P. O. Box 680 Walvis Bay Namibia

Email: P. O. Box 680, Walvis Bay l Email: [email protected] Cell: +264 81 232 6843 l EFax: +264 88 655 5160

COMPREHENSIVE ENVIRONMENTAL MANAGEMENT PLAN FOR THE EXISTING ROAD TRANSPORTATION OF SULPHURIC ACID ALONG THE TRANS-ZAMBEZI B8 (WALVIS BAY – WENELA), NAMIBIA

Prepared For

Kilwe Transport & General Traders Ltd. P. O. Box 680 Walvis Bay Namibia

REPORT NO. RMH802/2019-08 Final Version, April 2018

Compiled by

DOCUMENT INFORMATION

Title Comprehensive Environmental Management Plan for Road Transportation of Sulphuric Acid along the Trans-Zambezi (Walvis Bay – Wenela Border), Namibia

Project Manager Vilho Mtuleni Author Vilho Mtuleni Reviewer TGi-Enviro Leap Consulting cc Client Kilwe Transport and General Trader Ltd. Date last printed 27/04/2019 Date last saved 30/04/2019 Project Number ELC-RMH04/2019 Report Number RMH/2019-08 Status Final Reviewed Issue Date

Our consultancy Portfolio / Specialization is composed of:

• ENVIRONMENTAL ASSESSMENTS (SEA / EIA) CONSULTANCY • ENVIRONMENTAL ASSESSMENT (SEA / EIA) REVIEW • ENVIRONMENTAL AUDITING AND MONITORING • ENVIRONMENTAL EDUCATION AND AWARENESS • ENVIRONMENTAL POLICY REVIEWS • ENVIRONMENTAL CONSULTANCY • ENVIRONMENTAL SAFETY, HEALTH AND MANAGEMENT • DATA COLLECTION AND ANALYSIS

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TABLE OF CONTENT LIST OF FIGURES ...... v LIST OF TABLES ...... v 1 INTRODUCTION ...... 1 2 ENVIRONMENTAL LAWS AND POLICIES ...... 4 3 PUBLIC CONSULTATION ...... 7 3.1 AUTHORITIES AND INTERESTED AND AFFECTED PARTIES (I & APs) ...... 7 3.2 STEPS IN THE CONSULTATION PROCESS ...... 7 4. PROJECT DESCRIPTION ...... 9 4.1 PROJECT LOCATION ...... 9 4.2 BASELINE DATA ON AFFECTED ENVIRONMENT AND PROPOSE PROJECT ...... 10 4.2.1 BASELINE OF THE RECEIVING ENVIRONMENT ...... 10 5. SUMMARY OF IDENTIFIED ENVIRONMENTAL IMPACTS ...... 18 5.1 OVERALL OBJECTIVES OF THE EMP ...... 18 5.2 METHODS OF IMPACT SCOPING / ASSESSMENT ...... 18 5.3 STAKEHOLDER MANAGEMENT AND MITIGATION ...... 19 5.3 IMPACT SCOPING / ASSESSMENT ...... 20 5.3.1 HAZARDOUS PRECAUTIONARY MEASURE AND COMPLIANCE ...... 20 5.3.1.1 ASSESSMENT OF IMPACT: TRANSPORT SAFETY AND SECURITY COMPLIANCE ...... 20 Tabulated Summary of Assessed Impact – Safety and Security ...... 20 CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES ...... 20 5.3.1.2 ASSESSMENT OF IMPACT: ACCIDENTS – RISKS INCIDENTS LEADING TO SPILLAGE ...... 21 Tabulated summary of the assessed impact – risks incident leading to spillage ...... 21 CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES ...... 21 5.2.1.3 ASSESSMENT OF IMPACT: CONTAMINATION OF SOILS AND UNDERGROUND WATER ...... 22 Tabulated summary of the assessed impact – contamination of soil and underground water ...... 22 CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES ...... 22 5.3.2 AIR POLLUTION AND FIRE RISKS ...... 23 5.3.2.1 ASSESSMENT OF IMPACT: AIR POLLUTION ...... 23 Tabulated Summary of the Assessed Impact – Release of Dust into the Atmosphere ...... 23 CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES ...... 23 5.3.2.2 ASSESSMENT OF IMPACT: FIRE AND HEALTH RISKS ...... 23 Tabulated Summary of the Assessed Impact – Generation of noise from operations (Machinery and cultivation) ...... 23 CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES ...... 23 5.3.3 SOCIO-ECONOMIC ASPECTS ...... 24 5.3.3.1 ASSESSMENT OF IMPACT: TRAFFIC VOLUME – INCREASE AND ASSOCIATED IMPACTS ...... 24 Tabulated Summary of the Assessed Impact – Increase in Traffic Volume and Associated Impacts ...... 25 5.3.3.2 ASSESSMENT OF IMPACT: SOCIAL INTRUSION ...... 25 Tabulated Summary of the Assessed Impact – Socio-Economic Impacts ...... 25 CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES ...... 25 5.4 CONCLUSIONS AND RECOMMENDATIONS ...... 25 REFERENCES ...... 26 APPENDICES ...... 27 APPENDIX A: SPILL SITE REHABILITATION REPORTS AS PER MET INSTRUCTION ...... 27 APPENDIX B: CONTINGENCY (EMERGENCY RESPONSE) PLAN ...... 28 APPENDIX B: EAP PROFILE & RESUME ...... 29

LIST OF FIGURES LIST OF FIGURES Fig 1: Illustration of the key Corridor routes used by the landlocked countries to haulage cargo from wetsern economic traders throught the Ports of Luderitz and Walvis Bay, these these include the Trans-Zambezi Routes used by Kilwe T&G ...... 1 Fig 2: Shows the different Southern African Development Community (SADC) Logistics Corridor including the Trans-Zambezi (B8) and consisting of both Rail and Road Routes ...... 2 Fig 3: Shows the Trans-Zambesi (B8) Route along which the Tankers are driven passing by seven key settlements (Swakopmund, Karibib, Omaruru, Otjiwarongo, Grootfontein, Rundu and Katima Mulilo) on the road enroute to Sisheke in Zambia ...... 9 Fig 4: Map shows areas under different forms of conservation, mapped against main agricultural practices with the project area...... 10 Fig 5: Map shows areas under various kinds of conservation management in Namibia, in addition to other important land-uses which include national parks, community conservancies and forests along the project route...... 11 Fig 6: Shows the annual rainfall variation across an east-to-west transect gradient and across the different land types ...... 12 Fig 7: Structural section across the Northern Platform, Otavi-Mountain Landscape area and around Kombat...... 13 Fig 8: Show the five Categories of key ecological biomes of Namibia Broad-leafed and Acacia savannahs...... 14 Fig 9: Shows the most common type of vegetation on the project site, consisting of savannah characterized woody species well adapted to the sandy Kalahari sands (the invasive Acacia melifera is observed) ...... 14 Fig 10: Common soil and geological material predominantly consisting of the Cenozoic sediments, Precambrian rocks and Neo-Proterozoic rocks...... 15 Fig 11: Shows areas of sensitivity in respect to water resources along the project route, these are crucial in protecting in case of accidents as key human settlements, economic and livelihood centers are found here...... 16 Fig 12: Shows a comparison of overall terrestrial species diversity (green) against overall endemism (brown), with the most diversity observed in the Okavango and Zambezi regions thus flagging red in terms of environmental risks...... 16 Fig 13: Illustrate green vegetation biomass as an indicator of terrestrial productivity, this makes a good indicator of environmental degradation in case of a risk incident...... 17 Fig 14: Illustrate of appropriate displaying of safety and label markings, in case of sulphuric acid a corrosion sign is displayed alongside other relevant safety labels ...... 20 Fig 15: Shows a common nature of impacts and potential contamination of soils at an accident scene ...... 21 Fig 16: Shows a typical illustration of unintended impacts the use of earthmoving equipment may lead to habitat destruction as seen in the two images above ...... 21 Fig 17: Illustrates the predicted change (between 2013 and 2025) in traffic volume along the B8 route currently used by Kilwe T&G Trader, as a measure of potential impact associated to their operation of 30 sulphuric acid tanker fleet ...... 24

LIST OF TABLES LIST OF TABLES Table 1: List of activities identified in the EIA Regulations (GG. 4878 R.29 of 2012) which apply to hazardous substance treatment, handling and storage activities in Namibia ...... 3 Table 2: List of all the applicable permits / authorizations required by Kilwe Transport & Gen. Trader Ltd ...... 6 Table 3: Consultation Process with IA&Ps and Authorities for exting approvals ...... 7 Table 4: Criteria for Assessing Impacts ...... 18 Table 5: Actions relating to stakeholder communication ...... 19 Table 6: Annual average daily traffic volume across different types of vehicles between Karibib and Grootfontein (on B8) ...... 24

1 1 INTRODUCTIONINTRODUCTION

1.1 General Introduction

The logistics infrastructure in Namibia consists of two ports, the port of Walvis Bay and the port of Lüderitz, and four corridors, the Trans-Kalahari, Trans-Caprivi, Trans-Oranje, and Trans- Cunene (Fig. 1). Namibia’s geographical location puts the country in an advantageous position to serve the logistic needs of its neighbouring countries. Situated on the west coast of Africa, Namibia’s ports are closer to major markets in Europe and the Americas than other ports in the region, such as the port of Durban or Dar es Salaam (Fig. 2).

The Walvis Bay Corridors consist of a network of roads and railway that connect Namibia’s ports to regional economic powerhouses such as Angola and South Africa, as well as several landlocked SADC countries that are dependent on foreign ports for import and export (Savage, Fransman & Jenkins, 2013). Figure 8 maps the locations of Namibia’s ports and corridors, and identifies the principal shipping routes used for international trade.

Fig 1: Illustration of the key Corridor routes used by the landlocked countries to haulage cargo from wetsern economic traders throught the Ports of Luderitz and Walvis Bay, these these include the Trans-Zambezi Routes used by Kilwe T&G

Due to the limited capacity and reach of Namibia’s railway system, landed and shipped goods are primarily transported in and out of the Port of Walvis Bay by means of trucks, and therefore the discussion of the corridors in this report will refer to road transport. Road cargo volume has seen an average annual growth of 33% from 2005 to 2009 (Savage & Fransman, 2014). Such high growth can be attributed to the stable political environment in Namibia, well-paved roads and low tariffs, all of which contribute to shorter transit times (Savage, Fransman & Jenkins, 2013).

Amongst the different logistics operators is RMH Logistics cc, a solely Namibian own enterprise that specialise in environmental rehabilitation services amongst other of their operations. RMH Logistics cc, is currently acting on behalf of Kilwe Transport and General Traders LTD (Zambia). Kilwe Transport & General Traders operates thirty (30) tanker (haulage) trucks that transport about 1000 tonnes of Sulphuric Acid on a monthly basis from the Husab Mine to Sisheke, Zambia.

Fig 2: Shows the different Southern African Development Community (SADC) Logistics Corridor including the Trans- Zambezi (B8) and consisting of both Rail and Road Routes

In accordance with the provisions of the Environmental Impact Assessment (EIA) Regulations No. 30 of 2012 gazetted under the Environmental Management Act, (EMA), 2007, (Act No. 7 of 2007), the Handling in term of Transportation of Sulphuric Acid which is classified as Hazardous Substance in the EMA No. 7 of 2007 regulations by Kilwe Transport and Gen. Traders Ltd is a Listed Activity and may not be undertaken without an Environmental Clearance Certificate (see Table 1).

Table 1: List of activities identified in the EIA Regulations (GG. 4878 R.29 of 2012) which apply to hazardous substance treatment, handling and storage activities in Namibia EMA No. 7 of 2007 Relevance to Kilwe Transport Description of activity Legislation & Gen. Traders Ltd Activity 9 (9.2) 9.2 Any process or activity which Hazardous requires a permit, license or other form The operation of a processing Substance treatment, of authorization, or the modification of plant in particular this project handling or storage or changes to existing facilities for any has the potential for the process or activity which requires an generation or release of amendment of an existing permit, emissions, pollution, effluent or license or authorization or which waste. requires a new permit, license or

authorization in terms of a law

governing the generation or release of emissions, pollution, effluent or waste.

Therefore, Kilwe Transport & Gen. Traders Ltd through RMH Logistics cc sought the services of Enviro-Leap Consulting cc to facilitate the compilation of an Environmental Management Plan for Obtaining the Environmental Clearance Certificate.

1.2 Keeping EMPs up to Date

This Environmental Management Plan (EMP) document is designed to meet legal requirements and avoid or minimize the impacts associated with the implementation of Kilwe Transport & Gen. Trader’s storage, handling and transportation of fuel.

It is the intention that this EMP should be seen as a “living document” which will be amended during the operation, as the activities might change or new ones be introduced.

Should a listed activity(s) as defined in the Environmental Impact Assessment Regulations: Environmental Management Act, 2007 (Government Gazette No. 4878) be triggered (as a result of future modifications/changes at the mine), this EMP will be updated as a result of another EIA process as stipulated in the regulations.

2 ENVIRONMENTAL LAWS AND POLICIES 2 ENVIRONMENTAL LAWS AND POLICIES This section draws information from the legal sources in Namibia, presenting an overview of the most relevant legislation related to impacts that may arise from undertaking of this activity with the aim of informing the applicant of the legal requirements pertaining to the project during it operational phase.

2.1. The Constitution of the Republic of Namibia, 1990

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:

(l) Management 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; 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 natural resources utilization, management, pollution control and waste management.

2.2. Environmental Management Act of Namibia (2007)

The EMA provides a broad definition to the term “environment” - land, water and air; all organic and inorganic matter and living organisms as well as biological diversity; the interacting natural systems that include components referred to in sub-paragraphs, the human environment insofar as it represents archaeological, aesthetic, cultural, historic, economic, paleontological or social values.

2.3. Water Act (No. 54 of 1956)

The Act “consolidate and amend the laws relating to the control, conservation and use of water for domestic, agricultural, urban and industrial purposes; to make provision for the control, in certain respects, of the use of sea water for certain purposes; for the control of certain activities on or in water in certain areas; for the control of activities which may alter the natural occurrence of certain types of atmospheric precipitation; for the control, in certain respects, of the establishment or the extension of townships in certain areas; and for incidental matters.”

It additionally controls the disposal of effluent and makes it a criminal offence to:

“Pollute fresh or sea water in a way that makes the water less fit for any purpose for which it is or could be used by people, including use for the propagation of fish or other aquatic life, or use for recreational or other legitimate purpose.”

2.4. Water Resources Management Act (No. 24 of 2004) (Not implemented yet)

The purpose of this Act is to broadly control the use and conservation of water for domestic, agricultural, urban and industrial purposes; to control, in certain respects, the use of sea water; to control certain activities on or in water in certain areas; and to control activities which may alter the natural occurrence of certain types of atmospheric precipitation.

2.6. Pollution Control and Waste Management Bill (guideline only)

Part 7 states that any person who sells, stores, transports or uses any hazardous substances or products containing hazardous substances shall notify the competent authority, in accordance with sub-section (2), of the presence and quantity of those substances.

The competent authority for the purposes of section 74 shall maintain a register of substances notified in accordance with that section and the register shall be maintained in accordance with the provisions. Part 8 provides for emergency preparedness by the person handling hazardous substances, through emergency response plans.

2.7. Public Health Act (No. 36 of 1919)

Section 111 it is the duty of every local authority to take all lawful, necessary and reasonably practical measures for preventing the pollution so as to endanger health of any supply of water within its district and to take measures against any person so polluting any such supply.

Section 119 states that no person shall cause a nuisance or shall suffer to exist on any land or premises owned or occupied by him or of which he is in charge any nuisance or other condition liable to be injurious or dangerous to health.

Section 132 empowers the Minister to make regulations regarding, inter alia, the drainage of land or premises, the disposal of liquids and the removal and disposal of rubbish, refuse, manure and waste matters as well as regarding the establishment and carrying on of factories or trade premises which are liable to cause offensive smells or effluvia or to discharge liquid or other material liable to cause such smells or effluvia or to pollute streams and prohibiting the establishment or carrying on of such factories in unsuitable localities.

2.8. Atmospheric Pollution Prevention Ordinance (No. 11 of 1976)

Governs the control of noxious or offensive gases, Prohibits scheduled process without a registration certificate in a controlled area. Requires best practical means for preventing or reducing the escape into the atmosphere of noxious or offensive gases produced by the scheduled process

2.9. The Forest Act (12 of 2001)

The Forest Act (12 of 2001) allows for the declaration of protected areas in terms of soils, water resources, plants and other elements of biodiversity. This includes the proclamation of protected species of plants and the conditions under which these plants can be disturbed, conserved, or cultivated.

2.10. Parks and Wildlife Management Bill (2009)

The Parks and Wildlife Management Bill (2009) aims to provide a legal framework for the sustainable use and maintenance of Namibia’s ecosystems, biological diversity and ecological processes; and repeals the Nature Conservation Ordinance (4 of 1975). This Bill allows the Namibian Ministries of Environment and Tourism, and Minerals and Energy, to allow mining to take place within parks subject to the relevant assessments and authorizations.

2.11. Nature Conservation Ordinance (4 of 1975)

The Nature Conservation Ordinance (4 of 1975) provides for the declaration of protected areas and protected species.

2.12 National Heritage (27 of 2004)

The National Heritage Act (27 of 2004) provides protection and conservation of places and objectives of significance, as all archaeological and paleontological objects belong to the state.

To provide for the protection and conservation of places and objects of heritage significance and the registration of such places and objects; to establish a National Heritage Council; to establish a National Heritage Register; and to provide for incidental matters. The Act is aimed at protecting, conserving and registering places and objects of heritage significance. All protected heritage resources (e.g. human remains etc.) discovered, need to be reported immediately to the National Heritage Council (NHC) and require a permit from the NHC before they may be relocated.

2.13. Labor Act, 2007 Act (11 of 2007)

Construction safety is regulated under the Health and Safety Regulations under the Labour Act. The health and safety framework in Namibia regulates the following aspects: • Construction safety; • Electrical safety; • Machinery safety; • Hazardous substances; • Physical hazards and general provisions; • Medical examinations and emergency arrangements;

2.2 The United Nations Convention on Biological Diversity

This over–arching international convention is relevant to biodiversity conservation and management. Further, the following (Table 2) presents a list of permits that will be required in order for the proponent to be compliant with the law:

Table 2: List of all the applicable permits / authorizations required by Kilwe Transport & Gen. Trader Ltd Permits/Certificates/Authori Aspect Regulator zations Environmental clearance for MET* Storage, handling and Infrastructure and Operations transportation of Import and Export Permits MoF** hazardous substances (Transit) Transportation Permit - Relevant Local Authority as Listed in Section 3.1 of this EMP i.e. Walvis Bay Municipality, Municipality of Swakopmund, Arandis Town Council, Usakos Hazardous Waste Disposal Consent Letters from relevant Town Council, Karibib Town (disposal of contaminated Local Authorities nearest to Council, Omaruru Town Council, soils at appropriate waste the accident site (in case of Otjiwarongo Municipality, disposal site) accident) Grootfontein Municipality, Nkurenkuru Town Council, Rundu Town Council, Katima Mulilo Municipality, Communal Settlement Representatives such Traditional Authorities etc. Kilwe Transport & Gen. Site Access permission Surface Use Agreement Trader Ltd Note: * = Ministry of Environment and Tourism, **= Ministry of Finance (Customs)

3 PUBLIC CONSULTATION 3 PUBLIC CONSULTATION The range of environmental issues to be considered in the EMP has been given specific context and focus through consultation with authorities. Included below is a summary of the people consulted, the process that was followed, and the issues that have been identified.

It should be noted that since the facility has been in existence and operation, it was not necessary to conduct a full–scale public consultation process. Therefore consultations were limited to the Ministry of Environment and Tourism as competent authorities relating to their authorization needs (Environmental Clearance Certificate respectively) for storage of fuel on site for domestic use.

3.1 AUTHORITIES AND INTERESTED AND AFFECTED PARTIES (I & APs)

The following authorities and IAPs are involved in the EMP development process: • National authorities: Ministry of Environment and Tourism, and Ministry of Mines and Energy, National Roads Authority. • IAPs: For the purpose of the stakeholder consultation plan the following OMA’s and local authorities are identified as interest and affected parties in case of emergencies. These are however not by any means the only IAPs, but crucial in ensuring that when implementing the contingency plan: - The Department of Environmental Affairs – Office of Environmental Commissioner - The Namibian Police (Commanding Offer nearest to the Accident Site) - The Namibian Roads Authority - Any of the Local Authorities Departments of Waste Managements of the following villages, town and municipalities; o Walvis Bay Municipality o Municipality of Swakopmund o Arandis Town Council o Usakos Town Council o Karibib Town Council o Omaruru Town Council o Otjiwarongo Municipality o Grootfontein Municipality o Nkurenkuru Town Council o Rundu Town Council o Katima Mulilo Municipality o Communal Settlement Representatives such Traditional Authorities etc.

3.2 STEPS IN THE CONSULTATION PROCESS

Table 3 below sets out the steps in the consultation process that has been conducted to date.

Table 3: Consultation Process with IA&Ps and Authorities for exting approvals TASK DESCRIPTION DATE Notification - regulatory authorities and IAPs Environmental Approval to store and handle hazardous May 2019 Clearance substance (Fuel, Petrol and Diesel) on the farm Certificate – Storage for domestic consumption. and Handling of Fuel MET Instruction for Consultation with Ministry of Environment and 08 April 2019 Site Rehabilitation Tourism for advice on Rehabilitation Site Assessment Site visit for environmental impacts assessment 09 April 2019 and Consents and verification of land ownership.

4 PROJECT DESCRIPTION

4. PROJECT DESCRIPTION 4.1 PROJECT LOCATION

The project entails the transportation of sulphuric acid by tankers with a capacity of 20 ton each, these is conveyed on a fleet of thirty (30) totalling to a monthly volume of 1000 tones. The Tankers transit through the Trans-Zambezi (B8) higher, with the consignment initially arriving at the Port of Walvis Bay and destined for Sisheke in Zambia (Fig. 3).

Given that the Kilwe T&G Trader’s activity involves transportation of hazardous substance (corrosive chemical) across the country, a number of different receptors along the route are subject to environmental management considerations. Namibia is a large country of 823 680 km2 on the Atlantic coast of southern Africa. Namibia’s landscapes are defined largely by a combination of characteristics of topography, geological processes and drainage. Along the project activity’s route at the west, is the coast and Namib Desert lanscapes, the south-central and southern areas a steep escarpment runs north-south and divides the country into low-lying coastal plains about 70- 100 km wide to the west and a higher inland plateau to the east.

The hilly and mountainous plateau gives way in the east and north to a flat Kalahari sandveld, sloping gently to the east and south, and blown into dunes in some areas. Inselbergs lie scattered throughout the central and western areas, the granitic Brandberg rising from the coastal plains to 2579 m above sea level, the highest point in Namibia. Namibia has just four perennial river systems, all confined to its borders, three in the north (Kunene, Okavango and the Kwandu- Linyanti-Chobe-Zambezi Rivers) and one in the south (Orange River). All other drainage systems within Namibia are ephemeral. The Cuvelai drainage system entering northern Namibia from Angola carries water into the Etosha Pan, the largest salt pan in Namibia that extends about 130 km east-west at its widest point by about 50 km north-south. Twelve small islands lie close to the shore between Walvis Bay and the Orange River on the South African border.

Fig 3: Shows the Trans-Zambesi (B8) Route along which the Tankers are driven passing by seven key settlements (Swakopmund, Karibib, Omaruru, Otjiwarongo, Grootfontein, Rundu and Katima Mulilo) on the road enroute to Sisheke in Zambia

4.2 BASELINE DATA ON AFFECTED ENVIRONMENT AND PROPOSE PROJECT 4.2.1 BASELINE OF THE RECEIVING ENVIRONMENT

Geographic and Demographic

Namibia is characterized by four desert systems, the Namib, which runs along the entire west coast from the port town of Luderitz, northwards into southern Angola; the Succulent Karoo which lies south of Luderitz and extends across the Orange River into South Africa; the Nama Karoo which occurs immediately to the east of the previous two desert systems and covers most of the southern third of Namibia, tapering to a narrow belt from central Namibia northwards; and the Southern Kalahari which extends eastwards across to Botswana. However, the Trans-Zambezi route only crosses through three of these, namely the Namib Desert, Nama Karoo and the tree and shrub savannah.

With a human population of about 2.4 million people, Namibia has one of the lowest population densities in the world, on average about 2.5 people per km2. The population is unevenly distributed with about 35% living in towns and villages. Those potentially to be affected by this project lives in Walvis Bay, Swakopmund, Arandis, Usakos, Omaruru, Otjiwarongo, Otavi, Grootfontein, Nkurenkuru, Rundu and Katima Mulilo (including some small villages along the B8). This area most suitable for human habitation covers just over 6% of Namibia, and has sufficient water and rainfall to support marginal agriculture. Most of the rest of the country has less than one person per km2.

Land uses outside of protected areas are still generally defined by broad farming practices (Fig. 4). Within the project area in the northeast of Namibia, the important land-uses include timber and non-timber forest products, fish, wildlife and tourism benefits. About 14% of this area is under conservancies and community forests, however, 82% of total household income comes from non- farming activities.

Additionally, in the central-northern sections of the project area land-use consist of mainly Cattle rearing (about 1.4 million animals, which is equal to 64% of the national herd) with an area extend covering about 31 million hectare. Again, the land use situation is far more complex than this suggests. About 34% of the area falls within communal and freehold conservancies, and more than 65% of Namibia’s registered tourism establishments occur here. Only some 40 000 ha in Namibia are under intensive commercial cropping in the Otjozondjupa, Kavango and Zambezi regions. These areas fall within the high rainfall Grootfontein- Tsumeb-Otavi triangle, and irrigated farms along the Okavango and Zambezi Rivers.

Fig 4: Map shows areas under different forms of conservation, mapped against main agricultural practices with the project area.

Critically, an important outcome of Namibia’s policy and legislative framework to devolve rights over wildlife, tourism and forestry to local land owners and custodians is that land adjacent to protected areas is often more suited and more profitable under wildlife and tourism than under conventional farming. This in turn has led to a significant reduction in park-neighbour boundary conflicts as neighbours begin to practice compatible land uses. For example, of all national park boundaries falling in communal areas, over 70% now have conservancy and tourism concession areas as neighbours (Fig. 5).

This offers huge opportunities for future collaboration, to enhance both ecological and economic values, to improve management, particularly at a landscape level, and to mitigate the impacts of climate change.

Fig 5: Map shows areas under various kinds of conservation management in Namibia, in addition to other important land- uses which include national parks, community conservancies and forests along the project route.

Climatic baseline

Namibia is the most arid country in Africa south of the Sahara. Namibia’s climate is driven by three major climate systems, the Inter-Tropical Convergence Zone, the Subtropical High Pressure Zone and the Temperate Zone. The Inter-Tropical Convergence zone feeds in moist air from the north while the Subtropical High Pressure zone pushes the moist air back with dry cold air. The latter normally dominates, leading to an absence of water in the atmosphere and giving Namibia its arid climate. The lack of moisture in the air also results in intense radiation from the sun, high daytime temperatures, high evaporation rates, low soil moisture and rapid temperature loss at night. Namibia’s rainfall ranges from about 600 mm in the extreme north-east to less than 50 mm (Fig. 6) in the extreme south and along the coast (Mendelsohn et al. 2002). Central-to north-western Namibia experiences one of the steepest rainfall gradients anywhere in the world, ranging from about 400 mm to less than 50 mm over a distance of just 230 km. Rainfall is highly erratic and unpredictable with an inter-annual coefficient of variation that ranges from about 30% in the north-

11 east to over 100% in the driest areas. Another way of looking at the variation is to assume that 13 in every 14 years are “normal” while one year in the sequence is abnormally dry. Along the project route and across the different biomes (Fig. 6), the mean and average driest “normal” years would look as follows: Walvis Bay 50 mm and 0 mm, Karibib 150 mm and 20 mm, Otjiwarongo 420 mm and 230 mm, Katima Mulilo 620 mm and 360 mm. For most of Namibia rain falls in the summer months starts in November to March but in recent years the season may begin and terminate later in the year.

Fig 6: Shows the annual rainfall variation across an east-to-west transect gradient and across the different land types

About 22% of Namibia’s land is classified as desert (hyper-arid), 70% is classified as arid to semi- arid and the remaining 8% is classed as dry sub-humid (Mendelsohn et al. 2002). Most of the country receives an annual average of more than nine hours of sunlight per day. The north and south of the country experience the highest temperatures with the average maximum for the hottest month being over 34°. Temperature data for Windhoek is available from about 1910. The five-year running average of the annual average temperatures from 1920 to 1940 declines slightly from about 19.5° to 18.5° then rises to about 20° by 1970 and 21° by 2000. The four hottest years occur after 1997. The annual average winter temperatures mirror this trend. All of Namibia, except for the coastal plains, experiences humidity of below 30% during the day for much of the year - in the north-east for about six months, the north-centre for seven months, the central area for eight months and in the south for all 12 months. High temperatures and low humidity result in high rates of evaporation. Evaporation rates from an open body of water inland of the coastal plains range from about 2000 mm to over 2660 mm per annum.

Geological Setting of the various landscapes along the route

The transportation of sulphuric acid by Kilwe T&G Trader will transit along the Trans-Zambezi Highway (B8), which runs through a variety of geological setups consisting of the Damara Sequence, Swakop Group, Karoo Supergroup, Mulden Group and the Tsumeb Subgroup. The carbonate rocks are of late Proterozoic age, and constitute the Otavi Group of the Damara Sequence. The Damara orogen is made up of a 400 km-wide northeast-trending intracontinental arm and a north- south trending coastal arm. The intracontinental arm separates the northern Congo Craton from the southern Kalahari Craton (Fig. 7).

Fig 7: Structural section across the Northern Platform, Otavi-Mountain Landscape area and around Kombat.

The Damara Orogenic Belt is the most prominent geological feature of central Namibia, and it forms part of the network of Neoproterozoic orogenic belts that formed during the assembly of the supercontinent Gondwana about 550 million years ago. It consists of a NE-trending arm, the Damara Belt, which extends through central Namibia, across northern Botswana to the Zambezi Belt and thereafter to the Mozambique Belt, and a NNW-trending coastal arm, the Kaoko Belt which extends into Angola and continues northwards. The Damara Belt is divided into seven tectonostratigraphic zones, which are, from north to south, the Northern Platform, Northern Margin, Northern, Central, Southern and Southern Margin Zones, and the Southern Foreland (respectively abbreviated to NP, NMZ, NZ, CZ, SZ, SMZ and SF).

The Otavi Mountainland is located on the eastern side of the Northern Carbonate Platform of the Damara Orogen. This orogen is considered to be a late-Proterozoic orogenic belt generated during the Pan-African collision of the Sao Francisco- Congo and Kalahari cratons. The Damara Belt is an intracontinental, NE-trending branch of the Damara Orogen and can be divided in three major zones that are separated by the NE-trending lineaments in the Damara Belt. These zones com- prise the Northern, the Central and the Southern Zone.

The Central Zone is divided into the northern and southern Central Zone (abbreviated nCZ and sCZ). The southern Central Zone is differentiated by the presence of numerous granitic intrusions and a higher metamorphic grade than the nCZ (Nex, Kinnard, & Olivier, 2001). The rocks of the CZ mark the highest metamorphic grade of high-temperature low-pressure upper amphibolites to granulite facies rocks in the Damara Orogenic belt. The CZ has a structure characterized by elongate domal structures frequently cored by pre-Damaran basement (Nex, Kinnard, & Olivier, 2001).

The Central Zone is dominated by the variably pelitic, calcareous and glacio-marine Swakop Group (Nex, Kinnard, & Olivier, 2001) and the arenaceous sediments of the Nosib Group (Williams, 1989) underlain unconformably by the basement rocks of the Abbabis Complex (MgABag).

The Nosib Group is discordantly overlain by the Swakop Group via sharp or interfingering contacts, the former consisting two formations, the lower Etusis Formation, and the upper Khan Formation (Miller, 2008). The Etusis Formation (NEt) is made up of thin to thick beds of pinkish brown, reddish, buff-coloured to pale grey feldspathic quartzite with few arkose and rare ortho-quartzite layers. Locally presented clast- and matrix-supported basal conglomerate occurs in the form of wedgeshaped lenses (Martin & Porada, 1977). On the other hand, the Khan Formation (NKn) is dominated by massive, thinly to thickly bedded, greyish green clinopyroxene- and hornblende- bearing feldspathic quartzite. Other lithologies like amphibole pyroxene gneiss, amphibole and biotite schist, banded gneiss, mottled gneiss, biotite gneiss are locally present only (Williams, 1989).

The Swakop Group is divided into two subgroups, the basal Ugab and upper Khomas subgroups (Miller, 2008). The Rössing Formation (NRs) makes up the base of the Ugab Subgroup. It is dominated by dolomitic marbles in some places and by siliciclastic rocks in others. It is mainly characterized by interbedding of marbles, calc-silicate and siliciclastic rocks (Miller, 2008).

Biophysical (Vegetation and Wildlife)

Namibia’s vegetation and biomes are classified into five major types, shown in (Fig. 8). These are, the Lakes and Salt Pans, Nama Karoo, Namib Desert, Succulent Karoo and the Trees and Shrub savannah. Only three of these biomes fall within the project area and thus key receptors of environmental impact particularly in case of tanker capsizing resulting into potential spillage of the Sulphuric acid.

Tree and shrub savannah

The Kalahari Basin extends over most of the north-eastern half of the country, where soils are dominated by deep sand. Tree and shrub savannah grows on most of this substrate, and this biome is further broken down into Fig 8: Show the five Categories of key ecological biomes of Namibia Broad-leafed and Acacia savannahs.

Broad-leafed savannah occurs in the far north-east, and trees characteristic of this biome form open woodland with varying bush and grass undergrowth. Several large river systems (Zambezi- Chobe-Linyanti, Kwando, Okavango) flow through the north-eastern part of Namibia, and this area is known for its wetlands with riverine forest, floodplains and river channels that support a great abundance and diversity of plants and animals not found elsewhere in the country. The broad- leafed savannah is characterised by average annual rainfall above 450 mm, and fires (started mostly by people) are a common, almost annual occurrence (Mendelsohn & el Obeid 2005).

Fig 9: Shows the most common type of vegetation on the project site, consisting of savannah characterized woody species well adapted to the sandy Kalahari sands (the invasive Acacia melifera is observed)

Acacia savannah is characterised by open expanses of grasslands dotted with mostly thorny Acacia trees but also includes areas where Colophospermum mopane and other trees such as Commiphora dominate.

Nama Karoo

This biome covers most of the south-eastern part of the country and extends in a thin band along the escarpment, making a transition zone between savannah to the east and desert to the west. There is a varied assemblage of plant communities including shrubby vegetation and grasslands in the Kunene hills and central western plains, dwarf shrub savannah in the south central areas, and grasslands in the south. These variations reflect the variety of geological substrates, soils and landforms, which in turn are responsible for the high level of endemism that is found in this zone. A high proportion of Namibia’s plant, bird and reptile species occur only in this zone in the north- western part of the country.

Namib Desert

The coastal band of the country is characterised by extreme aridity. Rainfall is very low (< 100 mm) and highly variable but a more consistent source of water is fog, although delivered in much smaller amounts. Sand dunes dominate the substrate between Luderitz and Walvis Bay, forming the main Namib Sand Sea, and occur in smaller dune fields in the southern and northern Namib. Gravel and sandy plains dotted with inselbergs characterise the remainder. Vegetation cover is sparse and confined to small plants, grasses and shrubs. The desert is cut by a number of West- flowing Rivers which rise in the highlands further inland and create linear oases through the arid surroundings. Each river has an alluvial aquifer that supports trees and undergrowth and occasional springs, all of which contribute to the role of the rivers as lifelines crossing the Namib (Jacobsen et al. 1995).

Water and Soil Resource Potential

The eastern most regions lie on the western edge of a vast basin of sand (Fig. 10), and it is this sand that determines much about the vegetation, wildlife, farming and mineral potential of the region. Groundwater is generally available throughout both regions, and the quality of water is also generally good. Higher yielding aquifers are present in several areas: around Grootfontein, Leonardville, Hochfeld and in the Eiseb (Fig. 11). The site topography is flat with no water catchment streams, tributary or rivers observe, implying that most of the rain falling on the surface infiltrates directly into the Kalahari sandy soil.

Fig 10: Common soil and geological material predominantly consisting of the Cenozoic sediments, Precambrian rocks and Neo-Proterozoic rocks.

Fig 11: Shows areas of sensitivity in respect to water resources along the project route, these are crucial in protecting in case of accidents as key human settlements, economic and livelihood centers are found here.

Biodiversity and endemism hotspots

Due to it low productivity, the south-west African arid zone is endowed with modest diversity of species compared to more mesic habitats. What is most distinctive about Namibian biodiversity is its high degree of endemism (Barnard 1998). Overall terrestrial diversity of plants and animals is highest in the north-eastern parts of Namibia (Fig. 12, green map indicator), because of the higher rainfall and presence of wetlands and forest habitats that are not found elsewhere in the country. Many species in the north are also more tropical, with ranges that extend into neighbouring countries to the north and north-east. Species richness is highest in Namibia’s mesic wetlands and woodlands in the vertebrate classes particularly (Barnard 1998).

Fig 12: Shows a comparison of overall terrestrial species diversity (green) against overall endemism (brown), with the most diversity observed in the Okavango and Zambezi regions thus flagging red in terms of environmental risks.

Other zones of notably high diversity are centred on the karstveld (Tsumeb-Otavi area), in central areas of high ground, and in scattered areas further west and in the south. Habitat diversity is an important determining factor: plant and animal species are relatively more numerous where there are a variety of habitats situated close together (such as mountains slopes with different aspect, rock types, slopes and relief).

Unlike the concentration of biodiversity in the north-east, the great majority of Namibia’s endemic species are found in the dry western and north-western regions (Fig. 12, brown map indicator) (Barnard 1998, Mendelsohn et al. 2002). The patterns of endemism reflect the importance of arid habitats in supporting unique and specially adapted species.

Endemic species, particularly of birds, mammals and reptiles, are concentrated in the escarpment zone. In the Namib, endemics are associated with the dunes, rocky inselbergs and hills, and the sandy and gravel plains. For instance, approximately 60 reptile species (50% of all Namibian endemic reptiles) are endemic to, or found mainly in, Namibia’s Namib Desert (M.Griffin 1998). In birds, the greatest diversity of southern African endemics is centred on the arid savannah and Karoo biomes and extends into the escarpment (Brown et al. 1998). Highland areas of the country, including Waterberg, Khomas Hochland, Karas Mountains, Brandberg, inselbergs in the Sperrgebiet and the karstveld are particularly important for many endemic plants (Mendelsohn et al. 2002).

In respect to this project, habitats of special ecological importance and therefore requiring special care for both richness of species generally and of endemic species include (Barnard 1998): • The coastal zone; • The Namib sand sea and adjacent gravel plains; • The winter-rainfall desert zone; and • Caves and sinkholes.

Distribution of terrestrial primary productivity

Following the overall rainfall pattern for Namibia, plant production shows a gradual increase from south-west to north-east (Fig. 13). The important features of the map are areas of highest plant production are in the broad-leafed woodlands of eastern Zambezi, western Kavango and in the woodlands in the area of Tsumeb, Otavi and Grootfontein.

Relatively high plant production centred around Otjiwarongo is due largely to bush encroachment and a rapid decline from high to very low productivity across the western escarpment into the Namib proper in the northern half of the country. Overall, the northeastern regions are those that require extra environmental care or protection.

Fig 13: Illustrate green vegetation biomass as an indicator of terrestrial productivity, this makes a good indicator of environmental degradation in case of a risk incident.

7 5 ENVIRONMENTAL IMPACTS AND MANAGEMENT PLAN

5. SUMMARY OF IDENTIFIED ENVIRONMENTAL IMPACTS

5.1 OVERALL OBJECTIVES OF THE EMP

The following overall environmental objectives have been set for Kilwe Transport and General Trader Ltd’s Sulphuric Acid haulage operations are: · To comply with national legislation and standards for the protection of the environment. · To limit potential impacts on biodiversity through the minimisation of the footprint (as far as practically possible) and the conservation of residual habitat within the mine area. · To keep surrounding communities informed of farming activities through the implementation of forums for communication and constructive dialogue. · To ensure the legal and appropriate management and disposal of general and hazardous waste, through the implementation of a strategy for the minimisation, recycling, management, temporary storage and removal of waste. · To develop, implement and manage monitoring systems to ensure good environmental performance in respect of the following: ground and surface water, air quality, noise and vibration, biodiversity and rehabilitation.

5.2 METHODS OF IMPACT SCOPING / ASSESSMENT

As part of the Scoping and EMP processes for the Kilwe T&G Trader Ltd, environmental aspects and potential environmental impacts associated with the activities and facilities were identified. Detailed Kilwe Transport and General Trader’s activities associated with the operation shall be described in section of this EMP.

Both the criteria used to assess the impacts and the method of determining the significance of the impacts is outlined in Table 4. This method complies with the method provided in the Namibian EIA Policy document and the draft EIA regulations. Part A provides the approach for determining impact consequence (combining severity, spatial scale and duration) and impact significance (the overall rating of the impact). Impact consequence and significance are determined from Part B and C. The interpretation of the impact significance is given in Part D. Both mitigated and unmitigated scenarios are considered for each impact.

Table 4: Criteria for Assessing Impacts PART A: DEFINITION AND CRITERIA Definition of SIGNIFICANCE Significance = consequence x probability Definition of CONSEQUENCE Consequence is a function of severity, spatial extent and duration Criteria for ranking of the H Substantial deterioration (death, illness or injury). Recommended level will often be SEVERITY/NATURE violated. Vigorous community action. Irreplaceable loss of resources. of environmental impacts M Moderate/ measurable deterioration (discomfort). Recommended level will occasionally be violated. Widespread complaints. Noticeable loss of resources. L Minor deterioration (nuisance or minor deterioration). Change not measurable/ will remain in the current range. Recommended level will never be violated. Sporadic complaints. Limited loss of resources. L+ Minor improvement. Change not measurable/ will remain in the current range. Recommended level will never be violated. Sporadic complaints. M+ Moderate improvement. Will be within or better than the recommended level. No observed reaction. H+ Substantial improvement. Will be within or better than the recommended level. Favorable publicity. Criteria for ranking the L Quickly reversible. Less than the project life. Short term DURATION of impacts M Reversible over time. Life of the project. Medium term H Permanent. Beyond closure. Long term. Criteria for ranking the L Localized - Within the site boundary. SPATIAL SCALE of M Fairly widespread – Beyond the site boundary. Local Impacts H Widespread – Far beyond site boundary. Regional/ national

PART B: DETERMINING CONSEQUENCE SEVERITY = L DURATION Long term H Medium Medium Medium Medium term M Low Low Medium Short term L Low Low Medium SEVERITY = M DURATION Long term H Medium High High Medium term M Medium Medium High Short term L Low Medium Medium SEVERITY = H DURATION Long term H High High High Medium term M Medium Medium High Short term L Medium Medium High L M H Localized Within Fairly widespread Widespread Far site boundary Beyond site beyond site Site boundary boundary Local Regional/ national SPATIAL SCALE

PART C: DETERMINING SIGNIFICANCE PROBABILITY Definite/ Continuous H Medium Medium High (of exposure to Possible/ frequent M Medium Medium High impacts) Unlikely/ seldom L Low Low Medium L M H CONSEQUENCE

PART D: INTERPRETATION OF SIGNIFICANCE

Significance Decision guideline

High It would influence the decision regardless of any possible mitigation. Medium It should have an influence on the decision unless it is mitigated.

Low It will not have an influence on the decision.

*H = high, M= medium and L= low and + denotes a positive impact.

5.3 STAKEHOLDER MANAGEMENT AND MITIGATION

It is important that channels of communication are maintained over the life of the project for surrounding landowners, the general public members, as well as the local and traditional authorities, table 4 shows the stakeholders communication Management and Mitigation Plan.

Table 5: Actions relating to stakeholder communication Issue Management commitment Phase Maintain and update the stakeholder register, including stakeholders’ needs and expectations. Ensure that all relevant stakeholder groups are included. All A representative database would include all relevant local government, Understanding who the service providers, contractors, indigenous populations, local stakeholders are communities, traditional authorities, NGOs, shareholders, the investment

sector, community-based organizations, suppliers and the media. All

Ensure that marginalized and vulnerable groups are also considered in the stakeholder communication process. All Record partnerships as well as their roles, responsibilities, capacity and contribution to development. All Liaising with interested and Devise and implement a stakeholder communication and engagement affected parties at all phases strategy. All in the mine life Responsibility RMH Logistics cc and Enviro-Leap Consulting (On-contract)

5.3 IMPACT SCOPING / ASSESSMENT 5.3.1 HAZARDOUS PRECAUTIONARY MEASURE AND COMPLIANCE

5.3.1.1 ASSESSMENT OF IMPACT: TRANSPORT SAFETY AND SECURITY COMPLIANCE

Namibia subscribed to the South African Bureau of Standards (SABS) standards specifications on transportation of dangerous goods i.e. it is the duties of the operator, driver, consignor and consignee with regard to the transportation of dangerous goods by road are as prescribed in the Standard Specifications, and any other legislation applicable to the transportation of dangerous goods. In addition, a person may not transport or cause to be transported dangerous goods that may, in terms of the Standard Specifications, not be transported.

Failing to comply with key road transportation requirement may result in road hazards and potential incidents thus endangering both the tank operator or driver and other public road users.

Tabulated Summary of Assessed Impact – Safety and Security

Mitigation Severity Duration Spatial Scale Consequence Probability of Occurrence Significance

Unmitigated M L L M L M Mitigated L L L L L M

CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES

The transportation of dangerous substances may be subject to the regulations of the International Maritime Organization (IMO), the International Civil Aviation Organization (ICAO), the Namibian regulations governing the transportation of dangerous substances. The carrier must ascertain whether the goods being transported are regulated and, if so, to what extent.

It is essential to comply with safety rules respecting road freight transportation when dangerous substances are transported. More than any other type of transportation, the transportation of dangerous substances requires numerous precautions: i.e.; - Verify that safety marks for the dangerous substances have been correctly displayed (Fig. 14) - Be aware of safety procedures in the event of an accident - Ensure that the load complies with the appropriate load and dimension standards. - Recommend to drivers that, as much as possible, they use roads that allow them to avoid major urban centres. - Remind drivers to comply with traffic rules in tunnels and recommend that they only use bridges when it is absolutely necessary. - Maintain a reliable communication system that makes it possible to reach at all times staff who transport and handle dangerous substances. - Maintain a sound information exchange network with other industry stakeholders.

Fig 14: Illustrate of appropriate displaying of safety and label markings, in case of sulphuric acid a corrosion sign is displayed alongside other relevant safety labels

5.3.1.2 ASSESSMENT OF IMPACT: ACCIDENTS – RISKS INCIDENTS LEADING TO SPILLAGE

The nature of Kilwe Transport and General Trader’s operational activities has although very rare chances of spill incidents prone to accidents that may result in spillage of the sulphuric acid transported (Fig. 15). It is thus very crucial that measures are put in place to prevent such incidents from occurring, therefore if not properly managed the spill may be detrimental to both human and environmental safety. It may further lead to pollution of the aesthetic value of the wilderness and negatively impact the tourism potential of an area.

The impacts may two-fold, (1) the impact relating to the spillage leading to corrosion of any flora and fauna should the sulphuric acid chemical gets into contact with the vegetation and any living organisms inhabiting therein, and (2) if no proper measures are employed an emergency response (contingency / remedial action) not conducted with due diligence in respect to environmental management.

Fig 15: Shows a common nature of impacts and potential contamination of soils at an accident scene

Tabulated summary of the assessed impact – risks incident leading to spillage

Mitigation Severity Duration Spatial Scale Consequence Probability of Significance Occurrence Unmitigated H M L H L H Mitigated L L L L L L

CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES

It is recommended that if possible, at all costs preventative measures must be employed to ensure minimal socio-environmental impacts by employing competent drivers and providing awareness raising on potential impacts that ay result from accidents. Of particular interests, are the impacts that may occur as a result of poor consideration of further damage to the environment during the rehabilitation of contaminated sites e.g. no further trembling should be allowed to cause unintended environmental harm (Fig. 16).

Fig 16: Shows a typical illustration of unintended impacts the use of earthmoving equipment may lead to habitat destruction as seen in the two images above

Aggregate material to be obtained for rehabilitation must be obtained from authorised borrow pits and disposal of contaminated overburden removed from an incident site must be at an approved sites and under supervision of the relevant local authority.

Secondly, a contingency plan (Emergency Response Intervention Plan) which includes a step-by-step guide on procedures to be followed during an accident involving a tanker transporting sulphuric acid i.e. the emergency response intervention plan must provide guidance on initial actions for fire crews when they first arrive at the scene of a chemical transport accident without having appropriate and reliable product specific emergency information at hand.

Emergency Response Intervention Cards information is structured according to a standard format: 1. Page header with substance name, UN number, hazard number, SABS label, SABS class, classification code (hazard identification number) 2. Properties 3. Dangers 4. Personal protection 5. Emergency response ‒ General measures ‒ Measures fabric outlet ‒ Measures in case of fire 6. First Aid Kits 7. Special precautions in the recovery of dang goods 8. Precautions for the use of aid ‒ Removal of protective clothing (Decon P) ‒ Cleaning of equipment (Decon G)

5.2.1.3 ASSESSMENT OF IMPACT: CONTAMINATION OF SOILS AND UNDERGROUND WATER

The potential impact from chemical spillage resulting from capsized tankers carrying the sulphuric acid leading to both the contamination of soil and potentially groundwater (in case of extreme spillage). Groundwater contamination may be in the form of infiltration of hydrocarbons and other agents contained in the sulphuric acid, if the remedial management measures are not properly implemented.

This in this case is highly depended on where and accident occurs but the areas at greatest risks in particular reference to this project are the national park, “yellow” and “red” flagged areas for water and ecological sensitivity. These includes areas with the Namib Desert where the dominant sand types consist of gravel material and some extend sand, the areas from Otjiwarongo all the way to Katima Mulilo are key risks receptors as due to the dominant sandy soils type which encourages speedy infiltration of liquid substances.

In some instance, the operation may require storage of fuels and lubricants at the incident scene site with an intention to cut on time, which may be lost when refuelling has to be done at the nearest fuel station that might be a distance. If not well managed, these fuel and lubricants may as well result in small spillages which hydrocarbons that are not good for areas where the groundwater potential is high and or water tables are shallow. The risk might be great if the incident occurs at site that is close to watercourses with surface water runoff.

Tabulated summary of the assessed impact – contamination of soil and underground water

Mitigation Severity Duration Spatial Scale Consequence Probability of Significance Occurrence Unmitigated H H L H L H Mitigated M L L L L H

CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES

Where possible, and in case the drivers are able to contain a spill or effect measures that reduces any spillage at an incident scene, the sulphuric acid must be safely so contained or blinded with an agent that reduces its corrosively. However, in an unlikely case where a blending agent is not accessible the spill must be contained by ponding (creation of an earthen walled pond) to minimize broader spreading of the chemical.

In the event where fuel (petrol or diesel) should be stored at the incident site, it must be safely and securely stored to optimise preventative measures and consequently reduce any chance of soil contamination. Any machinery servicing must as well not be conducted on the rehabilitation site unless in an emergency situation, in which case all fuel and lubricants should be collected and disposed off at an authorised waste disposal site I the nearby town.

5.3.2 AIR POLLUTION AND FIRE RISKS

5.3.2.1 ASSESSMENT OF IMPACT: AIR POLLUTION

Dust, though highly depended again on the nature, magnitude of spillage and geological structure of the soils at the incident site, will be generated by the use of heavy earth-moving equipment during the rehabilitation process.

However, because the rehabilitation activities extend and magnitude may be minimal the potential impacts are expected to be generally low. In addition, the prevailing winds will disperse Dust away from any sensitive receptors, which in addition to mitigation measure reduces the health risk associated with Dust.

Critically, the nuisance impact of potentially offensive Dust cannot be discounted if the normal operation regime is upset and farming is not conducted in the desired manner, or should Dust control mechanisms are not employed appropriately. In this case, the impact may be significant.

Tabulated Summary of the Assessed Impact – Release of Dust into the Atmosphere

Mitigation Severity Duration Spatial Scale Consequence Probability of Significance Occurrence Unmitigated M H L M H M Mitigated L M L L M L

CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES

Dust is subjective and dependent on difference in public perception, therefore there is no dedicated Dust- monitoring programme developed other than an incident register. Hence, a stakeholder committee should be established to log and attend to Dust complaints. Importantly, the record of complaints should include the date and time so that it may be associated with the Dust generating activity. This will aid the identification of the Dust source (or activity) and required management intervention devised to eliminate the activity as a future source.

5.3.2.2 ASSESSMENT OF IMPACT: FIRE AND HEALTH RISKS

Considering that risks associated with road transportation of cargo is the potential danger of coalition with other vehicle (road-users), and it is in such incidents that a fire might erupt. Additionally, the storage additional and use of fuel during emergency and or rehabilitation operations present a risk of fires as both unleaded petrol and diesel are extremely flammable and if not handled according to Material Safety Data Sheet instructions and SANS requirements, a fire risk exist. Hydrocarbons are carcinogenic and dermal contact and inhalation of fumes should be prevented.

Tabulated Summary of the Assessed Impact – Generation of noise from operations (Machinery and cultivation)

Mitigation Severity Duration Spatial Scale Consequence Probability of Significance Occurrence Unmitigated H M L M M H Mitigated L L L L L L

CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES

A holistic fire protection and prevention plan is needed. This plan must include an emergency response plan, fire fighting plan and spill recovery plan. Fire prevention should be adequate, and health and safety regulations should be adhered to in accordance with the regulations pertaining to relevant laws and internationally accepted standards of operation.

Further, mitigation measure for fire risks must be managed through carrying and making available on the tanker standard fire extinguishers (as per relevant applicable regulations.

Special note must be taken of the regulations stipulated in sections 47 and 48 of the Petroleum Products and Energy Act, 1990 (Act No. 13 of 1990). Maintain fire fighting equipment, good housekeeping and personnel training (fire fighting, fire prevention and responsible housekeeping practices).

5.3.3 SOCIO-ECONOMIC ASPECTS

5.3.3.1 ASSESSMENT OF IMPACT: TRAFFIC VOLUME – INCREASE AND ASSOCIATED IMPACTS

The activities associated with the Kilwe T&G Trader sulphuric transportation operations have socio- economic impacts the Namibian population in various ways such as by adding pressure on towards the increase in traffic volume along the B8 routes. A traffic study conducted to ascertain the potential impact relating of key Namibian routes as Logistic Corridors reveals that the Trans-Zambezi is one of the corridors that will experience an increase in traffic volumes (Fig. 17 and Table 6).

With Kilwe T&G Trader as an individual operator currently running a fleet of thirty tankers, the footprint is relatively significant and that carries sufficient weight in terms of socio-environmental impacts relating to road transport. Should any of their tanker be involved in an accident it present danger to lives of other roads users and on the environment in case of spillage.

Fig 17: Illustrates the predicted change (between 2013 and 2025) in traffic volume along the B8 route currently used by Kilwe T&G Trader, as a measure of potential impact associated to their operation of 30 sulphuric acid tanker fleet

Table 6: Annual average daily traffic volume across different types of vehicles between Karibib and Grootfontein (on B8)

Tabulated Summary of the Assessed Impact – Increase in Traffic Volume and Associated Impacts

Mitigation Severity Duration Spatial Scale Consequence Probability of Significance Occurrence Unmitigated H+ L L L L L Mitigated H+ M M H+ M H

CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES Human error is often the major cause of accidents in the long distance transportation of dangerous good business, this may occur as a result of not obeying road regulating signs and warning, not having sufficient rest and use of intoxicating substance while operating the tanker. Ensuring that all it drivers are sensitized on the potential danger associated with the hazardous substance they’ll be transporting will help reduce the danger resulting from negligence and reckless driving.

Operators of hazardous substances must be vigilant at all times while on duty or operating the tankers, therefore it is key that the Kilwe T&G Trader enforces strict for ensuring that no driver will operate the tankers on public road while under the influence of any toxic substance. They must also be afforded adequate for sufficient sleep and where necessary they must take drive rest at safe demarcated rest bay along their route.

5.3.3.2 ASSESSMENT OF IMPACT: SOCIAL INTRUSION The activities associated with the Kilwe T&G Trader sulphuric transportation operations have socio- economic impacts in its operations – some positive and some negative. These impacts related to amongst others employment/job creation, local and regional economies, land use and surrounding landowners and community safety and security.

Tabulated Summary of the Assessed Impact – Socio-Economic Impacts

Mitigation Severity Duration Spatial Scale Consequence Probability of Significance Occurrence Unmitigated H+ L L L L L Mitigated H+ M M H+ M H

CONCEPTUAL DESCRIPTION OF MITIGATION MEASURES Preparation of a health and safety plan for workers and impacted communities addressing issues including education on measures to prevent the spread of HIV/AIDS through awareness campaigns, provision of safety equipment for workers, child labor prohibited

5.4 CONCLUSIONS AND RECOMMENDATIONS

Potential impacts (Socio-economic, Generation of Effluent and Waste, and Ambient Air Pollution) were identified as a key environmental issue through the scoping process. Dust, which are a nuisance rather than a classic air pollutant, may emanate from different areas of the plant including the animal preparation area, from meat processing, skin and blubber splitting, skin cleaning and organ processing and from the storage of animal.

Nonetheless, all identified impacts are considered to be localized, short-medium term and minor due to the nature of the sulphuric acid transportation, where impacts are across a month and over the year.

It is thus recommended that the Office of Environmental Commissioner issues and Environmental Clearance on condition that all proposed measures will be implemented and adhered to. Further, it is the responsibility to maintain a living stakeholder consultation process to ensure that the public, road users and key stakeholder are kept aware of any potential danger in case of risk incidents.

REFERENCES REFERENCES Deane, J.G., 1995. The structural evolution of the Kombat deposits, Otavi Mountainland, Namibia. Communications of the Geological Survey of Namibia, 10: 99-107. Department of Water Affairs and Forestry, 2001. Groundwater in Namibia: An explanation to the hydrogeological map. MAWRD, Windhoek, 1, 128 pp. Directorate of Environmental Affairs, 2008. Procedures and Guidelines for Environmental Impact Assessment (EIA) and Environmental Management Plans (EMP), Directorate of Environmental Affairs, Ministry of Environment and Tourism, Windhoek. Klock H; 2001; Hydrogeology of the Kalahari in northeastern Namibia with special emphasis on groundwater recharge, flow modeling and hydrochemistry Colorado Department of Public Health and Environment (CDPHE). (2002): SCREEN Stationary Source Modeling Guidance, Colorado Department of Public Health and Environment - Air Pollution Control Division (CDPHE/APCD) Technical Guidance Series: Air Quality Modeling, January 1, 2002. Environmental Legislation Project, 2001. Baseline Review - Pollution Control and Waste Management Legislation in Namibia. Directorate of Environmental Affairs, Ministry of Environment & Tourism European Commission (2005): Integrated Pollution Prevention and Control, Reference Document on Best Available Techniques in the Slaughterhouses and Animal By-products Industries, May 2005, http://eippcb.jrc.ec.europa.eu/reference/sa.html Government Gazette, 27 December 2007. No. 3966, Act No. 7, 2007 Environmental Management Act 2007. Laukamp, C. (2007): Structural and Fluid System Evolution in the Otavi Mountainland (Namibia) and its Significance for the Genesis of Sulphide and Nonsulphide Mineralisation. Inaugural – dissertation Mendelsohn, J., Jarvis, A., Roberts, C. & Robertson, T. 2003.Atlas of Namibia.David Philips Publisher. Cape Town. Miller, R.M., 1983. The Pan-African Damara Orogen of South West Africa/Namibia. Spec. Publ. Geol. Soc. S. Afr., 11: 431-515. Ministry of Environment and Tourism, 2002 Atlas of Namibia. Comp. J. Mendelsohn, A. Jarvis, T. Roberts and C. Roberts, David Phillip Publishers, Cape Town. IFC, (2007): Environmental Health and Safety Guidelines, General EHS Guidelines: Environmental, Air Emissions and Ambient Air Quality, April 30 2007. Innes, J., Chaplin, R.C., 1986. Ore bodies of the Kombat Mine, South West Africa/Namibia. Mineral Deposits of Southern Africa, I & II: 1789 - 1805. Pulfrich, A., (2010). Environmental Impact Assessment for the Proposed Seismic Surveys in the Central Walvis Basin and Southern Orange Basin Areas, Namibia. Marine Faunal Assessment. Prepared by Pisces Environmental Services (Pty) Ltd for CCA Environmental (Pty) Ltd on behalf of HRT Oil & Gas and Universal Power Corp. World Bank Group, (1998): Pollution Prevention and Abatement Handbook, General Environmental Conditions and Summary of Air Emissions and Effluent Discharge Requirements, July 1998. World Health Organisation, (2005): WHO Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulphur dioxide, Global update 2005, WHO/SDE/PHE/OEH/06.02.

APPENDICES APPENDICES

APPENDIX A: SPILL SITE REHABILITATION REPORTS AS PER MET INSTRUCTION

APPENDIX B: CONTINGENCY (EMERGENCY RESPONSE) PLAN

APPENDIX B: EAP PROFILE & RESUME

PROFESSIONAL RESUME

VILHO PANDEINGE MTULENI ● ID: 701119 0034 4

Profession: Environmental Assessment Practitioner Postal Address: P. O. Box 686 ● Windhoek, Namibia, 9000 Mobile: +264 - 81 2326843 ● Code B Drivers license ● Single ● No criminal record Email: [email protected] or [email protected]

EDUCATION BACKGROUND

Full-time tertiary education: • National Diploma in Project Planning and Management, 2013, Southern Business School • National Diploma in Natural Recourses Management, 2000, Polytechnic of Namibia (now Namibia University of Science and Technology) • Matric (Grade 12 Certificate), 1995, Namibia College of Open Learning Short-courses • Ecological Modeling Course, 2009, Presented at the Polytechnic of Namibia by University of Potsdam (Germany) • Safety and off-road driving Course, 2001, Amibis Driving Academy • Basin Management Course (OmBMC), 2008, Southern African Institute for Environmental Assessments (SAIEA) • Advance training on Facilitations Skills, 2006, Indigo – Monkeys Valley, South Africa • SAFRINET Course in Entomology and Arachnology, 1997, Pretoria South Africa • Air Sampling Course, 1996, NOAA – Climate Monitoring and Diagnostics Laboratory (NOAA/CMDL). Boulder, Colorado, United States of America • Hands on Training on Fog Collection and constructing Fog collecting Units, 1996, La Serena Chile RELEVANT WORK EXPERIENCE Position Held: Environmental Role and Responsibilities: Consultant • Coordinate Environmental Assessment projects, conduct filed Institution: Enviro Leap studies and facilitate public consultation process Consulting cc • Manage all administrative activities of project management Year: Current, Part-Time components of the company • Facilitate application for environmental Clearance Certificates Position Held: Central Technician Role and Responsibilities: Institution: SASSCAL • Planning and undertaking field trips, Download data from Year: 2010 to present automatic weather station as well as soil moisture data loggers. • Monitoring of environmental components which involve data collection, capturing and processing. • Basic Administration and budgeting, Maintenance of SASSCAL vehicle Fleet and other equipment, Participation in training, workshops and conferences. Position Held: Central Technician Role and Responsibilities: Institution: BIOTA Southern • Planning and undertaking field trips, Download data from Project automatic weather station as well as soil moisture data loggers. Year: 2004 to 2010 • Monitoring of environmental components which involve data collection, capturing and processing. • Basic Administration and budgeting, Maintenance of BIOTA Vehicle Fleet and other equipment, Participation in training, workshops and conferences. • Supervised subordinates (Junior research technician and Para- ecologists)

RELEVANT WORK EXPERIENCE continuous… Position Held: Research Technician Role and Responsibilities: Institution: Gobabeb Training and Research • Coordinated the Long-term Ecological Research (Ecological Observatory Centre Network-EON) research projects, conducted and maintained the Centre’s Year: 1995 to 2004 research and research sites • Represented the Centre at national and regional international Workshops, Conferences / Congress • Corresponded with researchers both local and international (ref: data collection, sharing and implementation) • Supervised subordinates (Junior research technician and Interns)

SKILLS • Project Planning and Management (Incl. Proposal Writing, Budgeting and Basic Accounting, SIA / EIA Assessments) • Problem analysis and scoping, project design, monitoring and evaluation, and professional report writing • Leadership (supervision of sub-ordinates and leading project teams) • Training, facilitation of collaborative and educational workshops • Good communication in English (both written and verbal), basic spoken proficiency in four Namibian Languages • Computer literate (Ms word, Excel, PowerPoint, Outlook, SPSS and basic GIS) • Basic IT and server management, Basic electronics repairs • Can work without or with little supervision

AWARD AND ACHIEVEMENTS • Successfully completed First Aid advance Courses 2007 • National Science Award, Special Category: Research Assistant of the Year 2004 • Best poster presentation: Exploring fog as a supplementary water source in Namibia, St John’s Canada, 2001

RECENT PUBLICATIONS AND REPORTS Mtuleni V (2018) Environmental Management Plan for a Domestic Fuel Storage Tank on Farm Steenboklaagte No. 802, Kombat District, Otjozondjupa Region, Namibia. Mtuleni V (2018) Environmental Scoping and Management Plan for DNHT Investment (Pty) Ltd. Fuel Station and Associated Facilities at Okondjatu Village in the Okahandja District, Otjozondjupa Region, Namibia. Mtuleni V (2018) Environmental Scoping and Management Plan for DNHT Investment (Pty) Ltd. Fuel Station and Associated Facilities at Otjinene Village in the Gobabis District, Omaheke Region, Namibia. Mtuleni V (2018) Environmental Scoping and Management Plan for the Small-scale Dimension Stone Quarrying Operations on FarmingClaims on Farm Etusis No. 75, Karibib District, Erongo Region, Namibia. Mtuleni V (2018) Environmental Management Plan for the Existing Small-scale Dimension Stone Quarrying Operations on FarmingClaim 69448 at Farm Otjoruharui No. 251, Okahandja District, Otjozondjupa Region, Namibia. Mtuleni V (2018) Environmental Scoping Assessment Report for the Proposed Marble Quarrying from the Skaap River (Between Farms Hatsamas No. 283 And Stinkwater No. 282 at Dordabis, Windhoek District, Khomas Region, Namibia Mtuleni V (2017) Environmental Scoping and Management Plan for the Proposed Abattoir at Farm Lusa No. 788, Omaheke Region, Gobabis District, Namibia Mtuleni V (2017) Environmental Management Plan for the Operation of an Existing Seal Skin and Trophy Processing Plant in Luderitz, Karas Region, Namibia. Mtuleni V et al (2001) Exploring Fog as a supplementary water source in Namibia, Proceedings 2nd International Conference on Fog and Fog Collection St John’s, Canada Mtuleni V at al (1998). Namibian Application of Fog-Collection System Harare, Environmental Round Table Series. Mtuleni V et al (1998) Evaluation of Fog-Harvesting potential in Namibia. Proceedings, 1st International Conference on Fog and Fog Harvesting, Vancouver, Canada

REFERENCE CONTACTS 1. Ms. Bertchen Kohrs 2. Dr. Ute Schmiedel Liaison Officer, BIOTA Namibia Botanical Garden University of Hamburg, Germany Tel: +264-61-227913 Fax: +264- 61- 305213 Tel: +4940-42816-548 Fax: +4949-42816-539 E-mail: [email protected] E-mail: [email protected]

3. Dr. Joh Henschel 4. Dr. Mary Seely Former Executive Director: Former Executive Director and Associate (current) Gobabeb Training and Research Centre Desert Research Foundation of Namibia, Tel: + 264-64-694 198 Fax: + 264-64 694 197 Tel: +264 61 377500, Fax: +264 61 230172, Email: [email protected] Email: [email protected]