the proposed harvesting of an existing sand pile, …eia.met.gov.na/screening/341_emp.pdfdocument...

ENVIRONMENTAL MANAGEMENT PLAN (EMP

THE PROPOSED HARVESTING OF AN EXISTING

SAND PILE, EENDOMBE VILLAGE, OMUSATI REGION

June 2019

DOCUMENT INFORMATION

Title Environmental Management Plan (EMP) for Sand

Mining in the Eendombe Village, Omusati Region

Document reference number

Activity Sand Mining

Location Eendombe Village, Omusati Region,

Along the M123 gravel road between Okahao

and Outapi via Eendombe

Proponent Ongandjera Traditional Authority

Mr. Godlieb Anguku / Mr. Sakeus Amunyela

P.O. Box 2

Okahao

Mobile: 081 251 5099 / 0816021125

Tel:

E-mail: [email protected]

Version Final Report

Issue Date June 2019

Author: Silvanus Uunona, 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]

Environmental Management Plan (EMP) for the Proposed Sand Mining at Eendombe Village, Omusati Region

Table of Contents

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

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

1.1. Purpose of the EMP .................................................................................................... 1

1.2. Compliance to the EMP .............................................................................................. 1

1.3. Proponent responsibility to the EMP ........................................................................... 1

1.4. Possible adjustments to the EMP ................................................................................ 2

2. PPROJECT PLANNING AND DESIGNING ......................................................................... 2

2.1. Scope of the EMP ....................................................................................................... 2

2.2. Locality ....................................................................................................................... 2

2.3. Biodiversity and Ecology of the Area ........................................................................... 1

2.4. Sand Mining Process and Estimated Sand Volume .................................................... 2

2.4.1 Sand mining – Processes ........................................................................................ 2

2.4.2 Estimated Production Volume ................................................................................. 2

3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK POLICY .................................... 3

4. ROLES & RESPONSIBILITIES ........................................................................................... 7

3.1 The Environmental Compliance Officer (ECO) ............................................................ 7

3.2 Site Manager: ............................................................................................................. 7

3.3 Inspections, Auditing and Monitoring ........................................................................... 8

3.4 DISCIPLINARY ACTION ............................................................................................. 8

5. MITIGATION MEASURES .................................................................................................. 8

6. REHABILITATION ............................................................................................................. 25

6.1 Designing a Rehabilitation Plan ................................................................................ 25

6.2 Recommended Measures ......................................................................................... 25

7. CONCLUSION .................................................................................................................. 26

8. RECOMMENDATIONS ..................................................................................................... 27

LIST OF TABLES

Table 6.1 Operation Phase .............................................................................................. 8

Table 6. 2 Decommissioning phase ................................................................................. 9

Table 6 3 ESMP Impact Identification Section and Associated Aspects .......................... 9

Table 7. 4 Staff Induction ............................................................................................... 10

Table 7. 5 Health and Safety ......................................................................................... 12

Table 7. 6 Waste Management ...................................................................................... 16

Table 7. 7 Aspects of General Environment during Construction and Operation Phases

...................................................................................................................................... 18

Environmental Management Plan (EMP) for the Proposed Sand Mining at Eendombe Village, Omusati Region

Table 7. 8 Cultural and Heritage .................................................................................... 21

Table 7. 9 Aspects of Socio Economic during Construction and Operation phases ...... 22

ABBREVIATIONS

DEA Department of Environmental Affairs

EA Environmental Assessment

EAP Environmental Assessment Practitioner

ECC Environmental Clearance Certificate

ECO Environmental Compliance Officer

EIA Environmental Impact Assessment

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

EMP Environmental Management Plan

ESMP Environmental Social Management Plan

MET Ministry of Environment and Tourism

SM Site Manager

TEC Tortoise Environmental Consultants

Environmental Management Plan (EMP): Proposed Sand Mining at Eendombe Village, Omusati Region 1

1. INTRODUCTION

The project proponent, Ongandjera Traditional Authority hereby apply for an

environmental clearance certificate to mine an existing sand pile, that was left after

the construction of the M123 gravel road between Okahao and Outapi via

Eendombe. Tortoise Environmental Consultancy (TEC) has been appointed to

undertake the requisite Environmental Impact Assessment process (EIA) and

develop and Environmental Management Plan (EMP).

The aim of the EIA and EMP is to assess possible environmental and social risks,

weigh the identified impacts and develop mitigation measures. The EIA and EMP

are submitted to the Office of the Environmental Commissioner under the Ministry of

Environment and Tourism (MET), as part of the application for the Environmental

Clearance Certificate (ECC) for the proposed sand mining activities, located in

Eendombe village, Ogongo Constituency, Omusati region.

1.1. Purpose of the EMP

This (EMP) is a risk mitigation strategy that provide logical framework and

guideline to be undertaken by the project proponent during the construction and

operation of the project in order to mitigate environmental threats. This strategy

aims to develop environmental monitoring tools to control and maintain the

environment in an acceptable state. The monitoring plans developed for this

project included, defining roles and responsibility and mitigation measures to be

applied to the possible negative impacts throughout the project phases.

1.2. Compliance to the EMP

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

Environmental Management Act, 2007 (Act No. 7 of 2007). The project

proponent and its contractors are thus expected to strictly adhere to the

guidelines set out in this document.

1.3. Proponent responsibility to the EMP

The proponent, herein referred to as Ongandjera Traditional Authority, shall

assume overall responsibility to ensure implementation of the EMP and will be

held accountable against the remedial measures outlined herein. It is

recommended that the client should appoint a Site Manager who will be

responsible for monitoring of daily operations.


The Site Manager should ensure that a copy of the EMP is available at the

project premises at all times. Most importantly, an induction should be conducted

with all employees.

1.4. Possible adjustments to the EMP

The EMP is an open ended document and can be considered inconclusive. This

implies that, in-addition to the information contained in the EMP, any other

relevant information gained during the actual sand and gravel mining activities,

internal monitoring or auditing by MET can be added to the EMP (evolution of

activities), and such changes will be binding to Ongandjera Traditional Authority,

and all contractors / sub-contractors.

2. PPROJECT PLANNING AND DESIGNING

The design phase entails the conceptual framework (what, where, how big, etc.) of

the proposed development. At this stage, all environment impacts must be put into

consideration and incorporated in the project implementation.

During the planning phase, it is imperative that the design is evaluated and if any

environmental concern is detected at this stage, corrective measures should be

applied. In-addition, a contingency plan should be in place, in case, unforeseen

environmental concerns are detected at a later stage.

2.1. Scope of the EMP

The scope of this EMP emanated from the comprehensive Environmental Impact

Assessment of this project. It is presented into five aspects for effective

implementation;

Management Objective

Management Action/s required

Indicator/s and

Party responsible for implementation

2.2. Locality

Eendombe village is situated in the Omusati region, approximately 20 km south of

Okahao (town). The sand pile is located along the M123 gravel road between

Okahao and Outapi via Eendombe (Figure 1 & 2).


Fig 1: Location of the existing sand pile at the Eendombe Village, Ogongo Constituency, Omusati Region


Fig. 2 Proposed Sand Mining Site, Eendombe Village


Existing Sand Pile

Existing Sand Pile

Existing borrow pit

Existing Sand Pile

Community water point across the road

from the sand pile

Graveyard (background) about 300m from

the sand pile

Fig 3. View of the proposed sand mining site (existing sand pile) at Eendombe village

2.3. Biodiversity and Ecology of the Area

Eendombe village falls within the broad-leafed savannah woodland, with highly

variable summer (October-March) annual rainfall, 450-600mm and long dry spell

during the winter months.


The woodland savanna is characterized largely by sizeable woody trees canopy

with sizeable shrubs layer, on a thick Kalahari sand deposit. Woody tree species

in the area is dominated by the Omusati (Colophospermum Mopane)

2.4. Sand Mining Process and Estimated Sand Volume

2.4.1 Sand mining – Processes

This sand mining project will entail the use of moderm sand mining

machineries and equipment such as:

Front loader / JCB / TLB (to load the sand in the tipper trucks)

Tipper / Dump trucks (to transport sand)

The sand pile is a left over from the construction of the M123 gravel road

between Okahao and Outapi via Eendombe, and the proposal is simply to

harvest the existing sand pile. Therefore, the activity will have no further

environmental damages.

The existing borrow pit is not deep and it not change the landscape

significantly. Shallow borrow pits they do not pose serious threats to people

and livestock and are much easier to rehabilitate (allows the natural process

of sedimentation1 to take place as a natural rehabilitation phenomenon.

2.4.2 Estimated Production Volume

The proposal is to mine the existing sand pile, but at this stage the exact

volumes of sand are unknown.

1 Flood / fast flowing water has momentum and carries a lot of sediments (soil particles), and when it is slowed down, the soil particles (sediments) settles at the bottom, and thereby filling up the excavated pits, through a process called sedimentation.


3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK POLICY

Legislation Summary Applicability

The Namibian Constitution

The Namibian constitution is the supreme law of the country which is committed to sustainable development. Article 95(1) of the Constitution of Namibia 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”.

Contact an EIA to maintain the ecological process and diversity of the project area

The Environmental Management Act

The Environmental Management Act No 7 of 2007 aims to promote the sustainable management of the environment and the use of natural resources and to provides for a process of assessment and control of activities which may have significant effects on the environment; and to provide for incidental matters. The acts provides a list of activities that may not be undertake without an environmental clearance certificate. Further, the Act ensures that;

(a) Potential threats are considers timeously (b) A comprehensive stakeholder’s consultations is conducted and

all Interested and affected parties are given an opportunity to comment on the project

(c) Decision are robust by taking into account the above mentioned activities

Statutory requirement of the EIA and guidelines

Draft Pollution Control and Waste Management Bill

This Bill serves to regulate and prevent the discharge of pollutants to air and water as well as providing for general waste management. The Bill will repeal the Atmospheric Pollution Prevention Ordinance (11 of 1976) when it comes into force. The Bill also provides for noise, dust or odour control that may be considered a nuisance. Further, the Bill advocates for duty of care with respect to waste management affecting humans and the environment and calls for a waste management licence for any activity relating to waste or hazardous

Management of Waste, such as sewer and solid waste.



waste management.

Traditional Authorities Act, 25 of 2000

Provides for the establishment of traditional authorities and defines their powers, duties and obligations.

Land acquisition for the extraction of sand

Environmental Policy framework (1995)

This policy subjects all developments and project to environmental assessment and provides guideline for the Environmental Assessment. Its provision mandate that Environmental Assessment take due consideration of all possible impacts and incorporate them in the development or planning stages.

General requirement of the EIA and guidelines

The Occupational Safety and Health Act No. 11 of 2007;

Safety: A safety risk is a statistical concept representing the potential of an accident occurring, owing to unsafe operation and/or environment. In the working context “SAFETY” is regarded as “free from danger” to the health injury and to properties. Health: Occupational Health is aimed at the promotion and maintenance of the highest degree of physical, mental and social wellbeing of workers in all occupations. This is done by ensuring that all work-related hazards are prevented and where they occur, managed.

Employee health and safety risk at workplace In order to maintain good and healthy standards, at the work place, cleanliness, adequate sanitary facilities, protection against dangerous substances as well as education and training of both workers and management is necessary.

Public Health Act No. 36 of 1919

The Act serves 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 area being mined is fenced off to ensure public safety

Water Resources Management

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,

Construction activities pose danger to surface and underground water through the use of fuels and lubricants.



Act (2004) 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.

The proponent must ensure adequate handling of hazardous substance that may pollute water sources

Water Act No, 54 of 1956

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 resources, 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

Prohibition of contaminated water in the water body

Labour Act No. 6 of 1992

This Act aims to regulate labour in general and includes the protection of the health, safety and welfare of employees. The 1997 Regulations relating to the Health and Safety of employees at work sets out the duties of the employer, welfare and facilities at the workplace, safety of machinery, hazardous substances, physical hazards, medical provisions, construction safety and electrical safety.

No employer shall require or permit an employee to work in an environment that is deemed unfit without protective measures in place.

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

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 development at regional level.

Adhere to regional by laws, land acquisition should be done as require by law

Soil Conservation Act No. 76 of 1969

This act promotes the conservation of soil, prevention of soil erosion. Indiscriminate mining and movement of heavy vehicle exacerbate soil erosion and land degradation

Convention on Biological Diversity Rio De Janeiro (1992)

Namibia is a signatory to convention of preservation of rare and endemic species.

Omusati region is generallyby the savannah and broad leaved vegetation biomes, which supports a vast range of unique biodiversity. Many of which are



endemic to the region and which needs to be protected and conserved.

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.

Scrapping and excavation may unearth archaeological material.

Best Environmental Practises

Precautionary Approach Principle This principle is worldwide accepted when there is a lack of sufficient knowledge and information about the possible threats to the environment. Hence if the anticipated impacts are greater, then precautionary approach is applied. In this project, there are no eminent uncertainty however in cases when they arise, this approach should be applied. Polluter Pays Principle This principle ensures that proponents takes responsibility of their actions. Hence in cases of pollution, the proponent bears the full responsibility to clean up the environment.

The proposed sand mining is widely practised and associated impacts are well known. However, the practise has the ability to disturb ground water, hence precaution measure during mining must be considered In the event of an accident, where hydrocarbons or lubricant spillage occur, the proponent would be responsible to clean up the environment.


4. ROLES & RESPONSIBILITIES

This section outlines the roles and responsibilities of the respective key personnel

that would be responsible for effective implementation of the EMP. Formal

responsibilities are necessary to ensure that key procedures are followed.

Ultimately, the overall responsibility for the implementation of the EMP lies with the

proponent, Ongandjera Traditional Authority. It is necessary to delegate / assign

responsibilities to specific people (e.g Site Managers), during construction and

operation phase of the project. It may be possible that the Site Manger during the

Construction Phase will only be responsible for the construction and a new Site /

Estate Manager may be appointed for the Operational Phase. In that case, the

responsibility of the Site Manager during construction might not be transferrable

during operation.

There are at least two main role-players expected to participate in the environmental

management of the site these are:

Environmental Compliance Officer (ECO) representing MET for auditing and

monitoring compliance to the EMP;

Site Manager (SM) representing the Proponent.

All instructions and official communications regarding environmental matters shall

follow the organisational structure as determined by the Proponent. Based on the

adopted structure, it is essential that responsibilities outlined are assigned to specific

parties with adequate capacity and experience required to implement the EMP.

3.1 The Environmental Compliance Officer (ECO)

The ECO in the context of this document refers to the party responsible for the

environmental compliance and auditing activities required by the EMP for the life

cycle of the sand mining operations cycle. The ECO shall be a representative of

MET, and the designation shall be reserved for a suitably qualified compliance

officer. The ECO shall have adequate environmental knowledge to understand

the detailed environmental issues associated with the project, and is to be well

versed in the contents of the EMP and its associated reports.

3.2 Site Manager:

The site manager is appointed by the proponent (Ongandjera Traditional

Authority) and will be party responsible for overseeing daily mining activities at


the site, to ensure compliance with the EMP throughout construction. Hence the

responsibilities of the site manger (inter alia the Proponent) are to ensure that:

An induction session is conducted with all site employees to ensure that they

are adequately informed and conversant with the EMP requirements;

Develop procedures for reporting incidents and resolving problems on the site;

Maintains records relating to the compliance/non-compliance and submits

these as requested for by the competent authority.

3.3 Inspections, Auditing and Monitoring

The Environmental Management Plan (EMP) is an important and necessary tool

aimed at mitigating any negative environmental impacts as a result of the

proposed activity, as well assigning responsibilities to ensure compliance during

the project lifecycle. However, in the absence of random inspections, auditing

and monitoring, the EMP will be an ineffective tool, hence the importance thereof.

3.4 DISCIPLINARY ACTION

The EMP is a legally binding document. Non-compliance with the EMP may

result in disciplinary action being taken against the Proponent (Ongandjera

Traditional Authority). Such action may take the form of;

Financial penalties,

Legal action, fines, and/or

Suspension of work

The disciplinary action shall be determined according to the nature and extend of

the non-compliance, and exact penalties are to be weighed against the severity

of the incident.

5. MITIGATION MEASURES

To enable a systematic approach to impact identification, activities have been

classified into three (3) Phases and each phase is further broken down into specific

activities as presented below:

Table 5-1: Operation Phase

Activity Description

1 Digging and Scrapping of Topsoil

2 Stock pilling of Topsoil


3 Digging of Sand and Stock pilling

4 Loading, Transport and Hauling of Sand

Table 5-2: Decommissioning phase

Activity Decommissioning Phase

1 Removal of all infrastructure after closure

2 Rehabilitation of the land

Additionally, for ease of reference to potential impacts, the EMP is broken down into

different socio-economic and environmental section and for each section herein

referred to Environmental Social Management Plan (ESMP), specific aspects have

been identified and for each aspect, specific mitigation measures have been

recommended.

Table 5-3: ESMP Impact Identification Section and Associated Aspects

EMP Implementation /

Potential Impact

Category

Specific Aspects

A – Staff induction

Induction

Site Demarcation

Communication

B – Health and Safety

General safety at work place

Road Safety

Ablution facilities

Dust and Noise

C – Pollution and Waste

Management

General waste

Domestic waste

Hazardous Waste (Hydrocarbons and Lubrication)

D – Environment

Water

Ecology

Rehabilitation

E – Cultural Heritage Heritage resources / artefacts

F – Socio economic Employment opportunities for Locals

Alcohol and Drug use at construction site

Working hours

HIV / AIDS


SECTION A: STAFF INDUCTION

Table 5-4: Staff Induction

Aspect Objective Proposes Mitigation Measures Monitoring Indicator

Party responsible

Staff induction To ensure that all staff / employees are conversant with the requirements of the EMP

1. Induction for all staff / employees on the provisions of the EMP before work commencement, covering but not limited to: environmental awareness, emergency response, Reporting of incidents, HIV/AIDS awareness, alcohol and substance abuse, and Safety, Health and Environment (SHE) measures

2. Staff operating equipment (such as loaders, etc.) shall be adequately trained and sensitized to any potential hazards associated with their tasks

3. Quarterly induction reviews

Induction Minutes and Attendance Register, Signed by each and every staff member Staff members appointed at a later stage should also undergo induction Quarterly minutes

Site Manager

Punitive measures for staff, to ensure compliance

1. Adopt a disciplinary system to discipline staff for non-compliance, such as littering, speeding, safety risk both to themselves and to others, not using ablution facilities, etc.

Number of fines/warning issued daily/Monthly

Site Manager

Availability of the EMP on site for ease of reference

1. Ensure that a copy of the EMP is kept on site and accessible to team leaders

Availability of EMP on site and accessibility to team leaders

Site Manager


Aspect Objective Proposes Mitigation Measures Monitoring Indicator

Party responsible

Site Demarcation

Contain all project activities within the site boundaries

1. Clearly demarcate the project site by fencing Visible fence around the project site

Site Manager

Communication To ensure effective communication throughout the project lifespan

1. Develop a communication strategy (Chanel and medium of communication)

2. All correspondence should be written and signed off by witnesses (e.g. Site manager and team leaders)

3. The contact numbers for the Site Manager and Team Leaders must be available onsite (displayed) in case of emergencies.

Communication Strategy Letters, e-mail, Notices, Minutes

Site Manager

General Notice Board

To notify and warn the public of the project activities

1. A general notice board must be erected at the site entrance to notify the public of the activities and associated dangers.

Notice Board – Visible and Clear

Site Manager


SECTION B: HEALTH AND SAFETY

Table 5-5: Health and Safety

Aspect Objective Proposed Mitigation Measures Monitoring Indicator Party responsible

General

Safety at

Work Place

Ensure that the

safety of workers

is not

compromised and

adhere to the

Health and Safety

Regulations,

Government

Notice 156/1997

(GG 1617)

1. Develop a Health and safety Plan

(should be part of the induction)

2. Ensure that every employee went

through an induction course about

safety;

3. Employees must be equipped with all

necessary Personal Protective

Equipment (PPE). These includes,

Helmet, Overall, Safety Shoes, Safety

Glasses, Gloves, Welding shield,

Earmuff etc;

4. During operation, minor accident are

eminent, hence there must be a first aid

kit;

5. Only qualified personnel must be

allowed to operate special

machine/instruments

6. No employee must be allowed to be

onsite without PPE;

7. Adequate safety signs must be displayed

on site.

Health and Safety

included and reflected

in the Induction

Minutes

Adequate protective

gear for all staff

Availability of the first

aid kit onsite

Number of

warning/discipline

Visible safety signs on

site

Site Manager



8. Fence off the mining area

Road Safety Prevent traffic

hazards /

inconveniences

from slow moving

trucks

1. Signage to warn motorists about slow

moving heavy vehicles.

2. Heavy vehicle must have all necessary

reflective signage and signal lamps

3. Plan adequate intervals for delivery

trucks to avoid traffic congestions

4. Material transportation must stop at

Sunset.

Public Complaints /

Incident report/s

Site Manager

Health Reduce health

risks and

environmental

pollution and

ensure healthy

working

environment with

appropriate and

user friendly

ablution facilities

Ablution facility

should be

environmental

friendly

1. Employees must NOT be exposed to

noise levels above the required -85dB

(A) limit over a period of 8 hours. Should

the noise level be higher than 85dB (A),

the employer must implement a hearing

conservation program such as noise

monitoring;

2. Employees must be provided with

adequate and safe drinking water;

3. There must be suitable, clean and user-

friendly ablution facilities, with separate

Male and female toilets at a ratio of 1:15

for females and 1:30 for males;

4. Employ a cleaner or rotate cleaning

responsibilities amongst workers to

availability, cleanliness

and hygienic ablution

facilities

Incidents or

complaints of waste

discharge into the

environment

Site Manager



ensure hygiene;

5. Inspect ablution facilities regularly for

cleanliness;

6. Provide dust bins for solid waste

disposal;

7. No defecation should be tolerated in any

place other than provided toilets

8. Inspect ablution facilities regularly for

cleanliness

Dust

Mitigate dust and

noise impacts to

both employees

and the public

1. Use dust suppression measures to

mitigate dust impacts, especially at stock

pile area, note, water is scarce resource

and must be used sparingly, use

alternative method such as DUSTEX.

Etc.

2. Avoid working during windy times

3. Provide dust masks and ear muffs to all

employees operating in a dusty or noisy

environment

4. Reduce vehicle speed on gravel roads

5. Trucks transporting sand must be

covered during transportation

6. Where possible, install silencer on

Incident Report

Public Complains

Site Manager



Noise

exhaust to reduce noise levels

7. Only work during normal working hours,

do not work during the night

8. Provide worker with earmuffs

9. Vehicle engines must be shut down

when it is not in use

10. Vehicles and machines must be well

serviced to avoid unnecessary noise

emission

11. Only work during the day 06:00AM-

18:00PM


SECTION C: POLLUTION CONTROL AND WASTE MANAGEMENT

Table 5-6: Waste Management

Aspect Objective Proposed Mitigation Measures Monitoring

Indicator

Party

Responsible

Vehicle

emissions

Reduce greenhouse

gas (GHG) emissions

from poorly

maintained or

malfunctioning

equipment (vehicles /

machinery

1. All vehicles and equipment shall

be kept in good working condition

and serviced regularly (in

accordance with the servicing

frequency of the specific

machinery), in order to prevent

leakage and emission of

poisonous smoke etc.

2. Switch off engines when vehicle

is not in use

Vehicle servicing

records

Reports of smoke

emissions from

machinery

Site Manager

Oil Spills

Leakages

Manage oil spills and

leak from heavy

vehicles and

Machinery

1. There must be an immediate spill

response kit on site. Workers to

be properly trained

2. If an oil spill occurs, collect the

contaminated soil, store in drums

or appropriate structures and

dispose at approved waste

disposal site (e.g. Okahao

Municipal disposal site)

3. Ensure all vehicle are well

Physical

verification and

routine monitoring

Site Manager


Aspect Objective Proposed Mitigation Measures Monitoring

Indicator

Party

Responsible

service and contact leak

inspection regularly

4. Provide drip trays to stationary

vehicle

5. No servicing of vehicle must be

done on site

6. Re-fuelling must be done at

specific locality with concrete

budning

Solid Waste To manage domestic

waste

To prevent littering,

pollution,

contamination of

water and general

environmental health

hazards

1. There must be sufficient waste

bins. Color segregated for

different waste;

2. General waste must be

separated from hazardous

waste;

3. Hazardous waste must be

disposed of at an approved site;

4. Each category should be

collected separated disposed of,

in the most suitable and

environmentally acceptable

manner

Domestic waste

management

Scattered waste,

Littering and any

other unsightly

waste at the site

(eyesore)

Site Manager


SECTION D: ENVIRONMENT

Table 5-7: Aspects of General Environment during Construction and Operation Phases

Aspect Objective Action Required Monitoring

Indicator

Party responsible

Surface Water To avoid any

potential water

contamination.

1. Vehicles must not be serviced at

the site;

2. Vehicles must be well serviced to

avoid leakages

3. All contaminated soils must be

removed and be dumped at

Okahao Dumpsite or appropriate

site

4. Provide drip trays to stationary

vehicles to collect possible oil and

fuel drips

5. Re-fuelling of the excavator must

be done at an appropriate site

with impermeable bund.

Storm water

drainage system

in place

Site Manager

Biodiversity Protect trees and

other plants and only

remove trees when

necessary

1. The big mature trees must be not

be cut down

2. If a wild animal is spotted on site,

it must be not killed unless if it

poses danger to human life.

3. For the safety of animals and

Inspection report Site Manager



Indicator

Party responsible

humans, the edged of the pit must

be sloped to allow for ease

access.

4. Inspect the area before scrapping

to ensure zero harm to crawling

animals

Soil Erosion

To avoid soil erosion

1. Vehicles movement must be

coordinated on and around site

2. Only use the existing gravel road

to and from the site, do not form

other tracks

3. To allow natural flow of water in

the pit, the pit entrance must be in

the direction of water flow

4. Implement continuous

rehabilitation of the by trimming

and smoothing the slopes to be

less than one third of the initial

slope (1:3). This would allow easy

access to the pit by people and

animals, as well as allows for

smooth runoff of storm water and

prevent formation of gullies.

Physical

Observation

Site Manager



Indicator

Party responsible

5. Ensure adequate storage of top

soil, consider vegetation cover to

prevent wind and rain erosion.

Fire Risk To avoid field fires 1. Staff must be properly trained

on how to react and handle

bush fires

2. Firefighting equipment must

be on site 24hours and

regularly inspected to ensure

that they are working

3. Emergency response numbers

must be on site clearly and

visible space

4. There must be clear hazard

signs “NO OPEN FIRE” “NO

SMOKING

Fire incident

reports

Site Manager


SECTION E: CULTURAL HERITAGE

Table 5-8: Cultural and Heritage


Indicator

Party responsible

Heritage Resources /

artefacts

Reduce the impacts

of construction and

associated

earthworks on

heritage resources /

artefacts

1. Heritage remains or artefacts

discovered on site must be

reported to the National Museum

(+264 61 276800) or the National

Forensic Laboratory (+264 61

240461).

2. No artefacts must be removed or

be interfered with prior to

authorisation from the Namibian

National Heritage Council (NHC)

3. Recovery of heritage remains or

artefacts discovered and removal

thereof should be directed by the

National Museum

Sighting report/s

of heritage

resources /

artefacts

Site Manager


SECTION F: SOCIO- ECONOMIC

Table 5-9: Aspects of Socio Economic during Construction and Operation phases

Environmental /

Social Impact

Objectives Proposed Mitigation Measures Monitoring

Indicator

Party

Responsible

Employment

opportunities for

Locals

Promote benefits

to the local

community

1. Recruit locals for unskilled labour

2. Where possible, procure materials

from local suppliers

Employee

structure and

proportion of local

employment

Proponent and

Contractors

Alcohol and Drug

use

Prevent alcohol

and drug use at

the construction

site

1. Ban and warn the employees

against the use of alcohol and drug

at construction site

2. Provide awareness on the dangers

and health impacts of alcohol and

drug use

3. All employees must be screen with

the breathalyser to avoid intoxicated

personnel on site

Drunk /

Misbehaving

employees

Breathalyser

report

Monitor presence

of alcohol at the

construction site

Site Manager

Working hours Adhere to the

Labour Act No. 11

of 2007

1. Operate within the prescribed

working days and hours as per the

Namibian Labour laws and

regulations

Verification of

working hours

against the labour

Act

Site Manager


Environmental /

Social Impact


Indicator

Party

Responsible

Internship for

students

(Construction

phase only)

Provide

internships to

students from

Technical

institutions (e.g.

NIMT, VTC etc.)

1. Provide internships opportunities for

all trades

2. Advertise for student internships with

NIMT, VTC etc.

Student internship

register, trade etc.

Site Manager

HIV / AIDS Provide HIV /

AIDS awareness

to employees

1. The Ministry of Health and Social

Services provides free condoms to

all public amenities and health care

centres. Further it offers confidential

testing, counselling and treatment

including free access to anti-

retroviral medication (NPC, 2011).

Hence all washrooms, receptions

and gathering places should have

condoms at all time;

2. The developer should arrange for

HIV awareness for employees;

3. Prostitution is illegal in Namibia,

hence acts of prostitution must be

reported to authorities.

Availability of

condoms at

construction site

Minutes for

induction course

Reports of acts of

prostitution

Site Manager


Environmental /

Social Impact


Indicator

Party

Responsible

Security Orientation of

workers about

security for both

equipment and

themselves

1. Orientate all staff about the security

of equipment and themselves &

provide contact numbers for

emergency services e.g. Ambulance

and Police.

Proof of security

orientation and

emergency

contact numbers

Site Manager


6. REHABILITATION

Rehabilitation is the process of repairing and taking all necessary actions to limit

the damage caused by the developmental activity, to minimise potential danger,

to make the land suitable for other uses or simply to beautify the affected area

(so that it does not become an eyesore). Rehabilitation can also be referred to as

the measures taken to repair damaged environments (example refilling of borrow

pits with the overburden, re-vegetating, removal of unwanted infrastructure,

cleaning up etc).

In principle, an open pit poses safety and environmental risk. People and animals

may fall in during night, or drown when the pit is filled with water. Therefore, it is

crucial to develop a closure and rehabilitation plan for the borrow pits. It is

recommended that progressing / incremental rehabilitation should be

implemented right from the beginning of the mining activities, and should be

carried out throughout the project lifespan.

Overall, the aim of the rehabilitation plan is to ensure soil conservation, prevent

soil erosion, reduce safety risk (safety for both animals and people, particularly

children) and to ensure that the borrow pits do not become eye shores to the

public.

6.1 Designing a Rehabilitation Plan

A rehabilitation plan refers to a set of steps or measures to be taken in-order

to ensure that negative impacts associated with the development at hand are

mitigated. This however requires prior planning and integration of

rehabilitation activities throughout the project lifespan. Meaning, rehabilitation

measures should be taken right from the beginning of the project.

The environmental characteristics of an area where a project is located plays

a vital role in designing a rehabilitation plan.

6.2 Recommended Measures

The rehabilitation plan should encompass the following;

a) Inform relevant authorities and obtain relevant permissions for the project

closure

b) Staff awareness of the closure plan

Staff must be trained and made aware of the closure and rehabilitation

and their roles during implementation.


c) Fencing

To prevent accident and protect public safety, the mining area must be

fenced off, and any pit that is not fully rehabilitated.

d) Site Clean up

Contaminated soils and any material brought to the area must be

collected and be disposed of at an appropriate site. Burying of waste or

any foreign material is strictly prohibited.

e) Trimming and Smoothening of the pit

To ensure safety and prevention of soil erosion from the sharp angels

of the pit; The pit contours must be even and slopes smoothened and

not steeper than 1:3. Formation of a cut-off drain to enable permanent

drainage and to ensure smooth run-off. A deliberate natural structure

must be designed from the catchment area to guide storm water into

the pit.

f) Top Soil / Overburden

This soil contains seeds and it is fertile for re-vegetation. Therefore, the

topsoil should be used for smoothening of sharp angles and re-filling to

allow re-vegetation.

g) Compaction of disturbed surrounding

The compacted soil must be shallowly ripped and fertilized to allow

regrowth of vegetation.

h) Access roads

Access road made for this operation and would be no longer serve any

purpose after project closure, should be rehabilitated by ripping the

road surface to allow regrowth of vegetation.

i) Safety

After trimming of sharp slopes, the pit would not be completely

covered. Therefore, it still pose a risk of drowning to animals and

people. Hence, due diligence should be applied to determine before

the removal of the fence, to ensure safety.

7. CONCLUSION

Socio-economic development is very important for our livelihood and provides

services, income and employment opportunities, and hence activities such as

sand mining are vital and necessary for development. However, such

developmental activities should be conducted in a thoughtful and forward looking


manner. In other words, developmental activities, such as sand mining should

consider the future land use after such activity has come to an end.

Therefore to ensure that the land remains valuable for other land uses in the

future, rehabilitation should be part and parcel of such developmental activity

right from the beginning and throughout the project lifespan.

The scope of this project followed the TORs that were established through site

visit, and literature review to establish all possible environmental impacts and the

possible mitigation measure to the impacts concerning this project.

8. RECOMMENDATIONS

Tortoise Environmental Consultancy (TEC) believes that, the EMP adequately

addresses all environmental and socio-economic aspects for the continuation of

the sand and gravel mining activities. The sand and gravel mining activities are

crucial for the township development and socio-economic development for the

Oniipa Town and its inhabitants in general.

Provided that the proposed mitigation measures against social and environmental

threats are adequately implemented, the potential environmental and social

impacts are negligible (insignificant).

Given the above, TEC strongly recommend the approval and issuance of

environmental clearance certificate for sand mining activities at proposed site in

Eendombe village.

As stated under point 1.4, the EMP is a living document and if necessary, new

mitigation measures can be added.

the proposed harvesting of an existing sand pile, …eia.met.gov.na/screening/341_emp.pdfdocument...

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