application for the renewal of environmental...

APPLICATION FOR THE RENEWAL OF ENVIRONMENTAL

CLEARANCE CERTIFICATE FOR EPL 3542 LOCATED IN THE AREA

BETWEEN OTAVI, GROOTFONTEIN and TSUMEB OTJOZONDJUPA

REGION

CONSULTANT: PROPONENT

Mr. Ipeinge Mundjulu (BSC, MSc) Sabre Resources Pty Ltd

Red-Dune Consulting CC P O Box 87100

P O Box 27623 Windhoek Eros

Cell: +264 81 147 7889 Windhoek

Proponent Sabre Resources Pty Ltd

License Number EPL 3542

Location Between Otavi, Tsumeb and

Grootfontein, 15 Km North east of

Grootfontein

Stage Final

Author Ipeinge E. Mundjulu

Aim RENEWAL of Environmental

Clearance Certificate

DOCUMENT INFORMATION

Table of Contents Acknowledgements ......................................................................................................................... 1

Executive Summary ........................................................................................................................ 2

1. Introduction ............................................................................................................................. 3

2. Overview of the project .......................................................................................................... 3

2.1.1. Location .................................................................................................................... 3

2.1.2. Exploration activities ................................................................................................ 5

2.1.3. Period 2011-2017 ...................................................................................................... 5

2.1.4. Period 2017-2019 ...................................................................................................... 6

3. The Environmental Management Plan.................................................................................... 7

3.1. Purpose of the EMP.......................................................................................................... 7

3.2. Compliance to the EMP ................................................................................................... 7

3.3. Roles and Responsibilities ............................................................................................... 7

3.3.1. Proponent .................................................................................................................. 7

3.3.2. Environmental Compliance Officer (ECO) .............................................................. 8

3.3.3. Site Manager ............................................................................................................. 8

3.3.4. Employees ................................................................................................................. 8

3.4. Disciplinary Action .......................................................................................................... 8

3.4.1. Proponent .................................................................................................................. 8

3.4.2. Workers ..................................................................................................................... 8

4. The EMP Tables Mitigation Measure and Commitments ...................................................... 9

5. Conclusion and Recommendations ....................................................................................... 23

5.1. Conclusion ...................................................................................................................... 23

5.2. Recommendations .......................................................................................................... 23

6. Reference .............................................................................................................................. 24

7. Appendixes ........................................................................................................................... 25

7.1. Previous and Current Environmental Clearance Certificate .......................................... 25

7.2. Curriculum of the Environmental Assessment Practitioner ........................................... 26

List of Figures

Figure 2-1. Location of EPL 3542 ................................................................................................. 4

List of Tables

Table 4-1 Field Mapping, Geophysical Surveys And Soil Sampling ............................................ 9

Table 4-2 Drill Site Establishment ............................................................................................... 12

Table 4-3. Drilling ........................................................................................................................ 14

Table 4-4. Relevant to All Exploration Activities........................................................................ 17

Table 4-5. Closure and Rehabilitation.......................................................................................... 20

ACRONYMS

AIDS Acquired Immune Deficiency Syndrome

DEA Department of Environmental Affairs

ECC Environmental Clearance Certificate

EIA Environmental Impact Assessment

EMA Environmental Management Act (No. 7 of 2007)

EMP Environmental Management Plan

HIV Human Immune Virus

MET Ministry of Environment and Tourism

MME Ministry of Mines and Energy

RC Reverse Circulation

RDC Red-Dune Consulting CC

1

Acknowledgements

The renewal of an Environmental Clearance Certificate follows an existing Environmental

Management Plan (EMP) that was approved by the approving authority. The EMP for the

Exclusive Prospecting License 3540 was developed by SLR Consulting Namibia. Red-Dune

consulting has reviewed the EMP for purposes of renewing the Environmental Clearance

Certificate as requested by Sabre Resources Namibia Pty Ltd. Red-Dune Consulting hereby

acknowledge the great work done by SLR Consulting. This document remains the property of

Sabre Resources Namibia Pty Ltd and the Copyright, especially the EMP remains for SLR

Consulting Company

2

Executive Summary

Sabre Resources Pty Ltd is a holder of the Exclusive Prospecting: License (EPL) 3542. The EPL

was granted in 2011, exploration is a listed activity under the Environmental Management Act

(Act No. 7 of 2007) that may not be undertake without an Environmental Clearance Certificate

(ECC). The company was issued with an ECC in 2014. The following exploration activities took

place; Geological studies and field mapping, Soil surveys, Geophysical surveys and Drilling

(Reverse Circulation) between 2014 and 2017. The ECC was renewed in January 2017 where bi-

annual and rehabilitation reports report detailing undertaken activities were submitted, which

formed the basis of the ECC renewal in 2017.

For the period between 2017 to 2019 no exploration activities took place, hence the state of the

environments remained the same since the renewal of the ECC in 2017. Because of this, there were

no bi-annual reports produced. The renewed ECC is now due to expire in January 2020, hence the

company is hereby applying for the renewal of the ECC for the period of three years.

Exploration activities are not necessarily detrimental to the bio-physical environment because of

less evasive activities. The drilling holes are covered up, access road are restricted to the existing

roads if new roads are established to the target site, they are rehabilitated after use. With adequate

implementation of the EMP, the project operation would not have adverse impacts.

Water is a scarce resource in Namibia, the project is not expected to use significant amount of

water in a sense that, there would be no water abstraction. The area between Otavi, Tsumeb and

Grootfontein, often referred to as the “Maize Triangle” is rich in water resource, ground water "in

the area is found at 60m and drilling is expected to intersect groundwater. Drilling of boreholes

for water abstraction requires a permit from Ministry of Agriculture, Water and Forestry (MAWF).

In an event where the farm owner would want a drill site to become a water borehole, all necessary

permits should be obtained. At this moment, all holes shall be filled up completely.

3

1. Introduction

Sabre Resources Pty Ltd was granted the Exclusive Prospecting License EPL 3542 as per the

Mineral Resource Act 1992 in September 2011 which valid until August 2021 (Appendix 7.1).

Exploration activity is a listed under Environmental Management Act (Act No. 7 of 2007) (EMA),

that may not be undertaken without an Environmental Clearance Certificate (ECC). The company

was initially issued with an ECC in 2014 (Appendix 7.2). In accordance with EMA, the ECC is

valid for a period of three years and Section 56 of EMA provides for the renewal of the ECC. In

accordance with this provision, the ECC was renewed in 2017 and due to expire in January 2020

(Appendix 7.2). Accordingly, the company is hereby applying for the second renewal of the

Environmental Clearance for EPL 3542.

2. Overview of the project

2.1.1. Location

The EPL 3542 is located in the area between Otavi and Grootfontein (Figure 1). The southern

boundary is located at 19.63250000 S, 17.58666667 E and the northern boundary at 19.45777778

S, 17.99861111 E. Initially, the EPL covered an area of 47,497.0 hectares and was reduced to

23,694 hectares which is a 50 percent reduction in area in the renewal application submitted to the

ministry of mines and Energy in terms of the Minerals (Prospecting and Mining) Act, 1992 (Act

No. 33 of 1992) It covers several commercial farms, whose main land use is agriculture,

predominantly cattle farming.

4

Figure 2-1. Location of EPL 3542

Driehoek Pb/Zn

Border (Pb/Zn

Toggenburg Pb/Zn

5

2.1.2. Exploration activities

2.1.3. Period 2011-2017

Since the granting of the EPL in 2011, the following exploration activities took place between

2014 and 2016.

Geological studies and field mapping

o During this stage, various geological data for the area were collected from

different sources to analyses and study available information of the area.

Information are derived from aerial photo. These geological photos were studied

to generate target point where geochemical soil sampling were taken.

Soil surveys

o Soil survey was the process used to classify soil types and other soil properties in

target area which is used for geo-encoding. The collection of information of the

substrata, by air or ground, through sensors such as radar, magnetic and

electromagnetic to detect any mineralization in the area. This is a non-evasive

process that does not have impact on the environment.

Geophysical surveys

o Geophysical ground surveys used various method to gather geological information

such as magnetic and electromagnetics. Magnetic surveying measure local

magnetic field characteristic of the generated targets from geological mapping. This

activity was used to detect minerals that respond to magnetic field. It provided

information of a sub-surface area without physically opening the ground and is able

to detect metal ore in the ground. The activity was done from air and on ground.

On ground, a Magnetometer was carried by a person on the surveyed areas to collect

samples. While in aerial magnetic data was collected using a helicopter where the

Magnetometer is mounted and this was used on difficult terrain and on large

terrains. This activity does not pose significant impact to the environment

6

Drilling (Reverse Circulation)

o Reverse Circulation drilling often referred to as ‘RC’ drilling uses rods (shafts) with

inner and outer tubes with drill bit attached to an air-filled interchanging piston

known as a hammer. The hammer produces drill cuttings that are returned to surface

inside the rods. RC drill are carried on drill rigs, which are mostly powerful heavy

truck. World over, RC drilling is the most preferred method because it is less costly

and produces liable materials that are free from contamination. In an arid place like

Namibia, RC Drilling would be advantageous because it does not require water for

rock drilling unlike Diamond core drilling that requires water for lubrication. Once

the proposed exploration has been concluded, the impacted sites will be

rehabilitated in accordance with the requirements of the EMP.

The Bi-annual report and rehabilitation repots of evasive activities that took place were submitted

to the Ministry of Environmental and Tourism and it was these reports which formed the basis of

the ECC renewal in January 2017.

2.1.4. Period 2017-2019

There were no exploration activities during the period of 2017 – 2019. The status of the

environment remains as it was reported during the period of 2011-2017. MET is in position of

these reports.

7

3. The Environmental Management Plan

3.1. Purpose of the EMP

The Environmental Management Plan (EMP) is a risk strategy that contains logical framework,

monitoring programme, mitigation measures, and management control strategies to minimize

environmental impacts. It further stipulates the roles and responsibility of persons involved in the

project. These strategies are developed to reduce the levels of impacts for the projects.

3.2. Compliance to the EMP

This EMP is a legally binding document as given under the provisions of the Environmental

Management Act, 2007 (Act No. 7 of 2007). The proponent and its contractors must adhere to

the framework of this document.

3.3. Roles and Responsibilities

3.3.1. Proponent

The proponent, shall take overall responsibility for proper implementation of the EMP. It remains

the responsibility of the proponent to appoint key personnel for the implementation of the EMP.

The proponent must therefore;

Appoint a site Manager;

Ensure employees understand the guidelines of the EMP;

Ensure the EMP is well explain to Contractors;

Ensure safer working environment;

Provide workers with Personal Protective Clothing;

Ensure the environment is protected and;

8

In events where the proponent hires or subcontract contractors for the job, the proponent must

ensure that the contractor is in position to execute the mandate of the EMP;

3.3.2. Environmental Compliance Officer (ECO)

Compliance to EMP is enforce by the environmental inspector as provided for under

Environmental Management Act (No. 7 of 2007) (EMA). Hence the Environmental Compliance

Officer (ECO) is an individual appointed as an environmental inspector under EMA. Depending

on his/her work schedule, the ECO shall visit the site at any time for environmental inspection and

monitoring.

3.3.3. Site Manager

The Site Manager (SM) represents the proponent on site. He/she shall be responsible for daily

activities in ensuring environmental protection. All communication with regard to the

implementation of EMP must be channeled through the SM.

3.3.4. Employees

It shall be responsibility of employees to adhere to the provision of EMP. At all times when on

site, employees are expected to ensure their safety by wearing personal protective equipment

clothing, report worn out PPE and request for replacement.

3.4. Disciplinary Action

3.4.1. Proponent

The EMP is a legally binding document, non-compliance to the EMP is punishable upon

conviction under EMA. Amongst others, legal action, fines and suspension of work or both.

3.4.2. Workers

Workers found contravening the EMP must be disciplined by the proponent such as written

warning

9

4. The EMP Tables Mitigation Measure and Commitments

This EMP table is not altered as provided from the proponent. The EMP was developed by SLR Consulting. Red-Dune reviewed the EMP and the

gaps /comments are provided in red.

Table 4-1 Field Mapping, Geophysical Surveys And Soil Sampling

Activity Potential Impact

Management and Mitigation Measures Action Plan Frequency Responsible

Parties

Air survey Noise Discuss flight plans and schedule with land owners prior to air

surveys.

Avoid residences, game and livestock enclosures where possible.

Prior to

air

surveys

Project Manager

Pilots

Ground survey,

mapping and soil

sampling

Socio-

economic

Honour agreements set out in the site-access contracts

Consult and provide feedback regarding activities on the

individual properties

Provide contact details to a designated Sabre Resources person,

who will serve as liaison between landowners and the

exploration teams

Land owners to be provided with a list of all people working on

site

All staff operating on site will be provided with identification

and proof that they are working for the applicant

Ensure gates are closed after entry and exit.

Duration

of

mapping

and

surveying

Project

Manager

Site

supervisor

10



Parties

Biodiversity The footprint of the area to be disturbed for surveying/mapping

and for providing access to survey sites will be minimised as far

as is practically possible.

Sabre Resources will implement a zero tolerance policy with

regards to the killing or collecting of any biodiversity. This

applies to people directly employed by Sabre Resources as well as

any contractors working on their behalf.

Employees and contractors will be shown the value of

biodiversity and the need to conserve the species and systems that

occur within the project area.

No open fires will be permitted on site.

Speed limits will be enforced so as to prevent road kills.

Permits will be required for the removal of protected tree species.

Duration

of

mapping

and

surveying

Project

Manager

Site

supervisor

Air quality Vehicle speeds will be limited to 40km/h on access routes to limit

dust.

Duration

of

mapping

and

surveying

Project

Manager

Site

supervisor

11



Parties

Heritage In the event that archaeological resources are discovered, a

chance find emergency procedure will be implemented which

includes the following:

All work at the find will be stopped to prevent damage;

An appropriate heritage specialist will be appointed to assess

the find and related impacts; and

Permitting applications will be made to the necessary

authorities, if required.

In the event that any graves are discovered during the

exploration activities, these will be avoided and preserved as

a first priority. If damage is unavoidable, prior to damaging

or destroying any identified graves, permission for the

exhumation and relocation of graves must be obtained from

the relevant descendants (if known) and the relevant local

and provincial authorities

Duration

of

mapping

and

surveying

Project

Manager

Site

supervisor

12

Table 4-2 Drill Site Establishment

Activities Potential Impact Management and Mitigation Measures Action Plan

Frequency Responsible

Parties

- Access the drill site

using a new access

track where

necessary

- Set-up drilling

machine with drip

trays and

groundsheets

- Strip vegetation

and topsoil (up to

300mm where

available)

- Temporarily store

topsoil adjacent to

drill site

- Set-up ablution

Air quality –

dust and

gaseous

emissions

The movement of drilling related vehicles on the unpaved

access track will be on a small scale

Vehicle speeds will be limited to 30km/h on site

Vehicles and the drilling rig will be maintained in good

working order

Minimize new access route development (routes to be

approved by land owners prior to development)

On-going Project

Manager

Site

supervisor

Noise Vehicles will travel maximum 30 km/hour near

houses/settlements

Ongoing Project Manager

Site supervisor

Biodiversity Refer to biodiversity management measures relating to

ground surveying, mapping and sampling (Table 4-1).

Honour agreements set out in the site-access contracts,

specifically relating to the areas utilized for game and

livestock farming. Special consideration should be given to

the sensitive hunting season.

Ongoing Project

Manager

Site

supervisor

13



Parties

facilities

- Set-up fuel and

lubricants storage

area

- Waste management

Provide appropriate toilet facilities for the exploration

workers on the site or agree with landowner to use certain

facilities on the farm.

Land use Access agreements to be prepared and approved prior to drill

site establishment.

The footprint of the area to be disturbed will be minimised as

far as is practically possible.

Areas used as laydown areas are to be raked and/or ploughed

to encourage re- vegetation

Agree on relevant compensation with land-owners where

land uses are impacted

Ongoing Project

Manager

Site

supervisor

Heritage Refer to heritage management measures relating to ground

surveying, mapping and sampling (Table 4-1)


Site supervisor

Socio-economic Refer to socio-economic management measures relating to

ground surveying, mapping and sampling (Table 4-1)


14

Table 4-3. Drilling



Parties

- Drill borehole

- Contain all

drilling water in

the sump and

allow to settle

- Log the drill core

and place on core

trays

- Maintain ablution

facilities

Contamination

of

soil/Hydrocarbo

n spillages

In all areas where there is storage of hazardous substances

(i.e. hydrocarbons), there will be containment of spillages on

impermeable floors and bunded trays that can contain 110%

of the volume of the hazardous substances.

All refueling and any maintenance of vehicles will take place

on impermeable surfaces.

Pollution will be prevented through basic infrastructure

design and through maintenance of equipment.

Spill kits will be readily available on site. Employees and/or

contractors will be shown to use the spill kits to enable

containment and remediation of pollution incidents.

Environmental awareness training of contractor

Sabre Resourceswill establish environmental awareness in

employees and contractors

A PVC lined sump will be used for collection of oils and silt

contained in the drilling water

Any spills will be contained and cleaned up immediately

On-going

for all

drilling

activities

Project

Manager

Site

supervisor

15



Parties

Non-toxic and biodegradable drilling lubricant will be used

Groundwater

contamination

Refer to management measures relating to contamination of

soils.

Licenses in terms of the Water Resource Management Act

(Act No. 11 of 2013) will be obtained for all drilled holes

(not just boreholes).




On-going

for all

drilling

activities

Project

Manager

Site

supervisor

Air quality

deterioration

Vehicle speeds will be limited to 40km/h on access routes to

limit dust.

The movement of drilling related vehicles on unpaved access

track will be on a small scale.

Water sprays can be used around the lay-down area when a

drill-site is located

near settlements (or sensitive land-use areas, i.e. horticultural

areas).

On-going

for all

drilling

activities

Project

Manager

Site

supervisor

16



Parties

Noise generation Drilling will only be conducted during the day when drill

sites are located close to inhabited homesteads.

Drilling plans and schedules will be discussed and agreed

upon with land owners prior to initiation.

Vehicles will travel maximum 30 km/hour near

houses/settlements.

On-going

for all

drilling

activities

Project

Manager

Site

supervisor

Land use Refer to land use management measures relating to drill site

establishment (Table 4-2)

On-going

for all

drilling

activities

Project Manager

Site supervisor

Water abstraction Groundwater

quantity

Water use licenses in terms of the Water Resource

Management Act (Act No. 11 of 2013) will be obtained for

all boreholes.

Water levels will be measured prior to abstraction, during

abstraction (daily) and after completion. Levels will be

reported to land owners.

Should water be reached during drilling the landowners will

be informed. Should the landowners wish it; the holes will

On-going

for all

drilling

activities

Project

Manager

Site

supervisor

17



Parties

be cased and left for use by the farmers (liability relating to

the boreholes will then be transferred to the landowners).

Table 4-4. Relevant to All Exploration Activities


Frequency Responsible Parties

All exploration

activities

Social –

provision of

toilet facilities

and other

Socio

Economic

Impacts

(Employment,

Alcohol and

Drug Abuse,




Employment

Recruit locals for unskilled labour

Where possible, procure materials from local suppliers

Alcohol and Drug Abuse

Ban the use of alcohol and drugs at work place

On-going

for all

exploration

activities

Project Manager

Site supervisor

18



HIV and AID Teach employees about dangers alcohol and substance

abuse

All employees must be screen with the breathalyser to

avoid intoxicated personnel on site

HIV and AIDS

Provide HIV / AIDS awareness at induction

Avail Condoms at the mine site

Waste

Management

Waste generated will be handled in accordance with the

contract signed with the landowner.

Suitable receptacles for waste disposal will be provided at

appropriate locations on site. These receptacles will be clearly

marked for different waste types.

Employees and contractors will be shown the importance of

correct waste disposal as well as waste minimization and

recycling.

Waste will be removed from site and disposed of at a suitable

licensed waste disposal facility.

Project

Manager

Site

supervisor

19



Hazardous waste (including hydrocarbon contaminated

material/soil) will be disposed of at a licensed hazardous

waste disposal facility.

20

Table 4-5. Closure and Rehabilitation

Activities Potential

Impact

Management and Mitigation Measures Action Plan


Parties

General closure

activities:

- Close drill holes

(unless otherwise

agreed with farmers)

- Remove water from

the sump and drip

trays

- Remove oils and silt

from drip trays and

store until disposal to

permitted hazardous

landfill site

- Backfill the sump

once it has dried out

(dome to allow for

Groundwater

and

surface

water

contaminat

ion

In all areas where there is storage of hazardous substances

(i.e. hydrocarbons),

There will be containment of spillages on impermeable floors

and bunded trays that can contain 110% of the volume of the

hazardous substances.

All refueling and any maintenance of vehicles will take place

on impermeable surfaces.

Pollution will be prevented through basic infrastructure

design and through maintenance of equipment.

Spill kits will be readily available on site. Employees and/or

contractors will be shown how to use the spill kits to enable

containment and remediation of pollution incidents.

Any spills will be contained and cleaned up immediately

Once- Closure

of

drill site

Project Manager

Site supervisor

Noise pollution Vehicles will travel maximum 30 km/hour near

houses/settlements.

On-going Project Manager

Site supervisor

21


Impact



Parties

subsidence) and plug

borehole (unless an

agreement is in place

with landowner for

alternative uses)

- Move drill core trays,

ablution facilities,

water bowser, stores

and drill rig from the

site

- Dispose of any general

waste to a permitted

landfill site

- Remove temporary

fencing

- Rip and plough

compacted areas

Contaminati

on of soils

Refer to management measures relating to contamination of

water

On-going

and

closure

Project

Manager

Site

supervisor

Air

quality

deteriorati

on

Vehicle speeds will be limited to 40km/h on access routes to

limit dust.

The movement of drilling related vehicles on unpaved access

track will be on a small scale.

On-going Project

Manager

Site

supervisor

Soil erosion Impacted footprints are to be raked and/or ploughed to

encourage re- vegetation

Access routes will be ripped unless the land owners wish for

them to remain.

A monitoring program will be implemented to establish re-

vegetation progress

Agree on relevant compensation with land-owners where

land used for hunting

purposes is impacted

Starts at

closure,

continues for

a pre-

determined

time (as

stated in

agreements)

Project

Manager

Site

supervisor

22


Impact



Parties

- Replace topsoil over

disturbed area

- Rehabilitate access

track by ripping

- GPS marker to

identify

- drill site

Waste

management

Decommission ablution facilities

Ensure that all waste generated during activities is removed

from the site and

disposed of appropriately

Once off Project

Manager

Site

supervisor

Land use Land owners will be invited to carry out site inspections

following rehabilitation in order to ensure that it has been

carried out suitably.

Post-closure Project

Manager

Site

supervisor

23

5. Conclusion and Recommendations

5.1. Conclusion

The following are points of consideration;

The review of the Environmental Management Plan found it adequate, practical and

efficient towards the improvement of environmental sustainability;

No exploration activities took place between the period of 2017 and 2019;

The ECC is due for renewal in January 2020;

In accordance to the submitted bi-annual report in 2017, there were no red-flags or

complaints from farmers about environmental performance;

With adequate implementation of the EMP, the project is not expected to pose harm to

the environment.

5.2. Recommendations

It is recommended to the approving authority to approve the renewal of the

Environmental Clearance Certificate.

It is further recommended to the approving authority to conduct site inspections,

especially the drilled site and establish cordial relationship with farmers’ associations

whom are crucial at monitoring the exploration activities in order to ensure compliance to

the law and the EMP.

24

6. Reference

Dr. Martin Pickford and Dr Brigitte Denut 2010., Memoir 21 Karst Geology and

Palaeobiology of Northern Namibia, Ministry of Mines and Energy Geological Survey

of Namibia

Enviro Dynamics 2014., Environmental Assessment for the exploration of base metals on

exclusive prospecting licenses 5606, 4934, 5712 & 5713), Kavango East Region,

Namibia.

Greg Christelis and Wilhelm Struckmeier 2011., Groundwater in Namibia; An Explanation

to the Hydrogeological Map, Ministry of Agriculture Water and Forestry

J.E. Misiewicz 1988., The Geology and Metallogeny of the Otavi Mountain land, Damara

Orogen, Swa/Namibia, with particular reference to the Berg Aukas zn·pb-v Deposit - A

Model of Ore Genesis

25

7. Appendixes

7.1. Previous and Current Environmental Clearance Certificate

26

7.2. Curriculum of the Environmental Assessment Practitioner

application for the renewal of environmental...

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