ENVIRONMENTAL IMPACT ASSESSMENT (SCOPING) REPORT
FOR THE PROPOSED STORAGE AND LOGISTIC FACILITY FOR PETROLEUM PRODUCTS IN USAKOS, ERONGO REGION
AUGUST 2019
DOCUMENT INFORMATION
Title Environmental Impact Assessment (Scoping) Report the establishment of a storage and logistic facility for petroleum products in Usakos. ECC Application Reference number Activity Activity 9: Hazardous substance treatment, handling and storage Activity 10: Construction of public roads & railways Location Usakos Town Lands Erf number 40A/REM (industrial property) about 150 m from the railway and B2 Highway Proponent MDL International (Pty) LTD
For Official Correspondence: Mr. Domingos Manuel Chief Executive Officer Office: +264 61 217549 E-mail: [email protected]
For Technical Enquiries: Mr. Hans Shingenge General Manager: Commercial Services Office: +264 8111222912 E-mail: [email protected] Issue Date Authors: Grace Shihepo, Environmental Assessment Practitioner (EAP) Reviewer: Jonas Heita, Environmental Assessment Practitioner (EAP)
Copyright “This document is the intellectual property of TEC and may only be used for the intended purpose. Unauthorized use, duplication, copying or reproduction without referencing or obtaining written consent from TEC is illegal”
i Environmental Scoping Report: MDL Petroleum Products Logistic and Storage Hub@Usakos-Namibia
EXECUTIVE SUMMARY
MDL International Trade (PTY) Limited is a Namibian based company that specializes in onshore and offshore operations with the focus on petroleum products. The company proposes to establish a petroleum storage and logistic facility in Usakos for storage and distribution thereof. MDL envisioned to undertake the project in two phases; namely Phase 1 and 2. Each phase is characterized by a series of infrastructural development. The proposed petroleum storage and logistic hub triggers activities that are listed under the EMA.
MDL proposes to transport and distribute petroleum products using an innovative logistic scheme throughout the supply chain. The proposed process requires the company to incur high initial investment costs; however, the process is preferred due to its safety. This includes the use of ISO certified carrying and above ground storage tanks, improved storage floor and machinery. There will be no transfer of petroleum products at the facility, reducing oil spill incidences. During Phase 1 MDL supply chain involves petroleum transportation from Petroleum Farm in Walvis Bay until the fuel is distributed to the respective clients within the SADC region. Phase 2 petroleum products will be transported in two routes to the petroleum storage and logistic hub in Usakos.
The potential environmental impacts associated with the proposed project were determined by identifying the environmental aspects and then undertaking an environmental risk assessment to determine the significant environmental impacts. The impact assessment included all phases of the project, with specific emphasis on construction and operation in mind. The assessment of the biophysical and socio- economic environment revealed that there are no environmental fatal flaws or significant negative impacts associated with the project, and potential impacts can be minimised by implementing mitigation and management measures as prescribed in the project EMP.
As a safety approach the floor will be designed and constructed in a manner that will minimise chances of groundwater contamination, in an event of an accidental oil spill. The fuel tankers will always be required to be parked on the special flooring. Regular inspections are recommended on the tankers and flooring to monitoring any signs of fuel leakage or spillage in the area. Monitoring boreholes will need to be established near to the project site to track changes in groundwater quality. If fuel contamination is detected, actions must be taken to identify the source of contamination and mitigation measures implemented.
The impact on air quality, water quality and health & safety are considered the most notable potential impacts which may result from the proposed project. However, the impact mitigation measures contained within the EMP will aid in reducing the environmental and social impacts.
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TABLE OF CONTENTS
CHAPTER 1 ...... 1 1. INTRODUCTION ...... 1 1.1 MDL International Trade ...... 1 1.2 Location ...... 1 1.2.1 Project Rationale and Motivation ...... 4 1.3 Terms of Reference for Environmental Assessment ...... 5 1.3.1 Application for ECC ...... 5 CHAPTER 2 ...... 6 2. PROJECT INFORMATION ...... 6 2.1 Process Design...... 6 2.1.1 The Fuel Chain Process ...... 6 2.1.2 Storage Capacity ...... 6 2.1.3 Route 1: Via B2 Highway ...... 7 2.1.4 Route 2: Via the Trans-Namib Railway ...... 7 2.2 Tank Design ...... 8 2.3 Floor Design ...... 9 2.4 Project Phases ...... 11 2.4.1 Phase 1: Erection of a Temporary Logistics Hub ...... 11 2.4.2 Phase 2: Establishment of a Fuel Storage and Logistic Hub ...... 12 2.4.3 Socio-economic Development ...... 12 CHAPTER 3 ...... 14 3. LEGAL FRAMEWORK ...... 14 3.1 Environmental Protection: Namibian Constitution ...... 14 3.2 Environmental Management Act No. 7 of 2007 ...... 14 3.2.1 Listed Activities ...... 14 3.2.2 Environmental Management Plan (EMP) ...... 16 3.3 Environmental Assessment Policy (1995) ...... 16 3.4 Other Legal Requirements ...... 16 3.5 Precautionary and Polluter Pays Principles ...... 19 CHAPTER 4 ...... 20 4. AFFECTED ENVIRONMENT...... 20 4.1 Surrounding Environment ...... 20 4.2 Climate ...... 20 4.2.1 Vegetation and Biodiversity ...... 20 4.3 Socio-economics ...... 21 CHAPTER 6 ...... 22 5. IMPACT ASSESSMENT METHODOLOGY ...... 22 5.1 Assessment of Impact Significance ...... 22 5.2 Determination of Significance ...... 22 5.3 Environmental Mitigation ...... 23 5.4 Cumulative Effects...... 23 CHAPTER 7 ...... 24 6. IMPACT ASSESSMENT ...... 24
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6.1 Introduction ...... 24 6.2 Phase 1 ...... 24 6.2.1 Erection of a Temporary Logistics Hub ...... 24 6.2.2 Fuel Transportation via B2 Highway ...... 24 6.3 Phase 2 ...... 25 6.3.1 Fuel transportation via the Trans-Namibia Railway ...... 25 6.4 Cumulative Effects...... 25 6.4.1 Groundwater ...... 25 CHAPTER 8 ...... 26 7. PUBLIC PARTICIPATION PROCESS ...... 26 7.1 Introduction ...... 26 7.2 Consultation Activities ...... 26 CHAPTER 9 ...... 29 8. CONCLUSION AND RECOMMENDATIONS ...... 29 8.1 Conclusion ...... 29 8.2 Recommendations ...... 29
LIST OF FIGURES
Figure 1: Location of the proposed petroleum facility in Usakos as demarcated with the red polygon (source: google images) ...... 2 Figure 2: Project Location – Erf 40A/REM, Usakos Town Lands, already zoned as Industrial ... 3 Figure 3: Fuel transport via B2 road ...... 7 Figure 4: Typical semi-trailer ISO tank (Photo for illustration purposes only ...... 8 Figure 5: MDL temporary logistic base at Usakos (Source: http://mdlinternationaltrade.com/usakos) ...... 11 Figure 6: Facility layout upon completion of Phase 2 ...... 13
LIST OF TABLES
1: ISO Tank Main Parameters ...... 9 Table 2: Floor Design – Fuel Storage Facility ...... 10 Table 3: List of activities relevant to the proposed project ...... 15 Table 4: Additional permits required for the proposed development ...... 16 Table 5: Potential effects on groundwater ...... 25 Table 6: Summary of Stakeholder consultation activities ...... 26 Table 7: Issues raised during public consultation ...... 27
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DEFINITIONS
Acronym Definition dBA decibels EC Environmental Commissioner ECC Environmental Clearance Certificate EIA Environmental Impact Assessment EMA Environmental Management Act (Act No. 7 of 2007) EMP Environmental Management Plan I&APs Interested and Affected Parties MET Ministry of Environment and Tourism
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CHAPTER 1
1. INTRODUCTION
1.1 MDL International Trade
MDL International Trade (PTY) Limited (herein referred to as MDL) is a Namibian based company founded in 1993. The company specializes in onshore and offshore operations with the focus on petroleum products (including diesel, petrol, aviation jet fuel A1, aviation kerosene and HFC gas).
In 2016 MDL obtained a license from the Ministry of Mines and Energy to import, export and distribute petroleum products across the South African Development Community (SADC) Region. Thus, the company proposes to establish a petroleum storage and logistic facility in Usakos for storage and distribution thereof. The facility will supply both the local and regional market (SADC1) at an estimated ratio of 1:92.
The proposed petroleum storage and logistic hub triggers activities that are listed under the EMA. Meaning an EIA should be conducted. MDL envisioned to undertake the project in two phases; namely Phase 1 and 2. Each phase is characterized by a series of infrastructural development.
1.2 Location
Usakos is located about 140 kilometers east of Swakopmund town along the B2, in the Erongo Region. The petroleum storage and logistics hub will be established on an industrial property, Erf number 40A/REM which lies about 150 m from the railway and about 150 m from B2 Highway (see Figure 2).
1 SADC – Southern Africa Development Community 2 Target Market Ratio 1:9 (10% local to 90% regional)
1 Environmental Scoping Report: MDL Petroleum Products Logistic and Storage Hub@Usakos-Namibia
Figure 1: Location of the proposed petroleum facility in Usakos as demarcated with the red polygon (source: google images)
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Figure 2: Project Location – Erf 40A/REM, Usakos Town Lands, already zoned as Industrial
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1.2.1 Project Rationale and Motivation
Namibia is one of the few countries in SADC bordering the Atlantic Ocean, which connects and presents shipping opportunities (import and export) with the rest of the world. Most of the countries in SADC are landlocked and depend on countries with shipping opportunities (like Namibia) for their imports and exports. Walvis Bay provides the shortest route for landlocked countries in SADC for their imports and exports. SADC has a market of 400 million people.
Namibia recognizes the importance of harbor services for both its own shipping needs and the need to assist landlocked countries within the SADC region. As a result, Namibia developed a master plan to become an international logistics hub and gateway for landlocked countries. The master plan resulted in following:
▪ New container terminal of 40 hectares ▪ Deepening of the access channel for ships to the port to -14 meters depth. (This increased the competitive capability and made it a direct competitor to South Africa’s port of Cape Town). ▪ Dredging of the berths and extended the length of the quay. ▪ Development of transport corridors like the Trans-Kalahari Corridor through Botswana to Gauteng and Mozambique and the Walvis-Bay-Ndola- Lubumbashi-Corridor, which reaches Zambia, Zimbabwe and the south-eastern part of the Democratic Republic of Congo (DRC).
At present, local exports (Namibian products) through the Port of Walvis Bay only make up about 20% of the port’s annual freight turnover and comprises of Uranium, Gold, Diamonds, Marble, Granite, Salt and Fish (NamPort, 2018). Copper from Zambia (refined at Dundee Precious Metals in Tsumeb), and wood from the DRC and Zambia are among the bulk of transit goods exported through Walvis Bay.
The main imports are bulk fuel, copper and lead concentrates, fish products, sugar, wheat, cement, vehicles and steel. The goods are transported from Walvis Bay by road to neighbouring countries and vice versa. Botswana, Zambia and Zimbabwe are leasing land at the port each for interim storage their imports and exports (NamPort, 2018).
The proposed petroleum storage and logistics facility by MDL will also contribute to economic growth through income generation from tax and employment created, which is the core of NDP 5, Vision 2030, Harambee Prosperity Plan and the Growth at Home Strategy. These frameworks envision Namibia to be a regional logistics and industrial hub.
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1.3 Terms of Reference for Environmental Assessment
Tortoise Environmental Consultants (TEC) has been appointed to undertake an Environmental Impact Assessment (EIA), scoping exercise and to develop an Environmental Management Plan (EMP), for the proposed establishment of a petroleum storage and logistic hub in Usakos.
The assessment includes:
• Description of the receiving environment that may be affected by the proposed project and the way the physical, biological, social, economic and cultural aspects of the environment may be affected;
• Description and assessment of the significance of any significant effects, including cumulative effects, that may occur as a result of the undertaking of the activity or identified alternatives or as a result of any construction, erection or decommissioning associated with the undertaking of the proposed development;
• Information on the proposed management, mitigation, protection or remedial measures to be undertaken to address the effects on the environment that have been identified including objectives in respect of the rehabilitation of the environment and closure; and
• Description of the manner in which the MDL intends to modify, remedy, control or stop any action, activity or process which could cause pollution or environmental degradation.
1.3.1 Application for ECC
Upon completion, the EIA Scoping Report and EMP will be submitted to MET for review and decision, in accordance with Section 8 of the EIA Regulations, as part of the application for an Environmental Clearance Certificate (ECC).
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CHAPTER 2
2. PROJECT INFORMATION
2.1 Process Design The current approach to transporting and storage of petroleum products is through tanker trucks and underground storage tanks. The transfer process of the products from the tanker trucks to the underground tanks is associated with risks that can result in fire hazards and environmental contamination. If no proper precautionary measures are applied, the transfer process can result in oil spills that can affect underground water resources.
MDL proposes to transport and distribute petroleum products using an innovative logistic scheme throughout the supply chain. This includes the use of ISO certified carrying and above ground storage tanks, improved storage floor and machinery.
The proposed process requires the company to incur high initial investment costs; however, the process is preferred due to its safety. There will be no transfer of petroleum products at the facility, reducing oil spill incidences.
2.1.1 The Fuel Chain Process
During Phase 1 MDL supply chain involves petroleum transportation from Petroleum Farm in Walvis Bay until the fuel is distributed to the respective clients within the SADC region. Phase 2 petroleum products will be transported in two routes to the petroleum storage and logistic hub as summarized in figure 2-2 and 2-3 below. Petroleum will be transported using the portable semi-trailer containers which will be carried by trucks during Phase 1 or by trains during Phase 2, from the Petroleum Farm to MDL petroleum storage and logistic hub.
Onsite, the tanks will be offloaded using special forklift to minimize mechanical handling and stored until it is further processed for distribution. Fuel will be stored in the same containers allowing minimal fuel exchange. This will reduce the potential of oil spillage which is common in the traditional method.
2.1.2 Storage Capacity
The entire operation is expected to have a storage capacity of 247,500,000 litres. This translates to 11,000 tank containers to be stored with 22,500 litres capacity each. During Phase 1 transportation will commence with approximately 135,000 litres of petroleum per day.
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2.1.3 Route 1: Via B2 Highway
This route from the Walvis Bay Tank Farm will be employed mainly during the phase 1 and minimally in Phase 2 as the use of the train will be introduced to transport the petroleum containers tanks.
Petroleum from the vessel is transferred to Petroleum Tank Farm through docking facility via a pipe until it is further transferred into MDL petroleum containers tanks (mounted on truck). The truck will then transport the tanks to storage facility in Usakos via the B2 road between Walvis Bay and Usakos. The summarised route is summarised below in Figure 2-1.
Tank Farm MDL MDL Road containers Transportation Storage Transport Vessel Walvis Bay Tanks on Via B2 Facility in to Port Trucks Usakos Consumer
Figure Error! No text of specified style in document.-1: Fuel transport via B2 road
In this operation, MDL proposes to introduce intersection onto the B2 road for access and to allow smooth flow of traffic to and from the facility. The town planner will develop the layout sketch indicating railway intersection.
2.1.4 Route 2: Via the Trans-Namib Railway
During this route MDL will transport fuel via the Trans-Namib Railway. This routed will only be introduced in the second phase of the project. Similar to Route 1, fuel will be channelled onto tank farm using a pipe and transferred onto tankers mounted on the train instead of the truck. These special trains will transport fuel to MDL storage facility via the railway.
MDL Road Tank Farm MDL Containers transportation Transport Walvis Bay Storage Vessel Tanks on via Railway Facility to Port the train Consumer F Figure 3: Fuel transport via B2 road
During this process, MDL will construct a railway off-ramp to allow access from railway to the site railway station where the containers will be offloaded to the storage facility using the special forklifts. The town planner will develop the layout sketch indicating railway intersection.
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2.2 Tank Design
MDL will integrate the container tanks that can be transported both trucks and train. The container tanks per truck have a carrying capacity of 45,000 liters, and each container tank have a total carrying capacity of 22,500 liters. Semi-trailers are the preferred option for this operation due to the advantaged properties listed below:
• Same transporting container tanks can be used for storage minimizing fuel exchange through different media reducing the significant risk of spillage during operation. • Up to 9 levels container tanks can be stacked together optimizing the use of storage. • It allows for quick offloading at the facility. • Tanks are made of materials that can withstand up extreme heat (up to 300°C) which makes more heat resistant • It can take up to 2 hours before the tank ignites or catches fire due to material’s inability to can fire easily? (See an example of typical Semi-Trailer tank in figure 2-2).
Figure 4: Typical semi-trailer ISO tank (Photo for illustration purposes only
Description of an ISO Tank
An ISO Tank is a tank container which is built to the ISO standard (International Organisation for Standardisation). ISO tanks are designed to carry liquids in bulk, both hazardous and non-hazardous product. Table 2-1 below features the ISO tank main parameters
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1: ISO Tank Main Parameters
ISO Tank Main Parameters Frame material JIS G33125 SPA-H or equivalent Tank material SANS 50028-7 Type 1.442/1 Capacity 22,500 Ltr Tare mass 3870 kg Max gross mass 36,000 kg Working pressure 4 bar
2.3 Floor Design
As a safety approach the floor will be designed and constructed in a manner that will minimise chances of groundwater contamination, in an event of an accidental oil spill. The floor will be consisting four (4) types of pavements i.e. • Bituminous Pavement • Concrete Pavement • Prefabricated Concrete Blocks, and • Precast Concrete Kerb. The design sketches are presented in the table overleaf.
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Table 2: Floor Design – Fuel Storage Facility
Specification of the Bituminous Pavement
Specifications of the Prefabricated Concrete Blocks
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2.4 Project Phases
2.4.1 Phase 1: Erection of a Temporary Logistics Hub
During Phase 1, MDL will construct and erect temporary structures as shown in figure 2-5. This will include erection of temporal parking space for 20-40 trucks, few administration offices, ablution facilities plus a septic tank and water tanks for water supply.
The facility will cover a total area of 2.5 hectares and will serves as temporary logistic base, where MDL will be operating during Phase 1. This facility will be able to accommodate 40 trucks. The operation duration of this Phase 1 will be approximately 24 months than Phase 2 will advance setting up a storage facility.
Figure 5: MDL temporary logistic base at Usakos (Source: http://mdlinternationaltrade.com/usakos)
The temporal structure that is currently on the site
The temporary infrastructure has been erected on the site to proof MDL’s commitment towards the realisation of the proposed facility. As presented in Figure 2-5, the semi-permanent buildings can be seen. Figure 2-6 shows the signpost at the entrance of the site.
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2.4.2 Phase 2: Establishment of a Fuel Storage and Logistic Hub
Phase 2 will comprise removal of the non-permanent structures erected during phase 1 and construction of the permanent structures. MDL will construct and set up an operation and storage facility that includes the following supporting structures, as presented in Figure 6. • Decommissioning/removal of phase 1 structures • Administration building comprising office space; • Food outlet • Intersection (Traffic-circle) into the B2 road • Control Room; • Truck port / Parking area; • Iveco mechanical workshop; • Onsite Heliport; • Of-Ramp from Trans-Namib existing Railway; • Fuel storage yard made up of special floor (made out of non-permeable material) fitted with drainage • Connection to the Town Council sewer system; • Public Filling Station equipped with banking utilities and public amenities; • Run-off (storm) water system • Weighbridge fitted with scanner at the storage facility main gate
During this phase MDL will create more than 3,000 permanent and an additional of 1200 indirect jobs.
2.4.3 Socio-economic Development
Usakos town has a population of 7,000 inhabitants and covers a total area of 58 square kilometers of land. Compared to other Namibian towns, Usakos is relatively underdeveloped which consequently contributed to severe poverty and alcohol abuse being experienced in the town. As per agreement with the Usakos Authorities, MDL committed to develop the Town through various socio-economic projects.
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Figure 6: Facility layout upon completion of Phase 2
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CHAPTER 3
3. LEGAL FRAMEWORK
3.1 Environmental Protection: Namibian Constitution
The Namibian constitution is the supreme law of the country and makes provision for environmental protection and sustainable development. Article 95(1) of the Constitution states that “The State shall actively promote and maintain the welfare of the people by adopting policies aimed at the maintenance of ecosystems, essential ecological processes and biological diversity of Namibia and utilization of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future”.
To fulfill the Article 95 of the Constitution, in 2007, the Government for the Republic of Namibia enacted the Environmental Management Act (Act No. 7 of 2007) and subsequently, the EIA Regulations of 2012 (Government notice no: 30 of 2012).
3.2 Environmental Management Act No. 7 of 2007
The environmental management act No.7 of 2007 aims to promote the sustainable use of natural resources and provides the framework for the environmental and social impact assessment, demands precaution and mitigation of activities that may have negative impacts on the environment and provision for incidental matters. Furthermore, the act provides a list of activities that may not be undertaken without an environmental clearance certificate.
The purpose of the Environmental Management Act is:
a) to ensure that people carefully consider the impact of developmental activities on the environment and in good time b) to ensure that all interested or affected people have a chance to participate in environmental assessments c) to ensure that the findings of environmental assessments are considered before any decisions are made about activities which might affect the environment 3.2.1 Listed Activities
The Environmental Management Act (EMA), Act No. 7 of 2007, stipulates that, for each activity listed under the EIA regulations, an Environmental Impact Assessment (EIA) is required.
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Listed activities may not be undertaken without an Environmental Clearance Certificate (ECC). Section 7 of the Environmental Impact Assessment (EIA) Regulations (GN notice No. 30 of 2012), stipulates that if the proposed project triggers a listed activity, an EIA scoping exercise must be undertaken and a Scoping Report and Environmental Management Plan should be submitted to the Environmental Commissioner (EC) as part of the application for an Environmental Clearance Certificate (ECC).
Establishing the proposed logistics and storage facility triggers some listed activities in terms of the Environmental Management Act no. 7 of 2007 and the Environmental Impact Assessment Regulations of 6 February 2012. The specific listed activities that are triggered are listed in Table 3 below.
Table 3: List of activities relevant to the proposed project
Activity Specific Activity Proposed Activity Activity 5 5.1 The rezoning of land from Although a town scheme exists Land use open space to other land use for Usakos, the actual sub- and division rezoning of ervens has development not been concluded. Therefore, activities the proposed site is still zoned as undermine industrial and the sub- division needs to be rezone to industrial service. Activity 9 9.4 The storage and handling of The proposed project will Hazardous dangerous goods, including transport, store and handle up to substance petrol, diesel, liquid petroleum 235, 200, 000 liters of hazardous treatment, gas or paraffin, in containers with substances such as petrol, diesel, handling and a combined capacity of more than jet fuel and aviation Kerosene storage 30 cubic meters at any one location. 9.5 Construction of filling stations or any other facility for the underground and aboveground storage of dangerous goods, including petrol, diesel, liquid, petroleum, gas or paraffin. Activity 10 (a) oil, water, gas and The proposed project consists of Construction petrochemical and other bulk the construction of the railway supply pipelines; station, and access roads. (b) public roads (round about); An MDL truck port, fuel storage railways and harbours; and filling station for MDL fleet will be constructed.
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3.2.2 Environmental Management Plan (EMP)
In-addition to the EIA scoping exercise, the Environmental Management Act stipulates that for each activity undergoing an EIA process, an Environmental Management Plan (EMP) should be developed.
The EMP outlines mitigation measures against specific steps, stages or processes of the proposed development. Thus, the EMP can be defined as the tool used to prevent / minimize the impacts identified during the EIA process. For accountability, the EMP outlines specific roles and responsibilities for the role-players, and non- compliance is punishable by law.
3.3 Environmental Assessment Policy (1995)
The Environmental Assessment Policy for Sustainable development and Environmental Conservation emphasize the importance of environmental assessments as a key tool towards implementing integrated environmental management. Sets an obligation to Namibians to prioritize the protection of ecosystems and related ecological processes.
The policy subjects all developments to environmental assessment and provides guideline for the Environmental Assessment. The policy advocates that Environmental Assessment take due consideration of all potential impacts and mitigations measures should be incorporated in the project design and planning stages (as early as possible).
3.4 Other Legal Requirements
In addition to the EMA and the Environmental Assessment Policy, there exist other regulatory frameworks that MDL must comply with. This is due to the supporting infrastructure that are needed to compliment the proposed logistics hub. As such, MDL will be required to obtain additional specific permits for the supporting infrastructure as listed in table 4 below. The process of obtaining the additional permits can be undertaken concurrently to the EIA process.
Table 4: Additional permits required for the proposed development
Activity Type of Permits Department/Contact Hazardous Substance Fitness certificate Usakos Town Council storage facility Hazardous Substance Ministry of Health and Social Services handling Permit (Department of Public and Environmental Health) Filling Station ECC Department of Environmental Affairs Cross border fuel Fitness certificate Usakos Town Council exportation Fuel Export Permit Ministry of Mines and Energy
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Railway (off-ramp) Written formal application Mr. Michael Feldmann for clearance Executive: Operations (Trans-Namib) Tel: +264 61 298 2465 Email: Michael.Feldmann@transnamib. com.na Intersection- B2 Road Application for Access Mr. EAM De Paauw from B2 Highway Roads Legislation Compliance Tel: 061 284 7027 Email: [email protected]
Furthermore, the proponent has the responsibility to ensure that the project activities conform to all other relevant legal documents and guidelines as listed in Table 3.1 below).
Table 5 Other relevant legislation and applicability thereof
Legal Requirements Legislation Relevant Aspect of Project considered authority The Pollution Control and Waste Management Bill, intents to regulate and prevent the discharge of pollutants into the air and water as well as providing for general waste management. Upon gazettement, the Bill will repeal the Atmospheric Pollution Control and Pollution Prevention Ordinance (11 of 1976). Waste MET, MHSS The Bill also provides for noise, dust or odour Management and others control that may be considered a nuisance. Bill (in Furthermore, the Bill advocates for duty of care preparation) with respect to waste management affecting humans and the environment and advocates for a waste management licence for any activity relating to waste or hazardous waste management. The Public Health Act aims to protect the public from nuisance and states that no person shall cause a nuisance or shall suffer to exist on any Ministry of land or premises owned or occupied by him or of Public Health Health and which he is in charge any nuisance or other Act (Act No. 36 Social condition liable to be injurious or dangerous to of 1919) Services health. The proponent should ensure that the workers are provided with protective gear to safeguard their wellbeing. The activities should also be
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Legal Requirements Legislation Relevant Aspect of Project considered authority conducted in a manner that does not pose any danger to the general public and that any emissions which could be considered a nuisance should be contained at acceptable levels. This Ordinance serves to control air pollution from point sources. Any person carrying out a Atmospheric Ministry of ‘scheduled process’ which are processes Pollution Health and Prevention resulting in noxious or offensive gases typically Social Ordinance (Act pertaining to point source emissions have to Services No.11 of 1976) obtain a registration certificate from the Department of Health. This Act provides a framework for managing water resources based on the principles of integrated water resources management. It provides for the management, development, protection, conservation, and use of water resources. Furthermore, any watercourse on/or Water Ministry of in close proximity to the site and associated Resources Agriculture, Management ecosystems should be protected in alignment Water and Act (Act No. 11 with the listed principles. Forestry of 2013) Water is one of the most important resources, and determinant factor for any development. Therefore, water abstraction should satisfy the provisions of the water act (water abstraction / borehole permit should be applied from the respective ministry). This act states that, all water resources belongs to the State. It prevents pollution and promotes the sustainable utilization of the resource. To protect this resource, this act requires that Ministry of permits are obtained when activities involve the Water Act No, Agriculture, following: 54 of 1956 Water and (a) Discharge of contaminated into water Forestry sources such as pipe, sewer, canal, sea outfall and (b) Disposal of water in a manner that may cause detrimental impact on the water resources The ordinance is important for pollution control Hazardous Substances and provides for the control of toxic substances
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Legal Requirements Legislation Relevant Aspect of Project considered authority Ordinance No. including their manufacture, use, sale, disposal, 14 of 1974 dumping, import and export in order to ensure human and environmental safety. Soil This act promotes the conservation of soil, prevention of soil erosion. Typically, improper Conservation Act No. 76 of planning of construction can cause soil 1969 degradation and erosion. The Act makes provision for the protection and conservation of places and objects of heritage significance and the registration of such places National and objects. Part V Section 46 of the Act Heritage Act prohibits removal, damage, alteration or No. 27 of 2004 excavation of heritage sites or remains, while Section 48 sets out the procedure for application and granting of permits. The Regional Councils Act legislates the establishment of Regional Councils that are Ministry of responsible for the planning and coordination of Regional and regional policies and development. Regional Local The main objective of this Act is to initiate, Councils Act, Government, 1992 (Act No. supervise, manage and evaluate regional Housing and 22 of 1992) development. The Regional Council is Rural considered to be an interested and affected Development party (I&AP) and reserve the right to comment on the project and EMP.
3.5 Precautionary and Polluter Pays Principles
Precautionary Approach Principle
This principle is worldwide accepted when there is a lack of sufficient knowledge and information about proposed development possible threats to the environment. Hence if the anticipated impacts are greater, then precautionary approach is applied.
Polluter Pays Principle
This principle ensures that proponent takes responsibility of their actions. Hence in cases of pollution, the proponent bears the full responsibility and cost to clean up the environment.
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CHAPTER 4
4. AFFECTED ENVIRONMENT
4.1 Surrounding Environment
The general landscape of Usakos is composed of mountains, hills and rocky terrain. The area is classified as the Western Highlands Ecosystem Zone, and it is characterised by relatively low amounts of annual rainfall not exceeding 300mm. Rain in the area falls in summer between January and March and often leads to flows in seasonal river courses. The low rainfall coupled with low humidity and warm to hot temperatures gives rise to extreme climatic conditions in the area.
4.2 Climate
The average annual temperature of the area is between 20 – 24oC, with an average maximum of 32 - 34 oC and minimum of 4 - 6 o. The hottest month usually being December and coolest month being July, with an average of 1 to 5 frost days per year.
4.2.1 Vegetation and Biodiversity
The vegetation structure of the surrounding area is generally very sparse denuded and hard to identify due to the prevailing drought in the area. The specific location for the proposed logistics hub is disturbed and the vegetation onsite has been planted purposely as a measure of beautifying the landscape.
The proposed site is adjacent to a small stream and the vegetation appears to be concentrated along it. No wild animals were encountered nor expected to occur in the immediate surroundings. This is since the area is within the town boundaries and human activities are evident. Small rodents and birds are however expected to occur on site, but these would be of minimal disturbance to development as they can easily move away.
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The project site has been cleared in preparation for The surrounding landscape is dominated by sparse phase 1 activities to start. thorn bush
Some indigenous plants have been planted for Plants introduced at the temporal office aesthetics
4.3 Socio-economics
Key sectors in terms of employment in the Erongo Region are mining, fishing and manufacturing, agriculture as well as administration and support services. The region is one of the most affluent regions in Namibia as it has the second highest level of development at national level. The current population of Usakos stands at 9, 1473 inhabitants.
3 World Population Review 21 Environmental Scoping Report: MDL Petroleum Products Logistic and Storage Hub@Usakos-Namibia
CHAPTER 6
5. IMPACT ASSESSMENT METHODOLOGY
5.1 Assessment of Impact Significance
The significance of an effect is determined by considering and measuring the temporal and spatial scales and magnitude of the project and specific activities associated with the proposed development. The assessment of the environmental impacts of development activities should always strive to be objective and impartial. However, environmental assessment processes can be exposed to subjectivity inherent in attempting to measure significance.
5.2 Determination of Significance
For each impact, the EXTENT (spatial scale), MAGNITUDE and DURATION (time scale) would be described. These criteria would be used to ascertain the SIGNIFICANCE of the impact, firstly in the case of no mitigation and then with the most effective mitigation measure(s) in place. The mitigation described in the Scoping Report would represent the full range of plausible and pragmatic measures.
Significance is not defined in the EIA Regulations, however the Draft Procedure and Guidance for EIA and EMP states that the significance of a predicted impact depends upon its context and intensity. Accordingly, the following have been applied in the environmental assessment, which is based on professional judgement:
• High: effects are considered to be key factors in the decision-making process. These are generally (but not exclusively) associated with sites and features of national importance and resources/features that are unique and which, if lost, cannot be replaced or relocated. • Medium: effects are considered to be important factors, but which are unlikely to be key decision-making factors. • Low: effects are considered to be local factors that are unlikely to be critical to decision-making. The significance of effect has been derived by applying the identified thresholds for receptor sensitivity and magnitude of change, as well as the definition for significance. For each potential significant effect identified in the assessment, a summary is provided which includes the activity that would cause an impact; the potential effect; embedded or best practice mitigation; the sensitivity of receptor that would be impacted; the
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severity, duration and probability of effect; the significance of effect before mitigation and after additional mitigation.
5.3 Environmental Mitigation
Mitigation comprises a hierarchy of measures ranging from preventative of environmental effects by avoidance, to measures that provide opportunities for environmental enhancement. The mitigation hierarchy is: avoidance; reduction; compensation; remediation; and enhancement.
Embedded mitigation, which is part of the design, and good practice mitigation are taken into consideration during the scoping process and through the initial assessment of magnitude and determination of significance. Additional mitigation is identified if the significance of effect requires it and causes the effect to be further reduced. A final assessment of significance of effects is carried out taking into consideration the additional mitigation.
5.4 Cumulative Effects
The EIA Regulations clearly states that cumulative effects should be considered as part of the EIA for a proposed project. Cumulative effects can arise when a single resource or receptor is affected by more than one effect from the proposed project or from the combination of the proposed project and other development projects within the local area where combined effects can occur.
The proposed logistics facility is not the only development that is proposed in Usakos. The town being strategically located along the B2 Highway provides a gateway for investors that wish to access the coastal areas. It is therefore recognized that there is potential for cumulative effects to arise both within the proposed project (intra-project – combined effects from the proposed project and it’s supporting infrastructure on a receptor), but also from different developmental projects introduced in Usakos. For example, the noise generated during the construction phase of the proposed project may not cause a significant effect in isolation; however, a sensitive receptor may be significantly affected when noise from the proposed project is combined with noise generated from other construction projects in the area.
The assessment of cumulative effects is undertaken by receptor rather than by topic or activity. There is no formal guidance for cumulative impacts presented and therefore professional judgment is used for the assessment.
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CHAPTER 7
6. IMPACT ASSESSMENT
6.1 Introduction
This chapter presents the findings of a high-level assessment of the project facets which could result in significant environmental effects. The assessment is in line with the methodology presented in Chapter 5.
A list of potentially significant effects and other likely environmental effects that should be considered during the construction and operation of the proposed project in order to reduce adverse effects and minimize pollution (considered best practice) are contained in the EMP along with mitigation measures.
6.2 Phase 1
The project will be implemented using a two phased approach. A phased approach is used because the associated project supporting infrastructure will not be completed timeously as some require permits to be obtained.
6.2.1 Erection of a Temporary Logistics Hub
Construction of a temporary logistics hub has the potential to generate environmental impacts and diligence must be applied to mitigate for such impacts. The temporary hub is meant to serve as a truck-port for semi-trailer fuel tankers which are in transit to fuel destinations. The facility will be able to accommodate a maximum of 40 trucks.
The floor will be constructed in a manner that will minimise groundwater contamination, in an event that oil spills accidentally. The fuel tankers will always be required to be parked on the special flooring. Regular inspections are recommended on the tankers and flooring to monitoring any signs of fuel leakage or spillage in the area. A temporary administration block fitted with ablution amenities will also be erected to process the required paper work for the fuel tankers to proceed to delivery destinations.
6.2.2 Fuel Transportation via B2 Highway
Portable semi-trailer fuel tankers carried by trucks will be used to transport fuel that is procured from Walvis Bay. The fuel tankers will then be driven to the temporary logistics hub for further processing.
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Transporting fuel is considered a high-risk excise and requires diligence. Fuel tankers that will be used are ISO certified and fit for the purpose. This means that the tankers are relatively safe. However, the trucks must still be fully equipped with firefighting gear in case of an emergency.
6.3 Phase 2
This phase will comprise the construction of permanent structures and the supporting infrastructure. Mitigation measures for each supporting infrastructure are detailed in the EMP, however the key mitigation activities are listed below.
6.3.1 Fuel transportation via the Trans-Namibia Railway
This route will be introduced upon securing the authorisation to introduce a railway off-ramp into the MDL facility from the relevant authority. The assumption is that the authorisation to be obtained will include specific measures to be adhered to in ensuring that safety precautions are maintained.
6.4 Cumulative Effects
6.4.1 Groundwater
The town of Usakos uses groundwater as a source of water in the area. The area is known for its shallow groundwater resources and any risks of pollution to water sources is considered to be an impact with high concern. There is potential for groundwater quality to be affected as a result of the combination of several fuel related activities in the area, in particular the MDL fuel logistics hub. Such activities could cause spilled oil to seep through the ground and could reach groundwater.
Monitoring boreholes will need to be established near to the project site to track changes in groundwater quality. In the event that fuel contamination is detected, actions must be taken to identify the source of contamination and mitigation measures implemented. It should however be noted that the monitoring wells are a preventive measure. The proposed project has no been identified as a daily contributor to groundwater degradation however, in the case of a fuel spill at the site, an impact on groundwater must be prevented.
Table 5: Potential effects on groundwater
Receptor Effect Sensitivity Severity Duration Probability Significance Significance before after additional additional mitigation mitigation Groundwater Groundwater M M L M M XX Contamination
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CHAPTER 8
7. PUBLIC PARTICIPATION PROCESS
7.1 Introduction
Public consultation forms an integral component of the EIA process. Comments made during the public participation have been captured and addressed in both the EIA Scoping report and EMP respectively.
The public participation process (PPP) allows interested and affected parties (I&APs) to identify issues and concerns related to the proposed project which they feel should be addressed in the EIA process. In return, the environmental assessment identifies feasible mitigation measures that can be implemented to address the identified issues / concerns. Furthermore, the PPP provides I&APs with an opportunity to gain more information regarding the proposed project, and to voice any issues of concern during the public comment process.
In order to conform to the EIA regulations, a public consultation process has been undertaken. A full stakeholder consultation process was undertaken from the onset of the project to ensure that the widest range of stakeholders was adequately and effectively consulted.
7.2 Consultation Activities
A summary of the consultation carried out for the proposed project is summarised
Table 6: Summary of Stakeholder consultation activities
Task Description Action Background A BID was compiled and Background Information Information distributed to the public. The BID Document (BID) Document (BID) provides high level information developed and distributed about the proposed project and to interested and affected provides details on how I&APs parties (Appendix A-1) can register their interest Authority Consultative meetings were held Site meeting held with the consultations with the Environmental Usakos Town Council on Commissioner’s office (Ministry 18 May 2019 (Appendix of Environment and Tourism) A-2) and the Department of Water Affairs (within the Ministry of Agriculture, Water and Forestry
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Newspaper NEMA Act requires that 11 July & 16 July 2019 adverts advertisements be placed in at least two common newspapers for two consecutive weeks. As such, 4 x Adverts were placed in The Confidente and New Era newspapers for two consecutive weeks advertising the proposed project inviting I&APs to register their interest and to review the draft EIA Scoping and EMP reports Public Meeting A public meeting was held to 20 July 2019 present the proposed At Usakos Town Council development and solicit Chambers comments. Comments and Stakeholder comments have The comments and Response been incorporated in the response Report (CRR) is Report (CRR) environmental Scoping Report attached together will all and EMP. other public participation documentation
7.3 Concerns raised
Table 7: Issues raised during public consultation
Issues Raised Response
Development activities are welcomed in The proposed project support structures such Usakos Town however these should be as the fuel station remains as alternatives considerate of existing businesses in the which will still be evaluated when the need area. There are three fuel stations already in arises for them to be implemented. Usakos and the proposed fuel station to form part of the petroleum and logistics facility If found to be detrimental to the economic should be re-considered. performance of existing stations, it may have to be abandoned.
The project site is within the catchment area The proposal is to construct a special and Usakos is known to have shallow concrete pavement on site which will prevent groundwater resources. What measures will fuel from infiltrating into the ground. the project implement to ensure that no contamination occurs? Monitoring wells will also be installed to obtain water samples that will be sent to
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laboratories for contamination analysis.
MDL should work with Usakos Town Council MDL is currently working on an employment and obtain a database of unemployed youth scheme together with Usakos Town Council. in the area. These are the people that must be prioritised for employment before external people are brought in.
Site notice at Usakos Town Council notice board
Public meeting in progress at Usakos Town Council Public meeting in progress Chambers
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CHAPTER 9
8. CONCLUSION AND RECOMMENDATIONS
8.1 Conclusion
The environmental assessment concluded that NO significant environmental effects are likely to occur as a result of the construction and operation of the proposed MDL fuel logistics hub (narrated as the proposed project).
The EIA identified and assessed potential environmental effects and suitable mitigation and management measures to be applied during the construction and operational phases of the proposed project in order to mitigate potential environmental impacts as presented in the EMP.
8.2 Recommendations
Therefore, Tortoise Environmental Consultants (TEC) has no doubt and hereby strongly recommends approval and issuance of the Environment Clearance Certificate for the proposed project.
It is recommended that the subject of the environmental clearance certificate be: Environmental Clearance Certificate for the proposed Storage and Logistic Facility for Petroleum Products in Usakos, Erongo Region.
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