Environmental Management Plan

ENVIRONMENTAL MANAGEMENT PLAN

FOR THE EXPLORATION ACTI VITIES ON EXCLUSIVE PROSPECTIN G LICENSE (EPL) 7004 IN DOROB NATIONAL PARK, ERONGO REGION

September 2019

ENVIRONMENTAL AUTHOR IZATION INFORMATION

PROJECT: ENVIRONMENTAL IMPACT ASSESSMENT FOR THE EXPLORATION ACTIVITIES ON EXCLUS IVE PROSPECTING LICE NSE (EPL) 7004 IN DOROB NATIONAL PARK, ERONGO REGION.

PREPARED FOR: Pure Tantalum (Pty) Ltd P.O. Box 68 Uis Namibia Tel: +264 64 504189 Cell: +27 8247 69223 Email: [email protected] PREPARED BY: Nam Geo - Enviro Solution P.O. Box 3343 Windhoek Tel: +264(61) 402246 Fax: 088 6554084 Email:[email protected]

2 TABLE OF CONTENTS

1. INTRODUCTION AND BACKGROUND ...... 5 2. OBJECTIVES OF THE ENVIRONMENTAL MANAGEMENT PLAN ...... 5 3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 6 3.1 THE NAMIBIAN CONSTITUTION ...... 6

3.2 ENVIRONMENTAL ASSESSMENT POLICY (1994) ...... 7

3.2.1 Cradle to Grave Responsibility ...... 7

3.2.2 Precautionary Principle ...... 8

3.2.3 Th e Polluter Pays Principle ...... 8

3.2.4 Public Participation and Access to Information ...... 8

3.4 ENVIRONMENTAL MANAGEMENT ACT OF NAMIBIA (2007) ...... 8

3.5 ENVIRONMENTAL MANAGEMENT ACT REGULATIONS (2012) ...... 9

3.6 INTERNATIONAL CONVENTIONS AND PROTOCOLS - RELATED TO THE PROJECT ...... 10

4. ROLES AND RESPONSIBILITIES ...... 10 4.1 COMPETENT AUTHORITY ...... 10

4.2 Pure Tanta lum (Pty) Ltd ...... 10 4.3 Pure Tantalum (PTY) LTD (PROJECT MANAGER) ...... 11

4.4 Pure Tantalum (PTY) LTD (ENVIRONMENTAL OFFICER) ...... 11

4.5. SAFETY OFFICER ...... 12

5 .ENVIRONMENTAL M ANAGEMENT PLAN ...... 13 5.1 PROTECTION OF FLORA, FAUNA AND NATURAL FEATURES ...... 13

5.2 ACCESS ROUTES ...... 13

5.3 SITE MANAGEMENT ...... 14

5.4 STAFF MANAGEMENT ...... 14

5.5 WASTE MANAGEMENT ...... 14

5.6 MANAGEMENT PRINCIPLES ...... 14

7. DECOMMISS IONING AND site closure ...... 35

CONCLUSIONS ...... 37

4 1. INTRODUCTION AND BACKGROUND The EMP in the following sections has been developed spec ifically for use at the proposed exploration and prospecting activities on Excusive Prospecting License (EPL )7004 in the Dorob National Park This EMP is designed to address potential issues based upon discussions among the appointed consultants, the proponent, concerns and interest from public participations and from a site visit by the consultants.

The EMP is additional to and compliments Pure Tantalum (Pty) Ltd environmental policy and safety management systems to be developed by the proponent. This Environmental Management Plan (EMP) provides guidance for managing the construction, operation and possible decommissioning of the exploration and prospecting activities . The EMP is a working document which consists of a set of mitigation measures that will be implemented to eliminate, offset or reduce adverse environmental impacts to acceptable levels during the exploration and prospecting activiti es

The exploration project involves:

 Review of geological maps, published and unpublished geological data  Investigating the geological condition of the site  Geological mapping  Trenching

Decommissioning phase

 Removal of infrastructures

 Transportation off - site

 Site rehabilitation

2. OBJECTIVES OF THE ENVIRONMENTAL MANAGE MENT PLAN The environmental management plan (EMP) aims to take a pro - active route by addressing potential problems before they occur. The objectives of the EMP are therefore

5  To outline mitigation measures in order to manage environmental and socio - economic impacts associated with the project  Provide a framework for implementing the management actions recommended in the EIA for exploration and prospecting activities T o ensure that the project will be developed and operated according to the stipulated requirements of Namibia Environmental Management Act (No 7 of 2007)

 To ensure that the project will comply with relevant environmental legislations of Namibia and other r equirements throughout its operation.

NB . All Contractors and sub - Contractors taking part in the exploration and prospecting activities should be made aware of the contents of the EMP and of the Environmental Impact Assessment (EIA), so that they can plan their activities accordingly in an environmental sound manner.

3. POLICY, LEGAL AND ADMINISTRATIVE FRAME WORK The Environmental Management Plan (EMP) is a tool that can provide the assurance that the proponent has made suitable provisions for mitigation. The EMP describes the methods and procedures for mitigation and monitoring the impacts identified in the EIA report. The following legislation governs the EIA/EMP process in Namibia, pertaining to the proposed development.

3.1 THE NAMIBIAN CON STITUTION The Constitution of Namibia encourages wise and sustainable use of resources. According to Article 95 of Namibia’s Constitution it states that , the S tate shall actively promote and maintain the welfare of the people by adopting policies aimed at the maintenan ce of ecosystems, essential ecological processes and biological diversity of Namibia and utilization of living natural resources in a sustainable way for the benefit of all Namibians, both present and future. This article recommends that a relatively high level of environmental protection is called for in respect of pollution control and waste management.

6 3.2 ENVIRONMENTAL AS SESSMENT POLICY (199 4) The environmental assessment policy details the principles of achieving and maintaining sustainable development that support all policies, programmes and projects undertaken in Namibia. This is related in particular, to the wise utilization of the country’s natural resources, together with the responsible management of the biophysical environment, which is intended to benefit both present and future generation. Additionally, t he policy provides guidance on undertaking the assessment procedures.

It further provides a guideline list of all activities requiring an impact assessment. The proposed development is listed a s a project requiring an impact assessment since it is under mining activities.

Furthermore , the policy requires that all programmes and projects listed in the Policy, whether they are initiated by the government or private sector should be subject to an Environmental Assessment (EA). The government recognises that E nvironmental As sessments are key tools to further the implementation of a sound environmental policy which strives to a chieve sustainable development. The rationale of the policy is seen as informing decision makers and promoting accountability, ensuring that alternatives and environmental costs and benefits are considered, promoting the user (polluter) pays principle, and promoting sustainable development.

Apart fro m the requirements of the Draft Environmental Assessment Policy, the following sustainability principles need to be taken into consideration, particularly to achieve proper waste management and pollution control:

3.2.1 CRADLE TO GRAV E RESPONSIBILITY This principle states that those who manufacture potentially harmful products should be liable for their safe production, use and disposal and those who initiate potentially polluting activities should be legally responsible for their commissioning, operation and decommissioning.

7 3.2.2 PRECAUTIONARY PRINCIPLE This principle states that At its if there is any doubt about the effects of a potentially polluting activity, a cautious approach should be adopted.

3.2.3 THE POLLUTER P AYS PRINCIPLE A person who generat es waste or causes pollution should, in theory, pay the full costs of its treatment or of the harm, which it causes to the environment.

3.2.4 PUBLIC PARTICI PATION AND ACCESS TO INFORMATION In the context of environmental management, citizens should have ac cess to information and the right to participate in decisions making.

3.4 ENVIRONMENTAL MA NAGEMENT ACT OF NAMI BIA (2007) The Environmental Management Act 3 in Section 1 defines environment as the complex of natural and anthropogenic factors and elements that are mutually interrelated and affect the ecological equilibrium and the quality of life, including – (a) the natural environment that is the land, water and air, all organic and inorganic material and all living organisms; and (b) the human environmen t that is the landscape and natural, cultural, historical, aesthetic, economic and social heritage and values. The Environmental Management Act, No.7 of 2007 part11 further provides the principals of environmental management: The following are the principl es of environmental management: -

(a) Renewable resources must be used on a sustainable basis for the benefit of present and future generations;

(b) Community involvement in natural resources management and the sharing of benefits arising from the use of the resources must be promoted and facilitated;

(c) The participation of all interested and affected parties must be promoted and decisions must take into account the interest, needs and values of interested and affected parties;

8 (d) Equitable access to en vironmental resources must be promoted and the functional integrity of ecological systems must be taken into account to ensure the sustainability of the systems and to prevent harmful effects;

(e) Assessments must be undertaken for activities which may hav e significant effects on the environment or the use of natural resources;

(f) Sustainable development must be promoted in all aspects relating to the environment;

(g) The option that provides the most benefit or causes the least damage to the environment as a whole, at a cost acceptable to society, in the long term as well as in the short term must be adopted to reduce the generation of waste and polluting substances at source;

(h) A person who causes damage to the environment must pay the costs associated with rehabilitation of damage to the environment and to human health caused by pollution, including costs for measures as are reasonably required to be implemented to prevent further environmental damage;

(l) Damage to the environment must be prevented an d activities which cause such damage must be reduced, limited or controlled .

Moreo ver ,the Environmental Management A ct No.7 of 2007 in part V111( 1) states that , a person who is required to obtain an environmental clearance certificate must, in the prescr ibed form and manner and on payment of the prescribed fee, apply to the relevant competent authority for an environmental clearance certificate in respect of the listed activity to be undertaken.

3.5 ENVIRONMENTAL MA NAGEMENT ACT REGULAT IONS (2012) The Envi ronmental Management Act Regulations have been finalised (February 2012) and have been used as guidance in the compilation of this report. Namibia’s Environmental Assessment Policy was the first formal effort in the country to regulate the application of Environmental Impact A ssessment. The regulation set out the process to be followed

9 during the compilation of EIA reports as well as the minimum requirements for such reports.

3. 6 INTERNATIONAL CONVEN TIONS AND PROTOCOLS - RELATED TO THE PROJE CT There are va rious international conventions and protocols which relate to the project and these include the following:

 Vienna Convention for the protection of the Ozone layer, 1985  United Nations Framework Convention on Climate Change (UNFCCC) 1992  Kyoto Protocol, 1997  Convention on Biodiversity, 1992  African Convention on the Conservation of Nature and Natural Resources 1968

4. ROLES AND RESPONS IBILITIES This section describes the roles and responsibilities of the key stakeholders involved in the development, imple mentation and review of the EMP. The contractor in this report refers to : Pure Tantalum (Pty) Ltd and its appointed contractors.

4.1 COMPETENT AUTHOR ITY The Ministry of Mines and Energy is the competent authority however the Department of Environmental Affairs: Ministry of Environment and Tourism is responsible for the review of the EMP documents.

4.2 PURE TANTALUM (PTY) LTD The role of the contractor is as follows:

 Pure Tantalum (PTY) LTD as it is the contractor should delegate suitably qualified person(s) with the responsibility to ensure implementation of the EMP, and will:  Know the contents and implications of the EIA and monitor the implementation of EIA findings using the EMP  Revise the EMP as required and inform the relevant parties of the c hanges.  Protect the environment and rehabilitate the environment as prescribed in the EIA.

10  Give warnings and impose fines and penalties on the Contractor if the Contractor neglects to implement the EMP satisfactorily.

4.3 PURE TANTALUM (PTY) LTD ( PROJECT M ANAGER)  Pure Tantalum (PTY) LTD should appoint a project manager . The role of the project manager will be:  Liaising directly with the relevant authorities with respect to the preparation and implementation of the EMP and meeting the conditions documented in the environmental clearance certificate.  Bear the overall responsibility for managing the project contra ctors and ensuring that the environmental management requirements are met.  Inform the contractors of the EMP and Environmental clearance certificate obligations.  Approve all decisions regarding environmental procedures and protocols that must be followed.  Have the authority to stop any construction in contravention with the EMP.  In consultation with the Environmental Control Officer (ECO) has the authority to issue fines for transgressions of basic conduct rules and/or contravention of the EMP.  Maintain open and direct lines of communication b etween the proponent and Interested and Affec ted Parties (I&APs) with regard to environmental matters.  Attend regular site meetings and inspections where required .

4.4 PURE TANTALUM (PTY) LTD (ENVIRONMENTAL OFFIC ER) An Environmenta l Officer should be empl oyed by Pure Tantalum (PTY) LTD . A person appointed should be available for the duration of the exploration activities and should have appropriate training and experience in the implementation of the EMP and overseeing construction and operation process es. The Environmental Officer will implement EMP at all levels and sections (sub - contractors ).The responsibilities of the Environmental Officer include the following:

11  Assist the Project Manager and Contractor in finding environmentally responsible solutions to challenges that may arise.  Conduct environmental monitoring as per EMP requirements.  Monitor performance of the cont ractors and ensure compliance with the EMP.  Maintenance, update and review of the EMP.  Liaison between the contractor , authorities and other key stakeholders on all environmental concerns.  Compiling monthly and quarterly site inspection reports  Conducting environmental incidents investigation as well as coming up with corrective and preventative actions.  Iss uing site instructions to sub - contractors and employees.  Communicate all amendments of the EMP to the relevant stakeholders.  Waste Management  Conduct monthly audits to ensure that the system for implementing the EMP is effective.

4.5. SAFETY OFFICER The following responsibilities are to be done by the safety officer:

 Ensure that safety is practiced for all activities on site.  Prepare and implement safe ty procedures  Communicate all safety related issues.  Carryout any incident/accident investigations at the site  Conduct Trainings  Recording accidents and incidents at the site  Issuing PPE to employees  Carry out Safety Health and Environmental awareness inductions ,the following topics, at least but not limited to, should be covered,(the importance of complying with the relevant Namibian and International legislation, roles and responsibilities includin g emergency preparedness, basic rules of conduct Do’s and Don’ts).

12 5 .ENVIRONMENTAL MAN AGEMENT PLAN The contractor in this report refers to Pure Tantalum (PTY) LTD . Before commencement of any work , the Contractor shall brief his or her staff on the content of the EMP and the EIA. The Contractor has the responsibility for implementing the EMP and ensuring their staff complies with the guidelines. Daily audits must be carried out; and corrective acti on implemented when needed. Pure Tantalum (PTY) LTD and its management should promote the implementation of this EMP.

5.1 PROTECTION OF FL ORA, FAUNA AND NATUR AL FEATURES The Contractor is responsible for ensuring that the impacts on the environmen t around the exploration area is minimised. The Contractor shall not deface, damage or mark any natural features (e.g. endangered plant species) situated in or around the proposed site. Land disturbance should be minimised. No flora shall be removed, damaged or dis turbed outside the designated working areas. Removal, damage or disturbance to flora in the designated working areas is to be minimised. Sensitive, protected and endangered plant species are to be avoided during the removal of vegetation.

Washing of vehicl es, machinery, clothes or any hydrocarbon polluted items within 20m of any surface water body is strictly prohibited.

In order to protect the environment and achieve sustainable development of the environment, it is necessary to incorporate sound environmental management objectives and targets for the designated mining claims for tantalite and quartz . According to the Namibian legislation, all projects, plans, programmes and policies deemed to have adverse impacts on the environment require an EIA.

5.2 ACCESS ROUTES Existing roads and tracks should be use to the site. Uncontrolled driving should not be permitted.

13 5.3 SITE MANAGEMENT The staff should be educated and informed of their environmental obligations. Meaningful penalties for damages shoul d be stipulated, and the main contractor should be held responsible for all transgressions. Areas outside this designated working zone shall be considered “no go” areas. The contractor should carry out air and noise pollution control checks to be aware of the level of dust and noise emitted respectively.

5.4 STAFF MANAGEMENT The Contractor must ensure that their employees have suitable personal protective equipment, are properly trained and that a fire fighting and a first aid officer is onsite .

5.5 WASTE MANAGEMENT The developer shall remove all waste off - site to designated licensed disposal site. The Contractor must provide sufficient bins or containers on - site to store any solid or liquid waste produced. The bins and containers should be weat herproof and scavenger - proof.

5.6 MANAGEMENT PRINC IPLES These guideline principles will form the basis for environmental management on site. Should these principles require modification or additions during the activities this should be done at the discreti on of the responsible person, who will ensure that any modifications are communicated, explained to and discussed with all affected parties (i.e. the authorities, proponent, service providers and any affected parties who requests this information).

14 6. MANAGEMENT OF ENV IRONMENTAL ASPECTS This section details mitigation measures proposed for the exploration project

1 . HABITAT DESTRUCTIO N

Impacts Description Mitigation Monitoring Responsibility Measures Habitat Habitat destruction will differ Limit the exploration  Inspection. Pure Tantalum company destruction depending on the scale and activities to the site and appointed intensity of the exploration Use the existing roads and Environmental Officer activities. tracks to minimize the habitat destruction on other areas

2. BIODIVERSITY LOSS

Impacts Description Mitigation Monitoring Responsibility Measures Biodiversity Biodiversity loss is likely to be  Limit the operation to  Making sure Pure Tantalum company loss experienced during the drilling the specific site the cappin g and appointed stages. The natural movement of  Exploration teams need or plugging Environmental Officer animals in the areas can be to be trained and of drill holes disturbed as a result of the drilling provided orientation on to prevent activities. However, it is vital to how to best access sites small note that the impact will be of low for exploration with least mammals significance given that only impact on the from existing secondary roads are going observable and hidden becoming to be used. Moreover, there wi ll signs of fauna and flora trapped be no actual construction of and their habitats. buildings, only temporary  Avoid placing ac cess structures will be used hence routes through sensitive reducing biodiversity loss. Ground areas if there is any and disturbance will occur and will stick to old/ permanent result in any flora found on that roads or tracks.

16 specific area causing vegetation  Stick to speed limits loss and loss of biodiversity  Fence off all the Welwitschia's in the EPL to avoid destruction during exploration activities.  Avoid introducing ornamental plants , esp ecially potential alien species as part of the landscape of the camp site , but rather use localized indigenous species , should landscaping be attempted , which would also require less maintenance  No killing or capturing of

17 animals and littering  Rehabilit ation of sites that have been explored must be restored, as far as is possible to their prior state so as to mitigate the visual impact and to allow for the best possible re - colonization of the site, by lichens, plants and animals.

18 3 . RISK OF OCCUPATION AL HEALTH AND SAFETY

Impacts Description Mitigation Monitoring Responsibility Measures Risk of During exploration  Provide all staff on site with protective Regular site Pure Tantalum OHS activities employees equipment (helmets, glove s, respirators, inspection; company and might face OHS problems overalls, earplugs, goggles and safety shoes Conducting Appointed HSEO such as dust, noise and where applicable). Hazard and Risk stress. However if  Train workers how to use adequately the Identification mitigation measures are equipment implemented zero  Signage for personal protective equipment accident at work will be (e.g. protective clothing like safety boots and achieved hard hats)  Trainings on occupational health and safety  Safety talks to be done every day before commencement of work  Regular (once a year) medical check - ups  First Aid kits to be available at the site

19 4 . GROUND WATER CONTA MINATION

Impacts Description Mitigation Monitoring Responsibility Measures Water Typically, the following pollution  Proper toilet facilities Regular Pure Tantalum contamination sources will exist: human waste, dirty  Waste should be dumped at inspection c ompany , water and erosion from exposed designated areas. Site manager , soils in the form of suspended solids.  No burial of any waste or Contractors and The impact is likely to have low burning should be done on site Appointed HSEO significance given that the since all waste must be exploration activities will be done at disposed on approved disposal a small scale, no chemicals will be sites. used. Oils might be expected from  No littering on site frequenting vehicles and machinery  Usage of drip trays to prevent on site. spillage of oil and lubricants which can affect the soil and water and ground water pollution.

20 5 . DUST

Impacts Description Mitigation Monitoring Responsibility Measures Dust During exploration activities like  Pe rsonnel are required to Regular Pure Tantalum drilling and cutting of cores will wear personal protection visual company , be done which have an impact equipment if excessive dust is inspection Site manager of generating dust. Dust created for prolonged working , Contractors generated might affect workers.. periods And Appointed Even though, the intensity will  Soil watering when soil works HSEO be low, mitigation measures are being executed and where should be implemented dust is emitted especially to wor kers because  Use of dust suppression they will be the ones mostly at method risk.. The dust particles may  Workers at the site should be penetrate the human body and provided with respirators can cause respiratory tract  As per World Health irritation, illness (such as asthma Organisation (WHO) the dust attack, cough, and bronchitis) particulate matter should be and eczema if they are expose in the range of 150 - 230 µg/m 3

21 to high amounts of dust on an annual average and 60 - 90 µg/m 3 on a 24 - hours average

22 6 . NOISE

Impacts Description Mitigation Monitoring Responsibility Measures Noise Potential noise sources during the  Employees to be equipped with ear Regular Pure Tantalum pollution exploration of EPL7004 could originate protection equipment. tests of company , site from vehicles, machinery, hammers,  Regular servicing of the vehicles and noise Manager and excavators and drill rigs . Earthmoving machines Appointed HSEO equipment will be utilized from time to  Noise levels to be checked time during the exploration activities  Noise levels should not equal or and noise might be generated. exceed 85dBA for workers working However, it is vital to point out that an 8 hour shift ( according to ISO low levels of noise are expected 18000 ) because the operations will be done at  Employer shall provide audiometry a small scal e. Noise generated is and dosimeters to all employees expected to be found within the whose exposures equal or exceeds immediate area of the activity hence 85dBA as an 8 hour TWA workers are the ones who might be at risk. According to ISO 18001 standards, workers are not allowed to work under

23 noise levels that are equal or exceed 85 decibels per 8 hours.

24 7 . GENERATION OF WASTE

Impacts Description Mitigation Monitoring Responsibility Measures Generation Since there will be a temporary  Regular inspection of the site Regular site Pure Tantalum of waste camp site for the workers, there  Waste di sposal systems should inspection on company will be domestic waste such be implemented on site for housekeeping rubbish, and human waste both hazardous waste such as produced on site and. Hazardous oil and fuel and domestic waste waste in the form of oils and such as paper and plastic lubricants might be produced  Use oil tray to contain the from vehicles and other spillage in machineries machineries.. As per the Dorob  Strictly, no burning of waste on National Park rules, no waste the site or at the disposal site should be disposed of in the park ,a s it possess environmental where the epl area falls. and public health impacts  Dust bins should be on site  Contaminated wastes in the form of soil, litter, and other material must be disposed at

25 an appropriate disposal site at the nearest town.

26 8. VISUAL IMPACT

Impacts Description Mitigation Monitoring Responsibility Measures V isual Changes to the aesthetic appeal Minimize excess pathways and roads . Regular site Pure Tantalum impact of the overall area since there E xisting roads and tracks should be inspection; company and

will be machinery, vehicles and used . site Manager people around the area. Minimize the footprint of personnel, vehicles and machinery . Removal all waste on a daily basis and dispose of it in the appropriate manner . Removal of machinery from the exploration sites if periods of inactivity are extended .

Minimize the presence of secondary structure: remove inoperative support structure .

Remove all the infrastructure and reclaim or rehabilitate the project site after exploitation activities

9 . HERITAGE IMPACT

Impacts Description Mitigation Monitoring Responsibility Measures Heritage There are no known heritage During exploration activities  Inspection. Pure Tantalum company impact areas or artifacts deemed to be if any archaeological and Appointed impacted during exploration. Environmental officer . features or objects (e.g. Pottery, bones, shells, ancient clothing or weapons, a ncient cutlery, graves etc) that possess cultural values are found, it should be barricaded off and the Namibian Heritage Council (NHC) should be contacted immediately.

28 10 . GEOLOGICAL HAZARDS

Impacts Description Mitigation Monitoring Responsibility Measures Geological Mining activities normally upset  Reinforcement of pit  Inspection. Pure Tantalum company , hazards the equilibrium in the geological walls should be done to  Insert fixed site Manager and environment, which may trigger guard against landslides control points Appointed HSEO off certain geological hazards and rock fall. to monitor such as landslide, subsidence,  In a case where the size ground erosion and tremors together of the pits increases movement with their secondary effects. measures such as before During the project, the terracing of the pit walls landslides likelihood of geological hazards can be employed so as to happen. happening is expected to be guard against landslides probable thus if mitigation and rock falls. measures are not implemented.

29 11. ILLEGAL HARVESTING / POACHING

Impacts Description Mitigation Monitoring Responsibility Measures Illegal The Exploration project is under  Illegal harvesting and  Inspection. Pure Tantalum company harvesting / the national park, therefore an poaching is prohibited. . and site Manager Thorough security poaching issue of protected area is a around the exploration source of concern. Exploration site is required and project in a National can result people mus t be encourage to take pride into illegal harvesting / poaching in their surrounding therefore mitigation measures natural heritage, rather should be effectively than to illegally exploit it.

implemented .

30 1 2 . RISK OF HIV AND AIDS

Impacts Description Mitigation Monitoring Responsibility Measures RISK OF The probability of HIV/AIDS  Allocate time for workers  Inspection. Pure Tantalum company HIV AND spreading will be high and it to visit their families  Sensitization and Site Manager  Sensitization campaign AIDS can spread beyond the campaign to the staff on HIV/AIDS project boundary thus if and other STDs mitigation measures are not  Free distribution of condoms on site, implemented .  Free testing

 Free counselling to those already affected by the virus

31 13. SAFETY AND SECURITY

Impacts Description Mitigation Monitoring Responsibility Measures Safety and Generally projects attract  No unauthorized people  Inspection. Pure Tantalum company, security different people from around the mining area. . Site Manager and  Employees should be different locations. Some A ppointed HSEO . sensitized through people can end up stealing, educational practicing anti - social campaigns/workshops on the repercussions of behaviors like prostitution, such behaviors. alcohol and drug abuse .  Safeguard against the development of illegal settlements around the mini ng area  Use of alcohol detectors

32 14 . EMPLOYMENT CREATION

Impacts Description Enhancement Required Responsibility

Employment It is definite that jobs will  When recruiting, the responsible Pure Tantalum company and creation be created. The type of contractor is to ensure gender appointed Human Resource jobs will range from skilled, equality Department semi - skilled and unskilled.  Implementation of training programs so as to train the unskilled workers in order for them to enhance their perfo rmances and to gain more knowledge that they might demonstrate at other levels in future.

33 15 . REVENUE GENERATION

Impacts Description Enhancement Required Responsibility

Revenue According to the law of  Continuous payment of taxes Pure Tantalum company and Generation Namibia, operating due as regulated in the appointed Human Resource companies are to pay Department taxes. The proponent will Namibian laws definitely pay tax to the government hence this will benefit the nation at large given that money generated from taxes is diverted to the public by the gov ernment. .

34 7. DECOMMISSIONING AND SITE CLOSURE If the project proponent intends to decommission the project when it becomes unprofitable or because of depletion of resources in the area, a decommissioning and rehabilitation plan will have to be drafted and followed. All steps for decommission and rehabilitation will be taken to ensure th at the application of the best environmental management practices are adhering to legal and policy legislations

These progressions shall follow an appropriate decommissioning plan prepared by an appointed Environmental Consultant that will work in the best environmental practices as proved by the Ministry of Environment and the Ministry of Mines and Energy taking into considerations the principle of sustainable development principles. The anticipated impacts of a standard and provisional decommissioning pla n will only be highlighted in the Environmental decommissioning plan, taking into consideration biophysical, economic, social and political issues related to project decommissioning, thus a decommissioning environmental audit and management plan will have to be undertaken before the project is completely decommissioned to ensure sustainability and rehabilitation.

8. ENVIRONMENTAL MONITORING An environmental monitoring plan provides a delivery mechanism to address the adverse environmental impacts of a proj ect during its lifespan and to introduce standards of good practice to be adopted. An environmental monitoring plan is important as it provides useful information and helps to assist in detecting the development of any unwanted environmental situation, and thus, provides opportunities for adopting appropriate control measures.

Important parameters that are sensitive include habitat destruction , occupational health an d safety, , Geological hazards , dust and generation of wastes. The suggested monitoring details are outlined in the following sections.

IMPACT RECEPTORS TYPE OF FREQUENCY MONITORING G eological Land  Inspections  Every day hazards  Insert fixed control  Regularly as points for monitor required Risk of O .H.S Employees  Site inspection  Daily  Conducting Hazard and Risk Assessments  Safety procedures evaluation.  Health and safety incident monitoring Habitat Environment.  Site i nspection  Daily destruction Generation of Land  Site inspection on  Daily waste (solid) housekeeping  Regular collection of waste

Dust Employees,  Visual inspection  Daily Atmosphere

36 CONCLUSIONS The above Environmental Management Plan, if properly implemented, will help to minimise adverse impacts on the environment. Where impacts occur, immediate action must be taken to reduce the escalation of effects associated with these impacts.

The Environm ental Management Plan should be used as an on - site reference document during all phases of the proposed project , and auditing should take place in order to determine compliance with the EMP for the proposed site. Parties responsible for transgression of t he EMP should be held responsible for any rehabilitation that may need to be undertaken.

Nam Geo - Enviro solutions

September 2019

References

Anon. 2015b. Tourism Development Plan for the Dorob National Park (V1) 2015. NACOMA. Curtis, B & Mannheimer, C. 2005. Tree Atlas of Namibia. National Botanical Research Institute, Windhoek.674 pages DEAT (2006) Guideline 4: Public Participation in support of the Environmental Impact Assessment Regulations, 2006. Integrated Environmental Management Gui deline Series, Department of Environmental Affairs and Tourism (DEAT), Pretoria. DEAT (2006) Guideline 5: Assessment of Alternatives and Impacts in support of the Environmental Impact Assessment Regulations, (2006). Integrated Environmental Management Guid eline Series, Department of Environmental Affairs and Tourism (DEAT), Pretoria. DEAT (2006) Guideline 5: Assessment of Alternatives and Impacts in support of the Environmental Impact Assessment Regulations, (2006). Integrated Environmental Management Guide line Series, Department of Environmental Affairs and Tourism (DEAT), Pretoria. Government of Namibia. (2008). Government Gazette of the Republic of Namibia. Government notice No.1: Regulations for Strategic Environmental Assessment (SEA) and Environmental Impact Assessment (EIA) - Windhoek Government of Namibia. (2012). Environmental Management Act no. 7 of 2007 . Windhoek: Directorate of Environmental Affairs, Ministry of Environment and Tourism http://www.met.gov.na/national - parks/dorob - national - park/216/ ht tp://www.nacso.org.na/national - parks/dorob - national - park IFC.2007. Stakeholder Engagement: A good practice handbook for companies doing business in emerging markets. IFC, Washington D.C Mannheimer, C . (2015).Lofdal Specialist Baseline Vegetation Study. Doc . No. 1505e Mendelsohn J., Jarvis A., Roberts C. and Roberts T . (2002). Atlas of Namibia: A portrait of the land and its people. Tien Wah Press, Singapore Mines and Energy, Windhoek, Republic of Namibia.

38 MME (2010). Strategic Environmental Assessment for t he central Namib Uranium Rush. Ministry of Namibia Statistics Agency (NSA) Annual Report 2012 Namibia Statistics Agency (NSA) Annual Report 2014 The chamber of mines of Namibia.2007. Annual Review. Accessed on the 30/07/2018 from http://www.chamberofmines.org.na/files/9015/2458/3445/COM__2017_AR_Web.pdf Risk Based Solutions cc (2008). Case Investments (PTY)LTD - EPL No.4076