environmental performance report and management plan for...

ENVIRONMENTAL PERFORMANCE REPORT AND MANAGEMENT PLAN FOR WATER

ABSTRACTION BOREHOLES AT ABINBEV (NAMIBIA)

Okahandja, Otjozondjupa Region

JULY 2019

SLR Project No.: 733.19094.00007 Report No.: 2 Revision No.: 2 July 2019

Environmental Performance Report and Management Plan for Water Abstraction Boreholes at AB InBev (Namibia)

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DOCUMENT INFORMATION

Title Environmental Performance Report and Management Plan for Water Abstraction Boreholes at ABInBev (Namibia)

Project Manager Marvin Sanzila

Project Manager e-mail [email protected]

Author Marvin Sanzila

Reviewer Jonathan Crowther

Keywords AB InBev (Namibia), Environmental Performance Report, Environmental Management Plan, ECC renewal, groundwater abstraction, boreholes

Status Final

SLR Project No 733.19094.00007

Report No 2

DOCUMENT REVISION RECORD

Rev No. Issue Date Description Issued By

1 30 June 2019 Draft Report MS

2 31 July 2019 Final Report MS

BASIS OF REPORT

This document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescales and resources devoted to it by agreement with ABInBev (Namibia) for part or all of the services it has been appointed by the Client to carry out. It is subject to the terms and conditions of that appointment.

SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or collateral warranty.

Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.

SLR disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the work.

The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this report remain vested in SLR unless the terms of appointment state otherwise.

This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which may be unclear to it.

Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents referenced explicitly herein and should then only be used within the context of the appointment.


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CONTENTS

INTRODUCTION ................................................................................................................................. 1 1

PROJECT BACKGROUND ................................................................................................................................. 1 1.1

ENVIRO-LEGAL CONTEXT ............................................................................................................................... 1 1.2

LOCATION OF BOREHOLES AND INFRASTRUCTURE ............................................................................. 3 2

GEOLOGICAL SETTING ................................................................................................................................... 3 2.1

BOREHOLE LOCATION AND EXISTING INFRASTURCURE ................................................................................ 3 2.2

BOREHOLE WW204437- SOUTHERN CROSS ............................................................................................................................................. 3 2.2.1

BOREHOLES (WW204438 - NEARBY) AND (WW204440 - WESTERN) ..................................................................................................... 4 2.2.2

BOREHOLE WW204489 (BURGER BUTLER) ............................................................................................................................................... 4 2.2.3

BOREHOLE WW204439 (ROOI VLAK) ........................................................................................................................................................ 4 2.2.4

WATER MONITORING METHODS ........................................................................................................ 6 3

GROUNDWATER ABSTRACTION ..................................................................................................................... 6 3.1

WATER QUALITY ANALYSIS ............................................................................................................................ 7 3.2

GROUNDWATER MONITORING RESULTS ............................................................................................ 9 4

GROUND WATER ABSTRACTION RATES ......................................................................................................... 9 4.1

GROUND WATER QUALITY ANALYSIS ............................................................................................................. 9 4.2

POTENTIAL ENVIRONMENTAL IMPACTS ............................................................................................ 10 5

HYDROCARBON SPILLS AND WATER QUALITY ........................................................................................................................................ 10 5.1.1

WATER QUANTITY .................................................................................................................................................................................... 10 5.1.2

TAMPERING OF BOREHOLES .................................................................................................................................................................... 10 5.1.3

WASTE MANAGEMENT ............................................................................................................................................................................ 11 5.1.4

BIODIVERSITY ............................................................................................................................................................................................ 11 5.1.5

ENVIRONMENTAL MANAGEMENT PLAN ........................................................................................... 11 6

AIMS ............................................................................................................................................................ 11 6.1

ACTION PLANS TO ACHIEVE OBJECTIVES ..................................................................................................... 11 6.2

ROLES AND RESPONSIBILITIES ..................................................................................................................... 11 6.3

CONCLUSION ................................................................................................................................... 15 7

REFERENCES .................................................................................................................................... 16 8


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APPENDICES

APPENDIX A: ABINBEV GROUND WATER ABSTRACTION PERMIT NUMBER 11234 ..................................... 17 APPENDIX B: DESCRIPTION OF THE ABINBEV BOREHOLE\ SITES ................................................................. 18 APPENDIX C: ABINBEV’S LEGAL OPINION RELEVANT TO GROUNDWATER ABSTRACTION REQUIREMENTS20 APPENDIX D: AB INBEV (SABMILLER) GROUNDWATER INVESTIGATION STUDY .......................................... 21 APPENDIX E: GROUNDWATER QUALITY ANALYSIS RESULTS (FEBRUARY 2017- FEBRUARY 2018) .............. 22 APPENDIX F: LETTER OF CONSENT AND TERMS OF AGREEMENT BETWEEN ABINBEV AND THE MUNICIPALITY OF OKAHANDJA ............................................................................................................................. 23

LIST OF TABLES

TABLE 3-1: RECOMMENDED GROUND WATER ABSTRACTION RATES .............................................................. 6 TABLE 3-2: GROUNDWATER MONITORING PARAMETERS. ............................................................................... 7 TABLE 4-1: GROUND WATER ABSTRACTION MONITORING RESULTS (2016 - 2019) ......................................... 9 TABLE 6-2: MITIGATION ACTIONS RELATED TO WATER QUANTITY ................................................................ 12 TABLE 6-3: MITIGATION ACTIONS RELATED TO UNPLANNED ACCESS TO THE BOREHOLES ........................... 13 TABLE 6-4: MITIGATION ACTIONS RELATED TO WASTE MANAGEMENT ........................................................ 14

LIST OF FIGURES

FIGURE 2-1: REGIONAL SETTING OF BOREHOLES AT THE AB INBEV BREWERY ............................................ 5 FIGURE 3-1: AB INBEV BOREHOLE AND SCADA SYSTEM DISPLAY. ................................................................ 7


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ACRONYMS AND ABBREVIATIONS

Acronym / Abbreviation

Definition

AB InBev Anheuser-Busch ABInBev

DWAF Department of Water Affairs and Forestry

COW City of Windhoek

ECC Environmental Clearance Certificate

EIA Environmental Impact Assessment

EMP Environmental Management Plan

LDV Light Diesel Vehicle

MAWF Ministry of Agriculture, Water and Forestry

mbgl meters below ground level

MET Ministry of Environment and Tourism

SLR SLR Environmental Consulting (Namibia) (Pty) Ltd


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INTRODUCTION 1

PROJECT BACKGROUND 1.1

Anheuser-Busch AB InBev is the world’s largest multinational drink and brewing holdings company. AB InBev

has expanded its business ventures through the acquisition of various subsidiaries, most notably SAB Miller in

October 2016. This purchase led to AB InBev acquiring or opening additional branches across Africa, including

in Namibia. AB InBev (referred to as AB InBev in this report), previously known as SAB Miller Namibia (Pty) Ltd,

was officially started in 2014 and is committed to brewing the highest quality beer and improving livelihoods of

the local farmers, retailers and communities. AB InBev has constructed and operates a brewery located in the

industrial area of Okahandja, Otjozondjupa Region, Namibia.

The production of beer requires large volumes of water. In the past AB InBev’s water requirement/ demand

had been supplied by the Okahandja Municipality. The Municipality sourced the water from a local dam. The

ongoing drought conditions have reduced dam levels and led the Okahandja Municipality to constrain the

supply to customers. AB InBev has investigated various alternate water sources in order to augment the water

demand of 80 000 – 125 000 m3/annum.

In 2016, SAB Miller (now AB InBev) appointed SLR (Namibia) Environmental Consulting Pty (Ltd) (SLR) to

investigate groundwater abstraction as an alternative water source. The Municipality of Okahandja provided

support towards the option of using groundwater boreholes as an alternative water source as this would

minimise the demand of what supply from the municipality. This further led to an agreement of service

delivery between the municipality of Okahandja and AB InBev (Refer to Appendix F, for letter of consent and

terms of agreement from the Municipality of Okahandja). SLR drilled and pump tested four (4) successful

boreholes and tested an existing borehole belonging to the Municipality of Okahandja (handed over to AB

InBev). This confirmed that the, then, annual demand of 125,000 m3could be secured by groundwater

abstraction.

ENVIRO-LEGAL CONTEXT 1.2

In 2017, subsequent to the drilling and pumping testing, an application was made to the Department of Water

Affairs (DWAF) within the Ministry of Agriculture, Water and Forestry (MAWF) for a groundwater abstraction

permit. DWAF issued Permit Number 11234 for the four boreholes namely WW 204437, WW204438,

WW204439 and WW204722 (see Appendix A).

It was subsequently determined that the groundwater abstraction activity is not located within a “water

controlled area”. There is thus no requirement for AB InBev to hold a groundwater abstraction permit. In 2018,

AB InBev requested a legal opinion from ENSafrica Namibia to advise on the following:

Whether the proponent requires a water abstraction permit under any law or regulation granted by the DWAF;

Whether the proponent has to be granted permission for such abstraction from the Municipality of Okahandja.

The legal opinion (ENSafrica Namibia, 2018) found that there is no legal basis upon which the regulating

authority (MAWF) would be entitled to require the proponent (AB InBev) to hold a water abstraction permit, so

long as the proponent was not abstracting from a “water controlled area”. The project location and

groundwater abstraction activities are not within a “water controlled area”, but are in what is regarded as


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private water as interpreted from the Water Act, 1956 “giving sole mandate and exclusive right to the

proponent”.

The legal opinion further noted that AB InBev should hold an Environmental Clearance Certificate (ECC) for the

water abstraction activities in terms of the Environmental Management Act, 2007 (Act No. 7 of 2007). Under

the Environmental Management Act, 2007 (Act No. 7 of 2007) and The Environmental Impact Assessment

Regulations, which are regulated by the Ministry of Environment and Tourism (MET), an Environmental Impact

Assessment (EIA) process and the application for an ECC is required for listed activities including:

WATER RESOURCE DEVELOPMENTS

8.1 The abstraction of ground or surface water for industrial or commercial purposes.

Thus on the 7th of December 2018, AB InBev requested SLR to apply for an exemption from ECC for the

abstraction of groundwater from the four (4) boreholes located within the premises of the AB InBev beverage

production plant. (Refer to Figure 1 for site map to the boreholes). The MET declined the application, in a

response letter dated 21st of January 2019, and further requested the submission of an Environmental

Management Plan (EMP) that would form the basis of an approval for an ECC.

It is with this background and AB InBev’s groundwater abstraction activity that SLR prepared this report which

provides the following;

a description of current infrastructure and activities at AB InBev boreholes (WW204437, WW204438, WW20439, WW204440, WW204989);

details of the existing borehole monitoring programme;

consideration of current environmental performance and risks; and

mitigation measures associated with the ground water abstraction activities, monitoring and the maintenance of infrastructure thereof.


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LOCATION OF BOREHOLES AND INFRASTRUCTURE 2

Information provided in this section has been summarised from Appendix B, which includes photographs taken of the visited borehole sites. Additional information is taken from the SLR report on the drilling and pump testing of production boreholes at AB InBev’s premises.

GEOLOGICAL SETTING 2.1

In a geological context, the Okahandja Town sits on impermeable schist that has intrusions of the pegmatite

dykes towards the east and the Okahandja marble towards the west of the town. Schist is known to be highly

impermeable rock structures due to the large amounts of micaceous minerals within the rock that act as a

barrier to water. The schist may be intruded by quartz veins that fracture and increases its secondary porosity/

permeability. It is the fractures and faults within the schist that are primary targets for the best borehole yields.

This coincides with the location of AB InBev’s brewery and the close proximity of the boreholes, thus yielding

currently sustainable ground water required for production purposes at the brewery.

BOREHOLE LOCATION AND EXISTING INFRASTURCURE 2.2

AB InBev’s groundwater boreholes are located within a 5km radius of the production plant/ brewery (Figure

2-1). The ECC application will include the boreholes located within the plant area and identified as:

WW204437 (Southern Cross);

WW204438 (Nearby);

WW204439 (Rooi Vlak);

WW204440 (Western); and

WW204989 (Burger Butler).

Boreholes WW204437, WW204438, WW204439 and WW204722 are included in the groundwater permit

(11234) issued by MAWF (Appendix A). Borehole WW204440 is used as a monitoring borehole. Figure 2-1

indicates the regional setting of borehole around AB InBev (Namibia).

Borehole WW204437- Southern Cross 2.2.1

Borehole WW204437 is located within the fenced perimeter on the southern side of the brewery premises.

Access to the borehole is highly restricted by an electric- shock wire mesh fence surrounding the borehole. An

electric ground water abstraction pump is installed for this borehole with the main switch securely locked. The

electric pump is connected to the SCADA system and is remotely controlled from a control room. The SCADA

system accurately monitors the groundwater borehole and avoids commuting back and forth to the borehole

site (refer to Appendix B for additional borehole site description).

An underground pipeline from the reservoir tanks follows an interconnected network of other pipelines to

other boreholes on project site and leads up to the electric ground water abstraction pump. It is through this

network of pipelines water is delivered to reservoir tanks and distributed to various areas into the brewer

plant.


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Boreholes (WW204438 - Nearby) and (WW204440 - Western) 2.2.2

Boreholes WW204438 and WW204440 are both located on the western side of the AB InBev brewery

premises. Access to these boreholes is restricted as the boreholes are separately fenced off with an electric

shock-wire fence. Both boreholes are fitted with an electric metered pump that is connected to the SCADA

system located in a control room at the brewery and are remotely controlled. Borehole WW204440 is used as a

monitoring borehole. Personnel movement into these premises is restricted. The surroundings are vegetated

by thick Acacia thorn bush. (refer to Appendix B for additional borehole site description).




plant.

Borehole WW204489 (Burger Butler) 2.2.3

Borehole WW204489 is located within the premises of the AB InBev brewery in the ground on an interlocked

paving area. The borehole is clearly marked and securely locked to avoid unauthorised use or access. An

automated electric metered pump is installed and connected to the SCADA system.




plant.

Borehole WW204439 (Rooi Vlak) 2.2.4

Borehole WW204439 is located outside of the fenced ABInBev premises, about 100 m to the north. The

borehole can be reached by a gravel route through the Acacia Thorn bush and is secured with an electric shock-

wire fence. The fenced borehole is locked at all times. The borehole is fitted with a metered pump that is

connected to the SCADA System at the Control room. Monitoring of this borehole is undertaken remotely.




plant.


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FIGURE 2-1: REGIONAL SETTING OF BOREHOLES AT THE AB INBEV BREWERY

WATER MONITORING METHODS 3

GROUNDWATER ABSTRACTION 3.1

The extent to which AB InBev’s abstraction of groundwater is internally regulated is based on the results from

the SLR’s Groundwater investigation undertaken in 2016(Appendix D). This indicated that abstraction rates of

up to 360 m3 per day (normal production months at 5 days per week) and 720m3/day (during peak production

months) were sustainable. AB InBev undertakes regular monitoring of groundwater abstraction to ensure that

annual groundwater abstracted volumes are sustainable and do not exceed the feasible annual abstraction

rate.

Reference is given to conditions in the, now lapsed, ground water abstraction Permit Number 11234 and the

requirements instituted by MAWF. These sustainable abstraction rates were subsequently included in the

ground water abstraction permit with an upper abstraction limit of 80 000m3. However, the fact that the

groundwater abstraction activities take place outside of a “water controlled water area” should be noted. See

the discussion outlined in the legal opinion (Appendix C).

The recommended maximum and sustainable abstraction rate for all the boreholes are shown in Table 3-1. The

abstraction rate is based on a 24 hour /5day pumping cycle to allow the boreholes to recover and to allow the

measurement of rest water levels when the pump is switched off. The total recommended daily abstraction

rate from the boreholes is 312 m3 during a normal supply month.

The monitoring of abstraction activities is undertaken through an automated system where the boreholes are

fitted with water meters connected to a SCADA system at a control room. This allows for operational control

and monitoring of water abstraction rates and water levels of each borehole (see Figure 3-1). Continuous

observation of water levels during and after pumping is undertaken and monitored through the SCADA system

to ensure sustainability of the boreholes in the long term.

TABLE 3-1: RECOMMENDED GROUND WATER ABSTRACTION RATES

Borehole ID Recommended abstraction rates

Normal Month Peak Month

[m3/h] [m3/day] [m3/h] [m3/day]

WW204437 24 240 24 576

WW204438 2 24 2 48

WW204439 2 24 2 48

WW204440 Monitoring

WW204989 24 240 24 576


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Groundwater borehole and automated electric pump.

SCADA System Display.

FIGURE 3-1: AB INBEV BOREHOLE AND SCADA SYSTEM DISPLAY.

WATER QUALITY ANALYSIS 3.2

Water quality monitoring for AB InBev is undertaken annually. Different water sources including raw water,

Treated water, RO water, blended water and borehole water (groundwater) are sampled and sent to the Africa

Technical Centre in South Africa for analysis. Various parameters are analysed based on Namibian Drinking

Water Guidelines. The identification of the type of water drinking group is shown below in Table 3-2 whereby:

Group A = Water with an excellent quality

Group B = Water with an acceptable quality

Group C = Water with a low health risk

Group D = Water with a high health risk or unsuitable for human consumption

TABLE 3-2: GROUNDWATER MONITORING PARAMETERS.

Water Parameters Namibian Drinking Water Guidelines

Group A Group B Group C Group D

pH – Value at 25°C 6,0 – 9,0 5,5 – 9,5 4,0 – 11,0 4,0 – 11,0

Electrical Conductivity in mS/m at 25°C 150 300 400 400

Total Dissolved Solids at 180°C *

Suspended Solids at 105°C *

Total Alkalinity as CaCO3


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Water Parameters Namibian Drinking Water Guidelines

Group A Group B Group C Group D

Chloride as Cl * 250 600 1200 1200

Sulfate as SO4 200 600 1200 1200

Fluoride as F 1.5 2.0 3.0 3.0

Nitrate as N * 10 20 40 40

Ortho Phosphate as P *

Free & Saline Ammonia as N * 1.0 2.0 4.0 4.0

Sodium as Na 100 400 800 800

Potassium as K 200 400 800 800

Calcium as Ca 375 500 1000 1000

Magnesium as Mg 70 100 200 200

Total Organic Carbon as C [s]

Chemical Oxygen Demand as O2 (Total) *

Aluminium as Al 0.15 0.50 1.0 1.0

Arsenic as As * 0.10 0.30 0.60 0.60

Cadmium as Cd 0.010 0.020 0.040 0.040

Total Chromium as Cr 0.10 0.20 0.40 0.40

Copper as Cu 0.50 1.0 2.0 2.0

Iron as Fe 0.10 1.0 2.0 2.0

Lead as Pb 0.050 0.10 0.20 0.20

Manganese as Mn 0.050 1.0 2.0 2.0

Mercury as Hg * 0.0050 0.010 0.020 0.020

Nickel as Ni 0.25 0.50 1.0 1.0

Uranium as U 0.030 * (WHO, 2011)

Zinc as Zn 1.0 5.0 10 10


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GROUNDWATER MONITORING RESULTS 4

GROUND WATER ABSTRACTION RATES 4.1

Groundwater abstraction for production purposes has been limited to three boreholes (WW204437 (Southern

Cross), WW204438 (Nearby) and WW204989. This has been adequate for the beverage production output as

the bulk of input water has been available from the municipality. Based on AB InBev’s groundwater abstraction

monitoring results, the total annual consumption from all of the boreholes for the years 2016, 2017, 2018 and

2019 (to May) were 3 500 m3, 4 100 m3 , 0 m3 and 1 400 m3 respectively (refer to Table 4-1). This is significantly

lower than the predicted sustainable maximum abstraction of 80 000m3 indicated in the permit.

TABLE 4-1: GROUND WATER ABSTRACTION MONITORING RESULTS (2016 - 2019)

Year TOTAL Annual Abstraction rates

Boreholes

2016 3 500 m3 Southern Cross (WW204437)

2017 4 100 m3 Southern Cross (WW204437) and Nearby (WW204438)

2018 0

2019 (January- May 2019) 1 400 m3

WW204989 (Burger Butler)

GROUND WATER QUALITY ANALYSIS 4.2

AB InBev’s groundwater quality analysis results from sampling undertaken in February 2017 and February 2018 for the production boreholes (WW204437) are detailed in Appendix E. Per the Namibian Drinking Water Guidelines; groundwater was classified as High Risk (Group D) in 2017 and defined as Low Risk (Group C) in 2018.


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POTENTIAL ENVIRONMENTAL IMPACTS 5

The potential impacts of the groundwater abstraction by AB InBev are summarised below. The aspects and impacts discussed below relate to the groundwater abstraction activity including potential risks that may result from infrastructure where relevant in close proximity to the boreholes.

Hydrocarbon Spills and Water Quality 5.1.1

The location of the groundwater boreholes (WW204438, WW204439, WW204440 and WW204437) are distant from operational activities that may involve machinery which could cause a hydrocarbon spill and lead to pollution of the water resource. The likelihood of a hydrocarbon spills incidents happening in these specific areas from operational vehicles/ equipment and Light Diesel Vehicles (LDV) is Low. The exception is borehole WW204989 which is located in close proximity to the brewery production plant. There is a greater chance that it could be exposed to potential hydrocarbon spills from operational vehicles/ equipment and LDVs operated or parked within the proximity of the borehole. However, the surrounding of the borehole is interlocked with concrete floor and the likelihood of possible contamination is minimised. No evidence of any spillages or soil contamination by hydrocarbons was observed at the production plant or other infrastructure.

Hydrocarbon contamination of soil is unlikely from infrastructure associated with AB InBev boreholes. All the boreholes on the premises are fitted with electric pumps that are remotely controlled and therefore operational and maintenance activities that could subsequently result in hydrocarbon spillages onto soils are not likely. Should maintenance result in a hydrocarbon spill then it is likely that the soils would be affected. No evidence of any spillages or soil contamination by hydrocarbons was observed at any of the borehole sites.

Surface and groundwater quality could be compromised by hydrocarbon spills, depending on the magnitude of spill. Given the low likelihood of the primary cause (i.e. spillages outside of the production plant and storm water control areas) an impact on water quality is highly unlikely. The risk could be avoided with mitigations detailed in Section 6.

Water Quantity 5.1.2

Over-abstraction of groundwater could lead to reduced water quantities and a lowered groundwater level that could impact on water access for AB InBev and other users/the neighbouring community. AB InBev continues to monitor and manage groundwater abstraction rates and groundwater levels in order to avoid over abstraction.

Total annual abstraction by AB InBev over the period 2016 to 2018 has been a small fraction of the maximum abstraction rates recommended in the SLR Groundwater investigation study. Thus the risks to groundwater availability and other users are considered insignificant. Continuous monitoring of the groundwater abstraction rates and levels should occur.

Should AB InBev reach a point where the required groundwater abstraction is more than 125 000 m3/annum, a Water Source Vulnerability Assessment is recommended. Such work should assess the cumulative impact on the groundwater resource due to the additional water supply requirement. There may then be a requirement for a formal EIA process to be undertaken in order to support an application for an ECC.

Tampering of boreholes 5.1.3

Uncontrolled access to the borehole (WW 204439 Rooi Vlak) that is located outside the brewery may result in tampering/vandalisation of the borehole infrastructure. As per observation during the site visit on the 8th of


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March 2019, access to all the boreholes is highly restricted by the fencing embedded with electric shock wire fence. The borehole areas are kept locked at all time. Thus the risk to borehole infrastructure is relatively low.

Regular inspections of the boreholes area will continue to avoid unplanned access and for safety measures.

Waste management 5.1.4

Waste management is not undertaken in proximity to any of the boreholes and is not identified as an issue related to the operation of borehole infrastructure and therefore will not be further discussed.

Biodiversity 5.1.5

All of the boreholes are located within already disturbed areas that are subject to regular operational activities. Biodiversity that persists is that which is tolerant of disturbances. The biodiversity present on the site is not considered of value. Impacts on biodiversity at the borehole site and due to the operations of boreholes are not likely. No mitigation measures relative to the groundwater abstraction activity are identified.

ENVIRONMENTAL MANAGEMENT PLAN 6

AIMS 6.1

The aim of the Environmental Management Plan (EMP) is to detail the actions required to effectively implement mitigation and management measures. These actions are required to minimise negative impacts and enhance positive impacts associated with the groundwater abstraction activities.

The EMP gives the commitments, which form the environmental contract between AB InBev and the Government of the Republic of Namibia; represented by the MET.

It is important to note that an EMP is a living document in that it will be updated and amended as new information (e.g. environmental data), policies, authority guidelines and technologies develop. The conceptual management measures proposed to mitigate the potential impacts are detailed in the action plans below.

ACTION PLANS TO ACHIEVE OBJECTIVES 6.2

Action plans to achieve the objectives are listed in tabular format in Table 6-1, separated by activities. The action plans also includes the frequency for implementing the mitigation measures as well as identifying the responsible party.

ROLES AND RESPONSIBILITIES 6.3

The responsibility for effective implementation of this EMP lies with AB InBev.


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TABLE 6-: MITIGATION ACTIONS RELATED TO HYDROCARBON SPILLS, CONTAMINATION OF SOIL, GROUNDWATER AND SURFACE WATER QUALITY

Activities / facilities Potential Impact Management and mitigation measures Action plan

Frequency / target date

Responsible parties

Vehicles, machinery, and equipment on AB InBev premises.

Soil and groundwater contamination

Regular environmental awareness should include potential risks associated with hydrocarbons.

Vehicles, machinery and equipment shall be kept in good working condition to ensure they do not leak oil/diesel.

Vehicles and machinery shall be serviced in designated servicing bays/ area located as far as possible from the borehole sites. However, in the event where machinery needs to be repaired/serviced close to the boreholes, all care shall be taken to prevent spillage of oil/diesel by performing the work on impermeable surfaces such as drip trays.

All used parts from vehicles and machinery (which may include, but not limited to, oil filter, pipes, rags, cans) shall be collected and removed from site and disposed of in an appropriate manner.

All refueling of vehicles shall take place on impermeable surfaces in their designate areas.

Any spills shall be contained and cleaned up immediately

Spill kits shall be readily available on site. Employees will be shown how to use the spill kits to enable containment and remediation of pollution incidents.

AB InBev should ensure that, the current infrastructure at the production plant, including boreholes, includes protection measures against storm water events. AB InBev should look into storm water channels as measures against this possibility.

Daily AB InBev

TABLE 6-1: MITIGATION ACTIONS RELATED TO WATER QUANTITY



Responsible parties

Groundwater abstraction

Groundwater availability to other users

Water abstraction measures raised in the current un- constituted groundwater abstraction permit should be translated into a procedure for water management and a water monitoring programme.

AB InBev should continue adherence to the management and mitigation measures relevant to the sustainability of groundwater as detailed in the groundwater investigation study completed by SLR (2016).

Water meter installations should be as per groundwater abstraction permit conditions.

As per permit

conditions AB InBev


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Responsible parties

Regular inspection of water meters to ensure their functionality should be undertaken and compared to the automated readings on the SCADA System.

The SCADA system should be able to produce tangible information regarding groundwater abstraction rates and levels.

Groundwater abstractions rates and cumulative volumes must be recorded monthly.

Resting water levels of the pumped boreholes must be recorded once in every three months.

Water shall be used efficiently and wastage shall be avoided.

All associated infrastructure such as pipes and taps should be inspected for leakages and repaired to limit water loss.

Shall permitted water levels or those indicated in the SLR Groundwater study be exceeded; this should be reported immediately to the regulating authority.

It is recommended that, shall AB InBev require more groundwater than the threshold of 125 000 m

3/annum, a Water Source Vulnerability Assessment undertaken to assess

cumulative impact on the water resource.

A formal EIA process will then be undertaken for an application of an ECC.

TABLE 6-2: MITIGATION ACTIONS RELATED TO UNPLANNED ACCESS TO THE BOREHOLES



Responsible parties

Unplanned access to Boreholes

Tampered borehole infrastructure and groundwater contamination

Ensure all borehole capping are locked and that Dipper holes are also caped and locked.

Borehole areas are to be access controlled.

Access to the area where boreholes are present should be by permission of the responsible parties managing the boreholes only.

Daily AB InBev


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TABLE 6-3: MITIGATION ACTIONS RELATED TO WASTE MANAGEMENT



Responsible parties

Waste management activities around Borehole area.

Borehole contamination No waste shall be stored or managed near to the borehole areas.

All company policies related to waste management shall be adhered to.

Smoking and discarding of cigarette buds around borehole areas should be avoided.

Daily AB InBev


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CONCLUSION 7

The Environmental Performance Report is based on the findings observed during the site visit undertaken on 8

March 2019 and additional information supplied by AB InBev. SLR is of the opinion that the abstraction of groundwater by AB InBev to date has not resulted in any environmental impacts of concern. Management and mitigation measures relevant to the groundwater abstraction activity have been provided in the EMP in Section 6.

Provided that AB InBev continues to manage and monitor the water abstraction activities as they have, and implement the management and mitigation measures raised in this report, there is no reason why the MET should not issue the required ECC.

[Marvin Sanzila]

Project Manager

[Jonathan Crowther]

Approved Reviewer


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REFERENCES 8

SLR 2016, Groundwater Investigation for SAB Miller Namibia (Pty) Ltd. SLR Project No.: 733.19094.00001


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APPENDIX A: ABINBEV GROUND WATER ABSTRACTION PERMIT NUMBER 11234


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APPENDIX B: DESCRIPTION OF THE ABINBEV BOREHOLE\ SITES

Production Borehole Identification

Picture Description of the borehole and associated infrastructure.

Borehole WW204989

Borehole WW204489 is

located within the premises

of the ABInBev brewery in an

interlocked paving.

Borehole WW204437

Borehole WW204437 is located within the fenced perimeter on the southern side of the brewery premises.

Access to the borehole is highly restricted by a fence embedded with an electric- shock wire mesh surrounding the borehole.

An electric pump is installed for this borehole with the main switch securely locked.

The electric ground water abstraction pump is remotely accessed at a control room installed with a SCADA system

Borehole WW204439

Borehole WW204439 is located outside the ABInBev fenced premises about 100m North.

The borehole can be reached by a gravel route through the Acacia Thorn bush and is fenced off, embedded with an Electric shock-wire fence to avoid any access.

The fenced borehole is locked at all times.

The borehole is fitted with a metered pump that is connected to the SCADA System at the Control room.

Monitoring to this borehole is undertaken remotely.


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Boreholes (WW204438 and WW204440)

Borehole- WW204438

Boreholes WW204438 and WW204440 are both on the western side of the ABInBev brewery premises.

Access to these boreholes is also restricted as the boreholes are separately fenced off and embedded with an electric shock-wire fence.

Both boreholes are fitted with an electric metered pump that is connected to the SCADA system located in a control room at the brewery.

Borehole WW204440 is used as a monitoring borehole and is remotely controlled.

Personnel movement into these premises is also restricted and the surroundings are vegetated by thick Acacia thorn bush.

Borehole- WW204440


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APPENDIX C: ABINBEV’S LEGAL OPINION RELEVANT TO GROUNDWATER ABSTRACTION REQUIREMENTS


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APPENDIX D: AB INBEV (SABMILLER) GROUNDWATER INVESTIGATION STUDY


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APPENDIX E: GROUNDWATER QUALITY ANALYSIS RESULTS (FEBRUARY 2017- FEBRUARY 2018)


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APPENDIX F: LETTER OF CONSENT AND TERMS OF AGREEMENT BETWEEN ABINBEV AND THE MUNICIPALITY OF OKAHANDJA

AFRICAN OFFICES

South Africa

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T: +27 21 461 1118

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T: +27 11 467 0945

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T: +27 21 851 3348

Namibia

WINDHOEK

T: + 264 61 231 287

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