IMPACT ASSESSMENT CASE STUDIES FROM SOUTHERN AFRICA

Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources SAIEA Namibia Ltd. (formerly UraMin Namibia Ltd.) Southern African Institute for Environmental Assessment ... working for a better Africa TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Aims of the Project Brief description of the development

The Trekkopje Uranium Project aims to The Trekkopje Uranium Project is located in the conservancies are established to further enhance economically mine a shallow, large volume and Central Namib, some 70 km inland from the potential for rural communities to benefit from low grade uranium deposit, in order to supply Swakopmund. The project lies within the #Gaingu local natural resources, particularly through yellow cake to the international atomic energy Conservancy, in Erongo Region. The mining tourism. No settlements occur on the Trekkopje industry. In the context of global concern about tenement covers an area of over 30,000 ha. tenement, and the tenement and surrounding lands climate forcing through increased carbon Ršssing Uranium Mine lies 35 km south of the are wilderness lands, only rarely used for emissions and increasing energy demand, uranium property and the newly developed Langer Heinrich temporary grazing. is in demand as nuclear fuel feedstock. Nuclear Uranium Mine lies 81 km power plants typically produce only 10% of the to the south-south-east

CO2 emissions of a similarly sized coal-fired within the Namib- power station. At the time of submission of the Naukluft Park (see Figure EIA, the Project was designed to produce 3.7 1). Other uranium projects million pounds of uranium oxide annually to in the area include the supply part of this demand. Valencia Uranium Project, the Etango Project and The project will provide developmental benefits Swakop Uranium. to Erongo Region, in particular, and to the wider Namibian economy. The environmental and social The #Gaingu Conservancy impact assessment (EIA) was designed to is situated in communal minimise the social and environmental impacts land of the Oe-#G‰n associated with the mine and to ensure that Traditional Authority. positive impacts were optimised. Communal land is held in trust by the State for the benefit of the Namibian people, particularly for the advancement of rural communities, and Figure 1: Regional setting of the Trekkopje Uranium Project.

© SAIEA 2009 1 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Brief description of the development

The Trekkopje deposits will be extracted by Modular mining areas (pits) are planned, and as (2007), the design called for the prestripping of shallow, surface (open pit) mining methods, as far as the mining sequence will allow, the mined- 223 ha of land in 2009 to facilitate the creation 80% of the mineralization is shallower than 20 out pits will be used for dumping spent ore from of a 32 ha pit and 72 ha dump surface. The mining m. The surface topsoil (growth medium) will be the OOHLP, minimizing residual landscape operation would effectively cease in 2020, by removed and stored for later replacement in the impacts and facilitating concurrent reclamation. which stage the pit would be 56 ha and the rehabilitation phase. Hydraulic shovels will mine In the event that the mine sequence does not allow cumulative area covered by backfilling and dumps the ore at a rate of 100,000 t/d and load the ore for in-pit backfilling, waste will be placed on to would be 5,690 ha. (The design has been optimised directly into off-highway trucks which will then a dump outside of the pit. Extensive use is made subsequent to the completion of the EIA report.) transport the ore to a mobile primary crushing of conveyors to reduce dust generation at the mine plant in the pit. Ore will be conveyed to secondary site, since one of the largest sources of dust in There are two economically defined ore bodies crushers and then to the on-off heap leach pad open cast mining is the loading of ore and its at Trekkopje. The Klein Trekkopje deposit, which (OOHLP). The OOHLP consists of a number of subsequent transport in off-highway trucks. is approximately 15 km long by between 1 and 3 cells which are sequentially loaded using a stacker, km wide, and the Trekkopje deposit which is irrigated and then reclaimed once the leaching The EIA commenced in January 2006 and the approximately 5.5 km long and of a similar width process is complete. This is a continuous process scoping component was conducted via an to the Klein Trekkopje deposit. Both deposits with some cells being irrigated while others are extensive public participation programme. A series extend to a maximum depth of 30 m and are stacked or reclaimed. The OOHLP was designed of baseline investigations commenced in March covered with a layer of topsoil and overburden to store 30 million tons (Mt) of ore for 300 days 2006. The draft report was submitted for public that is 1 to 2 m thick. The Klein Trekkopje deposit with an average solution application rate of 10 review in November 2007. Once the comments will be mined first and is the subject of the EIA. l/h/m2. The uranium bearing solution will be from stakeholders had been received and the final collected and recirculated in a closed loop system public meetings held in Swakopmund, Arandis through the heap until it has a sufficiently high and Windhoek, the report was updated and uranium concentration. The fluid, now termed a submitted to MET. A positive record of decision pregnant leach solution (PLS), is pumped from was issued by MET in January 2008. the PLS pond to an ion exchange plant for further uranium recovery. The Trekkopje Uranium Project is currently in the construction phase. At the time of the EIA

© SAIEA 2009 2 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Brief description of the development

heap leach pad (HLP) would have covered an area at least as large as the pit, as spent ore is retained on the leach pad and recontoured on closure of the facility. Using an OOHLP, the crushed ore is leached and then returned to the pits, minimizing the footprint. This allows concurrent reclamation of the mine by backfilling mined areas and returning the land surface to its pre-mining condition. The final landforms arising from this approach are closer to the original land surface relative to a permanent HLP, and the total area disturbed is significantly smaller.

In the 2007/8 Life of Mine plan, all spent ore is returned to the pit and approximately 30% of waste (or overburden) mined can also be deposited in the pit. The balance will be stacked in carefully sited and designed waste dumps adjacent to the pit limits. Due to swell of the ore in the mining process the final topography on the pit footprint will be above original elevations, but the final Figure 2: Current extent of the ore bodies at the Trekkopje Uranium Project (Mapping: SRK Consulting). surface has been designed so that the maximum elevation will be 26 m above original topography. The low grade ore requires a cost effective means of alternatives, the two alternatives with the most of extracting the uranium, and heap leaching was striking differences in environmental impact are Similarly waste dumps are being designed to not selected as the preferred approach. While a project the permanent heap leach pads (HLPs) versus the exceed a height of 30 m. The OOHLP method of this scale requires assessment of a large number OOHLP configuration. A permanent single lift coupled with in-pit stacking provides a unique

© SAIEA 2009 3 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Brief description of the development

opportunity to design the entire operation to Water to supply demand in the Erongo coastal ¥ The desalination plant has been sized to treat reduce the surface footprint of the mine and region is derived from various aquifer and other 45 Mm3/a, with the mine using 20 Mm3/a. The improve the prospects for post mining ground water sources that have limited capacity remaining 25 Mm3/a was intended for local rehabilitation. to allow for any additional sustainable abstraction. water supply by the water utility The water requirements for the Trekkopje Project /municipalities. While not all dumps will be placed within the pit, have been estimated to be approximately 20 Mm3/a all the dumps envisaged under the OOHLP and had to be met from some other source. ¥ A water transfer pipeline from the desalination scenario are established within the maximum pit Desalination of sea water was the best option. facility to the mine will be about 50 km long limits established during the feasibility study The desalination plant at Wlotzkasbaken was the and requires booster pump stations along (Figure 3). This is in contrast to the initial design subject of a separate EIA process. This bulk water its length. for the permanent rock dump (assuming no supply system is made up of three major backfilling) that was originally located outside components, as follows: At the time of compiling the EIA, NamPower had of the pit limits, representing the worst case been requested to supply 15 MVA as permanent disturbance footprint scenario. ¥ A sea water extraction system is required to supply to the mine. Power for the mine is to be extract approximately 45 Mm3/a of sea water, sourced from the Khan substation on the farm The difference in surface area disturbed is feed it to the desalination facility and return Namibfontein, 34 km SW of Usakos, and will be summarized in Table 1. brine from the desalination facility to the sea. reticulated along the existing Khan-Henties Bay power line servitude. For both the water pipeline Permanent Pads OOHLP and the power line, existing utility servitudes were used wherever possible to reduce further Maximum pit area 4,600 ha 4,600 ha dissection of the Namib landscape. Permanent waste rock dumps outside of maximum pit area 1,500 ha 1,090 ha The socio-economic considerations for such a Area permanently disturbed by pads 6,100 ha 0 ha large project were considerable. Numerous Total 12,200 ha 5,690 ha employment opportunities would be created, both during construction and operation. The Table 1: Disturbed areas associated with each heap leach configuration considered expectations raised by this possibility had to be

© SAIEA 2009 4 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Brief description of the development Environmental setting

managed against a background of a large but low- tuberculosis and HIV. Considerable strain is Biophysical environment or unskilled labour pool. The benefits of such placed on social services such as health and employment, however, are numerous: remittances education. The EIA proposed a housing policy to The Trekkopje Project is located in the hyper- to labour-sending areas, increased revenue bases mitigate these effects. This policy was intended arid Namib Desert. Hot dry conditions during the for local authorities, greater consumer spend and to promote home ownership for the workforce. day and cool nights are common. There is no inflows to central government through employees surface water on the site, except during rare taxes and contributions to the Social Fund. periods of exceptional rainfall. Major rivers in the region, such as the Swakop River, flow less Housing was a critical consideration in an area than five times in a decade. Limited quantities of where accommodation and land for development highly saline ground water are present within the is scarce. The recommendations about housing tenement. the workforce also had to take into account the nature of the economy of the various towns. Trekkopje lies in the Central Namib vegetation Walvis Bay and Swakopmund both have zone. Desert environments are typically very diversified economies, which could sustain the sensitive to disturbance and require long recovery negative impacts of closure. Arandis does not times (sometimes thousands of years). For this have a diversified economy, and unless this reason, and the presence of many endemic species, evolves, the town will be severely impacted by careful management of the sensitive ecosystems the loss of jobs and revenue on closure. surrounding the ore deposit is required. The EIA Inward migration results from the announcement required the identification of rare and keystone of any large development project, and the species. Where buffer zones could not be created Trekkopje Project is no exception. Most inward to protect individuals, suitable species were to be migrants are unemployed and settle in informal removed for replanting. settlements, backyard shacks or houses occupied by multiple families. The consequences of this lifestyle are severe: alcohol abuse, domestic violence and enhanced environments for

© SAIEA 2009 5 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Environmental setting EIA process followed

Socio-economic environment communication and the absence of most factors A decision was made to engage at an early stage that are required for economic development, such with the people in the communal lands of the Oe- The Trekkopje Uranium Project has two principal as markets and sources of raw materials. #G‰n Traditional Authority, their traditional communities of impact, Arandis and Spitzkoppe, leaders and with the #Gaingu Conservancy and a third, Swakopmund, where the possible Committee. The Spitzkoppe community had no impacts of closure will not be as serious but where experience of large mining companies, and it was the immediate demand for services such as necessary to provide them with information on accommodation, education, water and energy what they could expect and what not. This could put a strain on the delivery capacity of local management of expectations, which proved to be and regional authorities. one of the most difficult aspects of the EIA process, was ongoing, as was consultation with All three communities are characterised by high the community. A development project for the unemployment rates. In Swakopmund, supply of potable water to the community was unemployment figures are increased by the large undertaken by UraMin, and this was only done number of migrant job seekers who come to the after the community had been guided through a town in the hope of finding employment in either needs assessment and had decided on their own the fishing or mining industries. Since 1992, when priority. This project, unexpectedly, became part Ršssing Uranium handed the town over to the of the Public Participation process. Namibian Government, the Arandis economy has been stagnant and very few job opportunities have Early and continued consultation had a number been available. of positive results: unrealistic demands, such as for regular payments of cash, were averted; the Spitzkoppe is extremely underdeveloped and the community and the Conservancy were empowered chances of developing an economy in the with knowledge of the impacts, both negative and community, which could provide significant positive, of the proposed project, and are today employment, are remote. It is cut off from the far more confident in dealing with other project mainstream economy by its remoteness, lack of proponents in their area. The Public Participation

© SAIEA 2009 6 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

EIA process followed

process for this community was designed to doubtful whether any great measure of success ¥ The project proponent gave full support empower them, to minimise impacts and to show was achieved in this respect, with the exception to the greatest possible degree of transparency respect for their leadership structures. Currently of some women who formed SMEs and are doing in stakeholder transactions, the community and AREVA have a sound and well, although some of them are still dependant mutually respectful relationship, in spite of the on mines as their main or only client. ¥ Stakeholders were advised as soon as possible fact that the hopes of multiple employment of any major deviations from the original opportunities will not be realised. A particular decision was made to engage with a project description, and broad range of NGOs. This was because of events The Arandis community was engaged in an where NGOs had not been engaged, which resulted ¥ The EIA team frequently asked for, intensive series of public and focus group meetings in poor public perception of the proponent and and received, information from stakeholders. Ð with women, the youth, local development active NGO opposition to the project. In addition, agencies and actors. Management of expectations some NGOs did not have a strong platform to It was the response of the stakeholders to this Ð particularly of employment Ð proved even more voice their concerns, and the Public Participation form of engagement that made the EIA process difficult in this community, which had experience process gave them such an opportunity. This ÔdifferentÕ. They had a clearly defined entry point of mining operations. Very few people voiced particular series of engagements had tremendous for expressing their concerns about the project, any opposition to the project or asked any value for the EIA process, because NGOs, and their comments covered all components of questions, except when it would start employing although fundamentally opposed to the project, the EIA. They provided information about crucial people. In this case it was necessary to change became partners rather than opponents, provided I&APs who had been overlooked in the original the focus of awareness raising to the number of information and raised red flags about critical stakeholder mapping, about particularly sensitive employees the mine would eventually need and, issues. landscapes and species Ð there was not an aspect more importantly, the education and skills levels of the project where stakeholders did not comment, that would be required for employment. The A real partnership developed between the EIA ask for explanations or offer advice. It was possibility of becoming a service provider was team and stakeholders. This was possible because: therefore relatively easy to ensure that cross- stressed, with the concomitant opportunity for cutting issues in the final EIA were reflected as also working in non-mining related sectors. ¥ All comments and queries from stakeholders such in the various components. The information Training, completing schooling and skills were responded to and, where feasible, obtained during the Public Participation process acquisition were emphasised repeatedly. It is included in project considerations, could not have been gained in any other way.

© SAIEA 2009 7 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Main environmental impacts & issues

Positive of concern regarding Arandis, and the EMP makes aquifers. Water consumption by Trekkopje and provision for measures to avoid or mitigate this. neighbouring mining companies reduces the The proposed Trekkopje Project will contribute These measures include issues of housing, skills amount available to ecosystems and communities. not only towards the achievement of national training of the workforce before closure and the Current information indicates that a number of development objectives, but more directly to the development of alternative economic activities. mines in Erongo Region will close within a few alleviation of poverty and unemployment in local years of each other. This will intensify the communities. A particularly significant Cumulative negative impacts of job losses and a decline in contribution could be the raising of skills levels revenues. in both Arandis and Spitzkoppe in technical, Several impacts have historically occurred in the conservation and management fields. environment surrounding the Trekkopje Project. In-migration of work seekers places increased Expansion of nearby cities and towns, and the strain on social services and on existing Negative infrastructure attendant on large development communities. projects in a fragile desert environment, result in Liabilities that may be anticipated and need to be negative environmental impacts. The net result is addressed through management plans include a fragmentation of landscapes by water, road and environmental impacts, including potential power line servitudes. Further impacts arise from pollution, environmental degradation and increased access, and the escalation of activities disruption of ecosystems over large areas, such as game poaching and illegal species increased demand for and use of natural resources, collection. All of these impacts can constrain including water, potential radiation hazards, future productive land-use for activities such as potential social dislocation, unsustainable tourism and small-scale agriculture. economic development, and loss of land use. The challenge is to provide measures that manage Large scale uranium mining already occurs close social impacts and growth, while minimizing long to the site, at Ršssing Uranium and at Langer term damage to ecosystems. The last issue is Heinrich, and several exploration companies are particularly important for closure planning. prospecting nearby. These activities increase dust The creation of dependency on mine revenue is loading in the atmosphere and remove water from

© SAIEA 2009 8 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Decision-making process Implementation of the EMP & compliance auditing

The EIA process fed into the decision making An EIA compliance audit was conducted, at the leadership of the Spitzkoppe community and the process of the client and the design engineers request of the client, nine months after the Record #Gaingu Conservancy. A communication strategy (SRK). This enabled strategic decisions, such as of Decision came through. The audit was also is currently being drawn up. the alteration of the heap leach configuration, to conducted against international good practice and be made before the EIA was completed, thereby found that management systems were appropriate Measures are taken to monitor environmental reducing the resistance to implementation. to control environmental performance at the performance with quarterly reports being An external reviewer was used. Results of this desired level, but that the EIA had not fully produced. A suggestion that was not in the EMP, review were presented at the public meetings at anticipated the changes in the project as a but should have been, is that these reports should the end of the public review period. consequence of increased engineering detail and be incorporated into an overall sustainability Recommendations in the independent review should have specified the requirement for report issued annually. These reports can provide report were incorporated into the final version of development of specific environmental codes of a framework for environmental reporting by the the EIA submitted to MET. practice more clearly. Fortunately, the client had company and are an effective tool for established an environmental policy and broad communicating with stakeholders. The public A number of critical comments were lodged during guidance action was available for areas not clearly nature of such reports often results in greater the EIA process. These included objections to delineated in the EIA. This was also supported resources being directed towards environmental uranium mining and to the inadequate review by clearly designating accountability and and social monitoring by the mine, with periods. These were dealt with in meetings, either responsibility in the EMP: responsibility for concomitant potential for improved environmental key informant or focus group, or through the environmental management rests with the performance. issues trail. Where feasible, these were addressed Environmental Superintendent and through the in the EIA report. No appeals were lodged. line management to the General Manager. Another useful suggestion is the compilation of an environmental management manual Ð this is A dedicated post for a Community Development essentially a compendium of the mine EMP, Officer should be created. The scope of work falls regulatory requirements and the environmental under the authority of the Manager, External operating procedures already in place at Relations, and is undertaken by the Corporate Trekkopje. These can be continually updated and Communications Officer. Regular meetings are can be augmented by new procedures required by held with the Arandis Town Council, the the operation.

© SAIEA 2009 9 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Main elements of excellence Lessons learnt in this EIA The EIA team must be an integral part of the The independence of the EIA practitioners must The closure strategy for the Trekkopje Project is design process. Through the interaction between be fiercely guarded. This engenders trust on the being developed with the specific objective of the EIA team and the design engineering, the mine part of the stakeholders, and enables the minimizing disturbance and long term design changed radically, resulting in an practitioners to use different and creative ways environmental impacts, leaving the post mining appreciably smaller final footprint. of conducting the EIA process. land in a useful, safe and stable configuration capable of supporting native plant communities, Stakeholder engagement is not just about Pubs and coffee bars are wonderful places wildlife habitat, watershed functions and limited informing I&APs about a project and answering for stakeholder engagement. livestock grazing. This is an outcome of the Public their questions. It is about raising awareness about Participation process, influencing the design potential impacts, informing people of their rights through the EIA process. and helping them to articulate their concerns. It is a process which should empower communities. The reduced footprint area means that there is a You can never engage too soon. Early engagement possibility of later using the mine license area creates problems, but these are negligible for alternative activities. It also reduces the compared to the benefits of having stakeholders impacts on areas surrounding the mine, areas that as partners throughout the process; are part of the #Gaingu Conservancy and intended for community-based ecotourism and other natural An EIA process has three clients Ð the proponent, resource-based activities. the environment and the community. It is the proponentÕs best interest to ensure that the two The EIA was a leader in raising awareness of the ÔsilentÕ clients are given due attention. cumulative effects of uranium mining in the Transparency is the overarching principle. Erongo Region. These were considered for all Stakeholders will co-operate when they are told relevant components, including the socio- of events, changes and impacts. They will not do economic, both with regard to operational and so if they find out about them through other closure impacts. sources.

© SAIEA 2009 10 Daniel Limpitlaw and Marie Hoadley, Turgis Consulting Client: AREVA Resources Namibia Ltd. (formerly UraMin Namibia Ltd.) TREKKOPJE URANIUM PROJECT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

Lessons learnt

What could have been done better?

¥ Expectations could have been better managed. ¥ The entire process needs to be more user friendly. ¥ More time and effort could have been spent on engaging with the extremely marginalised ¥ The time allowed for public review of the and with those who have no access to modern draft EIA was not sufficient. This meant that communication methods. stakeholders were not fully informed and ready to engage at the final round of public ¥ It is important to ensure the legitimacy participation meetings. of community representatives, that they are recognised as such by the community and will ¥ When the final notification of a public review articulate the communityÕs concerns. of an EIA is disseminated, a copy of the non This acts as a control on attempts to ÔhijackÕ technical summary should accompany it. Most the process for narrow personal or stakeholders will read a succinct summary, political agendas. and follow up on their own particular interest in the main report. Few will read a voluminous ¥ More time could have been made available and comprehensive report in the hope of upfront for more detailed baseline biophysical finding their own concerns addressed in it. studies. The paucity of data on certain aspects of the biophysical aspects of the Namib was underestimated.

¥ The public review process should be more sympathetic to the constraints and patience of stakeholders. www.saiea.com

© SAIEA 2009 11