proposed 132 kv khurub substation to aussenkehr …eia.met.gov.na/screening/957_emp.pdfproposed 132...

PROPOSED 132 kV KHURUB SUBSTATION TO AUSSENKEHR SUBSTATION TRANSMISSION POWER LINE

EVIRONMENTAL IMPACT ASSESSMENT PROCESS

Environmental Management Plan for Construction of the Power Line DRAFT Environmental Assessment Practitioner: Mrs Jaana-Maria Ball

May 2017

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Khurub to Aussenkehr Power Line EIA Version 1/May 2017 EMP for Construction

17 May 2017

DECLARATION OF INDEPENDENCE

I, Jaana-Maria Ball, confirm my independence as an Environmental Scientist and declare that

I have no interest, be it business, financial, personal or other, in any proposed activity,

application or appeal in respect of which Lithon Project Consultants (Pty) Ltd was appointed

to manage the Environmental Impact Assessment (EIA) process or I was appointed as the

Environmental Assessment Practitioner (EAP), in terms of the Environmental Management

Act, 2007 (Act No. 7 of 2007) and the Environmental Impact Assessment (EIA) Regulations,

2012, other than fair remuneration for worked performed, specifically in connection with the

EIA process for the construction and operation of the transmission power line from the Khurub

Substation to the Auassenkehr Substation, as well as that for the expansion of the Aussenkehr

Substation. I further declare my objectivity in these assessments and that I am confident in the

results of the studies undertaken and conclusions drawn as a result – within the limitations as

are described in the associated reports.

___________________________

Full Name: Jaana-Maria Ball

Title / Position: Environmental Consultant

Qualification(s): BSc (Botany and Zoology), BSc (Hons), MSc (Botany), MBA, Dip. Proj.

Man, Dip. Bus. Man.

Experience: years: 20 years

Professional registrations

and date of first

registration:

Pr. Sci. Nat. (400049/98), 1998 SAIE&ES, 1998

SAAB, 2000 EAPAN, 2014

BEAPA (in progress)

Contact details:

2 Lucius Way, The Vines, Constantia, 7806, South Africa

Email: [email protected]; Cell: +27 83 650 5489

mailto:[email protected]

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Proposed 132 kV Khurub Substation to Aussenkehr Substation Transmission Power Line

Draft Environmental Management Plan for Construction of the Power Line

CONTENTS

Chapter Description Page

ANNEXURES 4

GLOSSARY OF TERMS, DEFINITIONS AND ABBREVIATIONS 5

1 INTRODUCTION 8

1.1 The Environmental Management Plan 8

1.2 Legal Framework and Environmental Clearance 10

1.3 Details of the Principal Parties 11

1.4 Summary of the Proposed Activities and findings of the EIA 11

1.5 The Receiving Environment and Assessment of Potential Impacts 12

1.6 Summary of Identified Impacts 15

2 MANAGEMENT AND ORGANISATIONAL STRUCTURE 17

2.1 Contractual Obligations 17

2.2 Project Manager (PM) 17

2.3 NamPower SHEW Section 18

2.4 Contractor/ Sub-contractors 19

2.5 Site Documentation and Record Keeping 21

3 ENVIRONMENTAL SPECIFICATIONS DURING CONSTRUCTION 23

3.1 Principles and Compliance 23

3.2 Site Establishment 28

3.3 Biodiversity Management 30

3.4 Soil Impacts 32

3.5 Construction Plant, Material and Site Management 34

3.6 Waste Management 36

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3.7 Stormwater Management and Erosion 41

3.8 Air Quality 42

3.9 Noise Control 44

3.10 Community and labour relations 44

3.11 Security and Crime 47

3.12 Health and Safety 48

3.13 Monitoring 50

3.14 Construction Site Decommissioning 53

3.15 Completion of Contract 54

ANNEXURES

Annexure A: Curriculum Vitae of Mrs. Jaana-Maria Ball Annexure B: Locality Plans Annexure C: Photographs Annexure D: Facility Illustrations

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GLOSSARY OF TERMS, DEFINITIONS AND ABBREVIATIONS

Affected

Environment

Those parts of the socio-economic and biophysical

environment impacted on by development

Alternatives A possible course of action, in place of another, that would

meet the same purpose, need and requirements of the

proposal. Alternatives can refer to any of the following but are

not limited hereto: alternatives sites (location) for development,

type of activity, alternative site layouts, alternative designs,

alternative technology (including processes and materials),

operational aspects. In Integrated Environmental Management

the so-called “no action” alternative may also require

investigation in certain circumstances.

Application An Application for an Environmental Clearance Certificate in

terms of the EIA Regulations (2012).

Assessment The process of collecting, organising, analysing, interpreting

and communicating data that are relevant to the decision.

Construction

Activity

A construction activity is any action taken by the Contractor,

his subcontractors, suppliers or personnel during the

construction process.

Contractor That main organisation appointed by the NamPower (i.e. the

Applicant) to undertake construction activities on the site.

NamPower may undertake some of the work itself. For the

purposes of this EMP the division/ unit within NamPower who

may do the work is to be referred to as the Contractor and will

take on all the necessary responsibilities outlined in this

document.

DEA Directorate of Environmental Affairs

EAP Environmental Assessment Practitioner who has been

designated by the proponent, NamPower, to manage the

assessment process.

EIA Environmental Impact Assessment

EMP Environmental Management Plan: The EMP for the project

sets out general instructions that will be included in a contract

document for the construction phase of the project. It describes

how activities that may have significant environmental effects

on the receiving environment are to be mitigated, controlled

and monitored. The EMP will ensure the construction activities

are undertaken and managed in an environmentally sound and

responsible manner.

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Environment Means the surroundings within which humans exist and that

are made up of:

a. The land, water and atmosphere of the earth.

b. Micro-organisms, plant and animal life.

c. Any part or combination of a) and b) and the

interrelationships among and between them.

d. The physical, chemical, aesthetic and cultural

properties and conditions of the foregoing that influence

human health and well-being.

Environmental

Specifications (ES)

Instructions and guidelines for specific construction activities

designed to help prevent, reduce and/or control the potential

environmental implications of these construction activities.

I&APs Interested and Affected Parties: In relation to the assessment

of the listed activity includes any person, group of persons or

organisation interested in or affected by an activity, and any

organ of state that may have jurisdiction over any aspect of the

activity.

kV Kilo volts

MET Ministry of Environment and Tourism

NGC Namibia Grape Company

NYS National Youth Service

PM Project Manager: Appointed entity responsible for overall

management of the construction phase of the project including

the management of all contractors.

PPP Public Participation (Consultation) Process: A process referred

to in Regulation 21 of the EIA Regulations (2012), in which

potential interested and affected parties are given an

opportunity to comment on, or raise issues relevant to, specific

matters.

Project This refers to all construction activities associated with the

proposed activities.

Rehabilitation Rehabilitation is defined as the return of a disturbed area,

feature or structure to a state that approximates to the state

(where possible) that it was before disruption, or to an

improved state.

Scoping Report A document prepared by the proponent (or someone appointed

by them) to present the case for the assessment of an activity

as part of the assessment process.

SHEW Safety, Health, Environment and Wellness

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SS Substation

Solid Waste Means all solid waste, including construction debris, chemical

waste, excess cement/concrete, wrapping materials, timber,

tins and cans, drums, wire, nails, food and domestic waste

(e.g. plastic packets and wrappers).

the Act or EMA Environmental Management Act, 2007 (Act No. 7 of 2007).

TX Transmission

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Khurub to Aussenkehr Power Line EIA Version 1/May 2016 Scoping Report Appendix J: EMP for Construction

1 INTRODUCTION

1.1 The Environmental Management Plan

Introduction

//Karas region is geographically extensive with low levels of population density; large

parts of the region are comprised of the Namib and Kalahari deserts. Agriculture (most

notably small stock farming) is one of the most dominant economic sectors in the

proposed project area, and there are grape farms located along the banks of the

Orange River. The majority of the employed population derive income as employees

(i.e. private, commercial agriculture and government). There are minimal settlements

or small-scale livelihood activities on the land adjacent to that proposed transmission

power line corridor. The directly affected farms are (from the Khurub Substation to the

Aussenkehr Substation): Farm 462, Portion 9 Aussenkjer 147, Portion 7 Aussenkjer

147 and Portion 8 Aussenkjer 147 (Annexures B: Locality Plans and C:

Photographs).

There exists a 66 kV power line between the Khurub Substation and the Aussenkehr

Substation, which has been operated for the past 11 years by NamPower. The new

132 kV transmission power line is urgently required as the Aussenkehr Substation

currently supplies important agricultural loads in the south of Namibia and in particular

the majority of the grape farming industry of Namibia.

The Environmental Impact Assessment (EIA), and it’s specialist studies, considered

the potential impacts of constructing and operating (including maintaining) the

proposed 132 kV transmission power line from the Khurub Substation to the

Aussenkehr Substation, a distance of approximately 40 km (Annexure D: Facility

Illustrations). The Study identified a preferred power line corridor alignment, within

which an access track is proposed to run parallel to the power line. The transmission

power line will have a final servitude of 44 m width, with only 12 m of that being cleared

for the track. The access track will be used to bring in construction materials, as well

as to access the power line and its associated monopoles for maintenance purposes,

throughout the infrastructure’s life span.

The EIA assessed a power line corridor alignment with a length of approximately 40

km and width of 500 m (250 m from the centre line). Emphasis was placed on the

optimisation of the corridor route as well as cumulative impacts of two power lines within

the study area. The proposed corridor runs parallel to the existing power line corridor

for much of its length.

The proposed project was granted Environmental Clearance by the Environmental

Commissioner of The Directorate of Environmental Affairs: Ministry of Environment and

Tourism (MET) on 24 January 2017.

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Purpose

The preparation of an EMP is recognised as a tool in Integrated Environmental

Management (IEM) to address negative impacts and to enhance positive impacts on

site. This EMP informs all relevant role-players in the project as to their environmental

rights and duties. It is to be included in the tender documentation and the Contract with

the appointed Contractor. Its focus is on the construction phase of the proposed

development and contains all the mitigation measures/ management actions proposed

in the EIA process.

This EMP must be read in conjunction with the Scoping Report for the proposed

construction and operation of the power line, as well as NamPower’s policies.

An EMP for the operational phase has also been compiled. It contains all the mitigation

measures/ management actions proposed in the EIA process for the operation of the

facility.

Objectives

The objectives of an EMP are to:

Ensure compliance with all relevant legislation and Regulations with bearing on the

proposed project.

Verify environmental performance through information on impacts as they occur.

Provide required management actions in order to respond to unforeseen events.

Provide feedback for continual improvement in environmental performance.

Refine identified mitigation measures to further reduce potential impacts to minimal

or insignificant levels.

Stipulate specific actions to assist in mitigating the environmental impact of the

project.

Identify measures that could optimize beneficial impacts.

Create management structures that address the concerns and complaints of

Interested and Affected Parties (I&APs) with regards to the proposed project

(development).

Establish a method of monitoring and auditing environmental management

practices during all phases of the activity.

Ensure that environmental safety recommendations are complied with.

Specify time periods within which mitigation measures must be implemented, where

appropriate.

The completion of the project is not delayed due to problems with landowners

arising during the course of construction.

NamPower needs commitment from the PM, the SHEW Department and the Contractor

on the following issues:

To take into consideration the neighbouring landowners and their rights.

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To always behave professionally on and off site.

To ensure quality in work completed – technical and environmental.

To resolve problems and disputes arising from damage immediately, in order to

ensure a smooth flow of operations.

To underwrite NamPower’s environmental policy at all times.

To use this EMP for the benefit of all parties.

To preserve the natural and social environment by limiting destructive actions on

site.

Content

The content of the EMP must comply with the Environmental Management Act (Act No.

7 of 2007) and be consistent with the requirements as set out in the EIA Regulations of

2012, and it’s guidelines, and in summary must contain:

Details and experience of the person who prepared the EMP.

Description of the anticipated impacts, and the methods and procedures for

mitigating these identified impacts.

Description of the activities and works the draft EMP will cover.

Outline of the roles and responsibilities of the project managers, engineers,

contractors, NamPower SHEW Section and the authorities.

Mechanisms for monitoring compliance with the EMP.

Time periods within which the measures contemplated in the draft EMP must be

implemented.

Description of the process for managing any environmental damage and identifying

required site rehabilitation measures.

1.2 Legal Framework and Environmental Clearance

This EMP is focused on sound environmental management practices and is based on

national and international best practices, and relevant legislation, policies and

guidelines. All stakeholders should note that obligations imposed by the EMP are

legally binding in terms of environmental statutory legislation and in terms of the

additional conditions to the general conditions of contract that pertain to this project. In

the event that any rights and obligations contained in this document contradict those

specified in the standard or project specifications then the latter shall prevail.

All legislation and policies applicable to the development must be strictly enforced,

including the following:

The Constitution of the Republic of Namibia, 1990

Electricity Act No. 4, 2007

Nature Conservation Ordinance 4, 1975

National Development Plan: Vision for 2030

Environmental Management Act No. 7, 2007

Environmental Assessment Policy for Sustainable Development and

Environmental Conservation, 1995

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Convention on Biological Diversity, 1992

EIA Regulations, 2012

The list of applicable legislation provided above is intended to serve as a guideline only

and is not exhaustive nor inclusive.

1.3 Details of the Principal Parties The Project Proponent/ Applicant is NamPower, the Namibian state power utility. They

are also the Project Managers for the construction activities.

The EIA process is being managed by Lithon Project Consultants (Pty) Ltd and the

appointed independent Environmental Assessment Practitioner (EAP) is Mrs. Jaana-

Maria Ball who is a registered Reviewer and Lead Practitioner with the Environmental

Assessment Practitioners Association of Namibia. She prepared all the documentation

emanating from this process, as well as this EMP and her credentials as well as CV

are contained above and in Annexure A.

The independent technical specialist studies that were undertaken to inform the

Scoping Study of any potential impacts arising from the proposed development were

undertaken by:

Avifuanal Assessment – Mr. CJ Brown of Sustainable Solutions Trust

Social Impact Assessment – Mrs. Kerryn McKune-Desai

Archaeology Assessment – Prof. John Kinahan

Botanical Assessment – Dr. Colleen Mannheimer

Drainage Assessment – Mr. Chris Muir

Their contact details, expertise and experience as well as Declarations of

Independence are found in Appendix I of the Scoping Report.

Mr. Johan van Rensburg was the spatial mapping expert who undertook all the mapping

for the EIA.

1.4 Summary of the Proposed Activities and findings of the EIA

The proposed project comprises the construction and operation of a 132 kV power line

from the Khurub Substation (which has recently undergone an expansion) and the

Aussenkehr Substation. A number of alternatives (‘no-go’, technology, methodology,

equipment, mitigation measures) to the construction and operation of the power line

were considered and assessed during the EIA process. The no-go alternative was not

recommended given the importance of the transmission line in the overall power supply

system in Namibia and the need for NamPower to fulfil its mandate as a national Utility.

Four alternative power line corridors were assessed during the assessment. Each

alternative was scoped and a new alternative put forward for assessment that avoided

potential negative biophysical as well as socio-economic impacts. The favoured

alternative is presented in Appendix B: Site Locality Plan. The preferred corridor

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alignment avoided sensitive environmental features, most notably sensitive mountain

slopes which are susceptible with erosion and support sensitive biota, future land use

(i.e. township development as per the draft Master Plan of 2015), infrastructure and

high-value cultivated land. The recommended alternative has the least impact on the

receiving environment, as the land is not designated for township and not considered

to be significantly environmentally sensitive.

The infrastructure proposed is illustrated in Appendix D: Facility Illustrations. It

includes a transmission line conductor strung onto a 24 m high concrete or steel mono-

poles placed approximately 250 to 300 m apart. These monopoles will not have guy

ropes and will be placed on a 2 m by 3 m concrete base. This formed the development

‘proposal’ or proposed project as assessed in the EIA process.

The proposed construction work to be carried out on the power line includes:

Site establishment, including site demarcation and fencing (temporary and only

where required). There will be no Contractor’s Camp or cooking facilities, as the

staff of the Contractor will stay in accommodation in the nearby towns;

Digging of holes for the concrete pylon (monopole) base. It is unlikely this will

require blasting as the hills have been avoided;

Casting of concrete platforms for the poles;

Transportation of plant, machinery and equipment to site;

Transport of the conductor into position by means of a pulley system or by rolling

large coils of conductor into position;

Hoisting and lifting of the poles into position;

Stringing of the conductor; and

Construction of the access road.

The transmission power line will take approximately 6 to 8 months to construct,

depending on whether one or more Contractors are appointed to undertake the work

and/ or the working front is on both ends of the transmission line.

Prior to construction, a final ‘walkdown’ of the proposed centreline of the transmission

power line corridor alignment will be undertaken and the sites of each of the poles

finalised and demarcated. During final positioning of the poles sensitive features (e.g.

plant habitats and archaeological sites) will be avoided.

1.5 The Receiving Environment and Assessment of Potential Impacts

Land use

The surrounding land use is predominantly agriculture and conservation, although the

Aussenkehr – Noordoewer valley has recently been declared as a settlement area and

a Master Plan is currently being prepared for potential publication in November 2016.

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Avi-fauna

The avi-faunal scoping study (as contained in the Scoping Report) shows that 133 bird

species have been recorded in the local area. Of these, 32 species are wetland birds

(cormorants, herons, ducks, African Fish Eagle, waders, kingfishers, wagtails)

occurring along the Orange River. A further 16 species are directly associated with the

reed, woodland and irrigated crop field habitats supported by the river (storks, doves,

woodpeckers, swallows, sunbirds, weavers, waxbills). The remainder of the species

are associated with the Karoo biome.

Four species are listed as “Threatened” in Namibia’s Red Data book and three species

are “Near Threatened”. Black Stork, Booted Eagle and Ludwig’s Bustard are all classed

as “Endangered”, the African Fish Eagle is listed as “Vulnerable” and Verreaux’s Eagle,

Cape Eagle-Owl and Sclater’s Lark are all “Near Threatened”. All occur as “uncommon”

or “rare” in the project area, with the exception of the African Fish Eagle which is

recorded as “common” along the Orange River.

None of the species are endemic or near-endemic to Namibia, though 45 species are

endemic to southern Africa, and more specifically to the south-western arid zoo-

geographic region. The proportion of the global populations of these species occurring

in Namibia ranges from <5% to over 70%, with 24 species having 30% or more of their

global populations in Namibia. Eight species are Palaearctic migrants, breeding in the

northern hemisphere and two are intra-African migrants breeding in southern Africa.

The potential impacts on the avifauna were considered to be short-term and can be

mitigated to a low significance. If collision is found to be a significant risk, then line

markers (e.g. flappers) may be considered for high risk areas. The design of the poles,

insulators and line configuration is important to avoid electrocution. Fitting perch

dissuaders (e.g. wire brushes) above insulators or providing alternative perch sites can

be used where birds foul insulators, causing short circuits.

Terrestrial Ecology

The transmission line corridor lies within an area of low botanical diversity and

sensitivity and currently fallow. It does not contain any significant natural vegetation nor

fauna (animals). Damage to flora and fauna could be limited given careful planning and

mitigation of collateral damage to the surrounding natural environment.

Floodline

There are no major drainage catchments in the project area that should affect the

construction of the powerline. The site has a gentle slope that is not prone to water

erosion. No impacts are foreseen that cannot be mitigated. The specialist study is

documented in the Scoping Report.

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Heritage and Cultural Resources

As per the specialist study (documented in the Scoping Report) the land that the

proposed power line corridor will be constructed, although potentially rich in

archaeological sites has been partially disturbed by previous agricultural activities. It is

therefore likely that archaeological remains, if present, have been disturbed or

damaged. Disturbance or destruction of archaeological remains during construction is

a risk, as is the potential negative impact on the physical landscape setting of

archaeological sites. The precautionary principle should therefore be applied.

Should artefacts be found these must be appropriately managed to avoid negative

impacts and preserve the remains and applicable legislation followed. If found, the

immediate advice of a professional archaeology specialist or the Monuments Council

must be sought in this regard before any further damage is done. The area should be

immediately marked and cordoned off until expert instruction is obtained.

Social

The Aussenkehr Substation lies within Namibia’s //Karas region and Karasburg

constituency. //Karas region is geographically extensive with low levels of population

density; large parts of the region are comprised of the Namib and Kalahari deserts.

Agriculture (most notably grape and small stock farming) is the most dominant

economic sectors in the area. The majority of the employed population derive income

as employees (i.e. private, commercial agriculture and government). There are no

settlements or small-scale livelihood activities in the land next to the proposed power

line corridor. The directly affected land comprises the farms (from the Khurub

Substation to the Aussenkehr Substation): Farm 462, Portion 9 Aussenkjer 147, Portion

7 Aussenkjer 147 and Portion 8 Aussenkjer 147

The potential impacts that have been identified in the Scoping Report do not raise any

‘red flags’. The potential negative impacts are relatively minor and manageable through

effective mitigation and the positive impacts are going to generate long-term socio-

economic benefits for the local area.

The social assessment is contained within the Scoping Report.

Dust

Wind-blown dust is currently an issue in the Aussenkehr – Noordoewer valley,

especially during the dry months.

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1.6 Summary of Identified Impacts

Potential impacts of the proposed construction of the 132 kV power line between the

Khurub Substation and the Aussenkehr Substation were assessed as part of the EIA

process. They are summarised as follows:

Environmental

Aspect Project Phase Significance of

Potential Impact without Mitigation

Significance of Potential Impact with Mitigation

Avifauna Construction Low (-) Low (-)

Operation Low (-) Low (-)

Flora Construction Low (-) Low (-)


Fauna Construction Low (-) Low (-)

Operation Moderate (-) Low (-)

Archaeology and Heritage Resources

Construction Moderate (-) Low (-)


Floodlines Construction Low (-) Low (-)


Social Construction Low (-) Low (+)

Operation Moderate (+) High (+)

Economic Construction High (-) Low (+)

Operation Moderate (+) High (+)

– Note:

1. Impacts can be negative (-), neutral or positive (+). 2. The significance of a potential impact is based on the combination of

consequence of the impact and probability of the impact occurring, and defines the level to which the impact will influence the proposed project and/or the environment. It determines whether mitigation measures need to be identified and implemented or whether the resource is irreplaceable and/or the activity has an irreversible impact. Significance is rated as either Low, Moderate (Medium) or High.

This assessment, by the EAP, was based on the technical specialist’s reports on the

sensitivity of the receiving environment. The Reports emanating from the EIA process

included proposed management actions/ mitigation measures to avoid and/ or reduce

potential negative environmental impacts.

Construction-related nuisances, (noise, dust, litter) can be fully mitigated to acceptable

levels, provided mitigation measures stipulated in the EMP are followed. An

environmentalist from within NamPower’s SHEW Section should be employed

throughout the duration of construction.

The general theme of the comment received from the local public during the Public

Participation Process (PPP), undertaken as part of the EIA, was that they wanted the

proposed project to go-ahead as soon as possible provided that proposed mitigation

measures/ management actions were implemented and monitored.

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Given the low significance of any negative potential impacts, and the potential for

positive impacts of a high significance on social and economic development, as well as

the fact that the proposed project will have a positive impact on the ability of NamPower

to continue providing the services of power, the EIA recommended that the proposed

project receive an Environmental Clearance Certificate and the proposed construction

activities be implemented as soon as possible.

It was not recommended that the ‘no-go’ alternative be considered given the

importance of the power line between the Khurub Substation and Aussenkehr

Substations in the overall power supply system in the //Karas Region.

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2 MANAGEMENT AND ORGANISATIONAL STRUCTURE

2.1 Contractual Obligations In order to ensure that the EMP and its derivatives are enforced and implemented,

these documents must be given legal standing. This shall be achieved through

incorporating the EMP and/or subsequent versions as an addendum to the contract

documents for the particular project and specifying under particular conditions of the

contract for the tender that the requirements of the EMP and/or derivatives apply and

must be met by all parties. This will ensure that the obligations are clearly

communicated to contractors, and budgeted for the environmental requirements

specified in the EMP and/or its derivatives.

All parties should note that obligations imposed by the EMP are legally binding in terms

of the Environmental Clearance Certificate granted by the competent authority.

2.2 Project Manager (PM)

The Project Manager (PM) will ensure that the approved EMP is included in the contract

documentation issued to prospective contractors. NamPower will act as the PM.

Role

Specific to the implementation of the EMP, the role of the PM will be to:

Review and approve documents produced by the appointed Contractor in

response to stipulations in the EMP.

Oversee the general compliance of the Contractor (and its sub-contractors) with

the EMP and other pertinent site specifications.

Liaise between and with the Contractor and NamPower SHEW Section (i.e.

Environmentalist) on environmental matters, as well as any pertinent engineering

matters where these may have environmental consequences.

Responsibilities

The PM’s responsibilities will include:

Be familiar with the contents of the EMP, and his role and responsibilities as

defined therein.

Must make sure that SHEW requirements are included in the documents sent to

the Contractor.

Communicate to the Contractor, verbally and in writing, the advice of the

NamPower SHEW Section and the outcome and recommendations of the

NamPower SHEW Section Reports.

Ensure that the Contractor complies with this EMP i.e. enforcement of the EMP.

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Ensure that all activities on site are adequately planned and restricted to

designated areas and to minimise the footprint of the development area.

Request for, review and approve documents prepared by the Contractor in

consultation with the NamPower SHEW Section.

Review and approve drawings produced by the Engineer, Contractor or

professional team in connection with any aspect of the proposed development.

Issue site instructions giving effect to the NamPower SHEW Section’s

recommendations and requirements where necessary.

Review complaints received and make instructions as necessary.

Discuss with the NamPower SHEW Section the application of corrective action for

the infringement of the Environmental Specifications (ES), and other possible

enforcement measures when necessary.

Issue instructions for corrective action, as and when necessary.

Implement Temporary Work Stoppages as advised by the NamPower SHEW

Section where serious environmental infringements and non-compliances continue

to occur.

Ordering the removal of person(s) and/or equipment not complying with the EMP

Specifications.

Facilitate proactive communication between all role-players in the interests of

effective environmental management.

Ensure that all recording relating to compliance monitoring shall be kept on the site

for inspection by relative competent authority.

Reporting Structure

The PM will report to the Competent Authority as well as his/ her line managers within

NamPower, as and when required.

2.3 NamPower SHEW Section

The PM must appoint a suitably qualified and experienced environmentalist from within

the NamPower SHEW Section to monitor implementation of the EMP and measure

environmental compliance during the proposed construction works. The NamPower

SHEW Section is independent from the PM and the Contractor. The NamPower SHEW

Section is given authority to ensure that the EMP is fully implemented and that

appropriate actions are undertaken to address any discrepancies and non-

compliances.

Role

The overall role of the NamPower SHEW Section is to be the site ‘custodian’ for the

implementation, integration and maintenance of the EMP in accordance with the

contractual requirements. The NamPower SHEW Section will be required to liaise with

the PM on the level of compliance with the EMP achieved by the Contractor (and its

sub-contractors) on a regular basis for the duration of the contract.

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Responsibilities

The NamPower SHEW Section will have the following responsibilities, at a minimum:

To advise the PM on the interpretation and enforcement of the Environmental

Specifications (ES), including evaluation of non-compliances.

To supply environmental information as and when required.

To review and approve documents produced by the Contractor, in conjunction with

the PM.

To demarcate particularly sensitive areas (including all no-go areas) and sites for

the pole positions (if necessary in conjunction with the technical experts), and to

pass instructions through the PM concerning final pole positions and works in these

areas.

Advise the Contractor, through the PM, with respect to pole, insulator design and

final power line alignment within the corridor (with assistance from an avi-faunal

expert if necessary) to avoid unnecessary bird collisions and electrocution.

To monitor any basic physical changes to the environment as a consequence of

the construction works – e.g. evidence of erosion, dust generation – according to

an audit schedule.

Attend regular site meetings between the Engineer and Contractor.

To undertake regular monthly audits of the construction works and to generate

monthly audit reports. These reports are to be forwarded to the PM.

To communicate frequently and openly with the Contractor and the PM to ensure

effective, proactive environmental management, with the overall objective of

preventing or reducing negative environmental impacts and/or enhancing positive

environmental impacts.

To advise the PM on remedial actions for the protection of the environment in the

event of any accidents or emergencies during construction, and to advise on

appropriate clean-up activities.

Review complaints received and make instructions as necessary.

Identify and make recommendations for minor amendments to the EMP as and

when appropriate.

Ensure that the Contractor, his employees and/or Subcontractors receive the

appropriate environmental awareness training prior to commencing activities,

especially with respect to the dangers and precautions needed when working with

electrical power.

Reporting Structure

The NamPower SHEW Section will report to the PM.

2.4 Contractor/ Sub-contractors

The PM will appoint a Contractor to implement the development. It will be binding to

the Contractor to undertake the activities in an environmentally responsible manner, as

described in the EMP. The Contractor may from time to time appoint Sub-contractor(s).

20


Role

The employment of locals are limited on this power line project, as the work requires

highly skilled employees. NamPower may undertake some of the work itself. For the

purposes of this EMP the division/ unit within NamPower who may do some of the work

is to be referred to as the Contractor and will take on all the necessary responsibilities

outlined in this document.

Specific to the EMP, the role of the Contractor will be to:

Implement, manage and maintain the EMP for the duration of the Contract.

Designate, appoint and/or assign tasks to personnel who will be responsible for

managing all or parts of the EMP.

Assign appropriate authority, accountability and responsibility for these personnel

to carry out their duties.

Ensure that all subcontractors and other workers appointed by the Contractor are

aware of their environmental responsibilities while on site or during the provision

of their services off site.

Ensure that all subcontractors and other workers appointed by the Contractor are

complying with and implementing the EMP during the duration of their specific

contracts.

Provide appropriate resources including budgets, equipment, personnel and

training for the effective control and management of the environmental risks

associated with the construction.

Maintain a record of complaints and communicate these to the PM and the

NamPower SHEW Section.

Responsibilities

The Contractor will have the following responsibilities:

Be familiar with the contents of the EMP, and his role and responsibilities as

defined therein.

Comply with the Environmental Specifications contained in the EMP and

subsequent revisions.

Confirm legislative requirements for the construction works, and to ensure that

appropriate permissions and permits have been obtained before commencing

activities.

Prepare programme of activities and site plans for submission to the PM.

Review the site inspection reports and take cognisance of the information and

implement recommendations contained therein.

Notify the NamPower SHEW Section and PM, verbally and in writing, immediately

in the event of any accidental infringements of the Environmental Specifications

and ensure appropriate remedial action is taken.

Notify the NamPower SHEW Section and PM, verbally and in writing at least 10

working days in advance of any activity he/she has reason to believe may have

21


significant adverse environmental impacts, so that mitigation measures may be

implemented timely.

Ensure environmental awareness among employees, subcontractors and

workforce so that they are fully aware of, and understand the ESs and the need for

them.

Maintain a register of environmental training for site staff and sub-contractor’s staff

for the duration of the contract.

Undertake the required works within the designated working areas.

Rehabilitating services, utilities, private/public property and other areas adversely

affected by construction activities outside of demarcated areas in accordance with

the PM’s instructions.

Communicate and liaise frequently and openly with the PM and the NamPower

SHEW Section to ensure effective, proactive environmental management with the

overall objective of preventing or reducing negative environmental impacts while

enhancing positive environmental impacts.

Reporting Structure

The Contractor will report to and receive instructions from the PM.

2.5 Site Documentation and Record Keeping

The following documents must be kept on site in an accessible place, and maintained

by the Contractor:

Site Locality Plan (Annexure B) and Facility Illustrations (Annexure D)

Physical access plans

Site instructions

Pre-construction audit report, including photographic record

Complaints register

Records of all remediation / rehabilitation activities

Records of the quantities of general and hazardous waste generated on site and

disposal certificates or details of volumes of waste recycled

Water consumption

Electricity consumption

Copy of this EMP

Copy of the reports from the EIA process and the Environmental Clearance

Certificate

Monthly environmental compliance report

Environmental training records including Induction Training, ‘Toolbox Talks, specific

training

Emergency response plan and procedures

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Environmental Inspections and Audits

Environmental audits should be conducted according to the table below:

Table 1: Environmental audit details

Place Inspector/ Auditor Auditee Inspection/ audit frequency

Work places Contractor Contractor’s team Daily inspection

Construction site

NamPower SHEW Section

Contractor’s Environmental Officer

Fortnightly audit

The monthly environmental compliance report shall include:

Complaints received from affected parties and details of the actions taken.

Environmental incidents, spills of hazardous substances.

Environmental damage which requires rehabilitation.

Damages of private property such as roads, paths, boundary fences, security

installations, buildings, structures.

Consultation with Contractor’s staff including sub-contractors and suppliers

Document checks

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3 ENVIRONMENTAL SPECIFICATIONS DURING CONSTRUCTION

3.1 Principles and Compliance

No. Aspect/ Issue Management Measure Management Objective and

Measureable Target(s)

3.1.1 Environmental Principles for the Construction Works

1. The environment is considered to be composed of both

biophysical and social components.

2. Construction is a disruptive activity and all due consideration

must be given to the environment, including the social

environment during the execution of a project to minimise the

impact on affected parties, especially neighbouring landowners

who need to continue with their farming activities and other users

of access roads.

3. Minimisation of areas disturbed by construction activities (i.e. the

‘footprint’ of the construction area) should minimise many of the

construction related environmental impacts of the expansion

project and reduce rehabilitation requirements and costs.

4. Every effort shall be made to minimise, reclaim and/or recycle

waste materials.

5. Every effort shall be made to minimise energy and water use.

6. If archaeological artefacts or grave sites are found, the

immediate advice of a professional archaeology specialist or the

Monuments Council must be sought in this regard before any

further damage is done. The area should be immediately marked

and cordoned off until expert instruction is obtained.

3.1.2 Compliance with Environmental Legislation and Permits

1. The PM shall maintain a database of all pertinent legislation,

regulations and guidelines pertinent to the environmental

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management of the activities being undertaken.

2. The Contractor shall ensure that all pertinent legislation

concerning the protection of the environment is adhered to and

that prevention of pollution is strictly enforced.

3. The Contractor shall ensure that all relevant permits, certificates

and permissions have been obtained prior to any activities

commencing on site and are strictly enforced.

4. The workshop for plant and machinery will be off-site.

5. No overnight Contractor’s Camp nor cooking areas will be

established on site. Accommodation for Contractor’s staff will be

in the nearby towns.

6. It is anticipated that construction work will be undertaken during

week days, Monday to Friday from 07h00 to 18h00.

7. Access to the site is proposed via the current gravel access

roads to the Aussenkher and Khurub Substations, and from the

main tar road that runs between the towns of Aussenkehr and

Noordoewer. This access road are also used by other users e.g.

the Namibia Grape Company that farms grapes on the land that

surrounds the Substation, namely Portion 7 of Farm Aussenkjer

No. 147, which is owned by the National Youth Service.

8. It is anticipated that access to the site during the construction

phase would be required during normal working hours on

weekdays only. Various machinery (for example, concrete mixer,

mobile crane, mechanical wheelbarrow, stringing machines)

would need to be brought onto site. The Contractor’s staff would

need to access the site to undertake the work on a daily basis.

9. This access roads will need to be upgraded and maintained by

the Contractor, as it is currently full of potholes. All access roads

utilised during construction must be returned to the same state

(or better) as prior to construction.

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10. Details of any fences and gates affected or used during the

construction activities, including a drawing showing the location

of fences and access gates must be provided.

11. Details of the negotiated security arrangements with the National

Youth Service (NYS)/ Namibia Grape Company (NGC) and other

landowners must be included in the Access and Security Plan.

12. Expected solid waste types, quantities, methods and frequency

of collection and disposal as well as location of disposal sites

must be identified and documented. The statement shall further

include methods of minimising, controlling, collecting and

disposing of contaminated water, and details of any hazardous

substances/materials to be used, together with the transport,

storage, handling and disposal procedures for the substances.

13. The Contractor shall provide details identifying what safety

precautions will be implemented to ensure the safety of all staff,

and the general public at large, on site during the life of the

project. This will include protective clothing requirements for all

types of construction activities on site, including protection

against dust, noise, falling objects, work associated with

electricity and work at heights, if required.

14. The Contractor shall provide details regarding all relevant

emergency procedures that will be implemented for fire control

and accidental leaks and spillages of hazardous substances

(including fuel and oil). The Contractor shall further include

details of risk reduction measures to be implemented including

flood control, firefighting equipment, fire prevention procedures

and spill kits.

15. The Contractor shall provide details regarding how solid and

liquid waste generated on the construction site and site office will

be collected, stored, transported and disposed of. Details of any

service provider(s) appointed to manage this task must also be

26


provided.

16. The Contractor shall provide details of how stormwater

emanating within or adjacent to the site may impact on

construction activities. Details on how the Contractor will deal

with stormwater runoff and potential erosion within the

construction footprint and the greater are must be provided.

3.1.3 Environmental Awareness 1. Environmental awareness and training is an important aspect of

the implementation of the EMP.

2. An initial environmental awareness training session for all of the

Contractor’s (and sub-contractor’s) staff is required prior to any

work commencing which shall be conducted by a suitably

qualified person. NamPower’s SHEW Section will undertake this

induction training.

3. The NamPower SHEW Section will provide the Contractor with

the course content for the environmental awareness training

course, and the Contractor shall communicate this information to

his employees on the site, to any new employees coming onto

site, to his sub-contractors and to his suppliers.

4. The training session shall be delivered in English, with a

translator on-hand if required.

5. The emphasis should be on any (potential) environmental risks

and impacts relating to the construction activities to be

undertaken on site and the related environmental precautions,

which need to be taken to avoid or mitigate these impacts.

6. Records of training session including attendance, nature of

training and date of training shall be kept to ensure all staff

members have received the necessary training.

7. Training shall cover, as a minimum:

27


The legal status and importance of the Environmental Clearance

and the EMP, and where to locate copies thereof

Specific details of the Environmental Clearance and the EMP

Employees’ role in compliance with the EMP

Training targeted at specific personnel for example operators of

dangerous or heavy machinery

The environmental impacts, actual or potential, of their work

activities and the neighbouring farmers/ landowners

The environmental benefits of improved personal performance

Their roles and responsibilities in achieving conformance with the

environmental policy and procedures (this must be specific to the

employees attending the training)

Emergency preparedness and response requirements

The potential consequences of departure from specified

operating procedures

The mitigation measures required to be implemented when

carrying out their work activities

Environmental legal requirements and obligations

comply with national laws, international guidelines and

professional best practice standards. This may involve higher

level documentation, collection and removal of archaeological

remains and excavation of sites such as graves. The decision as

to the most appropriate mitigation course is taken by the National

Heritage Council in light of recommendations set out in a project

mitigation proposal.

Recognising archaeological sites and the that both the

archaeological site and its physical/ visual setting are protected

under the law, and that the precautionary principle needs to be

applied and work immediately stopped and expert advice sought

if archaeological sites are found

Details regarding plant and animal species, and farm lands, and

the procedures to be followed to protect these areas

The consequences of poaching of animals (including birds) or

28


removal of indigenous vegetation

The importance of not littering

The importance of using supplied toilet facilities

The need to use water and electricity sparingly

Details of and encouragement to minimise the production of

waste and re-use, recover and recycle waste where possible

Details regarding archaeological and/or historical sites which

may be unearthed during construction and the procedures to be

followed should such be encountered

3.2 Site Establishment

No. Aspect/ Issue Management Measure Management Objective and Measureable Target(s)

3.2.1 Site Identification

1. Sites for the poles shall avoid sensitive environmental features

(e.g. drainage lines, archaeological sites, sensitive plant

habitats, bird breeding/ roosting areas and flight paths). The

“walkdown” to determine the position of the poles shall be in

conjunction with the relevant experts.

2. A demarcated area at the site must be provided for the storage

of machinery and trucks as necessary. All necessary

permissions shall be obtained from landowners and for access

to and from public roads.

3. The site for materials and machinery storage shall be determined

in collaboration with the PM and the NamPower SHEW Section

before the Contractor moves on site, such that it is effectively

isolated from the sensitive elements of the surrounding

environment, and the neighbouring farmland.

4. The site for materials and machinery storage shall also be of

sufficient size to accommodate the needs of all sub-contractors

that may work on the project.

29


5. Spoil may be created from the excavations of the holes for the

poles. A demarcated area at the site must be provided for this

spoil as necessary. All necessary permissions shall be obtained

from landowners and for access to and from public roads to these

areas. The site shall be determined in collaboration with the PM

and the NamPower SHEW Section such that it is appropriately

positioned with respect to the surrounding environment, and the

neighbouring farmland.

6. The Contractor will produce a Site Layout Plan illustrating the

location and layout of the proposed materials and machinery

storage site, spoil and working areas. This plan must be

approved by the PM in consultation with the NamPower SHEW

Section.

7. The Contractor shall produce a photographic record of the area

earmarked for the storage site prior to site establishment. This

will serve as the benchmark against which rehabilitation will be

measured and shall be kept in the site environmental file.

8. It will be the responsibility of the Contractor to reinstate the

storage site to its original condition once the project has been

completed.

9. The working areas shall be kept to a minimum to reduce the total

physical ‘footprint’ of the construction site thereby reducing

environmental damage.

10. Utilities and other service providers shall be advised of the

construction activities. The Contractor will be responsible for any

damage to these services/utilities.

3.2.2 Site Demarcation 1. Prior to construction commencing, the Contractor, PM and

NamPower SHEW Section shall inspect the site and identify any

sensitive features.

2. Where necessary, the ‘no-go’ areas shall be identified and

30


indicated on the Site Plan.

3. The Contractor will be required to maintain all demarcation

fencing and other demarcating materials for the duration of

construction activities or as otherwise instructed by the PM.

4. The Contractor shall ensure that, insofar as he has the authority,

no person, plant equipment or material will enter the no-go areas

at any time.

3.2.3 Traffic Management 1. The movement of construction vehicles to and from the

construction site must be well coordinated by the PM, together

with the Contractor.

2. Large trucks and other heavy machinery may not be left

unattended.

3. The existing and agreed upon access roads to the site must be

used. No new roads must be made without prior approval from

the PM, the SHEW team, the respective landowners and

authorities.

4. All traffic calming measures must be constructed or erected

according to the appropriate municipal and provincial

specifications governing road works.

3.3 Biodiversity Management


3.3.1 Vegetation Clearance

1. The site is currently sparsely covered with low-growing

vegetation so minimal clearance of any vegetation is expected

during this proposed project. No clearance of vineyards is not

seen as being necessary during this project.

2. No grape vines/ trees/ flora shall be removed, damaged or

disturbed nor shall any vegetation be planted except to the extent

31


necessary for the carrying out of the construction works.

3. The removal and stockpiling of topsoil must also be carried out

in accordance with the EMP.

4. Areas which are not to be affected by construction, in order to

reduce erosion risks, must not be cleared.

5. The working area must be clearly demarcated and this footprint

strictly maintained.

6. It is not expected that spoil will be generated on site but if it is it

must be used on site.

7. Erosion control measures must be implemented in areas where

these risks of erosion are present.

8. All plants not interfering with construction shall be left

undisturbed.

9. Collection or wilful damage to any vines/ trees plants outside of

the areas demarcated for clearing is not allowed.

3.3.2 Removal of Invasive Species 1. All invasive alien vegetation within the works area shall be

removed and destroyed.

2. The Contractor, or responsible sub-contracted service provider,

must ensure that seeds from alien vegetation collected during

site clearance are not dispersed so as to counter the spread of

this vegetation type. Failure to do so may result in prosecution.

3. Removed invasive vegetation shall not be stockpiled on site for

more than 3 days.

4. Collect and remove as much material from site.

5. Removed vegetation must not be stockpiles in areas of

indigenous vegetation.

6. Bare soil around excavations for the monopoles must be

replanted with appropriate indigenous species to prevent the

32


establishment of invasive species and erosion and excess dust.

7. All areas disturbed by construction activities shall be inspected

regularly for invasive species to prevent the establishment and

spread of such species.

3.3.3 Wild Animal Management

1. Trapping, poisoning and/or shooting of animals (including birds)

is strictly forbidden.

2. The NNF Form shall be used for bird finds.

3. Any animals rescued or recovered will be relocated to suitable

habitat away from the development.

4. Logs and stumps provide important habitats for several reptile

species as well as smaller mammals, amphibians, arachnids and

scorpions. These animals shall be allowed to escape to suitable

habitat away from the disturbance or must be removed by a

suitably experienced and qualified person.

5. During construction activities wherever possible work shall be

restricted to one area at a time. This will give smaller birds,

mammals, reptiles and amphibians an opportunity to move into

undisturbed areas close to their natural habitat.

6. No domestic pets or livestock are permitted on site.

3.4 Soil Impacts No. Aspect/ Issue Management Measure Management Objective and


3.4.1 Topsoil 1. Topsoil shall only be stripped from areas that are to be worked.

2. Stripping of topsoil will be undertaken in such a manner as to

minimise erosion by wind or runoff.

3. No stripping of top soil during wet or windy conditions.

4. Topsoil will be stripped to a depth not exceeding 150 mm from

33


the original ground level.

5. Areas from which the topsoil is to be removed will be cleared of

any foreign material which could reduce the quality of the topsoil.

6. The Contractor shall ensure that subsoil and topsoil are not

mixed during stripping, excavation, reinstatement and

rehabilitation.

3.4.2 Stockpiles 7. Topsoil will be temporarily stockpiled, separately from (clay)

subsoil and rocky materials.

8. Topsoil will be stockpiled in areas as indicated on the site plan/s

approved by the PM and NamPower SHEW Section.

9. Soil must not be stockpiled on drainage lines.

10. Stockpiles shall be kept free of weeds.

11. Stockpiles shall not exceed 2 m in height.

12. If stockpiles are exposed to windy conditions or heavy rain, they

shall be covered to prevent loss of topsoil.

13. Stockpiled topsoil must not be mixed with spoil, rubble or building

material or be subject to compaction or contamination by

vehicles or machinery. This will render the topsoil unsuitable for

use during rehabilitation.

3.4.3 Erosion 14. It is strongly recommended that construction activities should

make use of a dry seasonal window as this will help reduce the

risk associated with erosion and siltation.

15. The Contractor must ensure that measures to limit erosion and

improper drainage caused by construction vehicles and activities

are in place.

16. The clearing of vegetation should be avoided as far as feasibly

possible, and should be limited to the construction footprint.

17. All existing disturbed areas will be revegetated to control erosion

34


and sedimentation.

18. Existing vegetation will be retained as far as possible to minimize

erosion problems.

19. Erosion control measures should be inspected regularly and

necessary repairs need to be carried out if any damage has

occurred.

3.5 Construction Plant, Material and Site Management

No. Aspect/ Issue Management Measure Management Objective and


3.5.1 Equipment Maintenance and Storage

1. All vehicles and equipment shall be kept in good working order

and shall be parked at an area approved by the PM.

2. All vehicles and plant will be inspected daily for leaks and spills.

Maintenance checks shall be logged and signed off in a site

maintenance file after each inspection.

3. Leaking equipment shall be repaired immediately (with a drip tray

in place) or removed from the site.

4. Stationary plant must be supplied with drip trays to prevent soil

contamination after hours.

3.5.2 General Materials Handling, Use and Storage

1. Materials shall be appropriately secured to ensure safe passage

between destinations. Loads including, but not limited to sand,

stone chip, refuse, paper and cement, shall have appropriate

cover to prevent it from spilling over the side of the vehicle during

transit.

2. The Contractor shall be responsible for any clean-up resulting

from the failure by his staff or supplier to properly secure

materials to be transported.

3.5.3 Stockpiling of Construction Material

1. Any stockpiling shall be in areas approved by the NamPower

SHEW Section within the defined working area.

35


2. The Contractor shall ensure that stockpiled material is not lost

due to exposure to the elements. If the stockpiled material is in

danger of being washed or blown away, the Contractor shall

cover it with a suitable material, such as hessian or plastic.

Stockpiles of topsoil shall not be covered with plastic.

3.5.4 Workshop 1. No on-site workshop is envisaged.

2. The Contractor shall ensure that there is no contamination of the

soil or surface water from leaking machinery or plant, and those

needing repair need to be removed immediately from site and

repaired. Each Contractor must have a spill control kit and staff

appropriately trained to utilise it.

3.5.5 Mortar and Concrete Batching 1. It is not envisaged that a concrete batching plant will be located

on site.

2. Small scale concrete mixing may however be required on site for

the monopole bases. Where possible, the Contractor should

make use of ready-mix concrete.

3. The proposed location of cement stores and sand and aggregate

stockpiles shall be indicated on the Site Layout Plan and

approved by the NamPower SHEW Section.

4. The Contractor shall ensure that minimal potable water is used.

5. Concrete and mortar shall not be mixed directly on the ground.

Mixing trays, wheelbarrows or concrete mixing machines can be

used.

6. The mixing works shall be kept neat and clean at all times.

7. Contaminated storm water and wastewater runoff from the

mixing works and aggregate stockpiles shall be collected and

removed off the site.

8. Used cement bags must be stored tidily in weather-proof

containers until disposal off-site. Unused cement bags must be

36


stored weather-proof to prevent leaching of cement.

9. All reasonable measures must be taken to ensure that

transportation of concrete does not result in spillage.

10. Cleaning of equipment and flushing of mixers shall not result in

pollution of the surrounding environment, and preferably be done

off site.

11. Suitable screening and containment shall be in place to prevent

windblown contamination associated with any loading and

batching.

12. Waste concrete, cement sludge and mortar leftovers shall be

removed from site to an approved landfill site. Washing the

remains into the ground is not acceptable.

3.5.6 Work Stoppage and Temporary Site Closure

13. The Engineer, in consultation with the NamPower SHEW

Section, shall have the right to order work to be stopped in the

event of significant infringements of the ESs until the situation is

rectified in compliance with the specifications. In this event, the

Contractor shall not be entitled to claim for delays or incurred

expenses.

3.6 Waste Management


3.6.1 Solid Waste Management

1. The contractor must obtain documentation to prove where and

how waste was disposed of.

2. Waste concrete shall be disposed of at the nearest registered

solid waste disposal facility.

3. No burning, burying or dumping of any waste materials,

vegetation, litter or refuse shall be permitted.

37


4. Solid waste shall be removed from site on a weekly or fortnightly

basis by the Contractor or appropriate service provider.

5. Domestic waste must be collected in a skip and disposed of at

the nearest registered solid waste disposal facility.

6. No burning of cleared vegetation or waste on site.

7. Solid waste shall be recycled where possible and the remainder

disposed of at an approved municipal land fill site or waste

disposal service provider.

8. Labelled recycling containers shall be provided.

9. Disposal certificates for each waste removal event shall be

issued and kept in the site environmental file for auditing

purposes.

10. No burning of cleared vegetation shall be allowed on site.

Chipping or composting of vegetation shall be allowed where

viable.

3.6.2 Wastewater Management

1. Contaminated water (or sediment leaden water) needs to be

identified and isolated.

2. The Contractor shall prepare a document as how wastewater will

be controlled and managed on site, including providing for the

appropriate disposal of contaminated water.

3. No grey water runoff or uncontrolled discharges from the

site/working areas shall be permitted.

4. Water containing environmental pollutants shall be collected and

removed from site.

5. Potential pollutants of any kind and in any form shall be kept,

stored and used in such a manner that any escape can be

contained.

6. The Contractor shall notify the PM and NamPower SHEW

38


Section of any pollution incidents on site.

3.6.3 Sanitation 1. Adequate temporary toilet facilities are to be provided at the site.

2. Toilets at a ratio of one toilet per 10 workers shall be provided at

the site camp. Separate toilet facilities for males and females

shall be provided.

3. All temporary/portable toilets shall be secured to the ground to

the satisfaction of the PM to prevent them from toppling over or

being blown over by wind.

4. The type and exact location of the toilets shall be approved by

the PM prior to establishment. No septic tanks are to be

established.

5. The Contractor shall ensure maintenance of all toilets in a clean

sanitary condition to the satisfaction of the PM. Toilets are to be

serviced at least once per day and toilet paper shall be provided.

6. The Contractor shall ensure that no spillage occurs when the

toilets are cleaned or emptied and that the contents are removed

from the site to an appropriate location/facility. The

Contractor/service provider is to provide proof that the toilet

contents are disposed of at an appropriate facility.

7. Discharge of waste from toilets into the environment and burial

of toilet waste is strictly prohibited.

3.6.4 Fuels (Petrol and Diesel) and Oil

1. Fuel shall not be stored on site, but shall be transported to the

site in small quantities as and when required, and vehicles to be

fuelled off site.

2. Where fuel is to be stored on site in small quantities, all

necessary approvals regarding storage and dispensing shall be

obtained from the appropriate authorities.

3. The location of temporary fuel stores shall be approved by the

PM and NamPower SHEW Section.

39


4. Areas for the storage of fuel and other flammable materials shall

comply with standard fire safety regulations.

5. A separate container must be made available for the biological

treatment of soil polluted by oil.

6. The contractor shall provide details of the proposed fuel storage

facility to the NamPower SHEW Section.

7. At least one person trained in first aid and the handling of fuels

must be available to the construction team at all times.

8. Smoking may only be allowed in designated areas, which must

contain a fire extinguisher.

9. There shall be adequate fire-fighting equipment at or close to the

fuel storage area.

10. Fuel shall be kept under lock and key at all times.

11. The Contractor shall ensure that there is always a supply of

absorbent material readily available to absorb/break down any

hydrocarbon spillage. The quantity of such materials shall be

able to handle a minimum of 200 litres of hydrocarbon liquid spill.

This material must be approved by the PM prior to any refuelling

or maintenance activities.

12. In the case of a spill, contaminated material must be removed

from the site immediately and disposed of at an appropriate

hazardous waste facility.

13. The washing of plant must take place off site.

3.6.5 Other Hazardous Substances

1. All potentially hazardous raw and waste materials are to be

handled by the Contractor’s trained staff and stored on site in

accordance with manufacturer’s instructions and legal

requirements.

2. All hazardous waste must be disposed of in accordance with

40


national, regional and local legislation.

3. Appropriate training for the handling and use of such materials is

to be provided by the Contractor as necessary. This includes

providing for any spills and pollution threats that may occur.

4. Products shall be clearly labelled and symbolic safety/ hazard

warning signs shall be provided.

5. If potentially hazardous substances are to be stored on site, the

Contractor shall provide a document as to how hazardous

substances/materials are to be used together with the

procedures for the storage, handling and disposal of the

materials in a manner which will reduce the risk of pollution that

may occur from day to day storage, handling, use and/or from

accidental release of any hazardous substances used.

6. Hazardous chemical substances used during construction shall

be stored in secondary containers.

7. The relevant Material Safety Data Sheets (MSDS) shall be

available on site. Procedures detailed in the MSDS shall be

followed in the event of an emergency situation.

8. Where hazardous substances is removed from site for disposal,

proof of disposal for auditing purposes shall be kept in the form

of disposal certificates.

3.6.6 Emergency Procedures 1. The Contractor shall ensure that his employees and

subcontractors on site are aware of the procedure for dealing

with accidental spills and leaks.

2. All leaks of hydrocarbons or chemicals shall be repaired

immediately.

3. Stormwater runoff must not be contaminated by leaking oil or

chemicals.

4. The Contractor shall also ensure that the necessary materials

41


and equipment for dealing with the spills and leaks are available

on site at all times.

5. The site shall have a supply of absorbent material readily

available to absorb any accidental hydrocarbon spills. The

quantity of such material shall be able to absorb/ deal with a

minimum of 200 litres of spill.

6. The contractor shall contain the spill using sand berms,

sandbags, sawdust or absorbent materials.

7. The area shall be cordoned off and secured.

8. Contaminated material shall not be disposed of into any

stormwater or sewer systems.

9. The Contractor shall notify the NamPower SHEW Section, PM

and relevant authorities of any spills that occur.

10. The Contractor shall assemble and clearly list the relevant

emergency telephone contact numbers for staff and brief staff on

the required procedures. These contact details shall be listed in

the site office, Contractor’s Camp and any other suitable areas.

11. The treatment and remediation of areas affected by emergencies

shall be undertaken to the satisfaction of the PM and NamPower

SHEW Section at the cost of the Contractor where his staff have

been proven to be responsible for the emergency.

3.7 Stormwater Management and Erosion No. Aspect/ Issue Management Measure Management Objective and


3.7 Stormwater Management and Erosion

1. The Contractor shall take all reasonable measures to control

stormwater and the erosive effects thereof.

2. During construction, the Contractor shall protect areas

42


susceptible to erosion by installing necessary temporary or

permanent drainage works as soon as possible.

3. Areas affected by construction related activities and/or

susceptible to erosion must be monitored regularly for evidence

of erosion.

4. On any areas where the risk of erosion is evident, special

measures may be necessary to stabilise the areas and prevent

erosion. These may include, but not be restricted to:

Confining construction activities.

Using mechanical cover or packing structures.

Straw stabilising – must not contain weed seeds.

5. The erosion prevention measures must be implemented to the

satisfaction of the PM and NamPower SHEW Section.

6. Where erosion does occur on any completed work/working

areas, the Contractor shall reinstate such areas and areas

damaged by the erosion at his own cost and to the satisfaction

of the PM and NamPower SHEW Section.

7. Human and vehicular traffic and movement over stabilised areas

shall be restricted and controlled. Any damage to the stabilised

areas shall be repaired and maintained to the satisfaction of the

PM and NamPower SHEW Section.

3.8 Air Quality


3.8.1 Air Emissions

8. The Contractor will be required to ensure that all vehicles and

plant used are maintained in good working order to help reduce

air emissions.

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9. The burning of substances that may emit foul smelling smoke

or vapour, e.g. oil rags, tar paper, is not permitted.

3.8.2 Dust Control

1. The Contractor shall be responsible for the control of dust

arising from his operations and activities.

2. Control measures shall include regular spraying of

working/exposed areas with water at an application rate that

will not result in soil erosion or runoff. The frequency of spraying

will be agreed with the PM.

3. The excavation, handling and transport of erodible materials

shall be avoided under high wind conditions.

4. Soil stockpiles shall be wetted and/or sheltered from the wind,

as required.

5. Dust sources must be sprayed with water regularly at an

application rate that will not result in soil erosion or runoff.

6. The excavation, handling and transport of erodible materials

shall be avoided under high wind conditions.

7. Vegetation/ vines shall only be removed when approved by the

PM and the NamPower SHEW Section.

8. Operate vehicles within speeds limits, where no speed limit has

been specified the limit shall be 20 km per hour or less.

9. Vehicles heavily contaminated with dust to be washed before

leaving the site to prevent the spread of dust.

10. Vehicles transporting materials which may generate dust shall

be covered with a tarpaulin.

44


3.9 Noise Control No. Aspect/ Issue Management Measure Management Objective and


3.9

1. Noisy activities such as demolition shall be restricted to 07h00 to

18h00 Monday to Friday and excluding public holidays.

2. The Contractor shall keep noise level within acceptable limits,

and comply with all relevant guidelines and regulations.

3. All vehicles and machinery shall be fitted with appropriate

silencing technology that shall be properly maintained.

4. Reverse hooters of vehicles must be set at such a level that the

beeping sound does not create a nuisance.

5. The use of all plant and machinery shall be appropriate to the

task required in order to reduce noise levels and/or

environmental damage.

6. Any complaints received by the Contractor regarding noise will

be responded to and recorded and communicated to the PM and

the NamPower SHEW Section.

3.10 Community and labour relations


3.10.1 Community Relations 1. The Contractor shall inform the neighbouring landowners of the

contact details for complaints in accordance with details provided

by then NamPower SHEW Section.

2. The Contractor must keep a Complaints Register on Site. The

Register shall contain contact details of complainants, the nature

of the complaint, details on the complaint itself, as well as the

45


date and time that the complaint was made and resolved.

3. The Contractor and/or NamPower SHEW Section shall be

responsible for responding to queries or complaints.

4. Ensure that adequate lines of communication are established

between the landowners, the neighbouring landowners and the

//Karas Regional Council, the Engineers, the Contractor,

neighbouring farmers/operators and the public at large to deal

with any public grievances.

5. Develop, implement and maintain an effective public complaints

registration and response system.

6. Train and raise awareness of staff to respect public property,

needs and right of way and to minimise disturbance and treat

neighbours and the public respectfully.

7. Deal with transgressions by staff severely (fines and dismissals).

8. Make use of local labour, local service providers and local

suppliers of material as much as reasonably possible.

9. Engage proactively with local authorities/ police to ensure that

job seekers do not try and enter the site seeking jobson the

construction site.

10. Formulate a rapid response plan to deal with security matters.

3.10.2 Impact of Workers 1. The employment of locals are limited on this power line project,

as the work requires highly skilled employees. In addition to

appointing Contractors, NamPower may undertake some of the

work itself.

2. Establish a labour policy to facilitate the employment and skills

training of locals, where feasible and as far as possible.

3. Set clear targets and criteria for local employment, if there are

opportunities to do so.

46


4. Create opportunities for the employment of women, where

feasible.

5. Use labour intensive methods of construction where possible.

6. The Contractor is to make it clear that no “on the door”

recruitment will be undertaken, this will hopefully mitigate a

possible influx of job seekers to the site.

7. HIV/AIDS awareness and life skills training must be provided to

all employees.

3.10.3 Liaison with Neighbouring Landowners

1. The Contractor must obtain a list of affected land owners, the

neighbouring land owners/ farmers, their contact details from the

PM in advance.

2. All land owners and neighbouring land owners must be informed

10 working days in advance of the desired dates at which

construction is to commence on their property.

3. Details of the construction activities to be undertaken, staff

undertaking these activities and any potential damage to

property are to be discussed with the landowners before

construction commences.

4. The Contractor shall not engage in any formal discussions with

landowners without prior consent from the PM.

8.

3.10.4 Prevention of Damage to Private Property

1. The Contractor, and his staff, must be extra vigilant, during the

construction activities, to prevent damage from occurring to any

private property including irrigation systems, pumps, buildings,

fences, cultivated fields and roads.

2. If damage to private property occurs the contractors must notify

the PM and take photographic evidence of the event.

3. The Contractor shall be responsible, at his own cost, for the

repair and reinstatement of any damages to existing structures

resulting from the construction works.

47


4. Any complaints received from the public or landowners regarding

any of the listings above shall be investigated and, if

substantiated, may result in a fine, suspension or dismissal of the

guilty party.

3.11 Security and Crime No. Aspect/ Issue Management Measure Management Objective and


3.11 Security and Crime 1. Contact with farm workers should be limited.

2. Any poaching or theft of plants must be immediately reported to

the PM and NamPower SHEW Section who shall notify the

relevant authorities.

3. Unsocial activities such as the consumption or illegal selling of

alcohol or drugs on site are prohibited.

4. Any staff of the Contractor or NamPower found to be engaged

in prohibited activities shall have disciplinary and / or criminal

action taken against them.

5. No person shall enter the site unless authorised to do so by the

Contractor or NamPower’s SHEW Section.

6. If any fencing interferes with the construction process, it may be

temporarily moved or removed until construction is completed.

The extent of such moving or removal of fences shall be

negotiated and agreed with the landowner in advance and in

writing.

7. Trespassing on properties adjoining the site is strictly forbidden.

8. The site must be secured in order to reduce the opportunity for

criminal activity at the locality of the construction site.

48


9. Appropriate fencing, security gates, shelter, signage and/or

security guards are to be provided at the construction site to

prevent theft of plant and materials, as well as to ensure the

security of site staff.

10. Gates must be closed after use where necessary during the

construction period.

3.12 Health and Safety


3.12.1 General Safety at the Construction Site

1. Comply with all Acts and regulations related to occupational

health and safety.

2. The construction site shall be off limits to the general public at all

times during the construction period and during site clean-up.

Adequate signage and communication in this regard shall be

implemented.

3. Safety precautions must be taken to ensure that labourers,

management, residents of communities neighbouring the site

come to no harm.

4. All potential construction-related danger areas must be clearly

demarcated with hazard tape and/or be fenced as appropriate.

Hazardous activities, such as stringing the lines, shall be

undertaken by highly skilled personnel and with the necessary

safety precautions and training having been put in place, prior to

the activity taking place.

5. Emergency numbers for the local police, fire department, and

other emergency services must be placed in a prominent clearly

visible area on site.

6. Fire-fighting equipment (e.g. fire extinguishers, fire blanket) must

49


be placed in prominent positions across the site where it is easily

accessible.

7. A speed limit of 40 km/h must be adhered to by all vehicles and

plant.

3.12.2 Personal Protective Equipment

1. Personal Protective Equipment (PPE) must be made available to

all construction staff and the wearing and use of PPE must be

compulsory.

2. Hard hats and safety shoes must be worn at all times and other

PPE worn where necessary i.e. dust masks, ear plugs, hard hat,

safety boots and overalls.

3. No person is to enter the site without the necessary PPE.

3.12.3 Staff Safety Considerations

1. All safety measures, work procedures and first aid must be

implemented on site.

2. A Health and Safety Plan must be developed by the Contractor

to govern staff safety while on site.

3. Contractors must ensure that all equipment is maintained in safe

operating condition.

4. A record of health and safety incidents must be kept on site.

5. Any health and safety incidents on site must be reported to the

PM immediately.

6. First aid facilities must be available on site at all times.

7. Material stockpiles must be stable and well secured to avoid

collapse and possible injury to site workers.

3.12.4 Eating Facilities

1. The Contractor shall designate eating areas, subject to the

approval of the PM.

2. There shall be no open fires on site.

3. The eating areas must be kept tidy and clean at all times to

50


prevent the luring of vermin, domesticated or wild animals.

4. Sufficient bins with vermin proof lids for waste disposal shall be

present within a 5 m radius of the eating area at all times.

3.12.5 Fire Prevention and Control

1. The Contractor shall take all reasonable and precautionary steps

to ensure that fires are not started as a consequence of his

activities on site.

2. The Contractor shall ensure that there is basic fire-fighting

equipment available on site. Fire-fighting equipment must be in

working order and serviced to date.

3. Flammable materials shall be stored under conditions that will

limit the potential for ignition and the spread of fires.

4. Smoking shall only be permitted in designated areas with fire

extinguishers.

5. The Contractor shall hold fire prevention talks with staff to create

an awareness of the risks of fire.

3.13 Monitoring


3.13.1 Obligations of the Contractor 1. The Contractor, or suitably qualified and experienced staff

member acting on his behalf, shall inspect the site on a daily

basis to ensure that the environmental specifications of the EMP

are adhered to.

2. The Contractor shall provide the PM with a weekly verbal report,

at a minimum, detailing compliance with the EMP as well as

environmental performance.

3. The Contractor shall maintain a record of incidents (spills,

impacts, complaints, legal transgressions) as well as corrective

51


and preventive actions taken, for submission to the PM at the

scheduled project meetings.

3.13.2 Environmentalist Audits

1. The PM shall appoint a qualified and experienced NamPower

SHEW Section (i.e. Environmentalist) to ensure implementation

of and adherence to the EMP.

2. The NamPower SHEW Section shall conduct audits to ensure

that the system for implementation of the EMP is operating

effectively. The audit programme shall consist of the following at

a minimum:

Audits at fortnightly intervals at a minimum.

An audit one week prior to practical completion of the project.

A post construction audit within 1 week after the Contractor

has moved off site.

3. The Contractor shall inspect the site on a daily basis to ensure

that the environmental specifications are adhered to.

4. The Contractor shall provide the PM with a verbal report, on a

weekly basis, detailing both compliance with the EMP, as well as

environmental performance.

5. The Contractor shall maintain a record of incidents (spills,

impacts, complaints, legal transgressions) as well as corrective

and preventive actions taken, for submission to the PM at the

scheduled project meetings.

6. The NamPower SHEW Section shall conduct audits to ensure

that the system for implementation of the EMP is operating

effectively. The audit shall check that a procedure is in place to

ensure that:

The EMP being used is up to date.

Variations to the EMP, non-compliances and corrective

52


actions are documented.

Emergency procedures are in place and effectively

communicated to personnel.

3.13.3 Compliance with the EMP

The Contractor and/or his agents are deemed not to have complied with the EMP and remedial action if:

1. Within the boundaries of the site or extensions there is evidence

of contravention of the EMP clauses.

2. Environmental damage ensues due to negligence.

3. The Contractor fails to comply with corrective or other

instructions issued by the PM, within a time period specified by

the PM.

3.13.4 Tolerances 1. Environmental management is concerned not only with the final

results of the Contractor’s operations to carry out the Works, but

also with the control of how those operations are carried out.

2. Tolerance with respect to environmental matters applies not only

to the finished product but also to the standard of the day-to-day

operation required to complete the Works.

3. It is thus required that the Contractor shall comply with the

environmental requirements on an ongoing basis and any failure

on his part to do so will entitle the PM to rectify the matter subject

to the details set out.

3.13.5 Specific Monitoring It is recommended that:

1. Access roads be inspected on a fortnightly basis for signs of

damage, erosion and dust creation. It is anticipated that large

vehicles will be used during the transport of materials (e.g. poles,

conductors), equipment and machinery.

2. Frequent monitoring during construction should consider

possible sources of dust and erosion, and whether these are

53


controlled and managed appropriately. Special attention should

be given to the presence of any new erosion features, unstable

slopes and crossings of drainage lines of the access roads

3.14 Construction Site Decommissioning


3.14.1 Removal materials and equipment

1. All structures, vehicles, plant and materials are to be removed

once the works are completed.

2. The site is to be checked for spills of contaminant substances,

and these shall be cleaned up and disposed of appropriately.

3. The Contractor is to check that the site is free from building

rubble, concrete, conductor, poles, spoil materials and waste

materials.

4. All residual stockpiles must be removed or spread on site as

directed by the NamPower SHEW Section.

5. The Contractor must repair any damage that the construction

works has caused to properties, access roads and structures/

fixtures.

3.14.2 Temporary Services 1. The Contractor must arrange the cancellation of all temporary

services.

2. All areas where temporary services were installed are to be

rehabilitated to the satisfaction of the NamPower SHEW Section.

54


3.15 Completion of Contract No. Aspect/ Issue Management Measure Management Objective and


3.15

1. Prior to completion, the Contractor is to timely notify the PM of

proposed ‘Practical Completion’ meetings and ‘snagging lists’ to

provide an opportunity to identify work outstanding or incomplete.

2. The PM is to approve ‘Practical Completion’ and must timely

inform the NamPower SHEW Section of Contract Completion so

that a final audit can be arranged.

3. A copy of the final audit, completed by the NamPower SHEW

Section, must be sent to the competent authority for review and

comment.

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