should not be washed within 25m of any surface water body.

Impact Evaluation

 Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Surface -VE 2 3 6 2 M M water

11.1.12. TRAFFIC AND ROAD SAFETY

All drivers of delivery vehicles and construction machinery should have the necessary driver’s licenses and documents to operate these machines. Speed limit warning signs must be erected to minimise accidents. Heavy-duty vehicles and machinery must be tagged with reflective signs or tapes to maximize visibility and avoid accidents.

Impact Evaluation

 Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

Traffic -VE 2 4 6 3 M M

11.1.13. FIRES AND EXPLOTIONS

There should be enough water available for firefighting purposes. Ensure that all firefighting devices are in good working order and are serviced. All personnel must be trained about responsible fire protection measures and good housekeeping such as the removal of flammable materials on site. Regular inspections should be carried out to inspect and test firefighting equipment by the contractor.

GREEN EARTH Environmental Consultants 54 Impact Evaluation

 Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Fires and -VE 2 4 6 3 M M Explosions

11.1.14. SENSE OF PLACE AND GENERAL AMBIANCE

The placement, design and construction of the proposed tyre pyrolysis plant should be as such as to have the least possible impact on the natural environment. The proposed activities will not have a large/negative impact on the sense of place in the area since it will be constructed in a manner that will not affect the neighbouring portions and it will not be visually unpleasing.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Nuisance -VE 1 4 6 3 M M Pollution

11.2. IMPACTS DURING OPERATIONAL PHASE

11.2.1. FLUE AND GREENHOUSE GAS EMISSIONS

The pyrolysis plant will not contribute to GHG emissions as it does not require oxygen, thus does not produce CO². The waste does not comprise of halogens, therefore there will be no hazardous emissions. The production of hydrogen chloride (HCI) is avoided by the absence of polyvinyl chlorine (PVC) in the mixed plastic waste. Rubber, carbon black, metal, textile, zinc oxide, sulphur and additives will however contribute to hydrogen chloride. The particulate matter will comprise of carbon black, sulphur, zinc oxide, clay filler, calcium carbonate, magnesium carbonate and silicates (EPA, 1991). The pyrolysis units are expected to have minimal air pollution impacts since most of the pyrolysis gas generated in the pyrolysis process will be burned as fuel in the process.

During burning, the organic compounds will be destroyed. Assuming complete combustion, the products will be water, carbon dioxide, oxygen and nitrogen from excess gas and hydrogen from pyrolysis gas. The table below shows the composition of pyrolytic gas used for energy recovery in the gas burner:

GREEN EARTH Environmental Consultants 55

Table 3: Gas Composition from Pyrolysis (EPA, 1991)

A wet scrubber should be used in order to minimise the impacts that emissions may have on the environment. A wet scrubber is wetted packed towers to reduce gas. The scrubber is used to remove contaminants namely NO×, SO×, fly ash and particulate matter from the gas stream by passing the stream through a packed structure which provides a wetted surface area to reduce contact between the gas and the scrubbing liquor. The contaminant is absorbed into or reacted with the scrubbing liquor. A demister is fitted at the top of the tower to prevent entrainment of droplets of the scrubbing liquor into the extraction system or stack. See below an example of a wet scrubber:

Figure 29: Wet Scrubber Image

Fugitive emissions will comprise of volatile organic compounds (VOC). Approximately 100 MT of tyres per day, 50 kg of VOC are emitted (EPA, 1991). It is estimated that the plant (5 MT/day) will produce 2.5 kg of VOC per day. VOC will be reduced through supervision, maintenance practices, training of personnel and the use of specific components (valves, pumps, compressors).

GREEN EARTH Environmental Consultants 56 Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Emissions -VE 3 4 6 3 M L

11.2.2. WASTEWATER GENERATION

Employees will produce domestic wastewater and water will be used in the scrubber liquor in the flue gas cleaning operation. Ozone and sulphuric acid are formed in the cleaning operation. The wastewater produced must be treated. The wastewater will be pumped into bag filters and then recycled to the spray nozzles of the wet scrubber. The particulate solids will be collected and dried prior to disposal at the landfill.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

Wastewater -VE 2 4 6 3 M M

11.2.3. ECOLOGICAL IMPACTS

Staff and visitors should only make use of walkways and existing roads to minimise the impact on vegetation. No firewood may be collected on the site. Minimise the area of disturbance by restricting movement to the designated working areas during maintenance and drives.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

Ecology -VE 1 4 6 3 M M

11.2.4. DUST POLLUTION, ODOUR AND AIR QUALITY

Vehicles transporting goods and staff will contribute to the release of hydrocarbon vapours, carbon monoxide and sulphur oxides into the air. Possible release of sewer odour, due to sewer system failure of maintenance might also occur. Odour due to the burning of tyres may also occur. All maintenance of bulk services and infrastructure at the project site must be designed to enable environmental protection.

GREEN EARTH Environmental Consultants 57

Figure 30: Noise Exposure Limits and Times

The site should be enclosed to avoid causing dust nuisance to the neighbouring activities. The project area should be sprayed with grey water to reduce dust generation.

Impact Evaluation

 Aspect  Impact  Scale  Duration  Magnitude  Probability  Significance Type  Unmitigated  Mitigated

 Dust & Air -VE 2 4 6 3 M M Quality

11.2.5. CONTAMINATION OF GROUNDWATER

Spillages might also occur during maintenance of the sewer system. This could have impacts on groundwater especially in cases of large sewer spills. Proper containment should be used in cases of sewerage system maintenance to avoid any possible leakages. Oil and chemical spillages may have a heath impact on groundwater users. Potential impact on the natural environment from possible polluted groundwater also exits.

Impact Evaluation

 Aspect  Impact  Scale Duration  Magnitude  Probability  Significance Type  Unmitigated  Mitigated

 Groundwater -VE 2 4 6 3 M M

 contamination

11.2.6. GENERATION AND MANAGEMENT OF SOLID WASTE

Household waste from the activities at the tyre pyrolysis plant and from the staff working at the site will be generated. This waste will be collected, sorted to be recycled and stored in on site for transportation and disposal at an approved landfill site.

GREEN EARTH Environmental Consultants 58 Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

Waste -VE 1 4 6 3 M M Generation

11.2.7. FAILURE IN RETICULATION PIPELINES

There may be a potential release of sewage, stormwater or water into the environment due to pipeline/system failure. As a result, the spillage could be released into the environment and could potentially be health hazard to surface and groundwater. Proper reticulation pipelines and drainage systems should be installed. Regular bulk services infrastructure and system inspection should be conducted.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Failure of -VE 1 4 6 3 M M Reticulation Pipeline

11.2.8. FIRES AND EXPLOSIONS

Food will be prepared on gas fired stoves. There should be enough water available for firefighting purposes. Ensure that all fire-fighting devices are in good working order and are serviced. All personnel must be trained about responsible fire protection measures and good housekeeping such as the removal of flammable materials on site. Regular inspections should be carried out to inspect and test firefighting equipment by the contractor.

Impact Evaluation

 Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Fires and -VE 2 4 6 3 M M Explosions

11.2.9. HEALTH, SAFETY AND SECURITY

The safety, security and health of the labour force, employees and neighbours are of great importance, workers should be orientated with the maintenance of safety and health procedures and they should be provided with PPE (Proper Protective Equipment) such as gloves, helmet and steel-toes shoes. Workers should be warned not to GREEN EARTH Environmental Consultants 59 approach or chase any wild animals occurring on the site. A health and safety officer should be appointed on site.

No open flames, smoking or any potential sources of ignition should be allowed at the project location. Signs such as ‘NO SMOKING’ must be prominently displayed in parts where inflammable materials are stored on the premises. Fire extinguishers should be placed on site. No open-air burning will be allowed near the storage facility and plant. No welding or heat generating devices is allowed near the site.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

Safety & -VE 1 4 6 3 M M Security

11.2.10. STORAGE OF TYRES AND HARMFUL SUBSTANCES

There are risks associated with storage of scrap tyres and waste plastics. Tyre fires if not managed can cause environmental and air pollution. This may cause health problems such as skin and eye irritation, cancer and nervous system ailments.

There is also a possibility for tyre leachate; this may contaminate groundwater, surface water and soil. Improper storage of tyres may become a breeding ground for mosquitoes, rodents and other animals. Therefore, the storage of tyres should be away from surface water courses, flood zones and groundwater recharge points. The storage area should have a concrete flooring to prevent leachate. Flammable or combustible liquids should not be stored near the tyre storage site.

Impact Evaluation

Aspect  Impact  Scale  Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

Storage -VE 1 4 6 3 M M

11.3. CUMMULATIVE IMPACTS

These are impacts on the environment, which results from the incremental impacts of the construction and operation of the proposed tyre pyrolysis plant when added to other past, present, and reasonably foreseeable future actions regardless of what person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over time. In relation to an activity, it means the impact of an activity that in it may not become significant when added to the existing and potential impacts resulting from similar of diverse activities or undertakings in the area.

GREEN EARTH Environmental Consultants 60

Possible cumulative impacts associated with the proposed project includes sewer damages/maintenance, vegetation and animal disturbance, uncontrolled traffic and destruction of the natural environment. These impacts could become significant especially if it is not properly supervised and controlled. This could collectively impact on the environmental conditions in the area. Cumulative impacts could occur in both the operational and the construction phase.

Impact Evaluation

 Aspect  Impact  Scale Duration  Magnitude  Probability Significance Type  Unmitigated  Mitigated

 Cumulative -VE 2 4 6 3 M M Impacts

12. ENVIRONMENTAL MANAGEMENT PLAN

The Environmental Management Plan (EMP) provides management options to ensure impacts of the proposed construction and operation of the tyre pyrolysis plant are minimised. An EMP is an environmental management tool used to ensure that undue or reasonably avoidable adverse impacts of the operations are prevented, and the positive benefits of the projects are enhanced.

The objectives of the EMP are:

 to include all components of the proposed project;  to prescribe the best practicable control methods to lessen the environmental impacts associated with the project;  to monitor and audit the performance of the project personnel in applying such controls; and  To ensure that appropriate environmental training is provided to responsible project personnel.

The EMP acts as a document that can be used during the various phases of the proposed project. The contractor constructing the tyre pyrolysis plant and associated facilities as well as the management and staff should be made aware of the contents of the EMP. See Appendix for EMP.

13. CONCLUSION

The EIA has been completed in line with the requirements of the Environmental Management Act, 2007 and Regulations and it is concluded and recommended that the specific site identified for the construction and operation of the tyre pyrolysis plant has the full potential to be used for the proposed activities. The identified environmental and social impacts can be minimized and managed through implementing preventative measures and sound management systems. It is recommended that the environmental

GREEN EARTH Environmental Consultants 61 performance be monitored regularly to ensure compliance and that corrective measures be taken if necessary.

In general, the construction and operation of the proposed plant would pose limited environmental risks, provided that the EMP for the activity is used properly during the planning, construction and operational phases. The EMP should be used as an onsite tool during the construction and operation of the project. Parties responsible for non- conformances of the EMP should be held responsible for any rehabilitation that has to be undertaken.

After assessing all information available on this project, Green Earth Environmental Consultants are of the opinion that the proposed project site is suitable for the proposed establishment of the tyre pyrolysis plant. The accompanying EMP will focus on mitigation measures that will remediate or eradicate the negative or adverse impacts.

14. RECOMMENDATION

It is therefore recommended that the Ministry of Environment and Tourism through the Environmental Commissioner support and approve the Environmental Clearance for: A TYRE PYROLYSIS PLANT FOR THE PRODUCTION OF OIL/DIESEL, CARBON BLACK, GAS AND STEEL ON PORTION 15 OF FARM OTJIWARONGO TOWNLANDS SOUTH NO. 308 and to issue an Environmental Clearance for the following ‘Listed Activities’:

GREEN EARTH Environmental Consultants 62 LIST OF REFERENCES

Atlas of Namibia Project, 2002. Directorate of Environmental Affairs, Ministry of Environment and Tourism. http://www.unikoeln.de/sfb389/e/e1/download/atlasnamibia/pics/climate/temperature- annual.jpg [accessed: February 19, 2014].

Christelis, G.M. & Struckmeier, W. 2001. Groundwater in Namibia, an Explanation of the Hydrogeological Map. Ministry of Agriculture, Water and Rural Development. Windhoek. Namibia, pp 128.

Commencement of the Environmental Management Act, 2012. Ministry of Environment and Tourism. Windhoek. Namibia, pp. 3 – 22.

Constitution of the Republic of Namibia, 1990. National Legislative Bodies. Namibia, pp. 6 – 63.

DEAT. 2006 Guideline 4: Public Participation in support of the Environmental Impact Assessment Regulations, 2006. Integrated Environmental Management Guideline Series, Department of Environmental Affiars and Tourism (DEAT, Pretoria.

DEAT. 2006 Guideline 5: Assessment of Alternatives and Impacts in support of the Environmental Impact Assessment Regulations, 2006. Integrated Environmental Management Guideline Series, Department of Environmental Affiars and Tourism (DEAT, Pretoria.

Environmental Management Act, 2007. Ministry of Environment and Tourism. Windhoek. Namibia, pp. 4 - 32.

Forestry Act, 2001. Office of the Prime Minister. Windhoek. Namibia, pp. 9 – 31.

Grunert, N. 2003. Namibia Fascination of Geology: A Travel Handbook. Windhoek. Klaus Hess Publishers. pp. 35 – 38.

Mannheimer, C. & Curtis, B. 2009. Le Roux and Muller’s Guide to the Trees & Shrubs of Namibia. Windhoek: Macmillan Education Namibia, pp. 249 – 439.

Namibian Environmental Assessment Policy, 1995. Ministry of Environment and Tourism. Windhoek. Namibia, pp. 3 – 7.

Nature Conservation Ordinance, 1975. Windhoek. Namibia, pp. 4 – 47.

Soil Conservation Act, 1969. Office of the Prime Minister. Windhoek. Namibia, pp. 1 – 14.

Water Resource Management Act, 2004. Office of the Prime Minister. Windhoek. Namibia, pp. 6 – 67.

Weather - the Climate in Namibia, 2012. http://www.info-namibia.com/en/info/weather [accessed: June 24, 2013].

GREEN EARTH Environmental Consultants 63 APPENDIX A: NEWSPAPER NOTICES

GREEN EARTH Environmental Consultants 64

GREEN EARTH Environmental Consultants 65 GREEN EARTH Environmental Consultants 66

GREEN EARTH Environmental Consultants 67

APPENDIX B: BACKGROUND INFORMATION DOCUMENT

GREEN EARTH Environmental Consultants 68 APPENDIX C: LIST OF I&APS

GREEN EARTH Environmental Consultants 69 APPENDIX D: COMMENTS FROM I&APS Comments Dear Sir/Madam

Green Earth Environmental Consultants are conducting an Environmental Impact Assessment for the construction and operation of a tyre pyrolysis plant for the recycling of end of life/used tyres for the production of oil/diesel, carbon black, gas and steel on Portion 15 of the Farm Otjiwarongo Townlands South No. 308, Otjozondjupa Region. You have been identified as an Interested and Affected Party to the proposed activity. See attached a Background Information Document which provides information on the proposed activity, the possible impacts on the receiving environment and the environmental assessment process to be followed.

Should you have any questions regarding the project, please contact Green Earth Environmental Consultants at the contact details provided on Page 1 of this document. The closing date for any questions, comments, inputs or information on the proposed project is 24 May 2019.

A public meeting will be held only if there is enough public interest. Only I&APs that registered will be notified of the possible public meeting to be held.

Kind regards

Carien

Morning Ms van der Walt

Portion 15 currently has access from a private/municipal road (that runs south-eastwards towards the town and joins the D2440) and not a district road. District road D2430 commences on the western side of the B1 and runs westwards. The access point of the private/municipal road onto the B1 is for the Roads Authority problematic as this creates with the D2430 a cross intersection that is potentially very dangerous for users of the B1 and should be closed. Please see attached Google Earth image and copy of SPC drawing indicating future road along route A-B which should be used as access from the D2440 northwards to the pyrolysis plant.

Regards GREEN EARTH Environmental Consultants 70 EAM de Paauw From: Abraham Kanime Sent: Wednesday, May 8, 2019 4:00 PM To: [email protected] Subject: I&AP for proposed Pyrolysis Plant

Good day,

May you please register me as Interested Party for this project EIA.

Name: Abraham Kanime Specific interest: air quality, waste management and supply of waste tyres

Please share draft scoping report.

Regards, Abraham From: Rene De Wet Sent: Monday, May 27, 2019 12:18 PM To: Carien Subject: FW: Background Information Document - Portion 15 of the Farm Otjiwarongo Townlands South No 308, Otjozondjupa Region

Good morning

Below is confirmation from our front desk that no enquiries or comments were received.

Regards, Rene

From: Adelma Seibes Sent: Monday, 27 May 2019 12:12 PM To: Rene De Wet Subject: RE: Notices - Consent and EIA - Portion 15 of Farm Otjiwarongo Townlands South No. 308

Hi Rene

No objection that I can find on Adelma’s computer.

From: Miriam Gomes Sent: Monday, 27 May 2019 9:17 AM To: Rene De Wet Subject: RE: Background Information Document - Portion 15 of the Farm Otjiwarongo Townlands South No 308, Otjozondjupa Region

Good morning Rene

In front office there were not any objections received. I will check with Adelma office whether she have and let you know.

GREEN EARTH Environmental Consultants 71 Regards

From: Rene De Wet Sent: Monday, May 27, 2019 8:13 AM To: Miriam Gomes; Adelma Seibes Subject: FW: Background Information Document - Portion 15 of the Farm Otjiwarongo Townlands South No 308, Otjozondjupa Region

Morning Ladies

Can you kindly confirm if any comments were received on the notice for the EIA being conducted?

Regards, Rene From: Werner van Riet Sent: Monday, April 29, 2019 10:21 AM To: [email protected]; [email protected] Subject: Recycling of used tyre

Good morning

Hope all is well ,

Could you please give more details concerning the above as we are in the process of looking for someone to dispose/Sell our tyres ,

We have the world’s biggest tyres on site 59/80R63.

Thank you very much Kind Regards … Werner

Werner Van Riet Team Leader Tyre Mining Maintenance

Husab Mine I Swakopmund I Namibia PO Box 8667 I Swakopmund I Namibia

Direct Extension : +264 (0) 64 – 411 1241 Mobile : +264 (0) 81 224 6333

E-mail : [email protected] Website : www.swakopuranium.com From: [email protected] [mailto:[email protected]] Sent: Monday, April 29, 2019 4:53 PM To: 'Werner van Riet'; [email protected]; 'Joagh Matsi' Subject: RE: Recycling of used tyre

Dear Werner

Your email below refers. Please note that we are only doing the EIA on this project.

Our client, Mr Joagh Matsi, will definitely be interested in sourcing tyres from you. I

GREEN EARTH Environmental Consultants 72 copied him in this email and trust that he will be in contact with you in this regard.

Kind regards

Charlie

GREEN EARTH Environmental Consultants 73

APPENDIX E: DEED OF TRANSFER

GREEN EARTH Environmental Consultants 74 GREEN EARTH Environmental Consultants 75 GREEN EARTH Environmental Consultants 76 GREEN EARTH Environmental Consultants 77 GREEN EARTH Environmental Consultants 78

APPENDIX F: LEASE AGREEMENT (the complete copy is available on request)

GREEN EARTH Environmental Consultants 79

GREEN EARTH Environmental Consultants 80

GREEN EARTH Environmental Consultants 81 GREEN EARTH Environmental Consultants 82 APPENDIX G: CURRICULUM VITAE OF CHARLIE DU TOIT

1. NAME : Charlie du Toit

2. DATE OF BIRTH : 29 October 1960

3. NATIONALITY : Namibian

4. EDUCATION AND PROFESSIONAL TRAINING:

Institution: Boland Agricultural High School, Paarl, Republic of South Africa

Date :from (month / year) : January 1974 To (month / year) : December 1978 Diploma obtained: Grade 12

Institution: University of Stellenbosch, RSA Date :from (month / year) : 1979 To (month / year) : 1982 Certificate obtained: BSc Agric Hons (Chemistry, Agronomy and Soil Science)

Institution: University of Stellenbosch, RSA Date :from (month / year) : 1985 To (month / year) : 1987 Degree obtained: Hons B (B + A) in Business Administration and Management

5. PROFESSIONAL EXPERIENCE (most recent experience first):

EXPERIENCE (SELECTED RECORDS) Name of Project Date Client EIA Omaruru Trade and Industrial 2015 NDC Estate which includes a service station on a portion of the Remainder of Portion B and Portion 57 of Omaruru Town and Townlands No. 85 EIA Kwando North Gateway Resort in 2015 Mufiljo Investment CC the Babatwa Park EIA Farm Wanderdunen No. 23 2014 Private owners and developers Rezoning to Industrial EIA Service Station on Portion 52 of 2014 Private owners and developers Farm Koichas No. 89, Mariental ERF 1581 Rundu, Regional Head 2013 NDC/Ministry of Agriculture, Office of Ministry of Agriculture, Water Water and Forestry and Forestry. EIA for closure of public GREEN EARTH Environmental Consultants 83 open space and rezoning of erf EIA Erf 376, Outjo development of 2013 NDC/Ministry of Trade and Tourist Market and SME Center Industry EIA Omugongo Trade and Industrial Private Developers Estate EIA of for Industrial development on portion 51 - 52, Dobra EIA for industrial development on 2012 Private owners and developers Portion 428 of Farm Brakwater No. 48 EIA for rezoning of Portion 176 of Farm Brakwater 48 to industrial EIA for rezoning to industrial and to use Portion 87 of Farm Brakwater 48 for a slaughter house Environmental Management Plan 2011 Private owners Taranga Island Lodge EIA Industrial development and use Portion 35 of Farm Dobra No. 49 Layout Planning and Subdivision for 2010 Private owners and developers residential development of Portion 33 of Farm Nubaumis No. 37 Layout planning and subdivision for a residential development on Portions

89 & 90 of Farm Brakwater Application for Goreangab Waterfront Development on Erf 3188, Goreangab under Special Projects Policy of City of Windhoek Feasibility, layout planning and 2009 NDC subdivision Portion 75 of Okahandja Town and Townlands Layout Planning and Subdivision of NDC Oshakati Town and Townlands No. 880 EIA Portion 24 of Farm Brakwater No. Private Developer 48 Layout Planning and Subdivision of Portion 24 of Farm Brakwater No. 48 Layout Planning and Subdivision – 2008 Private Developer new Dairy Production Unit, Farm Purple Gold 511, Seëis Layout Planning and Subdivision 2008 Private Developer Farm Arcadia No. 134, Seëis Assisting in the Layout Planning and 2007 Private Developers Formalization of Sukulu Wildlife Development, Farm Augeigas Layout Planning and Subdivision of 2006 - 2008 Private Owners and Developers various Brakwater Portions: GREEN EARTH Environmental Consultants 84

Portion Re/38, Farm Brakwater No.48 Portion 44, Farm Brakwater No.48 Portion 46, Farm Brakwater No.48 Portion 48, Farm Brakwater No.48 Portion 51, Farm Brakwater No.48 Portion 52, Farm Brakwater No.48 Portion 55, Farm Brakwater No.48 Portion 57, Farm Brakwater No.48 Portion 59, Farm Brakwater No.48 Portion 62, Farm Brakwater No.48 Portion 77, Farm Brakwater No.48 Portion 83, Farm Brakwater No.48 Portion 114, Farm Brakwater No.48

Layout Planning and Subdivision of 2005 -2008 Private Owners and Developers various Nubaumis Portions:

Portion 20/59, Farm Nubaumis No. 37 Portion 21, Farm Nubaumis No. 37 Portion 30, Farm Nubaumis No. 37 Portion 45/63, Farm Nubaumis No. 37

Layout Planning and Subdivision of 2005 -2008 Private Owners and Developers various Dobra Portions:

Portion 12, Farm Dobra No. 49 Portion 17, Farm Dobra No. 49 Portion 18, Farm Dobra No. 49

General Manager Commercial and 2003 - 2005 Pupkewitz Megabuild Marketing – Reporting to the MD -Key responsibilities:

Marketing - to analyse market trends and to ensure that customer expectations were met; Procurement – To establish, maintain, develop and optimise sound supplier relationships; Inventory management – to optimise the stockholding of the Group through the implementation of systems to manage slow moving and excess stock, the availability of stock and the product range; Logistics – to manage the inbound supply chain;

GREEN EARTH Environmental Consultants 85 Co-ordination with the operational, finance and admin and the human resources functions.

General Manager Trade – Reporting 1995 - 2003 Agra Cooperative Limited to the CEO - Key Responsibilities

Determination of Product range and mix; The selection of suppliers/vendors and transporters; The pricing strategy; The growth of turnover and the retention and improvement of margins; Inventory management; The simplification of processes and tasks at branch level; The reduction of shrinkage; The evaluation of Agra business units on positioning and performances; Feasibility studies on new investments.

Chief Agricultural Consultant 1989 - 1995 Pneumatic Green Energy CC in partnership with the Namibia Agricultural Specialist acting as Industrial Development Agency project leader on various projects undertaken by the NDC/FNDC on own initiative or on behalf of the governmental or private institutions. The own NDC operations managed by myself include the Eersbegin Date project, the Naute Irrigation project, the Shitemo project, the Musese project, the Vungu-Vungu dairy, the Shadikongoro project and the Mahangu and Cotton Farmers’ Support programs. Projects managed on an agency basis are the Etunda and Omega farmer settlement schemes. This operations include about 800 ha under irrigation and 3 000 ha under rain fed conditions. Crops like mahangu, groundnuts, cotton, wheat, dates, barley and vegetables are produced.

GREEN EARTH Environmental Consultants 86 Agricultural Researcher with the 1985 - 1988 Ministry of Agriculture Department of Agriculture acting as researcher and assistant other senior agricultural researcher on various assignments of the Department

I hereby declare that the information portrayed in this CV is accurate and true.

______Charlie du Toit

GREEN EARTH Environmental Consultants 87 APPENDIX H: CHARLIE DU TOIT IDENTIFICATION DOCUMENT

GREEN EARTH Environmental Consultants 88 APPENDIX I: CURRICULUM VITAE OF CARIEN VAN DER WALT

1. Proposed Position : Environmental Consultant/Practitioner 2. Name : Carien van der Walt 3. Date of Birth : 06 August 1990 4. Nationality : Namibian

5. Education: Years Institution Degree/Diploma 2009 to 2011 University of Stellenbosch B.A. (Degree) Environment and Development 2012 to 2013 University of South Africa B.A. (Honours) Environmental Management

6. Languages: Language Speaking Reading Writing English Excellent Excellent Excellent Afrikaans Excellent Excellent Excellent

7. Employment History: Elmarie Du Toit Town Planning Consultants 2010/2011 Vacation Work Green Earth Environmental Consultants 2011/2012 Permanent

8. Work undertaken that best illustrates capability to handle the tasks assigned: Name of assignment or project: Taranga Safari Lodge Year: 2012 Location: Rundu, Namibia Client: Mr Cobus Bruwer Main project features: Environmental Management Plan compilation Status: Clearance Certificate Obtained

Name of assignment or project: The sand mining operations of Sand Worx CC Waterfront Development Project Year: 2012 Location: Windhoek, Namibia Client: Green Building Construction Main project features: Environmental Management Plan compilation Status: Clearance Certificate Obtained

Name of assignment or project: Erf 35, Farm Brakwater No. 48 Year: 2012 Location: Windhoek (Brakwater)

GREEN EARTH Environmental Consultants 89 Client: Ms CJ Maposa Main project features: Scoping Assessment for Rezoning to Industrial and Environmental Management Plan Status: Clearance Certificate Obtained

Name of assignment or project: Erf 176, Farm Brakwater No. 48 Year: 2012 Location: Windhoek (Brakwater) Client: Mr Andre van Staden Main project features: Scoping Assessment for Rezoning to Industrial and Environmental Management Plan Status: Clearance Certificate Obtained

Name of assignment or project: Erf 428, Farm Brakwater No. 48 Year: 2012 Location: Windhoek (Brakwater) Client: Mr D Barnard Main project features: Scoping Assessment for Rezoning to Industrial and Environmental Management Plan Status: Clearance Certificate Obtained

Name of assignment or project: Erf 87, Farm Brakwater No. 48 Year: 2012 Location: Windhoek (Brakwater) Client: Indraai Abattoir Main project features: Scoping Assessment for Rezoning to Industrial and Environmental Management Plan Status: Clearance Certificate Obtained

Name of assignment or project: Areva Uranium Mine Year: 2012 Location: Swakopmund Client: Areva Uranium Mine Main project features: Scoping Assessment for Road Construction and Environmental Management Plan

Name of assignment or project: Wispeco Namibia Year: 2012 Location: Windhoek (Northern Industrial Area) Client: Wispeco Namibia

GREEN EARTH Environmental Consultants 90 Main project features: Environmental Auditing Report for site and Environmental Management Plan

Name of assignment or project: Tsumeb Industrial Development Year: 2012 Location: Tsumeb Client: Sand Worx CC Main project features: Scoping Assessment for Industrial Development and Environmental Management Plan Status: Clearance Certificate Obtained

I hereby declare that the information portrayed in this CV is accurate and true.

______Carien van der Walt

GREEN EARTH Environmental Consultants 91

APPENDIX J: CARIEN VAN DER WALT IDENTIFICATION DOCUMENT

GREEN EARTH Environmental Consultants 92

APPENDIX K: ENVIRONMENTAL MANAGEMENT PLAN

GREEN EARTH Environmental Consultants 93