final scoping report - groot...

Environmental Impact Scoping Report: Construction and Operation of the Proposed Silica Sand Processing

Plant in Eeshoke of Oshikango, Helao Nafidi Town, Ohangwena Region by Groot Silica (Pty) Ltd

Proposed Silica Sand Processing Plant EIA Scoping/ EMP Report 002/2016 Groot Environmental Engineers (Pty) Ltd

November 2016

Final Scoping Report for the Environmental Impact

Assessment and Environmental Management Plan for

Groot Silica Sand Mining and the Construction of a Silica

Sand Processing Plant in Eeshoke Village, Oshikango of

the Ohangwena Region

Final Scoping Report

January 2017

Environmental Impact Scoping Report: Construction and Operation of the Proposed Silica Sand Processing Plant in

Eeshoke of Oshikango, Helao Nafidi Town, Ohangwena Region by Groot Silica (Pty) Ltd


November 2016 of 118

Final Scoping Report for the Environmental Impact Assessment and

Environmental Management Plan for Construction and Operation of the

Proposed Silica Sand Processing Plant in Eeshoke Village, Oshikango of

Helao Nafidi Town, Ohangwena Region

Prepared for:

Groot Silica (Pty) Ltd

P.O. Box 3891

Ongwediva, Namibia

Prepared by:

Groot Environmental Engineers (Pty) Ltd

P.O. Box 3891

Ongwediva, Namibia

Report Purpose: Environmental Authorisation

Email: [email protected] Website: www.grootgroup.com/grootees

Authors:

Martha L. Hangula Luckson Zvobgo

mailto:[email protected]

http://www.grootgroup.com/grootees





DECLARATION

we hereby declare that we do:

(a) have knowledge of and experience in conducting specialist

assessments, including knowledge of the Environmental Management

Act (Act 7 of 2007) and the Regulations and Guidelines that have

relevance to the proposed activity;

(b) perform the work relating to the application in an objective manner, even

if this results in views and findings that are not favourable to the

applicant;

(c) comply with the abovementioned Act, its Regulations, Guidelines and

other applicable laws.

I also declare that there is, to my knowledge, no information in my possession

that reasonably has or may have the potential of influencing –

(i) any decision to be taken with respect to the application in terms of the

Act and its Regulations; or

(ii) the objectivity of this report, plan or document prepared in terms of the

Act and its Regulations.

Groot Environmental Engineers (Pty) Ltd

Specialist





EXECUTIVE SUMMARY

Introduction

Context and Background of the Proposed Project

Groot Silica Mining (Pty) Ltd proposes the development of a Silica sand mining

and construction of a processing factory in Eeshoke Village of Oshikango,

Ohangwena Region of Namibia. The size of the study area is 14ha (fourteen

hectares). The proposed development is located near the borders of Angola and

Eeshoke Village but it is in Eeshoke Village (Refer to Figure 1) in Oshikango District

under the Oukwanyama Traditional Authority in the Ohangwena Constituency of

Ohangwena Region. The area is in the east of Oshikango, 2 km away from the town.

The project is established to explore and mine silica sand and process associated

products on an exclusive 15-year renewable contract for the Tses Glass

Manufacturing Factories in Tses, Namibia. Groot Silica Mining Company wants to

transform Namibia into a self-reliant and enterprising nation in manufacturing and

industrial products and contribute to the realization of the fundamental aim and

aspiration of Vision 2030. This is the first processing plant of silica sand

manufacturing plant of such size to be set up in Namibia. Groot‟s Silica sand

manufacturing plant, set to produce 1.5 million tons per year of high quality silica

sand as a strong industrial support arm for Tses Glass and Export market. Sixty

percent of raw materials to be used in glass manufacturing in Tses will be from the

Groot Silica Processing Factory.

Proposed construction and operation of the Silica Sand Processing Plant fall under

the section 27 of the Environmental Management Act, 2007 (Act No. 7 of 2007) of

the activities that may not be undertaken without Environmental Clearance

Certification. To ensure compliance with the EIA regulations (GN 30, 6 February

2012) made under section 27 of the Environmental Management Act - EMA (Act No.

7 of 2007) and environmental best practice, Groot Silica (Pty) Ltd must conduct the

EIA Scoping and preparation of the EMP for it to obtain Environmental

Authorisation/Clearance Certificate for the proposed project.In light of the above

Groot Environmental Engineers (GEE) conducted the environmental scoping

assessment and the sound EMP to be adhered to and implemented by Groot Silica

for the effective management of the Environment.





Regulatory Environmental Requirements

The Ministry of Environment and Tourism, Department of Environmental Affairs

(MET:DEA), is the lead authority carrying out the authorisation process in

accordance with the Environmental Management Act (Act No. 7 of 2007, “EMA”).

The EIA Regulations under the EMA consist of two categories of activities namely:

Schedules 1 and 2 Activities which require a Basic Assessment Process, and

Schedule 2 Activities (GNR. 545 of 2010) which require both a Scoping and an EIA

Report for authorisation.

The activities associated with the proposed project fall within GNR. 544 and GNR

545 and as such have been assessed under the Scoping and EIA process.

Purpose of this Report

The purpose of this EIA is to identify all environmental aspects and impact

associated with the Silica Processing Plant. This will effectively enable the following:

Assessment of the state of the environment and establishment of

environmental issues and factors associated with the proposed plant project.

Assessment and prediction of all potential impacts of the project on

components of the environment in terms of magnitude and importance

Evaluation of alternatives and identification of the best options that is both

cost effective and with least potential environmental impact.

Incorporation of EIA recommendations into the project detailed design as well

as other stages of the project.

In line with the requirement of the NEMA EIA regulations of 2012, this EIA report

provides a detailed description of the pre-development environment, specifically in

terms of the biophysical and socio-economic environment of the study area.

Furthermore, the report provides a comprehensive description of activities as well as

numerous specialist studies undertaken for the EIA phase and public participation

process (PPP), as well as the way forward in the form of conclusions,

recommendations and the draft of environmental management plan.

The EIA process comprised of a number of key steps, these are described below:





Application Phase – identify listed activities that are triggered by the Project and

submit an application for Environmental Authorisation (EA) to the competent

authority.

Scoping Phase - identify interactions of project activities and environmental and

social resources to determine which should be included in the scope of the impact

assessment.

Specialist Studies – undertake specialist studies.

Environmental Impact Reporting Phase - the characteristics of the potential

effects of project activities on bio-physical and social resources and features are

evaluated and quantified to determine potential impact significance (or importance)

taking into account the sensitivity of the particular resource or receptor. This phase

also includes the identification of mitigation/management measures and the

development of an Environmental Management Programme.

Competent Authority Decision – the regulator‟s (Ministry of Environment and Tourism)

Project overview

The project is established to explore and mine Silica sand products on an exclusive

15-year renewable contract for the Tses Glass Manufacturing Factories in Tses,

Namibia. Groot Silica Mining Company wants to transform Namibia into a self-reliant

and enterprising nation in manufacturing and industrial products and contribute to the

realization of the fundamental aim and aspiration of Vision 2030. The Silica Sand

produced will be used as the primary raw material in the manufacturing of container

glass, float glass, insulation, and textile fiber glass as one of the primary ingredients.

The product can also be used for landscaping, foundry casting molds/cores, golf

bunkers and topdressing industry as well as other products like fillers and extenders,

used as raw materials in production of ceramic and equestrian surfaces. The

development of Groot Silica Mining by the proponent is creating more than 1,500

new direct employment opportunities locally. This is the first kind of silica sand

mining in Namibia that will further attract foreign investors. The proposed

development will significantly contribute to the GDP of Namibia. To supply and





export the surplus to other industries; locally, regionally, and internationally.

Use of Silica Sand

One of the primary ingredients for the container glass, float glass, insulation,

textile fiber glass, and all other related glass manufacturing.

Used for landscaping, foundry casting molds/cores, golf bunkers and

topdressing industry as well as other products as fillers and extenders.

Also used for sand blasting, adding texture to slick roads.

As a raw material in the production of ceramics and equestrian surfaces.

Project Developer

The applicant for the Environmental Clearance Certificate (ECC) is Groot Silica (Pty)

Ltd, a member of Groot Systems.Groot Systems is a collection of companies

involved in various advanced industrial ecosystem development activities such as

manufacturing, transport and logistics, commercial and residential properties,

fertilizers, and industrial food products. Other Groot Systems projects lined up for the

developments include Tses Glass, Groot Steel, Groot Chemicals, Westerville

Township, Groot Solar Energy, and Groot Foods. It is one of Namibia‟s upcoming-

diversified interlinked industrial ecosystem business conglomerates. Groot Systems

as a leading Infrastructure Company, it is focusing on developing self-sustained

advanced industrial ecosystems for the slow growing economies.

Table: Details of the project applicant

Applicant : Groot Silica Mining (Pty) Ltd

Representative Simon Kapenda

(Director and Founder) Groot Silica Mining

Physical Address 5564 Elyambala Street

Ongwediva

Namibia

Postal Address P.O. Box 3891

Ongwediva

Namibia

Cell Number +264-81-250-9027





Company Reg. no: 2016/0399

Email Address [email protected]

Website http//www.grootgroup.com

Environmental Assessment Practitioner (EAP)

Groot Environmental Engineers (Pty) Ltd (hereafter referred to as GEE) the

Environmental Assessment Practitioner (EAP) undertook the Scoping Report,

Environmental Impact Assessment (EIA) and Environmental Management Plan

(EMP) for the Construction and Operation of the Tses Glass Factories Development

in accordance with the requirements of the Environmental Management Act (Act

No. 7of 2007). GEE is a member of and a wholly owned subsidiary of Groot

Management Systems (Pty) Ltd.





Terms of Reference

This report presents the Environmental Impact Assessment (EIA) for the construction

and operation of the proposed Silica Sand Processing Plant by Groot Silica (Pty) Ltd.

Groot Environmental Engineers undertook the EIA for the proposed development.

Silica Sand Processing Plant fall under the section 27 of the Environmental

Management Act, 2007 (Act No. 7 of 2007) of the activities that may not be

undertaken without environmental clearance certificate. Therefore application was

subjected to a scoping and environmental impact assessment process as stipulated

in the EIA Regulations (GN 30 in GG 4878 of 6 February 2012) made by the

Environmental Commissioner under Section 27 (3) of the Environmental

Management Act No.7 of 2007.

In accordance with the Ministry of Environment and Tourism Department of

Environmental Affairs (MET:DEA) EIA Procedural Guidelines of 2012, the Project

Proposal and Terms of Reference (ToR) were submitted to the Ministry of

Environment through a letter referenced GEE/EIA/01 dated 26th of May 2016. MET:

DEA, as sited in Section 12 (1) of the EMA, 2007 and evaluated the ToR and

conveyed its approval of the ToR through a letter referenced on the 06th of June

2016 as regulated in the section 12(1) c(i)

The use of an EIA as a management tool in this project would ensure that Groot

Silica (Pty) Ltd complies with local, national, regional, and international

environmental laws, standard design codes, promote consultation, and reduce future

liabilities, so helping to protect the environment. The Terms of Reference for the

project activities is based on the requirements set out by the Environmental

Management Act, 2007 (Act No. 7 of 2007) Section 9(a), 9(b), 9(c) and 9(d) and its

Regulations (February 2012). The process covered the following steps, which are

reported on in this document as follows:

• Provides the introduction of the project(Section 1);

• Provide a detailed description of the proposed activities(Section 2);

• Identify all policy, legislation and guidelines that have reference to the

proposed project (Section 3);

• A summary of the needs and desirability of the project to the Community,

Region and Namibia (Section 4);





• Identify existing environmental (both bio-physical and socio-economic)

conditions of the area in order to determine their environmental

sensitivities(Section 5);

• Process followed to reach the alternative including the public input (from

Interested and Affected Parties (I&APs) and relevant authorities) and provide

them with a reasonable opportunity to participate during the process (Section

6);

• Consider the potential environmental and social impacts of the proposed

project development, and assess the significance of the identified impacts

(Section 7);

• Outline management and mitigation measures in an Environmental

Management Plan (EMP) that shall translate potential impact prevention and

mitigative measures into control measures (Section 8);

Sustainability Policy of Groot Silica

Groot Silica pledges to put in place a policy that will ensure the following:

Preserve the health, safety and security of all company and contractor

personnel and members of the public;

Preserve the integrity and security of company assets;

Minimize the impact of operations on the environment, and

Is sensitive to the needs and concerns of the host communities

Implications of implementing this policy are that:

All activities shall be analysed to systematically identify related hazards, risks

and sensitivities;

Arrangements shall be put in place to control the hazards, risks and

sensitivities and to deal with consequences should they arise; any activity

which is unhealthy, unsafe, environmentally unsound or may adversely

impact relations with the community, shall be suspended until an acceptable

solution is found; all personnel, including those of contractors, shall be trained

and made fully aware of the hazards,risks, sensitivities and controls in place;

plans and procedures shall be in place to respond to any emergency or loss

of control. Employees and contractors must plan and perform his work in

accordance with this policy. Each employee is required to report,and where





necessary, suspend any activity, which he considers is a contravention of this

policy.

A detailed health risk assessment was done on each stage and section of the

production factory and it has been attached as Appendix . The risk assessment has

been prepared based on WHO standards and local Namibian Health and Safety

Regulations GN 156/1997 (GG 1617) observing all sections of the law which details

various requirements regarding health and safety of labourers.

Environmental Impact Assessment

This is a systematic study of impacts of proposed project activities on the bio-

physical and the socio-economic components of the environment. Groot

Environmental Engineers (Pty) Ltd has undertaken this Environmental Impact

Assessment (EIA) study, to predict the impacts of the proposed development on the

environment and propose mitigation measures that will be incorporated into the

project environmental management plan. The EIA covers the project description,

baseline studies, consultation programmes, social and health impact assessment,

environmental quality assessment and impact quantification and an Environmental

Management Plan.

The EIA study will make an input into the conceptual design of the project, to ensure

that any identified adverse impacts are addressed at the early stage of the project

and mitigated during the activity stages, involving site preparation, construction of

the factories, operations and decommissioning.

Environmental Impact Identification and Assessment

The impact of the project activities was determined by identifying the environmental

aspects and then undertaking an environmental risk assessment to determine the

significant environmental aspects.

The environmental impact assessment has considered all phases of the project,

namely, construction phase, operational phase and the decommissioning phase. The

rating system used is applied to the potential impact on the receiving environment

and includes an objective evaluation of the mitigation of the impact.





During the EIA, the impact of the Silica Processing Plant on the biophysical and

socio-economic environments was assessed. From the assessment, it was

determined which parts of the three environments will be more significantly affected

as compared to others. It was this assessment that allowed the EAP to make an

informed analysis and provide an opinion of the proposed development.

EIA Methodology

In compliance with the Environmental Management Act No.7 of 2007 and the

Environmental Impact Assessment Regulations (GN 30 in GG 4878 of 6 February

2012), Silica Sand will be required to carry out and prepare an EIA and EMP to

address environmental, social and economic issues and concerns associated with

the proposed development in question. This process is going to be governed by the

Namibian Environmental Legislation as well as the EIA World Bank Standards

(2010).

The EIA study was undertaken in a holistic approach encompassing all different

aspects of the EIA process. The methodologies adopted for conducting this EIA are

as follows:

Desktop Research Desktop research was used to establish an environmental information database for

the EIA. Consulted materials include textbooks, articles, maps, internet,

photographs, GIS datasets, and past EIA reports and baseline report of the area

conducted between 2010 and 2016.

Scoping phase This was done to determine which studies to focus on the assessment as well as

impacts to be given much attention. The scoping procedure was as follows:

Identification of key assessments to be done based on project type and

scope;

Identify Interested and Affected Parties (I&APs);

Announcing the EIA process / registration of I&APs;

Distribution of the BID to I&APs and key Government Stakeholders;





Public and stakeholder consultation through the different media of communication, and public and focal meetings;

Consultation with Stakeholders

Experts in relevant fields, leaders of thought in environmental matters, Organs of the

State (Nampower, Namwater, Traditional Authorities, Regional Council's Offices)

Helao Nafidi Town Council, Regional Offices, local communities have been

consulted for their opinions on issues relating to the potential ecological and socio-

economic impacts of the proposed project. This provided an opportunity for

stakeholders and the public at large to engage in the process and to make

comments or express their concerns regarding the proposed project development.

This public participation process component is fundamental to the impact

assessment process and is an important informant to decision-making. An EMP, will

be developed that will address environmental management statements for all the

phases of the project, and this will form an integral part of the EIA.

Field Research

One-seasoned fieldwork activities have been carried prior to the EIA Scoping period

to verify and complement information gathered from desktop studies. The fieldwork

covered all relevant components of ecological, socio-economic and health

components of the environments.

Laboratory Analysis A Geo-technical survey was conducted by Namibian Civil Engineering Laboratory cc

where soil samples were collected during field sampling, analysed in the laboratory

by Namibian Civil Engineering Laboratory cc.

Draft Scoping Report A comprehensive draft scoping report was prepared after incooperated public

concerns and addressing issues raised during public participation. The draft scoping

report was made available to the public for commenting.

Impact Assessment and Evaluation





The assessment of all associated and potential impacts of the proposed project were

carried out using checklist method. Impacts evaluation was carried out using ISO

14001 approach. Impact assessment and evaluation formed that the part of the draft

scoping report. The assessment reviews all environmental, social and economic

aspects in relation to applicable policies and regulations.

Assessment of Impacts

Use an Impact Assessment matrix to establish the environmental risk of the

overall project, its alternatives and various components;

Establish mitigation protocols

Final Scoping Report and EMP The final report was prepared together with EMP after incorporating of the public

comments, and submitted to the MET. Therefore this report presents the final EIA

report and EMP for Silica Sand (Pty) Ltd proposed glass manufacturing factories

development.

Scope of work

Site preparations

A lot of excavations need to be done before any construction activity takes place due

to the land configuration, surface features and terrain. These excavations will ensure

minimum disturbance of the environment, noise impacts and dust.

Construction

Construction of the processing factories will be executed in accordance with a

standard planning framework that will be reviewed as it becomes expedient by

project team to ensure:

Maximum efficiency in construction;

Minimum adverse environmental and health impacts;

Earliest completion time;

Compliance with the laws of the land and all regulatory Namibian and

international requirements.





The construction phase will take 3-4 months and the commissioning of the factories

will take place 3 months after completing construction activities.

Monitoring and Operation during Construction

The factories‟ construction will be monitored with combined specialists team from

Groot Construction Company, and other many sub-contracted Experts, Groot

Environmental Engineers, monitoring will involve check wastes produced during the

construction activities is within the acceptable hazardous limits and is safely

disposed and to ensure minimum disturbance of the host environment.

Maintenance and Inspection

Regular surveillance of the factory construction phase will form an integral element

of the integrity monitoring system.

Wastes and Disposal Activities

Effective and responsible handling and disposal of wastes are key elements in

environmental management system. Wastes refer to any material (solid, liquid,

gaseous or mixture) that is surplus to requirements. Wastes generated shall be

segregated and disposed in accordance with the Namibian Waste Management

guidelines and the Environmental Management Act No. 7 of 2007 for waste

reduction, re-use and recycling as well as the Atmospheric Pollution Prevention

Ordinance 1976 Hazardous Substance Ordinance (No. 15 of 1973) and Regulations.

All the disposal of waste from the Silica Processing Plant construction and operation

activities must be disposed in accordance with these listed statutory Acts.

Commissioning and Decommissioning/Abandoned.

Upon completion of the construction of the factories, commissioning will follow. The

project will be commissioned 3-4 months after kick-off of project execution. The

factory is designed to last for a minimum of 15 years, upon which the factory

equipment can be replaced for another 15-year factory life cycle.

Existing Environment conditions

Relief/Topography





The site is low lying (a few meters above high tide level) and relatively flat. The site

is accessed by earth road. Vehicular access around the site could be poor

particularly during the rainy season due to compressible poor quality of surface soils.

At the time of the site investigation, the project site was seen to be a virgin land

covered by scattered Makalani Palms and thorny bushes. Topographically, the area

could generally be considered to be flat with no discernible cross fall. It is obvious

that no cuts will be made but substantial filling will have to be done.

Climate Average Rainfall:

Climatically, Ohangwena Region is semi-arid, and its natural environment has

generally arather low population carrying capacity.Oshikango climate is a grassland

climate with the average yearly rainfall of 588 mm. The driest month is June. There

is 0 mm of precipitation in June. Most of the precipitation here falls in February,

averaging 135 mm.

Temperature

Average daily temperatures vary between a minimum of 6° C in the coldest month

and a maximum of 36° C in the warmest month in the area (Mendelsohn et al. 2002).

Frost is rare.

Wind

This is not a very windy area but prevailing winds are mainly easterly and southerly

winds are prevalent, and are usually strongest during the rainy season (Mendelsohn

et al. 2002).

Soils Specifically, the site consists of dry through slightly moist to moist, very loose to

loose voided compressible silty fine sand. This represents Transported deposit of

recent age and it extends in excess of 3.0m below ground level. Generally, there is

uniformity horizontally and vertically across the site with regard to soil horizons.

Bedrock no rock was encountered across the site to a typical depth of 3.0m+ below

ground level.

Vegetation

The project site lies in the Oshana-Kalahari mosaic subsection of the Cuvelai as

described by Mendelsohn et al (2012). This zone carries many large, important fruit

trees, such as Bird plum, Jackal-berry, figs, Baobab, Manketti and Marula as well as





important wood and timber trees. Large specimens of Jackal-berry and Sycamore fig

occur on the banks of the deeper pools (ongombes).

Land use The surrounding area close to the site is home to local communal farmers. They are

the owners of the herds that feed on the vegetation which surrounds or are in the

proposed site. In a distance of not more than 1 kilometer, the new Open Market of

Oshikango can be seen currently undergoing construction while adjacent to the

newOpen Market there is a filling station fully operational.

Geology Available information indicates that Oshikango experienced a similar geological and

geomorphological history to Ohangwena Region and therefore the soil conditions

below Oshikango could be expected to be similar to those proven below

Ohangwena.

The upper soil layer across the entire site of the proposed factory generally consists

of loose/medium dense fine to course grained Sands and Clayey Sands of

transported origin. This transported deposit extends in excess of 3.0m bgl. The

underlying “bedrock” or weathered residual bedrock soils would probably be

relatively consistent in depth, composition and engineering properties from

Ohangwena.

Ohangwena Region is underlain by Kalahari Group. NCEL interpretation of an

aeromagnetic survey indicated that Oshikango is underlain by a blanket of

unconsolidated to semi-consolidated Aeolian and alluvial deposits of the Kalahari

and Namib Deserts.

Surface Water

There are no perennial natural surface water resources in Ohangwena, but the

westernparts of the region belong to the drainage system of the Cuvelai delta,

consisting of shallow ephemeral drainage basins called Oshanas. These Oshanas

cover about 35% of the region. Significant water flow occurs only during years of

high rainfall in northern Namibia and southern Angola.





Impacts

During Construction

Physical disturbance of land (soil)

This is during excavations, site preparations and construction activities. This result in

increased erosion, changes on soil properties i.e. soil structure due to ground

compaction and soil texture and poor scenery view of the area as a result of many

stockpiled excavated material.

Vegetation Disturbance and Removal

Construction activities shall involve removal (de-bushing) of limited thorn bushes

vegetation that are scattered at the site. This is during site preparation. The removal

of natural wildlife habitat (vegetation) will have no impact on the wildlife because the

area has no wildlife that depends on that vegetation.





Environmental Management Plan (EMP)

The EMP for the Silica Sand has been developed to meet long-term objectives of the

project activities and operations. The EMP is designed to guarantee and achieve the

implementations of the EIA findings highlighted in this report through the provision of

project execution and maintenance guidelines, audit procedures, construction

environmental management plan, waste management plan, operation management

plan, monitoring programme, resource requirements, responsibilities and training

procedures and the decommissioning and rehabilitation plan. The project execution

guidelines cover areas such as waste management, base camp operation, and

contingency and monitoring plans.

Conclusion

In line with the requirements of the EMA, EIA Regulations (GN 30 in GG 4878 of 6

February 2012), this EIA Report has provided, an explanation of the activities

undertaken during the EIA Phase and PPP was also provided. Importantly the report

addresses the impacts identified during the scoping phase that were anticipated for

the development, as well as providing mitigation measures to ensure for the

environmentally sustainable development of the Silica sand processing plant

Other impacts identified during the EIA, however deemed to be medium – low in

significance is the impact on views and the availability of services. Should the

proposed mitigation measures be implemented correctly, the Plant will be a viable

development and be able to meet its 'responsibility'.





TABLE OF CONTENT

LIST OF APPENDICES

Appendix A ENVIRONMENTAL MANAGRNRT PLAN

Appendix B GEOTECHNICAL REPORT

Appendix C BIODIVERSITY STUDY REPORT

Appendix D HEALTH RISK ASSESSMENT

Appendix E ISSUES AND RESPONSE TRAIL

Appendix F MINUTES OF MEETINGS HELD WITH

STAKEHOLDERS AND COMMUNITY PEOPLE

Appendix G PUBLIC MEETING ATTANDENCE REGISTER AND

REGISTER OF THE I&APs

Appendix H NEWSPAPER NOTICES

Appendix I FACTORY LAYOUT PLAN

Appendix J LAND OWNERSHIP LETTER

Appendix k CURRICULUM VITAE





LIST OF ABBREVIATIONS

TERMS DEFINATIONS

BID Background Information Document

DRS Draft Scoping Report

EAP Environmental Assessment Practitioners

ECC Environmental Clearance Certificates

ECO Environmental Control Officer

EIA Environmental Impacts Assessment

EIASR Environmental Impact Assessment Scoping Report

ESIA Environmental and Social Impact Assessment

ESR Environmental Scoping Report

EMP Environmental Management Plan

EMS Environmental Management System

GEE Groot Environmental Engineers

GHG Green House Gases

GIS Geographic Information System

HSE Health and Safety Environment

HSG Health and Safety Guidelines

ILO International Labour Organisation

I&APs Interested and Affected Parties

MET:DEA Ministry of Environment and Tourism’s Directorate of Environmental

Affairs





NHC National Heritage Council

NEMA Namibia Environmental Management Act

NPC Namibia Planning Commission

OSHAS Occupational Health and Safety Assessment Systems

PPP Personal Protective Equipment

SWWP Site Waste Management

ToR Terms of References

WHO World Health Organisation





LIST OF FIGURES





Chapter One: Project Introduction

PROJECT DESCRIPTION

This report presents an EIA of Groot Silica (Pty) Ltd for the proposed development

of the Silica Sand Processing Plant in Eeshoke Village, Oshikango of Helao

Nafidi Town Council, Ohangwena Region, Namibia. The size of the study area is

14ha (fourteen hectares). The proposed development is located western side of

Oshikango, in Eeshoke (Refer to Figure 1) in Ohangwena Region. The area is 1.28

km away from the B1 main Road.

The project is established to explore and mine Silica Sand and the process

associated products on an exclusive 15-year renewable contract for the Tses Glass

Manufacturing Factories in Tses, Namibia. Groot Silica Mining Company wants to

transform Namibia into a self-reliant and enterprising nation in manufacturing and

industrial products and contribute to the realization of the fundamental aim and

aspiration of Vision 2030. This is the first processing plant of silica sand

manufacturing plant of such size to be set up in Namibia. Groot‟s Silica Sand

manufacturing plant, set to produce 1.5 million tons per year of high quality silica

sand as a strong industrial support arm for Tses Glass and Export market. Sixty

percent of raw materials to be used in glass manufacturing in Tses will be from the

Groot Silica Manufacturing Factory.

Project Location

The project site for the SilicaProcessing Plant is located in Helao Nafidi Town

Council; Eeshoke village under Oshikango, the area is under the jurisdiction of

Oukwanyama Traditional Authority.

The factory site is bordered on the East-North side by a local access gravel road that

divides and an existing nearby railway station on the western to north-western side.

There is nearby some Mahangu fields, Railway station, Cemetery and Water

treatment plant which are under construction.





The site of the proposed development is currently vacant; there is an existing pit, no

evidence that the area have been formerly farmed. The site comprises of sand to

loamy soils that are suitable for cultivation and scant vegetation.

Project Coordinates (proposed Erf)

A Y -93484.568 X -508375.617

B Y -93252.074 X -508346.195

C Y -93252.077 X -508187.947

D Y -93110.397 X -508131.442

E Y -93110.401 X -507975.620

F Y -93190.160 X -507934.027

J Y -93190.186 X -507839.081

I Y -93497.783 X -507839.337

Environmental Impact Scoping Report: Construction and Operation of the Proposed Silica Sand Processing Plant in Eeshoke of Oshikango, Helao Nafidi Town, Ohangwena

Region by Groot Silica (Pty) Ltd


November 2016

Figure 1: Proposed Site Locality Map




November 2016

Figure: 2 Entire Proposed Site Location





EXISTINNG INFRASTURCTURE

The existing infrastructure on the proposed site lies on the western side of the

railway line. There is a buffer of 5m from the railway fence to the site. A bridge will be

constructed to go over the railway to facilitate for the movement of traffic. The site is

accessible through an existing path from a proclaimed road.

There are linear existing infrastructure that are in proximity with the proposed site are

clearly indicate on the on the google map below. Their significant impcts on the

proposed project will be addressed.

Transport and Communication

Currently, there is a tarred road that runs from Ondangwa to Oshikango and it has

interlinked with the Eenhana-Onhuno road that goes as far as Kavango Region.

Motorists in Ohangwena region, mostly those that visit Helao Nafidi Town commute

this road occasionally or on daily basis. There is also a railway running as far as

Ondangwa which links the beautiful town of Oshikango. See the map below




November 2016

Figure 3: Permanent Existing Linear Infrastructure Near the Project Site




November 2016

Project Scope

Design,Procure,Installation/Commission

Site preparations, excavations, earth movement

Installation of Silica Plant lasting 3 - 4 months.

Operation of the Silica Plant for 15 years, monitor the environment

Decommissioning of the processingplant and rehabilitation of the

affected environment

Planning and Design

Groot Silica has developed a conceptual site layout planbased on site conditions and

technical feasibility. The siteplan can also be viewed in more detail, see

APPENDIX.However, as the layout plan is based on conceptual design, the

suggestedfootprint will be subject to further investigation and refined based on

theenvironmental and social sensitivities of the Project area. The conceptuallayout

plan has been presented to the EIA specialist team for consideration. Aspart of their

specialist investigation, all specialists will be required to identifysite sensitivities, the

layout plan and associated mitigation measures will be presented in the Scoping EIA

Report.

Raw Material

• Sand

• Water-36 cubic per hour

Technical process

Ore Dressing Ore dressing plant, refined sand yard and tailing yard.

Production Capacity In this project, the daily output of refined sand is around 600 tonnes.

Shift Arrangement Two shifts, each of which lasts six hours, are arranged for the ore dressing plant

Production Quality

Chemical Composition

Fe2O3 less than 0.03 %

Al2O3 variation ±0.05%





CaO- MgO variation ±0.03%

TiO2 less than 0.03 %

ZrO2 less than 0.0001 %

Granularity Distribution

＋1.0 mm ＝ 0 %

1.0 mm～0.63 mm ≤ 2 %

－0.1 mm ≤ 5 %

Product

Refined sand 600tpd

Coarse sand 37.56tpd

Tailings 97.56tpd

Mortar 14.88tpd

Flow Description The technological flow is shown as below:

Scrubbing mud removing-first separation-mud removing-second separation-gravity

separation-gravity separation-gravity separation-dewatering.

Water Supply and Drainage Water supply and drainage inside and outside of each workshop in the plant. For

production water required to be filled into the water tank is around 36 cubic meters

per hour.

Water circulation

Water is designed to be recycled for this system. The amount circulating water is

around 816 cubic meters per hour.

Water Drainage

Treatment by vertical slurry pump. The suspension content for the treated water is less than 200 mg per litre. It is drained out of the plant.

For the fire fighting

The amount of water for fire fighting is around 20 litres per second. Production Flow

Step 1: In the silica powder making process, Jaw Crusher is used as primary

crushing machine, and then goes through the secondary crushing plant.





Step 2: The sand particles that meet the requirements enter into the sand making

machine for making fine sand, while the others enter into the tertiary crushing plant

for fine crushing, then go for sand making.

Step 3: The fine sand from the sand making machine must be washed by sand

washer.

Step 4: Then we need silica sand milling machine, it can grind silica sand into

powder.

Specific index comparison as follow:

Comparison

of

Reformation

Process Concentrate Index

Before

Reformation

screen classification - dry

magnetic separation -

dosing strong scrubbing-

flotation process

SiO2≥97.62%，Fe2O3≤0.24，Al2O3≤1.11%

After

Reformation

screen classification - dry

magnetic separation -

dosing strong scrubbing -

acid leaching process

SiO2≥99.4%，Fe2O3≤0.052，Al2O3≤0.048%

BULKS SERVICES AND INFRASTRUCTURE

A suite of associated infrastructure is required for the daily operations of the

proposed Silica SandProcessing Plant. All associated infrastructure will be located

within the proposed site.

Infrastructure required as part of the Project, includes

Roads and paved areas;

Energy supply and substation;

Water supply system and storage;

Chemical storage facilities;

Storm water management system;

Waste facilities;

Administrative offices;

Control rooms;

Maintenance and workshop areas;





Sanitation facilities; and

• Security facilities

• . Roads and Paved Areas

The site will be accessed via a tilled road that went until the railway; it will be

upgraded to with surface interlock for use by heavy vehicles. Within the site, a ring

road will be provided from the main entrance for access to the facility. The ring road

will be a concrete road of approximately 650m in length and 7m wide. The facility

itself and areas around the facility will be underlined by a concrete and brick paving

surfaces.

The Proposed site lies on the Western side of the railway line. There is a buffer of

5m from the railway fence to the site. A bridge will be constructed to cross over the

railway to facilitate for the movement of traffic. The site is accessible through an

existing path from a proclaimed road.

Site Services

It is understood that the proposed site is not serviced yet. During the construction,

they will be provision of water from Municipality and generator will be used during the

construction phase. A site services agreement will be made with the Helao Nafidi

Town Council, for the supplying of water will be set up prior to the Project

commencing. During the construction, silica factory employees will utilise the existing

sanitation facilities in town since the project is not far from Oshikango town. It is

anticipated that they will be no camping site for accommodation on site, employees

will have to be accommodated in Oshikango town and surrounding area in the area.

Additional portable water will be made available during the construction phase for

contractors.

The main resources that is used in the processing of the Silica is water, the

operation requires a huge amount of water. The water used for washing Silica will be

processed and reused in the processing of Silica. The main water supplier for this

project will be Namwater through the Helao Nafidi Town Council. Appropriate

structures will be put in place to redirect and collect rain water that will also be used

in the possessing.





• Waste Management

During the construction, large quantities of rubble will be generated due to the

destruction and removal of top soil and back filling of an existing pit, mentioned

above. Furthermore, the proposed site is strewn with litter and rubble. Environmental

Management Plan propose mitigation measure that will be used to clean the site

and the construction of a waste facility,which states that it is a crime to dispose

waste on an undesignated area. All regulated wastes be will removed by qualified

workers and properly disposed of; where practical, removed recyclable material from

the waste.

The processing of Silica produces minimal waste, which can be further processed

and used in other industries such as cement making. However the presence of the

workforce and other processes such as the packaging of the processed Silica, the

waste generated daily should be contained and disposed off at the Helao Nafidi

Town Council Waste Disposal.

Other wastes that are considered hazardous should be handled with care, according

to the Waste Management Act.

• Sanitation

With regard to sanitation, measures will be put in place to ensure that good sanitary

conditions are provided for all the workers, for example there should be toilets that

will be used by workers. These toilets should be sufficient enough to accommodate

the workforce. These toilets should be connected to the main sewerage of the town.

During the clearing and the construction phase, portable toilets will be used for the

employees while the construction of permanent structures, at least a minimum of one

unit for every 15 workers.

• Storm Water Management

Storm water management is critical for the day to day management of the Project.

The potential for contaminated storm water run-off is minimal, and therefore storm

water infrastructure will be constructed to optimise re-use of storm water. Separate

storm water channels will be constructed around the site to channel the water to a





designed dam proposed to be built in once the project starts that will accommodate

flood/ rain water during the rain season.

Storm water run-off from clean areas will flow into the water catchment pits to be

developed onsite. Storm water run-off from dirty areas will be diverted to a recycled

process water system for purification and reuse.

• Electricity Supplier

There will be low voltage power distribution system, electrical control in the

workshop, lightning and grounding, lighting system, external cable and road lamb.

Total installed capacity for this project is around 740kW. 10kV power is required.

One 1500kVA transformer will be installed. The motor with the power of less than

30kW will start directly while the motor with the power of over 30kW is started by soft

starter.

Electricity will be supplied to operate the facility as well as to provide power to the

associated buildings including the workshops and administrative offices. It‟s

anticipated that they will be a solar system as a backup.

Chapter Two: Policy, Legal and Administrative Framework

Introduction

One of the crucial components of the EIA is identifying and reviewing the

administrative, policy and legislative situation concerning the project activities. This is

so to inform the proponent about the requirements to be fulfilled on constructing and

operating a SilicaSandProcessing Plant. This section reviews the legislative

framework within which Groot Silica (Pty) Ltd; processing plant must operate under

in order to fulfil the environmental management requirements. This includes focus on

compliance with national and international legislation as far as planning, operational

and decommissioning phases of the project are concerned. All applicable policy,

legislative and other conditions will guide the proponent on operating the project in

accordance with best practices and environmental management requirements.

The Environmental Management Act 7 of 2007 is the primary custodian of the environment with the aim to:





Promote the sustainable management of the environment and the use of natural resources by establishing principles for decision making on matters affecting the environment; to establish the Sustainable Development Advisory Council; to provide for the appointment of the Environmental Commissioner and environmental officers; to provide for a process of assessment and control of activities which may have significant effects on the environment; and to provide for incidental matters.

The EMA No. 7 of 2007 is the central legislation and custodian of environmental

assessment in Namibia. This Act was promulgated in 2012 and provides for basic

principles of environmental protection and remediation. It further lays down the

duties, roles and powers assigned to authorities as far as environmental

management and, in particular, environmental assessments are concerned. The

Environmental Management Regulations 2012 clarify the listing and de-listing of

activities by the Environmental Commissioner and specify the processes to be

followed by proponents for different projects/developments. The Regulations provide

clear criteria pertaining to Environmental Assessment Practitioners and

Environmental Officers – also as regards to the eligibility of those involved. In both

the Environmental Management Act and in the above mentioned regulations such

activities that may not be undertaken without an environmental clearance certificate

are listed.

Furthermore, Namibia is a signatory to and has adopted international environmental

treaties such as The Convention on Biological Diversity, United Nations Convection

to Combat Desertification, United Nations Framework Convention on Climate

Change and Agenda 21 in compliance with local environmental regulations.

Therefore under the same mandatory, the project proponent will ensure

environmental compliance to resource management and sustainably use resource.

The project activities will consider less emission of GHGs and prevent excessive

land use which degradation and may threaten livelihood.




November 2016

LEGISLATION/POLICY PROVISION PROJECT APPLICABILITY

NATIONAL LEGISLATION

The Constitution of the Republic of Namibia (1990)

The articles 91(c) and 95(i) commits the state to actively promote and sustain environmental welfare of the nation by formulating and institutionalising policies to accomplish the Sustainable objectives which include:

Guarding against overutilization of biological natural resources,

Limiting over-exploitation of non-renewable resources,

Ensuring ecosystem functionality,

Maintain biological diversity.

Through implementation of the Environment Management Plan, the proponent shall be advocating for sound EMP as set out in the constitution. Ecological sustainability should inform and guide operations of Silica sandplant. Adhere to the both article 91 and 95, particularly during excavation, construction and on-going operations. Also maintain the biological diversity forming part of the EMP.

Environmental Assessment Policy of Namibia 1994

The Environmental Assessment Policy of Namibia states Schedule 1: Screening list of policies/ plans/ programmes/ projects subject to environment must be accompanied by an EIA. “The construction, operation of Tses Glass and its related activities" is among the list. The responsible Authority enforcing the law is the Ministry of Environment and Tourism (MET) Directorate of Environment. The policy provides a definition to the term “Environment” broadly interpreted to include biophysical, social, economic, cultural, historical and political components and provides reference to the inclusion of

An Environmental Impact Assessment is compulsory. Consider all environmental aspects during the impact assessment and test different options of environmental impact reduction.

Environmental Impact Scoping Report: Construction and Operation of the Proposed Silica Sand Processing Plant in Eeshoke of Oshikango, Helao Nafidi Town, Ohangwena Region

by Groot Silica (Pty) Ltd



alternatives in all projects, policies, programmes and plans.

Environmental Management Act No. 07 of 2007

Requires that projects with significant environmental impact are subject to an environmental assessment process (Section 27). The Act aims at Promoting the sustainable management

of the environment and the use of natural resources by establishing principles for decision-making on matters affecting the environment;

To provide for a process of assessment and control of projects which may have significant effects on the environment;

To provide for incidental matters. Requires for adequate public participation during the environmental assessment process for interested and affected parties to voice their opinions about a project (Section 2(b-c)). According to Section 5(4) a person may not discard waste as defined in Section 5(1)(b) in any way other than at a disposal site declared by the Minister of Environment and Tourism or in a manner prescribed by the Minister. Details principles which are to guide all EIAs. Moreover, the act also provides procedures for

All formal requirements as per the act will be duly identified and adhered to. The Project will follow this act accordingly and consider all aspects inclusive of the assessment process and acquire environmental clearance before the project is commenced. This Act and its regulations should inform and guide this EIA process. All formal requirements as per the act will be duly identified and adhered to. The Project will follow this act accordingly and consider all aspects inclusive of the assessment process and acquire environmental clearance.





adequate public participation during the environmental assessment process.

Soil Conservation Act 76 of 1969 This acts makes provision for combating and for the prevention of soil erosion, it promotes the conservation, protection and improvement of the soil, vegetation, sources and resources of the Republic of Namibia.

The Project will have a limited impact on the locality of the envisaged structures and surrounding as regards the existing soil and vegetation. Reforestation of parts of the cleared vegetation will be considered.

Hazardous Substance Ordinance (No. 15 of 1973)

The Ordinance applies to the manufacture, sale, use, disposal and dumping of hazardous substances, as well as their import and export and is administered by the Minister of Health and Social Welfare. Its primary purpose is to prevent hazardous substances from causing injury, ill-health or the death of human beings. This ordinance will be replaced by the Pollution Control and Waste Management Bill once it comes into force.

The project proponent will make it a priority to get relevant licensing for the use or handling of hazardous substances on site used in the glass production if any. Possibly raw materials to be used in the glass production (coke) must be safely housed in the silos within the batch housel.

Atmospheric Pollution Prevention Ordinance, 1976

Amongst other the bill aims to “prevent and regulate the discharge of pollutants to the air, water and land” Of particular reference to the Project is: Section 21 “(1) Subject to sub-section (4) and section 22, no person shall cause or permit the discharge of pollutants or waste into any water or watercourse.” Section 55 “(1) No person may produce, collect, transport, sort, recover, treat, store, dispose of or otherwise manage waste in a manner that results in or creates a significant risk of harm to human health or the

The proponent must ensure that emissions of crystalline silica in air, can control airborne silica levels at the mine, during processing and when transported,during factory operations comply with this regulation for not to threaten public health, adding on an integrated pollution management strategy following the EMP and will be operationalised on site.





environment.”

Vision 2030 and National Development Plans

Namibia‟s overall Development ambitions are articulated in the Nations Vision 2030. At the operational level, five-yearly national development plans (NDP‟s) are prepared in extensive consultations led by the National Planning Commission in the Office of the President. Currently the Government has so far launched a 4th NDP which pursues three overarching goals for the Namibian nation: high and sustained economic growth; increased income equality; and employment creation.

The proposed project will increase availability of infrastructure services (Schools, health facilities, roads) in Oshikango, Residential houses, and creating employment which will be in fulfilment to the NDP and Vision 2030.

Forest Act, 2001 (Act No. 12 of 2001)

The Act makes provision for the protection of various plant species through the Ministry of Agriculture, Water and Forestry (MAWF), Directorate of Forestry).

Relevant for the cutting down or harvesting of plant species during construction. Additional approvals from the Directorate of Forestry will be acquired to avoid indiscriminate cutting down of trees. The proponent will be advised to refrain from tourist activities on a stretch 100 m wide along the river banks.

National Biodiversity Strategy and Action Plan (NBSAP2)

The action plan was operationalised in a bid to make aware the critical importance of biodiversity conservation in Namibia, putting together management of matters to do with ecosystems protection, biosafety, and biosystematics protection on both terrestrial and aquatic systems.

Forming part of the EIA of and EMP for this Project, the proponent will consider all associated impacts, both acute and long term, and will propose methods and ways to sustain the local biodiversity. In particular during construction of factories, heavy machinery will be curbed and the bearings of traffic will be reduced through regulations





prescribed and monitored by the proponent.

National Policy on Climate Change for Namibia, 2010

In harmony with the findings of the IPCC over time and the Earth Summits being held annually the policy seeks to outline a coherent, transparent and inclusive framework on climate risk management in accordance with Namibia‟s national development agenda, legal framework, and in recognition of local environmental constraints and vulnerability. Furthermore, the policy pursues the strengthening of national capacities to reduce climate.

Water Resources Management Act, 2013 (Act No. 11 of 2013)

This Act provides for the management, protection, development, use and conservation of water resources and the regulation and monitoring of water services and for incidental matters. (Department of Water Affairs).

The project proponent will use council water for purposes for the factory construction and operation as it requires a lot of water at the cooling stage of glass manufacturing. Any bulk use of water resource will be in compliance with requirements of the Water resources Act by taking in account water abstraction licensing and following water abstraction limits as required by the Act.

Labour Act (No 11 of 2007) in conjunction with Regulation 156,

‘Regulations Relating to the Health and Safety of Employees

at work’.

135 (f): “the steps to be taken by the owners of premises used or intended for use as factories or places where machinery is used, or by occupiers of such premises or by users of machinery in connection with the structure of such buildings of otherwise in order to prevent or extinguish fires, and to ensure the safety in the event of fire, of persons in such building;”

In her capacity (Silica) as a biggest employer, proponent shall comply in particular with Chapter 4 of this Act, securing a safe environment and preserving the health and welfare of employees at work. He will apply proper hazard management plans and provide employees with personal protective equipment.





(Ministry of Labour and Social Welfare). This act emphasizes and regulates basic terms and conditions of employment, it guarantees prospective health, safety and welfare of employees and protects employees from unfair labour practices.

National Heritage Act 27 of 2004 This Act protects and conserves cultural heritage and cultural resources with special emphasis on places and sources of National heritage including graves, artefacts and any objects older than 50 years.

The project proponent shall commit to temporary isolate and then notify the National Heritage Council of Namibia in the event that any items or structures are discovered during the project construction phase.

Pollution Control and Waste Management Bill

The bill aims to “prevent and regulate the discharge of pollutants into the air, water and land”. Whilst the bill has not come into legal force it will be considered as if it were – since it will be promulgated at some time in the future and it regulates matters relevant in this context.

The proponent is advised to manage all waste materials produced during factory construction and operation are in line with Sections 55 (1) as regards the transportation of waste and the spillage of waste into wetland reservoirs. The proponent shall further ensure that applicable licences are obtained for the disposal of waste in the river if such disposal is considered (section 21 of the Act). Contingence plan will be developed for the dumpsite to minimize ground water pollution.

Environmental Impact Report: Proposed Silica Sand Mining and the Construction of a Processing Factory in Oshikango, Eeshoke in Ohangwena Region by Groot Silica Mining (Pty) Ltd



NEEDS AND DESIRABILITY/PROJECT JUSTIFICTION

Need of the project

The development of the proposed Silica Sand Processing Plant is undertaken to:

Utilize abundant vacant land in Oshikango.

To supply the ready existing market of glass products in Namibia, SADC

region and the whole of Africa.

Fulfil the Government of Namibia's prosperity plan (Harambee) by improving

the industry of Namibia as well as employment creation.

Value/ benefit of the project

Economic Benefits

Employment (local people from Oshikango and the entire Namibia),

To be a leading producer of quality silica sand products and industrial

minerals for the local and international markets,

Total 1,500,000 tons of Silica Sand per year,

219,000 tons per year of that is for Tses Glass,

SADC region being an emerging market in Africa with fastest growing

economies comparing to other countries,

The Silica Sand Plant is creating more than 1,500 new direct employment

opportunities locally,

The first of its kind silica sand mining in Namibia that will further attract foreign

investors,

Value-added silica sand processing for domestic and international

consumption,

Taxes and royalties from mining account for 25% of the country‟s revenue,

Contributes to the GDP of the country,

Contribute socially and economically to the community where we will operate,

Caring significantly for the development and improvement of social

infrastructure,

By doing so, we will allocate 2% of the net income for the implementation and

supporting community programs in the community we will operate,




Use of Silica Sand

• One of the primary ingredients for the container glass, float glass, insulation,

textile fiber glass, and all other related glass manufacturing.

• Used for landscaping, foundry casting molds/ cores, golf bunkers and

topdressing industry as well as other products as fillers and extenders.

• Also used for sand blasting, adding texture to slick roads.

• As a raw material in production of ceramic and equestrian surfaces

SocioeconomicBenefits

• Contribute socially and economically to the community where we will operate.

• Caring significantly for the development and improvement of social infrastructure

PROJECT ALTERNATIVES

Location Alternatives

No off-site or other site alternatives have been investigated due to the fact that this

property is owned by the developer, and because of the nearness of the railway line

to the site, this ensures easy access of raw material (Processed Silica Sand from the

North) to be used in the production of glass. However layout design alternatives

were assessed with the preferred alternative. The limitations inherent in this scenario

are understood. Both layout options were investigated in terms of the layout for the

proposed silica sand processing plant establishment. Due to land surface

configuration, soils, the alternative (non-preferred) layout was not deemed a feasible

option for the proposed facility due to cost and limited access points.

The do-nothing (“no go”) option would entail not using the site and maintaining the

site as is. From certain perspectives this is not a viable option as the site is vacant,

abandoned, no agriculture even and the area has been located under communal

land still village headman, not yet zoned by town council. By not developing the site,

the site will be anomalous in the context of the surrounding community land-uses,

and some of the direct and indirect socio-economic benefits (i.e. job creation,

maximum of utilisation of land, provision of raw material to the industry of Namibia,

etc.) will not materialise.




As part of the site selection process a number of potential sites were investigated,

through a site visit and desk-top analysis. The preferred site was identified based on

a number of criteria, including:

A site with an area of 14 ha and more;

Environmental constraints;

Water demand requirements, the proposed facility would require

Electricity requirements, the plant requires approximately

Easy access to major roads and highways; and

A site with existing industrial rights.

From and land use management and planning perspective the area has scant

vegetation and is viewed as flat. Which makes it suitable for the development of

industries, there existing nearby mahangu field cultivation or any other land use by

the local community members? Therefore not developing the site by the proponent

will see the land lying idle but however the not developing option assist in protecting

the natural features on the site (scant thorn bushes and other local indigenous

vegetation as well as the maintaining the natural view), however the development as

proposed will maintain the not cause destruction of vegetation and an associated

buffer area as an undeveloped but importantly as an actively managed and

controlled.

Site Layout Alternatives

The site layout is likely to undergo a number of alterations based on technical

aspects of the Project such as construction conditions and the environmental and

social considerations which will be explored during the EIA process. From a

technical perspective, the final site layout will depend on a number of factors

including the geotechnical features of the site; and the final dimensions and sizing of

built structures to meet the required production capacity.

After initial field surveys undertaken by the EIA team, areas that pose environmental

and/or social constraints will be fed back to the technical team in the form of a

constraints map, to be generated during the EIA phase. The technical team will then




generate a revised site layout taking these environmental and social constraints into

consideration. The output of this iterative process will encompass the consideration

of layout alternatives and will be used in the assessment of impacts in the EIA

Report

Technology Alternatives

In terms of the water diversion / channelling process, technology alternatives have

been proposed; technicians will apply method to that. Detail description of the

technology will be attached as appendix.

No-Go Alternative

It must be noted that it is mandatory to consider the “no go” alternative as part of the

EIA process. The “no-go” or “do nothing” option would entail maintaining the status

quo. Although this option will not be explicitly assessed in the EIA Report, it should

be noted that the assessment of all impacts is made relative to the existing

environment and the status quo accordingly there is de facto consideration of the “no

go” option. Assuming that the Project would not be developed at the proposed site,

the site would remain in its current state. The direct benefits associated with the both

the construction and operational phases of the Project such as employment

opportunities and associated economic benefits would not be realised, should the

development not proceed.

Chapter Three: Interested and Affected Parties’ Involvement Process

Objectives of the Public Participation Process

The public participation process (PPP) has been designed to comply with the

regulatory requirements set out in the Environmental Management Act of

Namibia as well as international good practice. Public participation in an EIA is

not only a statutory requirement in terms of the EIA Regulations (2012), but a

process that is designed to provide I&APs with an opportunity to evaluate all

aspects of the proposed development. I&APs represent relevant sectors of

society and organs of state. The EIA process is seen as a tool to facilitate




cooperative governance through informed consultation with a spectrum of

stakeholders. The aim of which is to ensure that an informed decision making

process is undertaken, which incorporates social, economic and environmental

considerations.

This chapter provides an overview of the PPP and describes the engagement

activities undertaken to date and the next steps in the public participation.

Objectives of the public participation process

The PPP has been designed to achieve the following objectives:

Ensure that stakeholders are well informed about the proposed development;

Provide a broad set of stakeholders sufficient opportunity to engage and

provide input and suggestions on the Project;

Make draft and final reports available for public/stakeholder comment and

input;

Verify that stakeholder issues have been accurately recorded;

Draw on local knowledge in the process of identifying environmental and

social issues associated with the Project, and to involve stakeholders in

identifying ways in which these can be addressed; and

Comply with the legal requirements and best practice.

The PPP has been designed in 4 phases within the EIA process

Table: Public participation process

Project Notification

Identify key stakeholders

Engage with key stakeholders

Provide Project overview and process information

Obtain issues of concern, comments and suggestions

Invite stakeholders to register as I&APs




Scoping Phase

Acknowledge and forward suggestions for enhanced

Project benefits and reasonable alternatives

Verify that issues raised by stakeholders have been

accurately recorded

Address concerns, suggestions and comments about the

Project in the Draft Scoping Report and the Draft Plan of

Study for EIA phase

Impact Assessment Phase

Provide I&APs with further information on the impacts

identified and associated mitigation measures allow

I&APs to comment on findings of the specialist studies

Verify that issues raised by stakeholders have been

accurately recorded and addresses.

Decision-making Phase

Notify I&APs of the decision and the appeal process

Public Consultation Activities

The following tasks have been undertaken during public consultation process which

started early October 2016.

Identification of Interested and Affected Parties (I&Aps) One of the key principles informing the PPP is that it should be an inclusive process.

Stakeholders have been notified and invited to register as I&APs through a series of

English PPP notification materials.

Stakeholders are grouped into the following categories:

Government: National, Provincial, District and Local authorities;

Landowners: Directly affected and surrounding landowners;




Communities: Surrounding communities;

Business: Small medium enterprises and formal organisations; and

Interest groups

After the scoping process, the EIA team identified I&APs and key stakeholders of the

proposed project. The public participation activities to be undertaken for this EIA

process were incooperated into the overall approach of the EIA background

information. Among key stakeholders identified were Ohangwena Constituency

Office, Oukwanyama Traditional Authority, and Chief Senior Headman of Oshikango,

Helao Nafidi Town Council, Engela District Hospital, Oshikango Constituency Office,

Oshikango Constituency Office, Ohangwena Regional Council, and Engela

Constituency Office. Other I&APs were allowed to register to the EIA team and a

special database was created capturing all their names and correspondence details.

The registration of I&APs took a period of 35 days. A register was created for those

people that register as I&APs according to the EMA Act No. 7 of 2007 section 22(1).

Distribution of BID

A Background Information Document (BID) was distributed on request by I&A Parties

and it was distributed to key stakeholders identified during the scoping process. The

Background Information Document (BID) provided a description summary of the

proposed project, and the project proponent and the whole procedure of the EIA to

be followed. The BID was then attached a written notice as regulated under the

Section 21 (2)(b) of the EMA Act of 2007. Key stakeholders that received the BID

are;

Key stakeholders that were given the BIDs

Table:

Stakeholders Contacted Person

Ohangwena Constituency

Office

Chief Regional Officer

Oukwanayama Traditional Authority Secretary

Oshikango Headman Senior Headman Mr J. Shilunga

Helao Nafidi Town Council Chief Executive Office




Engela District Hospital Regional director of health

Oshikango Constituency Office Chief Regional Officer

Ohangwena Regional Council Chief Executive Officer

Engela Constituency Office Chief Regional Officer

Newspaper Adverts

In compliance with the EMA Act No. 7 of 2007Section 21 (2) (c) notification of the

commencement of the EIA process for the project was advertised in a Namibian

nationwide newspaper and through placement of an advert, The New Era (local

newspaper), and The Namibian (APPENDIX). The advertisements were basically

notifying the public about the project and the EIA study and call for their participation.

Furthermore the newspaper adverts were requesting I&AP‟s to register.

Table: Details of public notification of the EIA study

Newspaper Area of Distribution Language Date Placed

New Era Country Wide English 14th of September 2016

The Namibian Country Wide English 13th October 206

Site notices Helao Nafidi Town

Council

English 15th of October 2016

Engela State Hospital English 15th of October 2016

Proposed Site English 11th of October

2016

Local Public Announcement

Three notice boards installed, one on site and the other two the local two public

areas which are;

Proposed site area- The EMA EIA Regulations of 2007 section 21 (2)(a)

require that a site notice be fixed at a place conspicuous to the public at the

boundary or on the fence of the site where the activity to which the

application relates is to be undertaken




Helao Nafidi Town Council

Engela State Hospital.

The notice boards were notifying the public about the EIA study, how they register as

I&APs, commenting and submitting their comments and concerns, where to get the

BID as well as the date of the public meeting and venue. The size of the notice

boards were 1.2m x 1m and were conforming to the size listed in the EMA Act No. 7

of 2007 section 21 sub-regulation (2).

Figure

Public Participation Meeting

The primary aim of the public meeting was to:




Provide I&APs and stakeholders with information regarding the proposed

project and associated infrastructure;

Provide I&APs and stakeholders with information regarding the EIA process;

Provide an opportunity for I&APs and stakeholders to seek clarity on the

project;

Record issues and concerns raised; and

Provide a forum for interaction with the project team

A public meeting was held on the 14th October 2016 at 10h00 at the Senior

Headmanof Oshikango. The meeting was fairly attended (Figure). A description of

the project was presented and opportunity given for those present to give their

comments and concerns. Minutes of the meeting are given in (APPENDIX) as well

the attendance register.




Information Collection

Issues and concerns raised by I&AP‟s have been incooperated in the report

comments on a response trail as attachment, APPENDIX. Some people submitted

their comments and concerns via electronics, comments raised will be included in

the report. In the interest and concerns, responses and clarification are provided

where possible. Efforts have been made to remain sensitive to language and ethnic

in the region.

Eliciting Stakeholder Concerns

Comments have been sought from stakeholders in response to information gathered

and disseminated during consultation. Discussions on alternatives and proposed

mitigation measures have been encouraged throughout the public consultation

process. Issues for stakeholders that may previously have been overlooked or are

outstanding are given a forum for review. This Step has presented a need

assessment and has provided a basis from which decisions have been made and

will continue to be made.




The key findings of the public meeting/participation and responses received by from

I&AP‟s are summarised below and indicate that the project can be implemented,

provided the recommendations are made.

SUMMARY OF ISSUES

THEME ISSUE

Economic Employment of general labour must consider employing local

people from

Oshikango, Eenhana and Surrounding area.

The company must take the social responsibility in the

Ohangwena Constituency.

Improve the life being of the Ohangwena Constituency.

Low income people need to be accommodated properly.

Job creation.

Health and Waste Management concerns including both solid waste and

waste water.

Safety Potential air, noise and water pollution due to development.

The company must provide enough health care to the factory workers

Infrastructure

The company must consider todevelop the following infrastructure in Oshikango and

Ohangwena Constituency as a whole Roads

Health Facilities i.e. clinics Houses for its workers

Ecological

Concerns regarding impacts on and conservation of natural vegetation.

Communication

Clear communication needs to be promoted between relevant authorities

and local community.

Clarify nature of new property (how it works, what processes

involved).

Public Review of the Draft Scoping Report

The draft ESR, together with the Plan of Study for EIA was made available for




authority and public review for a period of 30 days from 15 September 2016 to

01November 2016. In addition, the report was made available at the following public

locations within the study area, which are all readily accessible to I&APs:

• Groot Environmental Engineers Offices (Maroela Mall, Ongwediva)

• Helao Nafidi Town Council (Ohangwena Region)

• Ohangwena Constituency (Ohangwena Region)

• Senior Headman of Oshikango (Ohangwena Region)

• Also available on the Internet: http://www.grootgroup.com/grootees

At this period the key stakeholders and the general public were given access to the

report and to check whether their contributions have been incooperated into the

document and also to further comment on the report.

Final Environmental Scoping Report

The final stage in the Environmental Scoping Study entailed the capturing of

responses and comments from I&APs on the draft ESR in order to refine the ESR,

and ensure that all issues of significance are addressed. The final ESR was then

submitted to MET:DEA for review and decision-making.

http://www.grootgroup.com/grootees




Chapter Four: The Current Environmental and Social Set Up

RECEIVING ENVIRONMENT

Climate Change

Climatically Ohangwena region is semi-arid.

Average Rainfall: Oshikango climate is average yearly rainfall of 588 mm. The

driest month is June. There is 0 mm of precipitation in June. Most of the precipitation

here falls in February, averaging 135 mm.

Average Evaporation: Is very high due to strong solar radiation, low humidity and

rather high temperatures. Mean annual evaporation measured from an open water

surface at Ondangwa is as much as 2 485 mm, about 5 times as much as mean

annual rainfall. Some recent studies indicate that up to 83 % of all precipitation

evaporates soon after it has fallen. Since about 14 % of total precipitation is returned

to the atmosphere by plants through evapotranspiration and some water moves to

ponds, pans and Oshana, only about 1-2 % of rainfall recharges groundwater




resources (Figure 2). Local variations may however be significant, depending on

topography, vegetation and soil conditions.

Wind: In Ohangwena region are rather calm for most of the year. Strong winds occur

usually only before and during thunderstorms in the rainy season. Easterly and

north-easterly winds are common during most of the year.

Atmospheric Humidity In Ohangwena is low most of the year. Mean monthly

values of relative humidity range from about 17 % in September to about 50 % in

March.

Mean monthly temperatures range from 17.5°C in July to 26°C in December.

Average daily maximum temperatures during the hottest period in October

December can reach 40 C. Average daily minimum temperatures in the winter

months of June and July can reach down.

Topography

The topography of Ohangwena Region is characterized by an extremely flat plain

between 1090 and 1150 m above mean sea level. The gradient of the plain is

approx. 1:2500 decreasing from north to south.

The site is low lying (a few meters above high tide level) and relatively flat. The site

is accessed by earth road. Vehicular access around the site could be poor

particularly during the rainy season due to compressible poor quality of surface soils.

At the time of the investigation, the project site was seen to be a virgin land covered

by scattered Makalani Palms and thorny bushes (Please refer to picture).

Topographically, the area could generally be considered to be flat with no discernible

cross fall. It is obvious that no cuts will be made but substantial filling will have to be

done.




• Geology

Available information indicates that Oshikango experienced a similar geological and

geomorphological history to Ohangwena Region and therefore, the soil conditions

below Oshikango could be expected to be similar to those proven below

Ohangwena. The upper soil layer across the entire site of the proposed silica factory

generally consists of loose/medium dense fine to course grained Sands and Clayey

Sands of transported origin. This transported deposit extends in excess of 3.0m bgl.

The underlying “bedrock” or weathered residual bedrock soils would probably be

relatively consistent in depth, composition and engineering properties from

Ohangwena. Ohangwena Region is underlain by Kalahari Group.

Soil




The general soil profile of the site is summarised below for purposes of excavation

and material usage. The geotechnical report will be attached as an (appendix.)

General Soil profile

Material Type Description

Transported 0-1800 Dry to slightly moisture light grey loose

voided silty sand

Transported 1800-3000+ Slightly moisture to moist, light

yellowloose, voided. Lamb calcrete and

silcrete in the matrix of silty sands

Specifically, the site consists of dry through slightly moist to moist, very loose to

loose voided compressible silty Fine SAND. This represents Transported deposit of

recent age and it extends in excess of 3.0m below ground level. Generally, there is

uniformity horizontally and vertically across the site with regard to soil horizons.

Hydrology

The western part of Ohangwena region belongs to the Cuvelai floodplain or inland

delta, a drainage system of seasonal rivers and oshanas, which originates from the

Sierra Encoco highlands in Southern Angola, where mean annual rainfall exceeds 1

000 mm. The Cuvelai drainage system is a part of Etosha basin and it ends up in the

huge Etosha saltpan some 80 km south of Ondangwa. At Etosha mean annual

rainfall is about 430 mm.




Surface Water and Ground Water

Water Resources within Ohangwena Region there are no permanent rivers or lakes.

The water resources available for the inhabitants and their livestock are the

following:

surface water which flows during rainy season in amphoral rivers collects

in natural pans. This water can be collected and stored in ponds

reservoirs.

Flora

According to Mendelsohn et al (2002) plant diversity in the central-north varies

between 50 and 400 species. In the general area around Oshikango 335 species

have been recorded, including 20 important and protected tree species biodiversity

study will be attached as (APPENDIX).

Although approximately 16% of the Namibian flora as a whole is thought to consist of

endemic species (Craven & Vorster 2006), the level of plant endemicity is low in the

central north and only one endemic species, Ehretianamibiensissubsp. kaokoensis,

has been recorded in the general area of this site. This species is not likely to be

affected by the proposed projects.

In summary, the site lies in an area of low endemism and, due to its proximity to

Oshikango, has experienced a high level of anthropogenic impact over a long period

of time, including a large borrow-pit. Nevertheless, there are likely to be a limited

number of individuals of important protected tree species present on the site.

Fauna

The eastern forests and woodlands are the main habitats for wildlife in Ohangwena

region.Large wild mammals have become almost extinct during the last 40-50 years.

This is due both to increased hunting as well as disturbances of settlements.

Local elders gave accounts of the most animals that are still predominant in the

environment; the data was also augmented by a desk review of literature and actual




site survey. A rapid site assessment was conducted on the proposed site to

determine the actual vertebrate fauna and flora on site and which potentially could

be affected by silica processing plant.

The site area however is mostly being used as grazing area for donkeys and goats,

cattle during the visit observations number of cattle and goat stools were seen.

Table: Animals expected on/around the study area

Amphibians Mammals Birds Reptiles

Toads cattle Monteiro's hornbill Blind snakes

Rubber frogs Pigs White-tailed shrike Thread snake

Donkeys Black -faced

waxbill

Scorpion

Sand frog Rats and Mice White backed ashy

tit

Burrowing snake

Cacaos Hares/Rabbits Moosebird Tortoises

Platanna Squirrels Cape penduline tit, Errapin

Goats Short-toed rock

thrush,

Shaft-tailed

whydah

Cultural Heritage

The proposed site by the project is an area of low endemism that has experienced

high levels of anthropogenic damage in the past. The desktop study found that the

only serious negative impact that the development might have on the flora was the

loss of protected trees, including several species of considerable importance for

humans.

Graves and Houses

There is an existing graveyard which lies approximately about 200 m from the site;

there is no need to relocate the graveyard. There are two houses that will be




relocated upon the commencement of the project. The site will be fenced out to

avoid interference with the locals. It is anticipated that the there will be no significant

impact to the graveyard either during the construction phase or the operational

phase of the project.

Noise and Dust

Increased Noise Levels during the Construction Period

Construction vehicles and equipment such as drillers, compactors and other

machineries to be used to install services during the construction phase can be a

nuisance and disturbance. Noise and vibrations will also have an impact on animals

such as birds and reptiles. Birds are known to abandon their nests if subjected to

continuous noise.

Increased Noise Levels during the Operational Phase

During the operational phases of the project which entails the processing of Silica

Sand, the noise level is expected to increase due to the use of machinery and

vehicle movements. Processing machinery and processes such as the crushing of

the silica is expected to create a considerable noise level. Prolonged exposure may

cause hearing damage to the workers and the people around. The noise can also be

a nuisance to the animals.

Increased Noise Levels during Decommissioning

During this stage of the project the noise impact is expected to be moderate and low

noise is anticipated as fewer and fewer machinery will be used and few people will

be at the site.




SOCIO ECONOMIC BASELINE

Demographic Profile

Oshikango is situated in the northern part of Namibia in Ohangwena Region.

Oshikango holds the Border Post that links Namibia and Angola, and the neighboring

villages and settlements such as Edundja, Engela, Ohangwena and Omafo.

Oshikango is a settlement under Helao Nafidi Town Council in the Ohangwena

Region. Helao Nafidi council is comprised of 3 constituencies, namely Oshikango,

Engela and Ohangwena constituencies. The estimated population of the three

constituencies is about 19 375. Ohangwena Region ranks among the poorest

Regions in the country in terms of average annual household consumption and

average annual household expenditure. A household that spends 60% to 80% of

their total expenditure on food is classified as poor household and a household that

spends over 80% of their total expenditure on food is classified as extremely poor

household. In accordance with this classification, about 32% of the people of

Ohangwena Region are poor, and 10% are extremely poor, bringing the poverty

prevalence in Ohangwena to 42%. Poverty is more widespread in Ohangwena

region than in the country at large considering that only 38% of the national

population lives in poverty or extreme poverty.

Migration

Oshikango Border Post has the dynamics of a typical emerging peri-urban

settlement. Recently, the economy of Oshikango is experiencing a lapse in both the

formal and informal sector. This epidemic was brought about by the collapsing of

Angola`s economy hence some potential investors have withdrawn and neglected

the beautiful town of Oshikango. Most of the residents of Oshikango town are

Oshiwambo speaking people, but the town also has an influx of other nationalities

from other countries and ethnic groups of Namibia.

Furthermore, Oshikango has no formal residential settlements. Majority of business

people reside in Omafo, Ongha, Engela, Ohangwena, Oshakati, Ondangwa,

Ongwediva or the nearby villages. There is, however, a booming informal settlement




on the increase, which lacks services such as running water, electricity, modern

houses with corrugated iron roof tops and brick walls.

Land-use of the Project Site

During rainy seasons, the land that is allocated to Groot Silica Mining (Pty) Ltd

gathers water for livestock. There is a pit that retains the water but does not go on

throughout the whole year. The space is also used for grazing. There is not much

development taking place as the locality of the site is deep in the village.

Surrounding Land –use The surrounding area close to the site is home to local communal farmers. They are

the owners of the herds that feed on the vegetation which surrounds or are in the

proposed site. In a distance of not more than 1 kilometer, the new Open Market of

Oshikango can be seen currently undergoing construction while adjacent to the

market there is a filling station fully operational.

Agricultural

The residents of Eeshoke and nearby villages depend mostly on subsistence

farming. Their yearly yields have been subsequently affected due to poor rains over

the years. They farm variety of crop products such as millet, sorghum, maize, etc.

and are also engaged in herding animals such as goats, sheep, cattle, donkeys,

chickens as well as pigs as a form the predominant activities.. If the rain continues

pouring poorly, the livelihood of the locals will drastically be affected, their animals

will die and crop production will be severely stunted

Employment and skills

Locals in and around Oshikango commute on a daily basis within or above the

boundaries of Helao Nafidi to reach their working places. Ranging from the youth of

employable age to adults, the locals find themselves working in different sectors as

their expertise permits them. The majority works in private sectors (i.e. in SMEs,

either self-employed or recruited by others ); whilst others work for public sectors

such as in schools, police stations, hospitals, Border post.




The day-to-day activities in and around Oshikango makes this hub one of the busiest

towns in the north. People from different walks of life comes to Helao Nafidi to either

come buy products sold in the open markets or in shops around the town of

Oshikango due to affordable prices compared to other town around the country

hence this movement creates job opportunities to the residents.

Income level and poverty The locals of Oshikango town depend on business most often. They go buy stocks in

Angola on lower prices and then come resell the products to the Namibians at

affordable prices. The readily materials sold in Oshikango ranges from car parts,

motorcycles, textile, tiles, kitchenware etc. It is these commodities that help the

locals earn a living. Some of the locals also engage in selling at the open market,

they serve variety of goods such as food (i.e. kapana, raw meat, fat cakes, fruits etc.)

and other variety of products. This however is not sufficient to sustain the living

standards of the population as their monthly income level is marginally +/- N$600 per

person.

Health

Helao Nafidi lacks adequate health facilities that can cater for the needs of the

population it serves. Oshikango specifically has only private clinics and private

pharmacies. However, there is Engela State Hospital within the reach of the locals

comprising of different facilities such as a Primary Health Care, a Casualty and

wards for In-patient admissions. Decentralization of health services needs to be

realized in order to sustain the health standards of Helao Nafidi district; more health

facilities need to be set up in order to accommodate the rapid increase of the

population.




Chapter Five: Impacts Assessment for the Silica Sand Plant Project

SUMMARY OF IMPACTS TO BE ASSESSED

A key part of scoping is a preliminary analysis of the ways in which theProject may

interact (positively and negatively) with environmental andsocioeconomic resources

or receptors. Based on the analysis of the affectedenvironment presented above,

together with preliminary comments receivedfrom stakeholders and members of

public, key issues have been identified forfurther investigation during the impact

assessment phase.The proposed Project will result in construction, operational

anddecommissioning phase impacts. Furthermore, the “legacy” left behind

upondecommissioning will also be included in the EIA process.

Specialist studies will include an analysis and assessment for each of the different

phasesassociated with the Project. Furthermore, cumulative impacts will also

beidentified and assessed, in light of current and reasonably

foreseeabledevelopments in the surrounding region. A mitigation hierarchy of

avoidance, avoid, abate, remedy and compensate will be adopted for all specialist

investigations.

Description of Environmental Aspect The following is a comprehensive list of project impacts that could result from the

interaction of project activities with environmental and social resources. Potential

impacts were identified without consideration of mitigation and management actions

that the developer will undertake (embedded controls). This was to be able to identify

the full scope of potential impacts.

This list below will be further developed in terms of potential extent and magnitude

through the EIA process. This will be followed by a detailed assessment. During the

process, some impacts may be „scoped out‟ and removed from the EIA process.




Table provides an overview of likely aspects arising from each of the key Project

activities and considers their likely interaction with socio-economic and

environmental resources and receptors.

Interaction between Project Activities and Receiving Environment

Rec

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ep

tor

Rec

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ep

tor

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Project Activities

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Pre-construction and

construction

Clearance of vegetation

Construction of access road and ring Road

Site levelling and grading

Installation of required site

services

Installation of project components

Operation

Operation of proposed facility

Presence of facility

Import and storage of chemicals/

fuel

Distribution of products by truck




Presence of workers on site

Employment and procurement

Waste management

Decommissioning

Removal of facility components

Removal of foundations

Site restoration & rehabilitation

Illustrates the manufacturing process of the proposed Silica Sand Plant depicts the

associated emissions and wastes as a result of the manufacturing process, which

may have a potential impact on the biophysical and socioeconomic environments.

These potential impacts are described further in the sections that follow.

Potential Significant Impact The following section describes potentially significant issues based on the initial site

visit, discussions with the Project team, issues and concerns raised by I&APs during

the initial notification process, and available information about the environmental

effects of the proposed Silica Plant. It is likely that many of these impacts can be

adequately addressed through the implementation of appropriate mitigation and

management measures. However, some require further specialist investigation as

part of the EIA as indicated.

Impacts to Soil and Geology

The potential effects on soils and geology from construction may include:

The formation of sinkholes;

The potential for soil properties at the site will be permanently altered due to

site preparation (e.g. compaction of soil and soil contamination); and

Site preparation and vegetation clearance activities which could

causeinstability and increased erosion potential.

These impacts can be easily mitigated or managed through the implementation of

various measures, including the appropriate foundations and engineering design. A




geotechnical and dolomite stability investigation will be undertaken for the proposed

development.

Erosion will be avoided during operations by the establishment of hardstanding

around the proposed facility.

Impact to Water Resources. A catchment dam, which is to be positioned down gradient or at the lowest point of

the site. This natural gradient will be further enhanced by the construction of surface

bed channels and drains to direct run-off water into the catchment pits/dam.When

required, the water stored in these dam will be pumped to the facility to supplement

the water requirement. Up to 90 percent of the water to be use in the plant process

will be recycled and reused with minimal amounts being lost through the lime by-

product generated.

With the water treatment plant situated approximately 1.8 km east of the proposed

site, the potential for surface water contamination is unlikely, also due to the fact that

there are no drainage channels located on or around the proposed site. The potential

for groundwater contamination is associated with uncontrolled spills of fuels and

lubricants during the construction and operational phases. Fuel storage on site will

be limited to bunded areas. Basic precautions to prevent groundwater contamination

will be identified in the draft EMP developed during the EIA phase of the Project.

Impacts to Flora and Fauna

The development of the proposed project could result in impacts on flora and fauna

due to disturbance, displacement or direct habitat loss. The disturbance associated

with construction activities can also result in the introduction and rapid colonisation of

alien (non-native) species. The following key potential impacts may result from the

proposed development:

Loss of habitat for floral and faunal species;

Displacement of certain faunal species, temporarily or permanently from the

establishment of the proposed development; and




Fragmentation of habitat and fauna populations through the presence of

security boundary fencing around the development.

An ecological specialist study will be undertaken during the EIA phase to

assess the impact on terrestrial flora and fauna and the identification of

appropriate mitigation and management measures to be included in the EMP.

Reduced patch size - may reduce populations of key plant species, which in

turn may affect the abundance of insects including butterflies they support.

These require a minimum area to sustain viable populations and may in turn

affect other species e.g. predatory birds. Also small patch size may not be

able to support the range of habitat structure needed to sustain a range of

different species.

Edge effects – if vegetation is removed the new linear gap creates a new

microclimate and a change in physical conditions which can extend varying

distances from the road edge. This newly created habitat may provide habitat

for edge species and facilitate dispersal for some species.

Impacts to Heritage and Archaeology Excavations required for the installation of proposed facility, road construction, as

well as land clearing, could disturb or destroy features of cultural heritage value, if

they exist on the site especially the cemetery and mahangu fields (communal land)

found within the site.

Impacts to Air Quality The construction, operation and decommissioning of the proposed facility will result

in emissions to air. These emissions have the potential to adverselyaffect human

health or result in nuisance to sensitive receptors. The key sources of emissions will

result from construction activities, including site clearance activities (dust) and

construction traffic resulting in the nitrogen dioxide (NO2) and particulate matter

(PM).

The operation of the Silica processing plant will also result in air emissions.

Furthermore, the increase in vehicle movements to and from the site on the local

road network has the potential to adversely affect air quality at receptors close to the




roadside. Dust from sand that might cause silicosis disease to workers and

surrounding residents.People who work in sand mining activities are most at risk for

exposure to high levels of respirable crystalline silica

To ensure environmental protection and for safety reasons, embedded controls will

be implemented to reduce these air emissions, particularly considering the existing

air quality of the region. Emissions of exhaust gases arising from on-site mobile plant

and non-mobileequipment such as generators will occur on a small scale and will be

localised. On this basis, this source of emissions will be scoped out of the

assessment.

Waste Generation Waste management within the Oshikango has for many years occurred without

consideration for future development. Landfill sites have generally been identified

with limited planning (site location) or design to reduce impacts on the natural

environment and currently pose a challenge in the Oshikango.

Waste generated during Project activities may arise from a range of

sources.Including excavated material (e.g. rock, sand, vegetation, and wood),

general waste from construction workers, equipment, materials and vehicles; and

general and limited hazardous wastes produced as a result of the production

process. In particular, maintenance activities may result in scrap metals and scrap

cylinders, including spent solvents/acids for cleaning purposes. Specific

requirements for waste management and disposal will be identified in the draft EMP

developed during the EIA phase of the Project.

Impact on Noise and Vibration During the operational phases of the project which entails the processing of Silica

sand the noise level is expected to increase due to the use of machinery and vehicle

movements. Processing machinery and processes such as the crushing of the silica

is expected to create a considerable noise level. Prolonged exposure may cause

hearing damage to the workers and the people around. The noise can also be a

nuisance to the animals.




The traffic level is expected to increase significantly during the construction and the

decommissioning phase of the project, anticipated potential impacts will be accidents

risks and traffic congestion.Traffic movement will be expected during construction

phase and will steadily increase as construction progress. The expected vehicle

movement per day is not yet determined, however an increase in traffic is

anticipated.

The following general construction activities can give rise to increased traffic on the

road:

Site clearing and earthworks – the vehicles carrying staff to site and delivering

machinery site clearing and earthworks;

Concrete works – vehicles transporting building materials (cement, gravel,

sand);

Structural steel erection – vehicles hauling structural steel to the Project site;

Mechanical installation – vehicles hauling plant equipment for installation at

the Project site;

The increase in the number of staff as construction work progresses can also

generate traffic through increased number of vehicles carrying workers to and

from the construction site.

There may be a minor increase in traffic during the construction and operation of the

proposed silica sand processing plant as a number of trucks will be required to

transport infrastructure, equipment and construction materials to the site during the

construction phase.

During operations, transportation trucks will be travelling to and from the site to

transport there and to the processing plant. A site traffic assessment will be

undertaken to provide further information regarding traffic levels and an assessment

of significance will be provided in the EIA.

During the operational phase of the project, road traffic as result of the transportation

of Silica sand from the mining site to the processing plant and transportation of the

processed Silica to the other project site such as Tses Glass Project in Tses and

Groot Ceramics in Omunkete Village in Oshikuku Constituency. The railway that




traverse cross to the proposed site, sign board indicating the hazards will be address

and communicated with relevant authority such as road authority.

The movement of traffic will be via an existing road (Theophelus Amutumbangele)

road and a bridge will be constructed on top of the Railway roads to facilitate the

movement of the trucks. The average number of trucks passing the bridge is not

estimated.

In addition transportation of staff to and from the processing plant will contribute to

traffic volumes anticipated during the operation phase. The general increase in

traffic volumes will result in increased congestion of the road leading to the Mine and

increased accident and safety risks to the communities. The significance of

theoperational phase of the Project on traffic is assessed as moderate.

ANTICIPATED ISSUES AND IMPACTS

Methodology Employed

The EIA regulations require “a description of significance of any significant effects,

including cumulative effects that may occur as a result of the undertaking of the

activity” in line with the Namibia environmental management legislation and

international best practices Groot Silica (Pty) Ltd shall implement an Environmental

Management Plan (EMP) in order to prevent, minimise and mitigate identified

negative impacts and endorse the positive impacts. Based on the current

environment and social set up of the proposed activities on site, therefore this

chapter will identify potential impacts, environmental and socio-economic impacts.

Each of the potential impacts identified is screened according to the set of indicators

set during the impact screening process as illustrated below. The scoping process

was used addressed all possible impacts and an analysis was made to investigate

its relevancy to the project. Furthermore impacts screening process was used to

determine the level of significance and degree of each impact. Below is the

assessment criteria used silica processing plant. In line with Namibia Environmental

Management Act No. 7 of 2007 and Environmental Impacts Regulations (GN 30 IN

GG 4878 OF 6 February 2012) with the direction on impacts analysis the following

impacts assessment criteria was identify the team and deemed necessary.




The assessment of all potentially identified impacts for the proposed construction

and operation of silica plant were subject to the following criteria as listed in the

Section 15(2) (h) (aa); (bb); (cc); (dd); (ee) and (gg) of the EMA Act No. 7 of 2007as

follows;

(aa) cumulative effects;

(bb) the nature of the effects;

(cc) the extent and duration of the effects;

(dd) the probability of the effects occurring;

(ee) the degree to which the effects can be reversed;

(ff) the degree to which the effects may cause irreplaceable loss of resources; and

(gg) the degree to which the effects can be mitigated

In order to determine significance of each of the potential impacts identified,

theyhave been subjected to the following questions displayed graphically (steps 1

and 2 – Fig.) and in tabular form (Table 8) below. These questions form the

methodologyfor assessing the significance of the effects or impacts identified

through this EIA process:

1. The first step was to screen out (set aside) all impacts which do not fall within

the scope of this project and responsibility of the Silica each of the potential

impacts identified was screened according to the set of indicators set during

the impact screening process as illustrated below. The list of impacts

discussed in this Section falls under the “YES” answer, namely those which

fall within the scope of the development and the responsibility of the client;

2. The next step was to determine whether sufficient information exists to assess

the potential impacts of those that remain. If insufficient information is

available to assess (with a high degree of confidence) and recommend

mitigation measures to address a given impact further investigation will be

required. However, if sufficient information is available to assess (with a high




degree of confidence) and recommend mitigation measures to address a

given impact no further investigation will be required and the impact will be

addressed in an EMP;

3. To fully understand the significance of each of the potential impacts, each

impact was subject to a range of assessment criteria. The application of these

criteria, in determining the significance of potential impacts, used a balanced

combination of duration, extent, and intensity/magnitude, modified by

probability, cumulative effects, and confidence.

4. Finally based on the answers obtained after applying steps 1-3 a decision was

made regarding the significance of the impact based on three categories –

low, medium or high (Table 11).

Criteria used to determine the significance of impacts and their definitions

ASPECT DESCRIPTION

NATURE This criteria indicates whether the proposed activity has a

positive or negative impact on the environment (environment comprise both socio-economic and biophysical aspects). Reviews the type of effect that the proposed activity will have on the relevant component of the environment and includes “what will be affected and how.

EXTENT Geographic area. This criteria measures whether the impact will

be site specific; local (limited to within 15 km of the area);

regional (limited to about 100km radius); national (limited to

within the borders of Namibia) or international (beyond Namibia‟s

borders).

DURATION This criteria looks at the lifetime of the impact, as being short/temporal (days, less than a year), medium (1-5 years), long (5-10 years but cease after operation), or permanent (more than 10 years).

INTENSITY This criteria is used to determine whether the magnitude of the impact is destructive or innocuous and whether it exceeds set standards, and is described as none (no impact); low (where the natural/social environment functions and processes are negligibly affected); medium (where the environment continues to function but in a noticeably modified manner); or high (where environmental functions and processes are altered such that they temporarily or permanently cease and/or exceeds legal standards




PROBABILITY Considers the likelihood of the impact occurring and is described

as uncertain, improbable (low likelihood), probable (distinct possibility), highly probable (most likely) or definite (impact will happen regardless of prevention measures).

SIGNIFICANCE Significance is given before and after mitigation. Low if the impact will not have an influence on the decision or require to be significantly accommodated in the project design, Medium if the impact could have an influence on the environment which will require modification of the project design or alternative mitigation (the route can be used, but with deviations or mitigation) High where it could have a “no-go” implication regardless of any possible mitigation.

STATUS OF THE IMPACT

A statement of whether the impact is positive (a benefit), negative (a cost), or neutral. Indicate in each case who is likely to benefit and who is likely to bear the costs of each impact.

DEGREE OF CONFIDENCE IN PREDICTION

This is based on the availability of information and knowledge used to assess the impacts.

The application of the above criteria is to determine the significance of potential

impacts by the proposed establishment uses a balanced combination of duration,

extent, and intensity/magnitude, modified by probability. Significance is established

by extend, duration, intensity and probability. The Impact assessment matrix further

gives significance of impact before mitigation and after mitigation as described

below:

Table: Environmental Impact Rating Criteria/Priority

Magnitude

Probability Minor Low Medium High Major

Almost

Certain

5

Low Medium High High High




Likely

4

Low Medium High High High

Possible

3

Low Medium Medium High High

Unlikely

2

Low Low Medium Medium High

Rare

1

Low Low Low Medium Medium

Impact Assessment

By subjecting each of the potential impacts to the criteria stipulated above, the EIA

team established the significance of each impact prior to implementing mitigation

measures and then after mitigation measures have been implemented. Some of the

mitigation measures are mentioned but detailed descriptions of management actions

are contained in the accompanying EMP.




Table 12: Environmental Impact Assessment Matrix for Silica Sand Plant establishment and operation.

Impact Status/nature Extent Duration

Intensity Probability Significance

Before Mitigation

Mitigation applied Post Mitigation

Construction Phase

Physical disturbance of land (soil) during excavations, site preparations and construction activities

-Erosion -Proliferation of tracks -Changes on soil properties i.e. soil structure due to ground compaction and soil texture. -poor scenery view of the area as a result of many stockpiled excavated material.

Local Short Medium Probable Medium -Restrict construction activities to defined areas. -Use surface anchored foundations with very limited rock breaking. -Ensure that only sites where structures are to be set are only affected. -Restrict the movement of

construction vehicles, bull

dozers, excavators to confined

routes. All personnel and

vehicles used for construction

purposes should remain within

these demarcated routes and

areas, i.e. vehicles should

not be allowed to drive

randomly across village areas,

but should remain within

demarcated and approved

routes. The purpose of this

Low




measure is to:

a) limit unnecessary

compaction of topsoil; and

b) Prevent disturbance of

vegetation outside of factory

site area.

-Avoid using machines that is

too heavy resulting in

compaction.

Any spoil generated excavations and site preparation should only be stockpiled in approved areas, and must be shaped and trimmed.

Physical removal of vegetation during excavations and construction activities (de-bushing) Vegetation leaf disturbance of the nearby vegetation due to dust during excavations and construction

-May result in removal and destruction of protected and endemic tree species -This will expose the land/soil to wind and water erosion. -May result in

local Long term

Medium Definite High -Vegetation removal must only be done on the area where structures are going to be set up. -Monitor and count all marked plant species to ensure they are not removed without a valid permit. -Wet the area before sand/gravel abstraction to supress dust.

Medium/ low




activities leaves of the vegetation changing its colour due to dust generated during excavations and construction activities and consequently the leaves will die.

-Reduce haulage speed to 30km/hr

Dust generated during site clearance, ground excavation, piling and earthworks, on site earth moving operations, site levelling, cutting, grinding and drilling operations etc. Vehicle movements over haul roads (especially

Dust releases can be a nuisance to the local residences as well as help contributing into local atmospheric particulate matter content

Local Medium

High Definite Medium -All construction traffic shall follow specifically designated routes -Speed limits shall be put into place on site for all vehicular movements -All vehicles carrying loose material shall be covered -Wheel wash facility shall be used for vehicles leaving site -Where necessary, use of road sweepers shall be incorporated to ensure gravel roads remain clear of dust and mud




unpaved). Vehicle movements on site during dry periods, re-suspension of particulates from construction vehicle movements on site, wind blowing across the site during dry periods. Stockpiling of excavated materials, cutting, grinding and drilling operations. Accidental spillage and loss of load from vehicles carrying loose material. Deep excavations, Tipping, Earthworks

-Road edges and pathways must be swept by hand and damped down as necessary -To be sealed or sprayed with chemical bonding agents as require -Location of stockpiles away from any sensitive receptors wherever possible -Monitoring and mitigation activity to be increased during significantly dry and windy periods -Where necessary, use of enclosures to be considered to ensure reduction in dust migration -Deliveries of significantly dusty materials to be sprayed to reduce dust potential -All cutting and grinding operations to be conducted in ways to reduce risk of dust -Water sprinkling before working on the construction areas

Noise generations from movement and working of

-Negative effect on local animals and

Regional

Temporary

Medium Highly probable

High -All vehicles and mechanical plant used for the purpose of the works shall be fitted with

Medium




construction equipment during different construction phases (site preparation, excavations, earthworks) Noise generations during the transportation of equipment and factory material to the site Vibrations from equipment and operations

birds and the noise causes nuisance to nearby residences

effective exhaust silencers. -Materials shall be delivered to the site during normal site working hours. -Maintenance: Regular and effective maintenance by trained personnel is essential and will do much to reduce noise from machinery. -No machinery will be left running unnecessarily. -Only machines that are in use must be on.

Disturbance and killing of soil rodents and small animals.

-Soil rodents and small animals like rabbits that are within the project area will be affected and my suffer relocation

local Long low Definite medium -Remove special small animal species encountered -Forbid indiscriminate killing of animals.

low




and some will be killed during excavations.

Direct habitat loss, as the area will be occupied by the factories.

Negative impact on local habitats and vegetative species

Local Permanent

high Definite High -Monitor and count all marked plant species to ensure they are not removed without a valid permit. -Ensure minimum disturbance to the surrounding environment.

Medium

Archaeological Landscape

Visual degradation

Local Short Term

Medium Improbable Medium -Demarcate, protect and avoid development near sites. If removal is inevitable, apply at Heritage Council via an archaeologist

Low

Change in landscape character (New land use)

New structures such as very big buildings and roads in the environment

local Long term

Medium Probable High -Ensure that new structures blend in with the environment and there is rehabilitation of disturbed area to leave the area in almost the same level as it was before if not better.

Low

Contamination of soils by

hydrocarbon pollutants (grease,

Heavy equipment oils and fuel storage tanks

local Short term

Medium Probable Medium -Ensure there is a spillage management plan in place and licensing of any oils or fuel stored on site

-Low




oils, fuel spills and leakages from machinery and fugitive wastes.

on site

Air Pollutants releases like carbon emission from construction vehicles.

-Dust releases can be a nuisance to the local residences as well as help contributing into local atmospheric particulate matter content

Regional

Medium term

Medium Probable Medium -There is need to service the equipment to reduce carbon emissions. -“Switch it Off” schemes and other energy saving campaigns shall be implemented on site to encourage all personnel to consider their carbon footprint.

Low

General Solid Waste from construction

(rubbles, cement bags, paint

containers, broken equipment etc.) and stockpiled

material removed during excavations

-General Waste from construction activities can result in pollution in the environmental especially material that is not bio-degradable.

local Long term

High Definite High -An effective construction waste management plan to be implemented by the construction supervisor and the contractor, separating waste before disposal.

Low




Employment opportunities

The project will create employment opportunities during the construction stage as manual labour will be taken from the local people. More than 1400 local people have been recruited to date and are going to be involved in daily construction activities.

Regional

Long term

High Definite High -Employ local individual through the local Helao Nafidi Town to ensure equal employment opportunities. -Local Traditional Authority to be involved in the recruitment of the locals from the areas (Oukwanyama traditional Authority and )

High

Health and social issues

Potential accidents and illnesses as the traffic flow increases, many risk associated on

Local Short term

Low Probable Medium -Health and safety regulations should be enforced on all the workers. -Safety regulations include life and health insurance, first aid kits; protective clothing such as uniforms and gloves.

Low




working with heavy construction equipment.

Operational Phase

Solid Waste from restaurant food waste, guests waste, packaging

Waste disposal into the natural environment can be detrimental to wild organisms and at times highly toxic

Local Long term

Medium Definite Medium -Implement a waste management system, separating waste accordingly and employ sustainable disposal strategies. -Recyclable waste will be sent for recycling in Oshikango.

Low

Nuisance particulate matter in the air.

The generation of dust and particulates from the inadequate storage of ash, char and carbon

Long Short term

Low Probable Low -According to the available information, no Dust will be generated from the process under normal operating conditions.




black.

General disturbance to the natural ecosystem of the area both fauna and flora ecological integrations.

Massive obstruction of sand and processing production has an impact on the surrounding ecosystems through noise, human movements, traffic, emissions.

Local Long term

Low Definite Medium -Restrict activities to defined areas.

Low

Wastewater Industrial Process Wastewater discharge

-Significant water use

Local Long term

Medium Definite Medium - Use of closed-water process systems -Recycling of the wastewater released.

Low

Disturbance of biodiversity due to vibrations (Local animals such as birds and small animals could be driven away from their habitats)

Local nuisance

Local Long term

Medium Restrict activities to defined areas. - For movement in the bushes use designated

Medium Low




tracks to avoid unnecessary removal of vegetation

Noise (The noise level from glass-pressing machines can be as high as 100 decibels or more, potentially causing hearing impairment.

Exposure to noise results in the hearing loss illness for those who will be working directly in the processing area with noise. .

Local Long term

Medium Definite Medium -Use of hearing protection and other PPE - High-quality industrial earplugs or ear muffs will be provided to those working directly in noise section

Respiratory Hazards (Dust, Fumes, and Toxic Compound Exposure)

Occupational health risks for silica processing will be related to the presence, in the workplace, of fine airborne PM

Local Long term

Medium Definite Medium

Segregating of raw material storage and batch preparation areas from other operational areas;

Implementing correct loading and unloading practices;

Using ventilation systems in the (silos) where the raw material will be housed.

Low

High population -Results in -Local -long Medium Definite High -Educate employees on social Medium




influx to small town of Tses.

social tensions and increase infections of sexually transmitted diseases particularly HIV and AIDS, and other Sexual Transmitted Diseases (STDs).

term integration and sexual behaviour -Strict enforcement of company laws and policies on social behaviour at work.

Social integration

Potential for conflict between people of different backgrounds and cultural beliefs.

Local Short Term

Medium Probable Medium -Public relations should adequately address community and the lodge should establish a public relations policy guiding tourist visitor‟s contact with locals.

Low

Community development

Employment creation to the locals (more than 1400 factory workers to be

Regional

Long term

High Definite High -Promote local businesses and employ locals on any general labour required. -Groot silica must also take part of the social responsibility.

High




recruited from the local areas), infrastructure services (roads, schools, health facilities as Oshikango developed) and business integrations

Decommissioning phase

Removal of Infrastructure

If there will be removal of infrastructure the environment is bound to be disturbed again and waste will be generated.

Local Short Term

Medium Probable Medium -In the event of infrastructure removal, the proponent has to notify the Ministry of Environment as well as dispose all waste sustainably. -A Waste Inventory and Management Plan for the Decommissioning phase shall be prepared and implemented during decommissioning.

Low

Accidents These accidents are associated with the high

Local Short term

Medium Probable Low -Movement of vehicles should follow road use guidelines and regulations of Namibia. -Reduce speeds of the

Low




flow movement of vehicles removing the material from the site. Railway station which is closer to the site could pose danger to the proposed project

vehicles carrying the material. - precaution measures of safety and health should be in place to prevent danger.

Loss of employment

During the decommissioning phase there will be retrenchment of employees which will affect their livelihoods and source of income.

Regional

Long term

Medium Definite Medium -In the event that the proponent decides to stop operations, appropriate retrenchment procedures should be followed. -Social security for employees should be put in place in anticipation for cases like these.

Low




CONCLUSION AND RECOMMENDATIONS

The Environmental Impact Assessment (EIA) process for the Tses Glass

development has been undertaken in accordance with the EIA Regulations

published in Government Notice No. 30, in terms of Section 56 of the Namibia

Environmental Management Act, 2007 (Act No. 7 of 2007). In order to protect the environment and ensure that the Tses Glass development is

constructed and operated in an environmentally responsible manner, there are a

number of significant pieces of environmental legislation that have been taken into

account during this study. These include:

The Constitution of Namibia (February 9, 1990)

The Constitution of Namibia (February 9, 1990)

Environmental Management Act Regulations (GN 30 in GG 4878 of 6 February 2012

Environmental Assessment Policy of Namibia (1994)

Atmospheric Pollution Prevention Ordinance(1976)

Soil Conservation Act (76 of 1969)

National Heritage Act, 2004 (Act No. 27 of 2004

Forest Act, 2001 (Act No. 12 of 2001)

Hazardous Substance Ordinance (No. 15 of 1973) and Regulations

Public Health Act (36 of 1919

Occupational Safety and HealthGN156/1997 (GG 1617)

This relevant legislation has informed the identification and development of

appropriate management and mitigation measures that should be implemented in

order to minimise potentially significant impacts associated with the project. The conclusions of this EIASR including comments and concerns from Interested

and Affected Parties (I&APs), are as a result of a comprehensive EIA study.

These studies are based on issues identified in the Environmental Scoping Study

and the parallel process of public participation through to the EIA phase. The public consultation process has been inclusive, and every effort has been made

to include representatives of all stakeholders within the process.




Assumptions, Uncertainties or Gaps in Know ledge

All assumptions, uncertainties and Gaps in knowledge described and listed below

was in compliance with the requirements of the EMA Act No 7 of 2007 Section

15(2)(i). All assumptions were drawn from reasonable experience of the EAPs.

All information provided by Silica Sand (Pty) Ltd and their specialist consultants to

the Groot Environment was correct and valid at the time it was provided;

Groot Environment does not accept any responsibility in the event that additional

information comes to light at a later stage of the process;

All data from an unpublished research is valid and accurate; and

The scope of this investigation is limited to assessing the potential environmental

impacts associated with the Tses Glass development.

The communities and stakeholders were having challenge on understanding the

whole project as it is a new project never implemented in Namibia and Africa.

Concluding Remarks and EAP Opinion

This final EIASR provides an assessment of both the benefits and potential negative

impacts anticipated as a result of the project development. It further provides a

description of the affected environment and alternatives proposed for the Tses Glass

development.

Should the proposed mitigation measures be implemented correctly, the Silica Sand

processing plant development will be a viable development to Helao Nafidi Town,

Namibia, SADC and Africa. The findings conclude that there are no significant

environmental fatal flaws that could prevent the proposed Silica sand development

and that the recommended mitigation and management measures contained in the

preceding chapter and Environmental Management Plan are implemented.

From the outcomes of this assessment it is the view of the Groot Environment that

this project will have a positive social and economic contribution. It has been




acknowledged that there will be impacts on the potential biophysical environment;

however with the implementation of the mitigation measures outlined in this report

and the EMP aswell as through adequate environmental monitoring and enforcement

those impacts can be successfully mitigated. This will in turn enable the development

proposal to take place in an appropriate manner.

Thus, from all the findings (specifically from the general public identified during

consultation period) of this report, it is recommended that the development be

authorised as the public is really positive and looking forward to see development in

their area.

Conditions and Final Recommendations

In order to achieve appropriate environmental management standards and ensure

that the findings of the environmental studies are implemented through practical

measures, the recommendations from this EIA study are included within an EMP.

The EMP must be used to ensure compliance with environmental specifications and

management measures. The implementation of this EMP for the life cycle phases of

the project is considered to be vital in achieving the appropriate environmental

management standards as detailed for this project.

In addition, the following key conditions should be included as part of the

authorisation:

a) The proponent is not negated from complying with any other statutory

requirements that is applicable to the undertaking of the activity. Relevant key

legislation that must be complied with by the proponent includes inter alia:

Provisions of the Environmental Management Act, 2007 (No. 7 of 2007);

Provisions of the Occupational Safety and Health GN 156/1997 (GG

1617)

Provisions of the Atmospheric Pollution Prevention Ordinance of 1976

Provisions of the Hazardous Substance Ordinance (No. 15 of 1973) and

Regulations

Provisions of the Public Health Act (36 of 1919)

Provisions of the National Heritage Act, 2004 (Act No. 27 of 2004)




b) The proponent must have a suitably experienced Environmental Control

Officer (ECO) for the construction phase of the development that will have the

responsibility to ensure that the mitigation / rehabilitation measures and

recommendations are implemented and to ensure compliance with the

provisions of the EMP.

c) Ambient Air Quality tests to be done after every 3 years of operation to check

whether the emissions from the factory are not exceeding the acceptable

levels as regulated in theAtmospheric Pollution Prevention Ordinance of 1976.

It is the responsibility of the proponent to make sure he get suitably, qualified

and experienced air quality tester after every 3 years of operation.

d) The Pollution Prevention Control Management Plan must be complied in

compliance with the following regulationsAtmospheric Pollution Prevention

Ordinance of 1976 and the Hazardous Substance Ordinance (No. 15 of

1973).

e) The Decommissioning and Rehabilitation Plan must be compiled.




Chapter Six: Environmental Management Plan (EMP)

Introduction

This Environmental Management Plan (EMP) has been drafted as part of the

Scoping Report which was compiled in terms of the Environmental Assessment for

the sand processing activities conducted by Silica Mining Pty. The content thereof

has been tailored according to the Regulations of the Environmental Management

Act, 2007 (Act No 7 of 2007) Regulation No 30 of 2011 listing No 8(j) (aa) (bb) (cc).

The aim thereof is to provide management measures to address the effects on the

environment that have been identified in the Scoping Report.

The propose Silica plant to be establishment will have environmental impacts as

indicated in the previous chapter. This section is aimed at describing The

Environmental Management Plan for impacts associated with Silica Sand (Pty) Ltd

proposed glass manufacturing factory establishment project. The EMP stipulates the

management of environmental programs in a systematic, planned and documented

manner.

The EMP below includes the organizational structure, planning and monitoring for

environmental protection at the proposed project area development and other areas

of its influence. The aim is to ensure that the proponent maintains adequate control

over the project construction and operations in order to:

To prevent negative impacts where possible;

Reduce or minimise the extent of impact during project life cycle;

Prevent long term environmental degradation.

This EMP has been divided into the following parts:

Construction Environmental Management Plan (CEMP)

Operations Management Plan (OMP)

Pollution Prevention Plan (PPP)

Decommissioning and Rehabilitation Plan (DRP)




EMP Administration

There is a strong need to clearly outline the roles and responsibilities of all

stakeholders to ensure that the EMP is fully implemented. There is also a need for

the proponent to appoint an overall responsible person (project manager) to ensure

the successful implementation of the EMP as highlighted below:

Environmental Coordinator

The Environmental Coordinator (EC) will inspect operational areas on a three

monthly basis and at the onset of processing activities, to ensure that all

specifications are met. The duties of the environmental coordinator will be the

following:

Advise the operations team in respect of implementation of the environmental specifications,

Conduct visits to ensure all work is aligned to the EMP,

The environmental coordinator shall inspect the site during the three monthly visits. All rehabilitation results will be included in the quarterly report,

Conduct inspections of the rehabilitation area and give guidance regarding rehabilitation measures if any.

The Operations Manager The duties of the Operations Manager (OM) or his nominated authority are as follows: Familiarize themselves with the requirements of the EMP,

Monitor employees‟ and contractors‟ compliance with the environmental specifications and enforce adherence,

Communicate all environment related incidents with the environmental coordinator and distribute internally to avoid repeats,

Maintain a record of activities relevant to environmental management,




The Operations Manager shall be responsible for monitoring and the enforcement of

the environmental management specifications on a day-to-day basis. Any violation of

Silica Mining Pty Ltd Environmental Management Plan, the environmental

specifications shall be recorded and the agreed on disciplinary measures taken.

Senior personnel and contractors The duties of the senior personnel/contractors are as follows:

Familiarize themselves with the requirements of the EMP,

Comply with the environmental management specifications,

Ensure that all team members are familiar with the environmental management specifications.

Environmental Management Requirements

The following are management actions that should be adhered to by the proponent,

Silica Mining Pty Ltd, at all times. These management actions cover the operational

and decommissioning phases of Silica mining. All activities should be carried out in

line with this Environmental Management Plan (EMP), as may be applicable to the

specific phase and activities carried out.

This section of the EMP details the various management processes, from where the

operations are currently to its end, concerning the effective management of all

operational areas.

The EMP is laid out as follows:

Planning and Design;

Operations Contract Preparation Management Requirements; and

Operations Mitigation Requirements

Table Legislation Framework and Related Contact Person




THEME LEGISLATION INSTRUMENT

MANAGEMENT REQUIREMENTS

CONTACT PERSON

Archaeology National Heritage Act 27 of 2004

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.

Rev Salomon April Tel: 061-244-375/385/598

Environmental Environmental Management Act 7 of 2007 EIA Regulations (EIAR) GN 57/2007 (GG 3812)

The amendment transfer or renewal of the environmental Clearance three years thereafter.

Dr Freddy Sikabongo/ Mrs Saima Angula Tel: 061-284751

Forestry Forest Act 12 of 2001 Nature Conservation Ordinance 4 of 1975

Shrubs and bushes within 100m from the site may not be cut. Destroyed or removed without authorised permission. A harvesting permit is required if surrounding vegetation is to collected (harvested) for any use.

Mr Ambuga Tel: 061-265450

Labour Labour Act 11 of 2007 Health and Safety Regulations (HSR) GN156/1997 (GG 1617).

Adhere to all applicable provisions of the Labour Act and the Health and safety regulations.

Labour Law Advice Tel: 061-309 957

Planning and Design Phase

This phase contains elements that should be considered during the planning and

design phase of the plant. This typically consists of studies to help companies

determine if and how a project can be safe, environmentally sound, economically

viable and socially responsible.




The planning and Design phase for the project is in progress which entails the

environmental assessment, the feasibility study and the environment.

Table Management requirements for the Planning and Design phase

Aspect Management Requirement

EMP Implementation

Develop an effective strategy to accurately carry out the mitigation actions relevant to the Silica Processing activities in this environment

Establish an applicable internal disciplinary system for non-compliance

Financial Provision

Allocate appropriate budgetary allowances to develop proper Silica Processing planning and environmental rehabilitation actions through the compulsory development of plans and strategies to mitigate negative environmental and social impacts

Recruitment For all new employees:

Adhere to the legal provisions for the recruitment of labour (target percentages for gender balance, optimal use of local labour and SME‟s, etc.) in the contract aiming for a 15% representation of women

The recruitment process must be formal and organised

Preference should be given to recruit those who live within the project area and are fit to work

Stakeholder Communication

Communicate planned activities with stakeholders through established community communication channels

Health and Safety Adhere to all legal requirements pertaining to health and

safety; and

Compile health and safety plan.

Silica Processing Contract Preparation Management

This phase contains elements that should be considered whenever Silica processing

activities are contracted or sub-contracted to a company other than the holder of the




mining right. It is further applicable to any related contract work which may be

employed by Silica Mining Pty Ltd as well as pertaining to the proponent themselves.

These management requirements are important to ensure that safe managing of the

environment takes place while sand processing activities are ongoing.

Sand mining contract and operational preparation management requirements

Aspect Management Requirement

EMP Implementation

Relevant sections of this EMP should be included in the tender documents for all development so that tenderers can make provision for implementation of the EMP

Financial Provision

Financial provision for the compilation of a Waste Management Plan should be included as a cost item within tenders concerning sand mining operations

Financial provision for the facilitation of an induction programme for senior and casual sand mining personnel as well as subcontractors and associated personnel should be included as a cost item within tenders concerning all sand mining activities

Financial provision for the compilation of a Vegetation Management Plan should be included as a cost item within sand mining tender documents

Financial provision for the drafting of a Communication Plan should be included as a cost item within sand mining tender documents

Recruitment For all new employees;

Provisions designed to maximise the use of local labour should be included within tenders concerning sand mining operations

A provision stating that all unskilled labour should be sourced from the area should be included within tenders concerning sand mining operations

Specific recruitment procedures ensuring local firms enjoy preference during tender adjudication should be included within tenders concerning sand mining operations

The following table provides a large-scale overview of all the major environmental

management themes pertaining to both generic and site-specific Silica processing




mitigation details. This table serves to act as quick reference (by colour), for the

detailed mitigation details that follow below. The identified impacts in the Scoping

Study are mitigated under these themes. In light of current operations and the fact

that various additional management and mitigation measures may be provided,

(once an integrated report has been compiled with all of the specialist

recommendations), this EMP should be amended to reflect an integrated approach

to the management of activities. These measures are therefore proposed as a

minimum to be conducted for 3 years during which time the compilation of an

operation specific plan may be drafted for Silica processing activities.

Table Generic and site-specific environmental management actions for Sand

mining phases

Theme Objective Mitigation Details Generic Site Specific

Waste Management Avoid and where not possible minimise all pollution associated with sand mining

Section A Section A

Health and Safety Safeguard health and safety of staff and the general public

Section B Section B

Dust and Noise Avoid and where not possible minimise dust and noise associated with sand mining activities

Section C Section C

Environmental Training and Awareness

Awareness creation regarding the provisions of the EMP as well as the importance of safeguarding environmental resources

Section D N/A

Environmental Conservation

Minimise sand mining activity footprint and safeguard biodiversity in ecologically sensitive areas

Section E Section E

Employment/Recruitment Minimise negative conflict through legal and fair recruitment practices

Section F Section F

Stakeholder Communication

Provide a platform for stakeholders to raise grievances and receive feedback and hence minimise negative conflict

Section G Section G




Social and Cultural Heritage

Ensure due consideration is given to matters regarding the cultural and general wellbeing of the affected community and matters incidental thereto

Section H N/A

SECTION A: WASTE MANAGEMENT

ASPECTS MITIGATION MEASURE

GENERIC MITIGATION DETAILS

Waste Management Plan

The Proponent should compile a Waste Management Plan that should address as a minimum the mitigation measures included below

Hazardous Waste All sand mining vehicles (4x4 vehicles and trucks) and equipment on site, should be provided with a drip tray/oil spill kit:

Drip trays and sealable containers are to be transported with vehicles wherever they go

Drip trays should be cleaned daily and spillage handled, stored and disposed of as hazardous waste

All sand mining machines and trucks should be

maintained regularly to prevent oil leakages. Maintenance of vehicles is not permitted to occur on site as far as reasonably possible, but if maintenance is to be undertaken on site, measures need to be put in place to avoid hydrocarbon spillages

Maintenance and washing of sand mining machines and trucks should be conducted at a suitable site/facility which adhere to the following:

The work area/facility should be lined to be

impermeable The work area/facility should have an oil-water

separator (oil trap) to collect any run-off from the washing and or maintenance activities, or be equipped with an oil and water separation system

Spilled oil or fuel should be treated as hazardous waste, disposed of as it occurs in the appropriate hazardous waste containers (sealable drums) on site, and removed off site at the end of each day to a secure location of site from where it should be disposed of at a appropriate hazardous waste disposal site \ as soon as possible. All such waste




should be provided to specialists in the handing and treatment of such materials

All hazardous substances (e.g. fuel, grease, oil, drilling fluids etc.) or chemicals should be stored in a specific location at the sand mining off-site on an impermeable surface which is bunded

Sewage and grey water from temporary portable toilets on site

Use of toilets instead of the veldt must be strictly adhered to

General waste

The plant site should be kept tidy at all times. All domestic and general waste produced daily should be contained

No waste may be buried or burned No waste is to be left uncontained, it should be stored

in suitable containers, over night Waste containers (bins) should be emptied regularly

and removed from site to the nearest official waste disposal site. All recyclable waste needs to be taken to the nearest recycling depot if available

A sufficient number of separate waste containers (bins) for hazardous and domestic/general waste must be provided on site. These should be clearly marked as such

Sand processing personnel should be sensitised to dispose of waste in a responsible manner and not to litter

No waste may remain on site after the completion of operations

SITE SPECIFIC MITIGATION

Sewage and grey water from temporary portable toilets on site

Portable toilets such as portable camping units, must be provided during construction (one for every 15 people) :

Discharging of the portable units should to be conducted at an existing suitable facility

Waste rock boulders.

All heaps of large rocks / unusable aggregate should be removed from operational

MONITORING REQUIREMENTS

Monitor whether the provisions set out in this EMP concerning waste management is being applied as per instructions

All non-compliances should be recorded and discussed at weekly site meetings and timeous remedial actions taken

All guilty parties that are in contravention of the provisions set out for managing waste should be given a penalty and according to the severity of the impact appropriate steps taken.




SECTION B: HEALTH AND SAFETY

ASPECTS MITIGATION MEASURES

GENERIC MITIGATION

Health and Safety Plan

The Proponent should compile a Health and Safety Plan that should address as a minimum the mitigation measures included below, as well as the Regulations Pertaining to Health and Safety at the Workplace

Road Safety

Demarcate roads clearly Off-road driving should not be allowed unless roads have

been approved by the affected landowner/occupant/ person or entity responsible for the road

All vehicles that transport sand and materials to and from the site must be roadworthy

Drivers that transport sand and materials should have a valid driver‟s license and should adhere to all traffic rules

Loads upon vehicles should be properly secured to avoid items falling off the vehicle

Drivers should not exceed a speed limit of 30km/ hour on all dirt roads

Safety around general work areas

Provide additional warning signage in areas of movement and in “no personnel” areas where workers are not active

Demarcate general work area with a suitable and visible marker

Only sand mining personnel will be allowed within these work areas

Fire extinguishers should always be available at the operational sites

Comply with all mitigation measures laid out in Section A (Waste Management mitigation details)

Workers at the working directly with acidic should be provided with proper protective plant equipments.

Ablutions

Separate ablutions (toilet) should be available for men and

women if required Portable toilets (i.e. easily transportable camp toilets)

should be available during the construction face.

Sewage waste needs to be removed on a regular basis to the Helao Nafidi sewage disposal site. Alternatively, it is to be pumped into sealable containers and store until it can be removed to such sites

Workers responsible for cleaning the toilets should be provided with latex gloves and masks and any other related PPE

Open fires No open fires may be made anywhere on or around




operational areas No wood may be collected within or near the operational

area without the required permit

General

Dust protection masks should be provided to workers when working in dusty environments

No person should be allowed to smoke on or close to

operational areas where acidic substances are used.

Provisions should be made for smoking workers; smoking zone should be clearly defined and indicated.

No workers should be allowed to drink alcohol or be under the influence of recreational drugs during work hours

No workers should be allowed on site if under the influence of alcohol or recreational drugs

Proper safety gear to be supplied to all personnel according to each one‟s level of risk exposure as per legal requirements

Provide at least 2 litres of fresh potable water during hot summer months) to each personnel member per day during work hours to prevent dehydration and promote productivity

Provide adequate shading accessories to personnel to prevent sunstroke

Frequent, short breaks in between work hours should be implemented

Workers should be regularly screen to determine their level of exposure to Silica Crystalline.

SITE SPECIFIC MITIGATION

Road Maintenance

All dirt roads used for sand transportation to be maintained by grading of the road

Collaboration with the Helao Nafidi Town Council regarding road maintenance of tar roads used for sand haulage to be reached


Non-compliances should be recorded and discussed at the weekly meetings with the operations manager and coordinator and appropriate steps taken to rectify such recorded non-compliances

SECTION C: DUST AND NOISE





GENERICMITIGATION DETAILS

Dust

Use processes and equipment that reduces dust generations Appropriately rated and fitted dust masks should be given to

personnel working in areas of dust exposure All haul roads should be treated with a chemical surfactant Grey water should be used for additional dust suppression if

available and as required.

Noise

Work hours should be restricted to between dawn and dusk

where sand mining involving the use of heavy equipment, power tools, and the movement of heavy vehicles is within 500 m from sensitive receptors (such as homesteads). In the event that this is not possible, the affected community need to be consulted well in advance to agree on a mutually acceptable solution

SITE SPECIFIC MITIGATION DETAILS

Noise

No work may be conducted on Sundays Sand processing activities may only be conducted on public

holidays with the permission of the relevant affected community The movement of vehicles are restricted to working hours or

times agreed upon between the team and affected community


When complaints are received from farmers or affected communities regarding noise and dust nuisance, additional abatement in the form of water spraying and restricted work hours should be implemented. Communication with those that complained should be continued to determine whether the problem has been resolved

SECTION D: ENVIRONMENTAL TRAINING AND AWARENESS



Environmental Induction (Training)

All personnel are to undergo environmental induction (training) all processing stages, which should include as a minimum the following: Detailed review of the current EMP to familiarize

personnel with requirements Explanation of the importance of complying with the

EMP Discussion of the potential environmental impacts of

the Silica sand processing activities Employees‟ roles and responsibilities, including

emergency preparedness Explanation of the mitigation measures that must be




implemented when particular work groups carry out their respective activities

Explanation of the specific mitigation measures within this EMP especially unfamiliar provisions


Environmental Manager to request attendance registers be completed by all personnel attending induction training sessions

SECTION E: ENVIRONMENTAL CONSERVATION

ASPECT MITIGATION MEASURE


Conservation of vegetation The proponent should compile a Vegetation Management Plan which should include the following as a minimum:

No trees occurring in this environment may be damaged or removed for any purpose without the required permit

Protected trees need to be marked and their location recorded on a map (especially with regards to road creation)

Conservation of fauna (includes livestock)

Movements of staff are restricted to the operational sites and work areas only

No hunting, trapping, fishing, setting of snares, or any other disturbance of any fauna species allowed without a required permit

Track / road creation Cutting down of trees should be avoided as far as possible

Access tracks and roads should not be wider than the normal width to accommodate an sand mining machines and trucks

No tracks / roads must be created unless unavoidable

Rehabilitation Remove all waste, and any other remains from the site

Fill holes, rip up, rake track/ roads,




and spread stockpiled topsoil back over the entire new track / roads made, to allow re-vegetation

Make sure that the environmental coordinator has a site inspection to check rehabilitation efforts of sand island

SITE SPECIFIC MITIGATION MEASURES

Protection of crops and orchards Buffer zones of at least 150m must be established around crops. In the event that this is not possible, the community need to be consulted well in advance to agree on mutually acceptable solution (which may include compensation)

Protection of flora A vegetation specialist is to be employed to identify sensitive flora species on each island which should tie in with an integrated overall plan for the area

Integrated recommendations regarding flora protection should be implemented as per the integration of an overall approach to conservation for the area.

General Protected plant should be avoided as far as possible. The layout of the plant should be set In such a way as to minimise the number of vegetation affected


Monitor operational areas and all access tracks and roads. Record all negligent plant destruction sightings, and apply the penalty system to all guilty parties Constant monitoring and record keeping of progress must be made until all

rehabilitation is done, approved and signed off by the Environmental Coordinator at the decommissioning of sand mining in an area (after each island has been removed)

SECTION F: SOCIAL AND CULTURAL HERITAGE






Archaeology Should a heritage site or archaeological site be uncovered or discovered during the construction phase, a “chance find” procedure should be applied in the order they appear below:

If operating machinery or equipment, stop work

Demarcate the site with danger tape

Determine GPS position if possible

Report findings to foreman

Report findings, site location and actions taken to superintendent

Cease any works in immediate vicinity

Visit the site and consult any potentially affected community to determine whether work can proceed without damage to findings

Determine and demarcate the exclusion boundary

Site location and details to be added to the project‟s Geographic Information System (GIS) for field confirmation by an archaeologist

Inspect site and confirm addition to project GIS

Advise the National Heritage Council (NHC) and request written permission to remove findings from work area

Recover, package and label findings for transfer to the National Museum

Should human remains be found, the following actions will be required:

Apply the chance find procedure as described above

Schedule a field inspection with an archaeologist to confirm that remains are human

Advise and liaise with the NHC and Police

Remains will be recovered and removed to either the National




Museum or the National Forensic Laboratory.

Contact person at NHC: Rev. Solomon April; Tel: (061) 244 375/385/594


Make sure no archaeological site is disturbed whilst excavation and recovery takes place

Make sure everything of importance, as identified by an appropriate specialist, is removed from site and declared safe by an archaeologist before sand mining can continue on the site

Rehabilitation and Decommissioning

This phase contains elements that should be considered when plant operational

activities have been completed. These management requirements are important to

ensure that rehabilitation of the environment is optimised. It is important to note that

ongoing rehabilitation initiatives have been captured and detailed in the various

themes (as set out above).

Management requirements for Rehabilitation and Decommissioning

ASPECT MANAGEMENT REQUIREMENT

EMP IMPLEMENTATION RECORD Filing and dating of all reports (including photographic documentation of successful rehabilitation initiatives)

A final site inspection to be conducted and documented 3 months after all activities associated with the sand processing initiative has been competed for the plant

FINANCIAL PROVISIONS Allocate appropriate budgetary allowances for all possible rehabilitation activities and initiatives (including such requirements for a communication strategy)

LANDOWNER AND I&AP Develop a communication strategy which will clearly indicate future operations (i.e. will further activities be conducted on the site.




APPENDIX B: GEOTECHNICAL REPORT

APPENDIX C: BIODIVERSITY STUDY REPORT

APPENDIX D: SPECILAIST INPUT (HEALTH RISK ASSESSEMENT)

APPENDIX E: ISSUES AND RESPOND TRIAL (PUBLIC CONSULATAION

DOCUMENT)

APPENDIX F: MINUTES OF THE MEETING HELD WITH STAKEHOLDERS AND

COMMUNITY PEOPLE

APPENDIX G: PUBLIC MEETING ATTANDENCE REGISTER AND REGISTER OF

THE I& APs

APPENDIX H: NEWSPAPER NOTICES

APPENDIX J: FACTORY LAYOUT PLAN

APPENDIX K: LIST OF EQUIPEMENT AND SPECIFICATIONS

APPENDIX L: CURRICULUM VITAE

final scoping report - groot...

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