for the proposed storage and logistic facility for...

ENVIRONMENTAL IMPACT ASSESSMENT (SCOPING) REPORT

FOR THE PROPOSED STORAGE AND LOGISTIC FACILITY FOR

PETROLEUM PRODUCTS IN USAKOS, ERONGO REGION

AUGUST 2019

i Environmental Scoping Report: MDL Petroleum Products Logistic and Storage Hub@Usakos-Namibia

DOCUMENT INFORMATION

Title Environmental Impact Assessment (Scoping)

Report the establishment of a storage and logistic

facility for petroleum products in Usakos.

ECC Application Reference

number

Activity Activity 9: Hazardous substance treatment, handling

and storage

Activity 10: Construction of public roads & railways

Location Usakos Town Lands Erf number 40A/REM (industrial property) about 150 m from the railway and B2 Highway

Proponent MDL International (Pty) LTD

For Official Correspondence:

Mr. Domingos Manuel

Chief Executive Officer

Office: +264 61 217549

E-mail: [email protected]

For Technical Enquiries:

Mr. Hans Shingenge

General Manager: Commercial Services

Office: +264 8111222912

E-mail: [email protected]

Issue Date

Authors: Grace Shihepo, Environmental Assessment Practitioner (EAP)

Reviewer: Jonas Heita, Environmental Assessment Practitioner (EAP)

Copyright

“This document is the intellectual property of TEC and may only be used for the intended purpose.

Unauthorized use, duplication, copying or reproduction without referencing or obtaining written

consent from TEC is illegal”

mailto:[email protected]

ii Environmental Scoping Report: MDL Petroleum Products Logistic and Storage Hub@Usakos-Namibia

EXECUTIVE SUMMARY

MDL International Trade (PTY) Limited is a Namibian based company that specializes in

onshore and offshore operations with the focus on petroleum products. The company

proposes to establish a petroleum storage and logistic facility in Usakos for storage and

distribution thereof. MDL envisioned to undertake the project in two phases; namely

Phase 1 and 2. Each phase is characterized by a series of infrastructural development.

The proposed petroleum storage and logistic hub triggers activities that are listed under

the EMA.

MDL proposes to transport and distribute petroleum products using an innovative logistic

scheme throughout the supply chain. The proposed process requires the company to

incur high initial investment costs; however, the process is preferred due to its safety. This

includes the use of ISO certified carrying and above ground storage tanks, improved

storage floor and machinery. There will be no transfer of petroleum products at the facility,

reducing oil spill incidences. During Phase 1 MDL supply chain involves petroleum

transportation from Petroleum Farm in Walvis Bay until the fuel is distributed to the

respective clients within the SADC region. Phase 2 petroleum products will be transported

in two routes to the petroleum storage and logistic hub in Usakos.

The potential environmental impacts associated with the proposed project were

determined by identifying the environmental aspects and then undertaking an

environmental risk assessment to determine the significant environmental impacts. The

impact assessment included all phases of the project, with specific emphasis on

construction and operation in mind. The assessment of the biophysical and socio-

economic environment revealed that there are no environmental fatal flaws or significant

negative impacts associated with the project, and potential impacts can be minimised by

implementing mitigation and management measures as prescribed in the project EMP.

As a safety approach the floor will be designed and constructed in a manner that will

minimise chances of groundwater contamination, in an event of an accidental oil spill. The

fuel tankers will always be required to be parked on the special flooring. Regular

inspections are recommended on the tankers and flooring to monitoring any signs of fuel

leakage or spillage in the area. Monitoring boreholes will need to be established near to

the project site to track changes in groundwater quality. If fuel contamination is detected,

actions must be taken to identify the source of contamination and mitigation measures

implemented.

The impact on air quality, water quality and health & safety are considered the most

notable potential impacts which may result from the proposed project. However, the

impact mitigation measures contained within the EMP will aid in reducing the

environmental and social impacts.

iii Environmental Scoping Report: MDL Petroleum Products Logistic and Storage Hub@Usakos-Namibia

TABLE OF CONTENTS

CHAPTER 1 ..................................................................................................................................... 1

1. INTRODUCTION ................................................................................................................... 1 1.1 MDL International Trade ...................................................................................................... 1 1.2 Location ...................................................................................................................................... 1 1.2.1 Project Rationale and Motivation ...................................................................................... 4 1.3 Terms of Reference for Environmental Assessment .................................................. 5 1.3.1 Application for ECC ................................................................................................................. 5

CHAPTER 2 ..................................................................................................................................... 6

2. PROJECT INFORMATION ................................................................................................... 6 2.1 Process Design.......................................................................................................................... 6 2.1.1 The Fuel Chain Process ......................................................................................................... 6 2.1.2 Storage Capacity ...................................................................................................................... 6 2.1.3 Route 1: Via B2 Highway ....................................................................................................... 7 2.1.4 Route 2: Via the Trans-Namib Railway ............................................................................ 7 2.2 Tank Design ............................................................................................................................... 8 2.3 Floor Design .............................................................................................................................. 9 2.4 Project Phases ....................................................................................................................... 11 2.4.1 Phase 1: Erection of a Temporary Logistics Hub ...................................................... 11 2.4.2 Phase 2: Establishment of a Fuel Storage and Logistic Hub .................................. 12 2.4.3 Socio-economic Development ......................................................................................... 12

CHAPTER 3 .................................................................................................................................. 14

3. LEGAL FRAMEWORK ....................................................................................................... 14 3.1 Environmental Protection: Namibian Constitution ................................................. 14 3.2 Environmental Management Act No. 7 of 2007 ......................................................... 14 3.2.1 Listed Activities ..................................................................................................................... 14 3.2.2 Environmental Management Plan (EMP) .................................................................... 16 3.3 Environmental Assessment Policy (1995) .................................................................. 16 3.4 Other Legal Requirements ................................................................................................ 16 3.5 Precautionary and Polluter Pays Principles .............................................................. 19

CHAPTER 4 .................................................................................................................................. 20

4. AFFECTED ENVIRONMENT............................................................................................ 20 4.1 Surrounding Environment ................................................................................................ 20 4.2 Climate ..................................................................................................................................... 20 4.2.1 Vegetation and Biodiversity ............................................................................................. 20 4.3 Socio-economics ................................................................................................................... 21

CHAPTER 6 .................................................................................................................................. 22

5. IMPACT ASSESSMENT METHODOLOGY .................................................................... 22 5.1 Assessment of Impact Significance ................................................................................ 22 5.2 Determination of Significance ......................................................................................... 22 5.3 Environmental Mitigation ................................................................................................. 23 5.4 Cumulative Effects................................................................................................................ 23

CHAPTER 7 .................................................................................................................................. 24

6. IMPACT ASSESSMENT ..................................................................................................... 24

iv Environmental Scoping Report: MDL Petroleum Products Logistic and Storage Hub@Usakos-Namibia

6.1 Introduction ........................................................................................................................... 24 6.2 Phase 1 ..................................................................................................................................... 24 6.2.1 Erection of a Temporary Logistics Hub ........................................................................ 24 6.2.2 Fuel Transportation via B2 Highway ............................................................................ 24 6.3 Phase 2 ..................................................................................................................................... 25 6.3.1 Fuel transportation via the Trans-Namibia Railway ............................................... 25 6.4 Cumulative Effects................................................................................................................ 25 6.4.1 Groundwater .......................................................................................................................... 25

CHAPTER 8 .................................................................................................................................. 26

7. PUBLIC PARTICIPATION PROCESS ............................................................................. 26 7.1 Introduction ........................................................................................................................... 26 7.2 Consultation Activities ....................................................................................................... 26

CHAPTER 9 .................................................................................................................................. 29

8. CONCLUSION AND RECOMMENDATIONS ................................................................. 29 8.1 Conclusion ............................................................................................................................... 29 8.2 Recommendations ............................................................................................................... 29

LIST OF FIGURES Figure 1: Location of the proposed petroleum facility in Usakos as demarcated with the red

polygon (source: google images) ................................................................................................................ 2 Figure 2: Project Location – Erf 40A/REM, Usakos Town Lands, already zoned as Industrial ... 3 Figure 3: Fuel transport via B2 road .................................................................................................................... 7 Figure 4: Typical semi-trailer ISO tank (Photo for illustration purposes only .................................. 8 Figure 5: MDL temporary logistic base at Usakos (Source:

http://mdlinternationaltrade.com/usakos) ....................................................................................... 11 Figure 6: Facility layout upon completion of Phase 2 ................................................................................ 13 LIST OF TABLES 1: ISO Tank Main Parameters ................................................................................................................................. 9 Table 2: Floor Design – Fuel Storage Facility ................................................................................................ 10 Table 3: List of activities relevant to the proposed project ..................................................................... 15 Table 4: Additional permits required for the proposed development ............................................... 16 Table 5: Potential effects on groundwater ..................................................................................................... 25 Table 6: Summary of Stakeholder consultation activities ....................................................................... 26 Table 7: Issues raised during public consultation ....................................................................................... 27

v Environmental Scoping Report: MDL Petroleum Products Logistic and Storage Hub@Usakos-Namibia

DEFINITIONS

Acronym Definition

dBA decibels

EC Environmental Commissioner

ECC Environmental Clearance Certificate

EIA Environmental Impact Assessment

EMA Environmental Management Act (Act No. 7 of 2007)

EMP Environmental Management Plan

I&APs Interested and Affected Parties

MET Ministry of Environment and Tourism

1 Environmental Scoping Report: MDL Petroleum Products Logistic and Storage Hub@Usakos-Namibia

CHAPTER 1

1. INTRODUCTION

1.1 MDL International Trade

MDL International Trade (PTY) Limited (herein referred to as MDL) is a Namibian

based company founded in 1993. The company specializes in onshore and offshore

operations with the focus on petroleum products (including diesel, petrol, aviation jet

fuel A1, aviation kerosene and HFC gas).

In 2016 MDL obtained a license from the Ministry of Mines and Energy to import,

export and distribute petroleum products across the South African Development

Community (SADC) Region. Thus, the company proposes to establish a petroleum

storage and logistic facility in Usakos for storage and distribution thereof. The facility

will supply both the local and regional market (SADC1) at an estimated ratio of 1:92.

The proposed petroleum storage and logistic hub triggers activities that are listed

under the EMA. Meaning an EIA should be conducted. MDL envisioned to undertake

the project in two phases; namely Phase 1 and 2. Each phase is characterized by a

series of infrastructural development.

1.2 Location

Usakos is located about 140 kilometers east of Swakopmund town along the B2, in

the Erongo Region. The petroleum storage and logistics hub will be established on an

industrial property, Erf number 40A/REM which lies about 150 m from the railway and

about 150 m from B2 Highway (see Figure 2).

1 SADC – Southern Africa Development Community 2 Target Market Ratio 1:9 (10% local to 90% regional)


Figure 1: Location of the proposed petroleum facility in Usakos as demarcated with the red polygon (source: google images)


Figure 2: Project Location – Erf 40A/REM, Usakos Town Lands, already zoned as Industrial


1.2.1 Project Rationale and Motivation

Namibia is one of the few countries in SADC bordering the Atlantic Ocean, which

connects and presents shipping opportunities (import and export) with the rest of the

world. Most of the countries in SADC are landlocked and depend on countries with

shipping opportunities (like Namibia) for their imports and exports. Walvis Bay

provides the shortest route for landlocked countries in SADC for their imports and

exports. SADC has a market of 400 million people.

Namibia recognizes the importance of harbor services for both its own shipping needs

and the need to assist landlocked countries within the SADC region. As a result,

Namibia developed a master plan to become an international logistics hub and

gateway for landlocked countries. The master plan resulted in following:

▪ New container terminal of 40 hectares

▪ Deepening of the access channel for ships to the port to -14 meters depth.

(This increased the competitive capability and made it a direct competitor to

South Africa’s port of Cape Town).

▪ Dredging of the berths and extended the length of the quay.

▪ Development of transport corridors like the Trans-Kalahari Corridor through

Botswana to Gauteng and Mozambique and the Walvis-Bay-Ndola-

Lubumbashi-Corridor, which reaches Zambia, Zimbabwe and the south-eastern

part of the Democratic Republic of Congo (DRC).

At present, local exports (Namibian products) through the Port of Walvis Bay only make up about 20% of the port’s annual freight turnover and comprises of Uranium, Gold, Diamonds, Marble, Granite, Salt and Fish (NamPort, 2018). Copper from Zambia (refined at Dundee Precious Metals in Tsumeb), and wood from the DRC and Zambia are among the bulk of transit goods exported through Walvis Bay. The main imports are bulk fuel, copper and lead concentrates, fish products, sugar, wheat, cement, vehicles and steel. The goods are transported from Walvis Bay by road to neighbouring countries and vice versa. Botswana, Zambia and Zimbabwe are leasing land at the port each for interim storage their imports and exports (NamPort, 2018). The proposed petroleum storage and logistics facility by MDL will also contribute to

economic growth through income generation from tax and employment created,

which is the core of NDP 5, Vision 2030, Harambee Prosperity Plan and the

Growth at Home Strategy. These frameworks envision Namibia to be a regional

logistics and industrial hub.


1.3 Terms of Reference for Environmental Assessment

Tortoise Environmental Consultants (TEC) has been appointed to undertake an

Environmental Impact Assessment (EIA), scoping exercise and to develop an

Environmental Management Plan (EMP), for the proposed establishment of a

petroleum storage and logistic hub in Usakos.

The assessment includes:

• Description of the receiving environment that may be affected by the proposed

project and the way the physical, biological, social, economic and cultural

aspects of the environment may be affected;

• Description and assessment of the significance of any significant effects,

including cumulative effects, that may occur as a result of the undertaking of

the activity or identified alternatives or as a result of any construction, erection

or decommissioning associated with the undertaking of the proposed

development;

• Information on the proposed management, mitigation, protection or remedial

measures to be undertaken to address the effects on the environment that

have been identified including objectives in respect of the rehabilitation of the

environment and closure; and

• Description of the manner in which the MDL intends to modify, remedy, control

or stop any action, activity or process which could cause pollution or

environmental degradation.

1.3.1 Application for ECC

Upon completion, the EIA Scoping Report and EMP will be submitted to MET for

review and decision, in accordance with Section 8 of the EIA Regulations, as part of

the application for an Environmental Clearance Certificate (ECC).


CHAPTER 2

2. PROJECT INFORMATION

2.1 Process Design

The current approach to transporting and storage of petroleum products is through tanker trucks and underground storage tanks. The transfer process of the products from the tanker trucks to the underground tanks is associated with risks that can result in fire hazards and environmental contamination. If no proper precautionary measures are applied, the transfer process can result in oil spills that can affect underground water resources. MDL proposes to transport and distribute petroleum products using an innovative logistic scheme throughout the supply chain. This includes the use of ISO certified carrying and above ground storage tanks, improved storage floor and machinery. The proposed process requires the company to incur high initial investment costs; however, the process is preferred due to its safety. There will be no transfer of petroleum products at the facility, reducing oil spill incidences.

2.1.1 The Fuel Chain Process

During Phase 1 MDL supply chain involves petroleum transportation from

Petroleum Farm in Walvis Bay until the fuel is distributed to the respective clients

within the SADC region. Phase 2 petroleum products will be transported in two

routes to the petroleum storage and logistic hub as summarized in figure 2-2 and

2-3 below. Petroleum will be transported using the portable semi-trailer containers

which will be carried by trucks during Phase 1 or by trains during Phase 2, from

the Petroleum Farm to MDL petroleum storage and logistic hub.

Onsite, the tanks will be offloaded using special forklift to minimize mechanical

handling and stored until it is further processed for distribution. Fuel will be stored

in the same containers allowing minimal fuel exchange. This will reduce the

potential of oil spillage which is common in the traditional method.

2.1.2 Storage Capacity

The entire operation is expected to have a storage capacity of 247,500,000 litres.

This translates to 11,000 tank containers to be stored with 22,500 litres capacity

each. During Phase 1 transportation will commence with approximately 135,000

litres of petroleum per day.


2.1.3 Route 1: Via B2 Highway

This route from the Walvis Bay Tank Farm will be employed mainly during the

phase 1 and minimally in Phase 2 as the use of the train will be introduced to

transport the petroleum containers tanks.

Petroleum from the vessel is transferred to Petroleum Tank Farm through

docking facility via a pipe until it is further transferred into MDL petroleum

containers tanks (mounted on truck). The truck will then transport the tanks to

storage facility in Usakos via the B2 road between Walvis Bay and Usakos. The

summarised route is summarised below in Figure 2-1.

Figure Error! No text of specified style in document.-1: Fuel transport via B2

road

In this operation, MDL proposes to introduce intersection onto the B2 road for

access and to allow smooth flow of traffic to and from the facility. The town

planner will develop the layout sketch indicating railway intersection.

2.1.4 Route 2: Via the Trans-Namib Railway

During this route MDL will transport fuel via the Trans-Namib Railway. This routed

will only be introduced in the second phase of the project. Similar to Route 1, fuel

will be channelled onto tank farm using a pipe and transferred onto tankers

mounted on the train instead of the truck. These special trains will transport fuel to

MDL storage facility via the railway.

F

During this process, MDL will construct a railway off-ramp to allow access from

railway to the site railway station where the containers will be offloaded to the

storage facility using the special forklifts. The town planner will develop the layout

sketch indicating railway intersection.

Vessel

Tank Farm

Walvis Bay

Port

MDLcontainersTanks onTrucks

TransportationVia B2

MDLStorageFacility inUsakos

RoadTransporttoConsumer

Vessel

Tank Farm Walvis Bay

Port

MDL Containers Tanks on the train

transportation via Railway

MDL Storage Facility

Road Transport

to Consumer

Figure 3: Fuel transport via B2 road


2.2 Tank Design

MDL will integrate the container tanks that can be transported both trucks and train.

The container tanks per truck have a carrying capacity of 45,000 liters, and each

container tank have a total carrying capacity of 22,500 liters. Semi-trailers are the

preferred option for this operation due to the advantaged properties listed below:

• Same transporting container tanks can be used for storage minimizing fuel

exchange through different media reducing the significant risk of spillage during

operation.

• Up to 9 levels container tanks can be stacked together optimizing the use of

storage.

• It allows for quick offloading at the facility.

• Tanks are made of materials that can withstand up extreme heat (up to 300°C)

which makes more heat resistant

• It can take up to 2 hours before the tank ignites or catches fire due to material’s

inability to can fire easily? (See an example of typical Semi-Trailer tank in figure

2-2).

Figure 4: Typical semi-trailer ISO tank (Photo for illustration purposes only

Description of an ISO Tank

An ISO Tank is a tank container which is built to the ISO standard (International

Organisation for Standardisation). ISO tanks are designed to carry liquids in bulk, both

hazardous and non-hazardous product. Table 2-1 below features the ISO tank main

parameters


1: ISO Tank Main Parameters

ISO Tank Main Parameters

Frame material JIS G33125 SPA-H or

equivalent

Tank material SANS 50028-7 Type 1.442/1

Capacity 22,500 Ltr

Tare mass 3870 kg

Max gross mass 36,000 kg

Working pressure 4 bar

2.3 Floor Design

As a safety approach the floor will be designed and constructed in a manner that will minimise chances of groundwater contamination, in an event of an accidental oil spill. The floor will be consisting four (4) types of pavements i.e.

• Bituminous Pavement

• Concrete Pavement

• Prefabricated Concrete Blocks, and

• Precast Concrete Kerb.

The design sketches are presented in the table overleaf.


Table 2: Floor Design – Fuel Storage Facility

Specification of the Bituminous Pavement

Specifications of the Prefabricated Concrete Blocks


2.4 Project Phases

2.4.1 Phase 1: Erection of a Temporary Logistics Hub

During Phase 1, MDL will construct and erect temporary structures as shown in

figure 2-5. This will include erection of temporal parking space for 20-40 trucks, few

administration offices, ablution facilities plus a septic tank and water tanks for water

supply.

The facility will cover a total area of 2.5 hectares and will serves as temporary

logistic base, where MDL will be operating during Phase 1. This facility will be able to

accommodate 40 trucks. The operation duration of this Phase 1 will be

approximately 24 months than Phase 2 will advance setting up a storage facility.

Figure 5: MDL temporary logistic base at Usakos (Source: http://mdlinternationaltrade.com/usakos)

The temporal structure that is currently on the site

The temporary infrastructure has been erected on the site to proof MDL’s commitment towards the realisation of the proposed facility. As presented in Figure 2-5, the semi-permanent buildings can be seen. Figure 2-6 shows the signpost at the entrance of the site.


2.4.2 Phase 2: Establishment of a Fuel Storage and Logistic Hub

Phase 2 will comprise removal of the non-permanent structures erected during phase

1 and construction of the permanent structures. MDL will construct and set up an

operation and storage facility that includes the following supporting structures, as

presented in Figure 6.

• Decommissioning/removal of phase 1 structures

• Administration building comprising office space;

• Food outlet

• Intersection (Traffic-circle) into the B2 road

• Control Room;

• Truck port / Parking area;

• Iveco mechanical workshop;

• Onsite Heliport;

• Of-Ramp from Trans-Namib existing Railway;

• Fuel storage yard made up of special floor (made out of non-permeable

material) fitted with drainage

• Connection to the Town Council sewer system;

• Public Filling Station equipped with banking utilities and public amenities;

• Run-off (storm) water system

• Weighbridge fitted with scanner at the storage facility main gate

During this phase MDL will create more than 3,000 permanent and an additional of

1200 indirect jobs.

2.4.3 Socio-economic Development

Usakos town has a population of 7,000 inhabitants and covers a total area of 58

square kilometers of land. Compared to other Namibian towns, Usakos is relatively

underdeveloped which consequently contributed to severe poverty and alcohol abuse

being experienced in the town. As per agreement with the Usakos Authorities, MDL

committed to develop the Town through various socio-economic projects.


Figure 6: Facility layout upon completion of Phase 2


CHAPTER 3

3. LEGAL FRAMEWORK

3.1 Environmental Protection: Namibian Constitution

The Namibian constitution is the supreme law of the country and makes provision for environmental protection and sustainable development. Article 95(1) of the Constitution states that “The State shall actively promote and maintain the welfare of the people by adopting policies aimed at the maintenance of ecosystems, essential ecological processes and biological diversity of Namibia and utilization of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future”.

To fulfill the Article 95 of the Constitution, in 2007, the Government for the Republic

of Namibia enacted the Environmental Management Act (Act No. 7 of 2007) and

subsequently, the EIA Regulations of 2012 (Government notice no: 30 of 2012).

3.2 Environmental Management Act No. 7 of 2007

The environmental management act No.7 of 2007 aims to promote the sustainable

use of natural resources and provides the framework for the environmental and

social impact assessment, demands precaution and mitigation of activities that may

have negative impacts on the environment and provision for incidental matters.

Furthermore, the act provides a list of activities that may not be undertaken without

an environmental clearance certificate.

The purpose of the Environmental Management Act is:

a) to ensure that people carefully consider the impact of developmental activities on the environment and in good time

b) to ensure that all interested or affected people have a chance to participate in environmental assessments

c) to ensure that the findings of environmental assessments are considered before

any decisions are made about activities which might affect the environment

3.2.1 Listed Activities

The Environmental Management Act (EMA), Act No. 7 of 2007, stipulates that, for

each activity listed under the EIA regulations, an Environmental Impact

Assessment (EIA) is required.


Listed activities may not be undertaken without an Environmental Clearance

Certificate (ECC). Section 7 of the Environmental Impact Assessment (EIA)

Regulations (GN notice No. 30 of 2012), stipulates that if the proposed project

triggers a listed activity, an EIA scoping exercise must be undertaken and a

Scoping Report and Environmental Management Plan should be submitted to the

Environmental Commissioner (EC) as part of the application for an Environmental

Clearance Certificate (ECC).

Establishing the proposed logistics and storage facility triggers some listed

activities in terms of the Environmental Management Act no. 7 of 2007 and the

Environmental Impact Assessment Regulations of 6 February 2012. The specific

listed activities that are triggered are listed in Table 3 below.

Table 3: List of activities relevant to the proposed project

Activity Specific Activity Proposed Activity

Activity 5 Land use and development activities

5.1 The rezoning of land from open space to other land use

Although a town scheme exists for Usakos, the actual sub-division rezoning of ervens has not been concluded. Therefore, the proposed site is still zoned as undermine industrial and the sub-division needs to be rezone to industrial service.

Activity 9 Hazardous substance treatment, handling and storage

9.4 The storage and handling of dangerous goods, including petrol, diesel, liquid petroleum gas or paraffin, in containers with a combined capacity of more than 30 cubic meters at any one location. 9.5 Construction of filling stations or any other facility for the underground and aboveground storage of dangerous goods, including petrol, diesel, liquid, petroleum, gas or paraffin.

The proposed project will transport, store and handle up to 235, 200, 000 liters of hazardous substances such as petrol, diesel, jet fuel and aviation Kerosene

Activity 10 Construction

(a) oil, water, gas and petrochemical and other bulk supply pipelines;

(b) public roads (round about); railways and harbours;

The proposed project consists of the construction of the railway station, and access roads. An MDL truck port, fuel storage and filling station for MDL fleet will be constructed.


3.2.2 Environmental Management Plan (EMP)

In-addition to the EIA scoping exercise, the Environmental Management Act

stipulates that for each activity undergoing an EIA process, an Environmental

Management Plan (EMP) should be developed.

The EMP outlines mitigation measures against specific steps, stages or processes

of the proposed development. Thus, the EMP can be defined as the tool used to

prevent / minimize the impacts identified during the EIA process. For accountability,

the EMP outlines specific roles and responsibilities for the role-players, and non-

compliance is punishable by law.

3.3 Environmental Assessment Policy (1995)

The Environmental Assessment Policy for Sustainable development and

Environmental Conservation emphasize the importance of environmental

assessments as a key tool towards implementing integrated environmental

management. Sets an obligation to Namibians to prioritize the protection of

ecosystems and related ecological processes.

The policy subjects all developments to environmental assessment and provides

guideline for the Environmental Assessment. The policy advocates that

Environmental Assessment take due consideration of all potential impacts and

mitigations measures should be incorporated in the project design and planning

stages (as early as possible).

3.4 Other Legal Requirements

In addition to the EMA and the Environmental Assessment Policy, there exist other

regulatory frameworks that MDL must comply with. This is due to the supporting

infrastructure that are needed to compliment the proposed logistics hub. As such,

MDL will be required to obtain additional specific permits for the supporting

infrastructure as listed in table 4 below. The process of obtaining the additional

permits can be undertaken concurrently to the EIA process.

Table 4: Additional permits required for the proposed development

Activity Type of Permits Department/Contact

Hazardous Substance storage facility

Fitness certificate Hazardous Substance handling Permit

Usakos Town Council Ministry of Health and Social Services (Department of Public and Environmental Health)

Filling Station Cross border fuel exportation

ECC Fitness certificate Fuel Export Permit

Department of Environmental Affairs Usakos Town Council Ministry of Mines and Energy


Railway (off-ramp) Written formal application for clearance

Mr. Michael Feldmann Executive: Operations (Trans-Namib) Tel: +264 61 298 2465 Email: [email protected]

Intersection- B2 Road Application for Access from B2 Highway

Mr. EAM De Paauw Roads Legislation Compliance Tel: 061 284 7027 Email: [email protected]

Furthermore, the proponent has the responsibility to ensure that the project activities

conform to all other relevant legal documents and guidelines as listed in Table 3.1

below).

Table 5 Other relevant legislation and applicability thereof

Legal Requirements

Legislation

considered

Relevant

authority Aspect of Project

Pollution Control and Waste Management Bill (in preparation)

MET, MHSS

and others

The Pollution Control and Waste Management

Bill, intents to regulate and prevent the discharge

of pollutants into the air and water as well as

providing for general waste management. Upon

gazettement, the Bill will repeal the Atmospheric

Pollution Prevention Ordinance (11 of 1976).

The Bill also provides for noise, dust or odour

control that may be considered a nuisance.

Furthermore, the Bill advocates for duty of care

with respect to waste management affecting

humans and the environment and advocates for

a waste management licence for any activity

relating to waste or hazardous waste

management.

Public Health Act (Act No. 36 of 1919)

Ministry of

Health and

Social

Services

The Public Health Act aims to protect the public

from nuisance and states that no person shall

cause a nuisance or shall suffer to exist on any

land or premises owned or occupied by him or of

which he is in charge any nuisance or other

condition liable to be injurious or dangerous to

health.

The proponent should ensure that the workers

are provided with protective gear to safeguard

their wellbeing. The activities should also be


Legal Requirements

Legislation

considered

Relevant


conducted in a manner that does not pose any

danger to the general public and that any

emissions which could be considered a nuisance

should be contained at acceptable levels.

Atmospheric Pollution Prevention Ordinance (Act No.11 of 1976)

Ministry of

Health and

Social

Services

This Ordinance serves to control air pollution

from point sources. Any person carrying out a

‘scheduled process’ which are processes

resulting in noxious or offensive gases typically

pertaining to point source emissions have to

obtain a registration certificate from the

Department of Health.

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

Ministry of

Agriculture,

Water and

Forestry

This Act provides a framework for managing

water resources based on the principles of

integrated water resources management. It

provides for the management, development,

protection, conservation, and use of water

resources. Furthermore, any watercourse on/or

in close proximity to the site and associated

ecosystems should be protected in alignment

with the listed principles.

Water is one of the most important resources,

and determinant factor for any development.

Therefore, water abstraction should satisfy the

provisions of the water act (water abstraction /

borehole permit should be applied from the

respective ministry).

Water Act No, 54 of 1956

Ministry of

Agriculture,

Water and

Forestry

This act states that, all water resources belongs

to the State. It prevents pollution and promotes

the sustainable utilization of the resource. To

protect this resource, this act requires that

permits are obtained when activities involve the

following:

(a) Discharge of contaminated into water

sources such as pipe, sewer, canal, sea

outfall and

(b) Disposal of water in a manner that may

cause detrimental impact on the water

resources

Hazardous Substances

The ordinance is important for pollution control

and provides for the control of toxic substances


Legal Requirements

Legislation

considered

Relevant


Ordinance No. 14 of 1974

including their manufacture, use, sale, disposal,

dumping, import and export in order to ensure

human and environmental safety.

Soil Conservation Act No. 76 of 1969

This act promotes the conservation of soil,

prevention of soil erosion. Typically, improper

planning of construction can cause soil

degradation and erosion.

National Heritage Act No. 27 of 2004

The Act makes provision for the protection and

conservation of places and objects of heritage

significance and the registration of such places

and objects. Part V Section 46 of the Act

prohibits removal, damage, alteration or

excavation of heritage sites or remains, while

Section 48 sets out the procedure for application

and granting of permits.

Regional Councils Act, 1992 (Act No. 22 of 1992)

Ministry of

Regional and

Local

Government,

Housing and

Rural

Development

The Regional Councils Act legislates the

establishment of Regional Councils that are

responsible for the planning and coordination of

regional policies and development.

The main objective of this Act is to initiate,

supervise, manage and evaluate regional

development. The Regional Council is

considered to be an interested and affected

party (I&AP) and reserve the right to comment

on the project and EMP.

3.5 Precautionary and Polluter Pays Principles

Precautionary Approach Principle

This principle is worldwide accepted when there is a lack of sufficient knowledge

and information about proposed development possible threats to the environment.

Hence if the anticipated impacts are greater, then precautionary approach is

applied.

Polluter Pays Principle

This principle ensures that proponent takes responsibility of their actions. Hence in

cases of pollution, the proponent bears the full responsibility and cost to clean up

the environment.


CHAPTER 4

4. AFFECTED ENVIRONMENT

4.1 Surrounding Environment

The general landscape of Usakos is composed of mountains, hills and rocky terrain.

The area is classified as the Western Highlands Ecosystem Zone, and it is

characterised by relatively low amounts of annual rainfall not exceeding 300mm. Rain

in the area falls in summer between January and March and often leads to flows in

seasonal river courses. The low rainfall coupled with low humidity and warm to hot

temperatures gives rise to extreme climatic conditions in the area.

4.2 Climate

The average annual temperature of the area is between 20 – 24oC, with an average

maximum of 32 - 34 oC and minimum of 4 - 6 o. The hottest month usually being

December and coolest month being July, with an average of 1 to 5 frost days per

year.

4.2.1 Vegetation and Biodiversity

The vegetation structure of the surrounding area is generally very sparse denuded and hard to identify due to the prevailing drought in the area. The specific location for the proposed logistics hub is disturbed and the vegetation onsite has been planted purposely as a measure of beautifying the landscape. The proposed site is adjacent to a small stream and the vegetation appears to be concentrated along it. No wild animals were encountered nor expected to occur in the immediate surroundings. This is since the area is within the town boundaries and human activities are evident. Small rodents and birds are however expected to occur on site, but these would be of minimal disturbance to development as they can easily move away.


The surrounding landscape is dominated by sparse thorn bush

The project site has been cleared in preparation for phase 1 activities to start.

Some indigenous plants have been planted for aesthetics

Plants introduced at the temporal office

4.3 Socio-economics

Key sectors in terms of employment in the Erongo Region are mining, fishing and

manufacturing, agriculture as well as administration and support services. The region

is one of the most affluent regions in Namibia as it has the second highest level of

development at national level. The current population of Usakos stands at 9, 1473

inhabitants.

3 World Population Review


CHAPTER 6

5. IMPACT ASSESSMENT METHODOLOGY

5.1 Assessment of Impact Significance

The significance of an effect is determined by considering and measuring the temporal

and spatial scales and magnitude of the project and specific activities associated with

the proposed development. The assessment of the environmental impacts of

development activities should always strive to be objective and impartial. However,

environmental assessment processes can be exposed to subjectivity inherent in

attempting to measure significance.

5.2 Determination of Significance

For each impact, the EXTENT (spatial scale), MAGNITUDE and DURATION (time

scale) would be described. These criteria would be used to ascertain the

SIGNIFICANCE of the impact, firstly in the case of no mitigation and then with the most

effective mitigation measure(s) in place. The mitigation described in the Scoping Report

would represent the full range of plausible and pragmatic measures.

Significance is not defined in the EIA Regulations, however the Draft Procedure and

Guidance for EIA and EMP states that the significance of a predicted impact depends

upon its context and intensity. Accordingly, the following have been applied in the

environmental assessment, which is based on professional judgement:

• High: effects are considered to be key factors in the decision-making process.

These are generally (but not exclusively) associated with sites and features of

national importance and resources/features that are unique and which, if lost,

cannot be replaced or relocated.

• Medium: effects are considered to be important factors, but which are unlikely to

be key decision-making factors.

• Low: effects are considered to be local factors that are unlikely to be critical to

decision-making.

The significance of effect has been derived by applying the identified thresholds for

receptor sensitivity and magnitude of change, as well as the definition for significance.

For each potential significant effect identified in the assessment, a summary is provided

which includes the activity that would cause an impact; the potential effect; embedded

or best practice mitigation; the sensitivity of receptor that would be impacted; the


severity, duration and probability of effect; the significance of effect before mitigation

and after additional mitigation.

5.3 Environmental Mitigation

Mitigation comprises a hierarchy of measures ranging from preventative of

environmental effects by avoidance, to measures that provide opportunities for

environmental enhancement. The mitigation hierarchy is: avoidance; reduction;

compensation; remediation; and enhancement.

Embedded mitigation, which is part of the design, and good practice mitigation are

taken into consideration during the scoping process and through the initial assessment

of magnitude and determination of significance. Additional mitigation is identified if the

significance of effect requires it and causes the effect to be further reduced. A final

assessment of significance of effects is carried out taking into consideration the

additional mitigation.

5.4 Cumulative Effects

The EIA Regulations clearly states that cumulative effects should be considered as part

of the EIA for a proposed project. Cumulative effects can arise when a single resource

or receptor is affected by more than one effect from the proposed project or from the

combination of the proposed project and other development projects within the local

area where combined effects can occur.

The proposed logistics facility is not the only development that is proposed in Usakos.

The town being strategically located along the B2 Highway provides a gateway for

investors that wish to access the coastal areas. It is therefore recognized that there is

potential for cumulative effects to arise both within the proposed project (intra-project –

combined effects from the proposed project and it’s supporting infrastructure on a

receptor), but also from different developmental projects introduced in Usakos. For

example, the noise generated during the construction phase of the proposed project

may not cause a significant effect in isolation; however, a sensitive receptor may be

significantly affected when noise from the proposed project is combined with noise

generated from other construction projects in the area.

The assessment of cumulative effects is undertaken by receptor rather than by topic or

activity. There is no formal guidance for cumulative impacts presented and therefore

professional judgment is used for the assessment.


CHAPTER 7

6. IMPACT ASSESSMENT

6.1 Introduction

This chapter presents the findings of a high-level assessment of the project facets

which could result in significant environmental effects. The assessment is in line with

the methodology presented in Chapter 5.

A list of potentially significant effects and other likely environmental effects that should

be considered during the construction and operation of the proposed project in order

to reduce adverse effects and minimize pollution (considered best practice) are

contained in the EMP along with mitigation measures.

6.2 Phase 1

The project will be implemented using a two phased approach. A phased approach is

used because the associated project supporting infrastructure will not be completed

timeously as some require permits to be obtained.

6.2.1 Erection of a Temporary Logistics Hub

Construction of a temporary logistics hub has the potential to generate environmental

impacts and diligence must be applied to mitigate for such impacts. The temporary

hub is meant to serve as a truck-port for semi-trailer fuel tankers which are in transit to

fuel destinations. The facility will be able to accommodate a maximum of 40 trucks.

The floor will be constructed in a manner that will minimise groundwater

contamination, in an event that oil spills accidentally. The fuel tankers will always be

required to be parked on the special flooring. Regular inspections are recommended

on the tankers and flooring to monitoring any signs of fuel leakage or spillage in the

area. A temporary administration block fitted with ablution amenities will also be

erected to process the required paper work for the fuel tankers to proceed to delivery

destinations.

6.2.2 Fuel Transportation via B2 Highway

Portable semi-trailer fuel tankers carried by trucks will be used to transport fuel that is

procured from Walvis Bay. The fuel tankers will then be driven to the temporary

logistics hub for further processing.


Transporting fuel is considered a high-risk excise and requires diligence. Fuel tankers

that will be used are ISO certified and fit for the purpose. This means that the tankers

are relatively safe. However, the trucks must still be fully equipped with firefighting

gear in case of an emergency.

6.3 Phase 2

This phase will comprise the construction of permanent structures and the supporting

infrastructure. Mitigation measures for each supporting infrastructure are detailed in

the EMP, however the key mitigation activities are listed below.

6.3.1 Fuel transportation via the Trans-Namibia Railway

This route will be introduced upon securing the authorisation to introduce a railway

off-ramp into the MDL facility from the relevant authority. The assumption is that the

authorisation to be obtained will include specific measures to be adhered to in

ensuring that safety precautions are maintained.

6.4 Cumulative Effects

6.4.1 Groundwater

The town of Usakos uses groundwater as a source of water in the area. The area is

known for its shallow groundwater resources and any risks of pollution to water

sources is considered to be an impact with high concern. There is potential for

groundwater quality to be affected as a result of the combination of several fuel

related activities in the area, in particular the MDL fuel logistics hub. Such activities

could cause spilled oil to seep through the ground and could reach groundwater.

Monitoring boreholes will need to be established near to the project site to track

changes in groundwater quality. In the event that fuel contamination is detected,

actions must be taken to identify the source of contamination and mitigation

measures implemented. It should however be noted that the monitoring wells are a

preventive measure. The proposed project has no been identified as a daily

contributor to groundwater degradation however, in the case of a fuel spill at the

site, an impact on groundwater must be prevented.

Table 5: Potential effects on groundwater

Receptor Effect Sensitivity Severity Duration Probability Significance

before

additional

mitigation

Significance

after

additional

mitigation

Groundwater Groundwater

Contamination

M M L M M XX


CHAPTER 8

7. PUBLIC PARTICIPATION PROCESS

7.1 Introduction

Public consultation forms an integral component of the EIA process. Comments

made during the public participation have been captured and addressed in both the

EIA Scoping report and EMP respectively.

The public participation process (PPP) allows interested and affected parties (I&APs)

to identify issues and concerns related to the proposed project which they feel should

be addressed in the EIA process. In return, the environmental assessment identifies

feasible mitigation measures that can be implemented to address the identified

issues / concerns. Furthermore, the PPP provides I&APs with an opportunity to gain

more information regarding the proposed project, and to voice any issues of concern

during the public comment process.

In order to conform to the EIA regulations, a public consultation process has been

undertaken. A full stakeholder consultation process was undertaken from the onset of

the project to ensure that the widest range of stakeholders was adequately and

effectively consulted.

7.2 Consultation Activities

A summary of the consultation carried out for the proposed project is summarised

Table 6: Summary of Stakeholder consultation activities

Task Description Action

Background

Information

Document (BID)

A BID was compiled and

distributed to the public. The BID

provides high level information

about the proposed project and

provides details on how I&APs

can register their interest

Background Information

Document (BID)

developed and distributed

to interested and affected

parties (Appendix A-1)

Authority

consultations

Consultative meetings were held

with the Environmental

Commissioner’s office (Ministry

of Environment and Tourism)

and the Department of Water

Affairs (within the Ministry of

Agriculture, Water and Forestry

Site meeting held with the

Usakos Town Council on

18 May 2019 (Appendix

A-2)


Newspaper

adverts

NEMA Act requires that

advertisements be placed in at

least two common newspapers

for two consecutive weeks.

As such, 4 x Adverts were

placed in The Confidente and

New Era newspapers for two

consecutive weeks advertising

the proposed project inviting

I&APs to register their interest

and to review the draft EIA

Scoping and EMP reports

11 July & 16 July 2019

Public Meeting A public meeting was held to

present the proposed

development and solicit

comments.

20 July 2019

At Usakos Town Council

Chambers

Comments and

Response

Report (CRR)

Stakeholder comments have

been incorporated in the

environmental Scoping Report

and EMP.

The comments and

response Report (CRR) is

attached together will all

other public participation

documentation

7.3 Concerns raised

Table 7: Issues raised during public consultation

Issues Raised Response

Development activities are welcomed in

Usakos Town however these should be

considerate of existing businesses in the

area. There are three fuel stations already in

Usakos and the proposed fuel station to form

part of the petroleum and logistics facility

should be re-considered.

The proposed project support structures such

as the fuel station remains as alternatives

which will still be evaluated when the need

arises for them to be implemented.

If found to be detrimental to the economic

performance of existing stations, it may have

to be abandoned.

The project site is within the catchment area

and Usakos is known to have shallow

groundwater resources. What measures will

the project implement to ensure that no

contamination occurs?

The proposal is to construct a special

concrete pavement on site which will prevent

fuel from infiltrating into the ground.

Monitoring wells will also be installed to

obtain water samples that will be sent to


laboratories for contamination analysis.

MDL should work with Usakos Town Council

and obtain a database of unemployed youth

in the area. These are the people that must

be prioritised for employment before external

people are brought in.

MDL is currently working on an employment

scheme together with Usakos Town Council.

Site notice at Usakos Town Council notice board

Public meeting in progress at Usakos Town Council Chambers

Public meeting in progress


CHAPTER 9

8. CONCLUSION AND RECOMMENDATIONS

8.1 Conclusion

The environmental assessment concluded that NO significant environmental effects

are likely to occur as a result of the construction and operation of the proposed MDL

fuel logistics hub (narrated as the proposed project).

The EIA identified and assessed potential environmental effects and suitable

mitigation and management measures to be applied during the construction and

operational phases of the proposed project in order to mitigate potential environmental

impacts as presented in the EMP.

8.2 Recommendations

Therefore, Tortoise Environmental Consultants (TEC) has no doubt and hereby

strongly recommends approval and issuance of the Environment Clearance Certificate

for the proposed project.

It is recommended that the subject of the environmental clearance certificate be:

Environmental Clearance Certificate for the proposed Storage and Logistic Facility for

Petroleum Products in Usakos, Erongo Region.

for the proposed storage and logistic facility for...

Documents