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ENVIRONMENTAL SCOPING AND MANAGEMENT PLAN FOR THE MINING AND
UPGRADING OF GRANITE VALUE ADDITION PLANT – RENEWAL OF MINING
LICENCE 152 IN ARANDIS, ERONGO REGION.
FOR
SAVANNA MARBLE CC
Prepared by
P. O. Box 70822, Khomasdal, Windhoek, Namibia.
+264 812 683 578
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PROJECT DETAILS
TITLE Environmental Scoping And Management Plan For
The Mining And Upgrading of Granite Value Addition
Plant – Renewal of Mining Licence 152 In Arandis,
Erongo Region.
TERMS OF REFERENCE
AND SCOPE OF THE PROJECT Savanna Marble CC
AUTHORS Outrun Consultants CC
CLIENT Savanna Marble CC
REPORT STATUS Final Report
DATE 11 February 2019
AUTHORISED SIGNATURE:
JOSIAH T. MUKUTIRI
EIA PRACTITIONER
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Table of Contents LIST OF ABBREVIATIONS .................................................................................................................... 8
EXECUTIVE SUMMARY ....................................................................................................................... 9
1. INTRODUCTION ........................................................................................................................ 11
1.1. Background ....................................................................................................................... 11
1.2. Benefits of the Proposed Project........................................................................................ 11
1.3. Terms of Reference and / or Scope of Work ....................................................................... 12
1.3.1. Activities carried out during the scoping phase ........................................................... 13
1.3.2. Activities carried out during the EIA process ............................................................... 13
1.4. Description of the Proposed Project .................................................................................. 14
1.4.1. Additions and Modifications to Upgrade the Granite Processing Facility ..................... 14
1.4.2. Construction of other Facilities for the well-being of Staff Members on Site................ 14
1.4.3. The Proposed Technology / Mining and Processing Methods .......................................... 16
2. METHODOLOGY ....................................................................................................................... 19
2.1. The Consultancy Team / Practitioner’s Details ................................................................... 19
2.2. Public Consultation and Stakeholder Engagement ............................................................. 20
2.2.1. Purpose of the Public Participation Process ................................................................. 20
2.2.2. Identification of Key Stakeholders ............................................................................... 20
2.2.3. Initiation of the Scoping Process ................................................................................. 21
2.2.4. Public Consultation ..................................................................................................... 21
2.2.5. Issues and Concerns Raised and Responses ................................................................. 22
2.2.6. Review Draft Scoping and Environmental Management Plan ...................................... 24
2.2.7. Public Participation: Way Forward .............................................................................. 24
2.2.8. Historical Stakeholder Engagement ............................................................................. 24
2.2.9. Stakeholder Engagement during the EIA Study ............................................................ 25
3. DESCRIPTION OF THE ENVIRONMENT ....................................................................................... 26
3.1. Project Location ................................................................................................................. 26
3.2. Climate .............................................................................................................................. 26
3.3. Wind Field ......................................................................................................................... 27
3.4. Topography ....................................................................................................................... 28
3.5. Soils and geology ............................................................................................................... 30
3.6. Radiation (safety issues) .................................................................................................... 30
3.7. Flora and Fauna ................................................................................................................. 31
3.8. Culture and Heritage ......................................................................................................... 34
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3.9. Existing Mine Infrastructure and Operational Activities as already in Existence .................. 35
3.10. Water .............................................................................................................................. 36
3.11. Energy ............................................................................................................................. 36
3.11.1. Potential Challenge ................................................................................................... 36
3.12. Accommodation and toilet facilities ................................................................................. 37
3.13. Current Land use, Stakeholder infrastructure / No go zones and the Unimpacted areas in
ML 152. ....................................................................................................................................... 37
4. ANALYSIS OF PROJECT ALTERNATIVES ...................................................................................... 39
4.1. The ‘No – Go’ Option ......................................................................................................... 39
4.2. Alternative Sites ................................................................................................................ 39
4.3. Strategic Alternatives......................................................................................................... 39
4.3.1. Road ........................................................................................................................... 39
4.3.2. Water ......................................................................................................................... 39
4.3.3. Electricity .................................................................................................................... 39
5. LEGAL AND POLICY REVIEW ...................................................................................................... 40
5.1. Summary of Regulatory Authorities and Permits Applicable to the Proposed Project ......... 44
6. IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES ................................................ 45
6.1. Hierarchy of hazards control measures .............................................................................. 45
6.1.1. Habitat Loss ................................................................................................................ 45
6.1.2. Visual Impacts ............................................................................................................. 46
6.1.3. Solid Waste ..................................................................................................................... 46
6.1.4. Occupational Health – Exposure to Dust ..................................................................... 46
6.1.5. Occupational Health and Safety – Incidents, Accidents / Injuries / Loss of Life ............. 48
7. ENVIRONMENTAL MANAGEMENT PLAN ................................................................................... 50
8. CONCLUSION, RECOMMENDATIONS AND WAY FORWARD ....................................................... 57
8.1. Conclusion ......................................................................................................................... 57
8.2. Recommendation .............................................................................................................. 57
8.3. Way Forward ..................................................................................................................... 58
8.4. History of stakeholder interactions (i.e. proof of good working relations) .......................... 60
8.5. Background Information and Invitation to Participate Document ....................................... 61
8.6. Advertisements ...................................................................... Error! Bookmark not defined.
8.7. List of IAPs .............................................................................. Error! Bookmark not defined.
8.8. Correspondence with IAPs ...................................................... Error! Bookmark not defined.
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8.9. Proponent’s Identification Documents, Founding Statement and Mining Licence ......... Error!
Bookmark not defined.
8.10. Consultant’s CV .................................................................... Error! Bookmark not defined.
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Figure 1: The EIA process followed during the study. ............................ Error! Bookmark not defined.
Figure 2: Block cutter used in the value addition facility. ................................................................. 14
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Table 1. Team of experts and their areas of responsibility in the EIA process. .................................. 19
Table 2: Applicable Legal Instruments, Permitting Authority and Current Status / ............................ 44
Table 3: Environmental Management Plan ...................................................................................... 51
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LIST OF ABBREVIATIONS Full name Acronym
Background Information Document BID
Environmental Impact Assessment EIA
Environmental Management Plan EMP
Interested & Affected Party IAP
Ministry of Environment & Tourism MET
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EXECUTIVE SUMMARY
The applicant, Savanna Marble CC is the mining licence holder of ML 152 granted for
a period running from the 5th of June in 2009 to 4th June 2019. At the time of the
granting of the licence only an internal EIA was done as all such projects were cleared
based on an environmental questionnaire submitted to the Ministry of Environment
and Tourism (MET) who would then issue an environmental contract. Over the years
Savanna Marble CC (Proponent) has been involved in mining and exporting of granite
blocks and partially processing slabs and tiles for further value addition. Slabs were
mostly transformed into table tops through further value addition in Windhoek. It is the
Proponent’s plan to prioritise production at the on site value addition plant and make
finished products such as tiles, slabs, curbstones, windowsills etc., which would form
the basis for the expansion of existing stone manufacturers, as well as for the
development of various new downstream businesses that can add further value to
Savanna Marble CC’s products.
Most significantly this processing activity will enable the Proponent to make use of a
large number of blocks that were rendered waste due to inconsistent colour or cracks
or any other reason that compromised the overall quality of the blocks. In a nutshell
this EIA study has been necessitated by the application for renewal of mining licence
ML 152 (due in June 2019) and the addition of Processing and Manufacturing
equipment on the existing facilities. This was enough to motivate for a comprehensive
Environmental Management Plan in compliance with the Environmental Management
Act (2007) which covers both the mining operations and value addition activities.
Outrun Consultants CC an independent consulting company, conducted the EIA
process for Savanna Marble CC. The EIA was conducted in 2 phases, the Scoping
Phase during which interested and affected parties were given the opportunity to
comment on the granite mining and processing activities. Comments received during
the scoping exercise were incorporated. The second phase gave rise to the draft
environmental scoping and management report which was shared with stakeholders
for their inputs. The mining and processing activities in Erongo Region pose potential
environmental damage in the form of destruction of the landscape and aesthetic view
of the desert and disturbance of the natural environment. There are indigenous plants
of interest which the Namibia Botanical Garden could relocate and propagate if the
need arise, however at this stage none of the sensitive areas containing protected
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plants or of historical, cultural & heritage significance fall within the target zones for
mining or processing activities. The predicted environmental impacts can be managed
resulting in minimal or insignificant residual effects through the successful
implementation of the proposed Environmental Management Plan. Specific
instructions have been formulated as part of the EMP.
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1. INTRODUCTION
1.1. Background
The applicant, Savanna Marble CC is the mining licence holder of ML 152 granted for
a period running from the 5th of June in 2009 to June 2019. At the time of the granting
of the mining licence only an internal EIA was done as all such projects were cleared
based on an environmental questionnaire submitted to the Ministry of Environment
and Tourism (MET) who would then issue an environmental contract. Over the years
Savanna Marble CC (Proponent) has been involved in mining and exporting of granite
blocks and partially processing slabs and tiles for further value addition. Slabs were
mostly transformed into table tops through further value addition in Windhoek. It is in
the Proponent’s plans to upgrade the value addition plant and make finished products
such as tiles, slabs, curbstones, windowsills etc., which would form the basis for the
expansion of existing stone manufacturers, as well as for the development of various
new downstream businesses that can add further value to Savanna Marble CC’s
products.
Most significantly this processing activity will enable the Proponent to make use of a
large number of blocks that were rendered waste due to inconsistent colour or cracks
or any other reason that compromised the overall quality of the blocks. In a nutshell
this EIA study has been necessitated by the following:
a. Renewal of mining licence ML 152.
b. Change of operations due to the inclusion of Processing and Manufacturing
activities for the purpose of local value addition and reduction of waste.
c. Development of a comprehensive Environmental Management Plan in
compliance with the Environmental Management Act (2007) which covers both
the mining operations and value addition activities.
1.2. Benefits of the Proposed Project
The benefits of the renewal of ML 152 and the proposed expansion and upgrading of
the granite manufacturing and processing facility can be summarised as follows:
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• Employment creation, subject to full capacity being reached, up to 30
permanent work postitions can be created considering that manpower will be
required to mine the granite blocks, processing of granite blocks into finished
products (cutting and polishing plant), packing, despatch and transportation.
• Downstream industries will also benefit from the availability of raw material
(granite blocks) and finished products for use in the construction industry.
• Environmentally, all the blocks on site which were rendered waste due to quality
inconsistencies will be processed into finished products.
1.3. Terms of Reference and / or Scope of Work
Savanna Marble CC appointed Outrun Consultants cc to conduct the Environmental
Impact Assessment. The EIA was carried out in 2 phases, the scoping phase and the
full EIA study.
The EIA study took consideration of:
• Due consultation with the applicant and interested and affected parties.
• Reviewed current development / activity at the local level.
• Identification of legal framework governing assessment.
• Identification of the nature of site.
• Identification through scoping and on – site evaluation of issues relating to the
proposed development and its potential impacts on site.
• Methodology of assessing potential impacts.
• Information relating to public participation process.
• Plan of study for assessment of impacts / issues.
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Bio physical, social and economic aspects formed part of the EIA study and guided
the Consultants during the study. Mitigation strategies and a complete environmental
management plan were developed as part of the EIA study. Alternatives including the
“no go” option were explored. The following activities were undertaken during the
scoping and detailed EIA phases:
1.3.1. Activities carried out during the scoping phase
The scoping process undertaken includes the following activities:
• Policy and legislation relevant to the establishment of a quarry and crusher.
• Description of the proposed project
• Description of the affected environment
• The public participation process
• A detailed description of the potential impacts associated with the proposed
project
• Evaluation of the significance of the potential impacts.
• Evaluation of whether a full EIA is required or an Environmental Management
Plan only.
• Submission of the final scoping report to MET: DEA for consideration and
decision making.
1.3.2. Activities carried out during the EIA process
The EIA study covered the following areas in detail:
• Detailed project description
• Public consultation and a register of issues raised
• Identification of the possible and known impacts of the project
• Detailed analysis of the impacts
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• Review of relevant policies and legislation and the development of a legislative
framework compliance plan
• Development of an Environmental Management Plan (EMP) with workable
mitigation measures for adoption.
1.4. Description of the Proposed Project
1.4.1. Additions and Modifications to Upgrade the Granite Processing Facility
The project is focused on upgrading and operating the granite cutting and polishing
facility. This entails extending the floor line for the various product lines as well as a
packing and dispatch area. Associated planned activities include the construction of
the ablutions, showers and canteen.
1.4.2. Construction of other Facilities for the well-being of Staff Members on Site
Staff canteen:
The staff canteen will comprise of a pantry for storing food stocks, a kitchen and
seating hall.
Figure 1: Existing Block cutter used in the value addition process.
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Ablutions and showers:
Dixy toilets catering for twenty people will be used and serviced by an external
contractor. Showers will be installed to serve the same number of people but the grey
water will be used to feed a syphon growing melons and other vegetables.
• Description of a Toi Toi Dixi toilet, Operation and Maintenance
The facility comprises of a 5 m3 waste water tank fitted with a sanitary cabin mounted
on top. The waste water tank can be drained when full and the waste disposed of at a
municipal facility (Arandis). The Proponent is advised to negotiate with Arandis Town
Council to obtain a permit authorizing the Proponent to use Town Council facilities for
waste disposal.
Figure 2: A typical Toi Toi Dixi toilet cabin.
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Figure 3: Container toilet type mounted on a ten cubic meter waste water tank.
Operational and / or Working Hours
The Proponent has planned to operate both the mining and the cutting and polishing
plant during normal working hours of the day, (excludes night shift).
Refurbishment and plant adaptations
Existing processing equipment was imported in 2012 and was kept under maintenance
until 2016. Trial production and run-in of the plant commenced after assembly in 2016.
Rehabilitation and mine closure:
Rehabilitation and mine closure plans will only be developed in the future based on
the status quo at the time. Crafting a rehabilitation and closure plan based on predicted
scenario will be inaccurate.
1.4.3. The Proposed Technology / Mining and Processing Methods
Dimension stone mining involves purely physical processes of cutting the granite
blocks, sorting and dispatch to the on-site processing plant for local value addition or
to Walvis Bay for export. The process can be described by the following key
processes:
• Granite block delineation
• Mining
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• Product sorting by Quality
• Product handling and Despatch
1.4.3.1. Granite block delineation
Granite blocks are marked on the ground by distinct parallel lines. A jack hammer is
used to drill 0.5m holes along the lines for a permanent demarcation of the blocks.
Currently the blocks are marked strip by strip moving down and also away from
recently mined out areas.
1.4.3.2. Mining
The mining process follows on the demarcated blocks. A Circular saw is placed on
tracks along the marked lines, it cuts vertically following the marked lines moving along
a track that is rigged on-site as the cutting progresses. The horizontal cutting of the
block is done by a rubberised diamond wire that is powered by a generator. The wire
cuts at the base of the block in a horizontal manner. The cut out block is then uplifted
by a forklift to the sorting area. The mine has a capacity to produce 100 granite blocks
per month with each block weighing and average of 15 tonnes.
1.4.3.3. Product Sorting by Quality
The blocks are then sorted out by quality; this is done merely by visual inspection of
the colour of the blocks by trained and experienced personnel. The quality sorting is
dependent on the market demand of the time which is driven by a desire for a specific
colour. The block that do not meet the market colour requirements are put aside in
anticipation of a future demand for that colour. All the blocks are marked using an in-
house numbering system that allows for block inventory and tracking of the blocks
through the processing chain.
1.4.3.4. Processing
The mine blocks are processed to various specifications as dictated by the clients’
needs:
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• Processing – Semi processed slabs (Material strips of various lengths and
thicknesses) for supply to local processors for further value addition;
• Project specific products that are cut to size according to requirements and;
• Finished products – Tiles and cladding
1.4.3.5. Product handling and despatch
The blocks that do not meet current market demands are stockpiled onsite and the
blocks that are meant for the market are processed as required and transported to the
loading bay where they are loaded onto trucks before transporting to destination
markets.
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2. METHODOLOGY
2.1. The Consultancy Team / Practitioner’s Details
Outrun Consultants CC is a privately owned consultancy company doing various
projects in Southern Africa Development Community (SADC) countries. Our core
services are:
• Environmental Impact Assessment
• Environmental Investigations
• Research and Training
• Feasibility Studies
• Agronomy
• Monitoring and Evaluation
Outrun draws its experts from regional and international universities such as University
of Zimbabwe (Zimbabwe), National University of Science and Technology (Zimbabwe,
Namibia), University of Namibia (Namibia) and other specialized consulting
companies and / or individuals. Outrun declares that we have no interests in this
project and are independent and acted as such during the EIA process as required by
the EIA regulations. The key team members who carried out this EIA are presented in
Table 1 below.
Table 1. Team of experts and their areas of responsibility in the EIA process.
ORGANIZATION AREA OF
RESPONSIBILITY /
FIELD OF EXPERTISE
TEAM MEMBERS
OUTRUN Project management
EIA coordination
Josiah T. Mukutiri
OUTRUN EIA process Josiah T. Mukutiri
Savanna Marble CC Development of the
business concept
Mark Hoffmann
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OUTRUN Literature review / Desk
study
Emmerencia Montzinger
OUTRUN Legislation & Policy
Review
Emmerencia Montzinger
OUTRUN Biodiversity Study Josiah T. Mukutiri,
Emmerencia Montzinger
OUTRUN Development of
Environmental
Management Plan (EMP)
Josiah T. Mukutiri
OUTRUN Public Consultation and
Facilitation
Phillip Hooks, Josiah T.
Mukutiri, and Mark
Hoffmann
N.B. Abridged CVs of key Team Members are annexed at end of the report.
2.2. Public Consultation and Stakeholder Engagement
2.2.1. Purpose of the Public Participation Process
The purpose of the public participation process is to:
• Provide information to IAPs and other stakeholders about the project
background, proposed site, project concept and predicted potential impacts.
• Establish the public’s interests, concerns and expectations regarding the
proposed project.
• Obtain input from IAPs, the public and other key stakeholders.
2.2.2. Identification of Key Stakeholders
The following key stakeholders were identified for consultation purposes:
• Namibia Botanical Gardens CC
• Goanikontes Oasis Rest Camp
• Ministry of Mines & Energy
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• Ministry of Environment & Tourism
• Civil Society Organisation
• Other members with interest or affected by the project.
2.2.3. Initiation of the Scoping Process
The scoping process was initiated by publicising it through the local media in which
we published legal notices informing readers of the EIA. The legal notices announced
the beginning of the scoping process and invited stakeholders and members of the
public to register as IAP as well as participation in public meetings. The legal notice
was also made into A3 posters displayed in public and popular gathering places such
as the school, shops and along the highway next to the site etc. See Annexure 2 for
the advertisements and poster. A Background Information Document (BID), see
attached copy in Annexure 3, was forwarded to I&APs who responded. The BID
contained the relevant information about the proposed project and promoted
stakeholders and public participation in the scoping process. A comment sheet was
provided at the end of the BID report inviting comments on issues of interest and
importance to the stakeholders.
2.2.4. Public Consultation
A meeting was held at Swakopmund High School Hall on the of….and . The meeting
was designed to give the stakeholders details regarding the project and the EIA
process being followed. Phillip Hooks facilitated the meeting.
The members present were given the chance to say their interests or concerns
regarding the project. Communication was interactive and two languages used
(English and Afrikaans). All the factors identified during the environmental scoping
phase were studied during the EIA and used to generate the draft Environmental
Scoping and Management Plan. The draft report was publicised and shared with
registered I&APs. All the issues and concerns raised are presented below. Records of
all consultations are also attached as annexures for this report.
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2.2.5. Issues and Concerns Raised and Responses
Records of all registered IAPs and stakeholders and the issues, concerns and
comments on the proposed project were compiled and are attached as annexure in
this report. Below is a summary of issues raised during the meeting and interviews:
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Table 2: Issues and / or concerns raised during consultations by category.
Subject Issues and / or Concerns raised
EIA PROCESS • Attendance at the public meeting was very poor but issues raised were genuine and
were considered in shaping the study in order to keep environmental damage under
control, (attendance register annexed).
CULTURE AND
HERITAGE
• Destruction of the old Germany railway line passing through the area.
BIODIVERSITY • Extensive flora is expected to occur in the targeted area, especially the dolerite ridge.
POTENTIAL NEGATIVE
IMPACTS
• Air pollution from dust generated by various activities ranging from mining blocks,
cutting and polishing blocks, vehicle movements on gravel
POSITIVE IMPACTS • Reduction and partial elimination of granite waste.
• Employment creation and thus improve the well-being of the local people. Employment
preference will be afforded to previously disadvantaged Namibians.
• Supply of raw materials and processed materials to downstream industry for economic
growth. Such industries include but are not limited to the construction industries etc.
• A contribution to the balance of payments through exports.
• Local Value addition allowing for the processing of blocks (waste) that cannot be sold
as complete blocks.
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2.2.6. Review Draft Scoping and Environmental Management Plan
The draft reports availability was published din the local media inviting reviewing and
commenting.
2.2.7. Public Participation: Way Forward
The comments on the reports were incorporated into the final Scoping Report and the
final Environmental Report respectively before submission to the MET: DEA. MET:
DEA’s decision regarding the EIA report will be made available to all IAPs.
2.2.8. Historical Stakeholder Engagement
Organisation Activity / Issue Status Quo
Erongo Red Connection to the grid On going relationship for
future connection although
the Proponent uses diesel
powered generators at the
moment
NAMWATER Connection to the
water pipeline
Completed
MET Environmental contract Environmental Pro-forma
Contract submitted to MET
MET EMA Act 2007,
Compliance
Environmental Scoping &
Management Plan will be
submitted to MET to renew
the existing Mining License.
MET Mad Marx movie
making
Joint effort with Swakop
Uranium to concertize MET
on the impact resulting from
the movie making activities.
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2.2.9. Stakeholder Engagement during the EIA Study
Only two key stakeholders were engaged and their comments incorporated:
• Namibia Botanical Gardens CC represented by Mr Frank Lohnert.
• Ministry of Environment & Tourism represented by Parks Warden - Mr Siegfried
Gawiseb.
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3. DESCRIPTION OF THE ENVIRONMENT
3.1. Project Location
The project site is located in the Arandis area running adjacent and parallel to the B2
Highway with the D1991 gravel connecting from the B2 and cutting through the SW
side of the site.
Figure 4: The location of the project site (ML 152) in relation to existing infrastructure, protected areas and other mines. Source: Map by Outrun Consultants CC.
3.2. Climate
Climate refers to the meteorological or weather elements measured in a particular
region or area over a long period of time of 20 to 30 years. The climate of an area is
generally affected by the latitude, terrain, altitude and distance or proximity to water
bodies. Climatic knowledge about an area is important because it shapes human
activities of the people inhabiting the area. This is because climatic factors such as
rainfall and temperature affects geomorphology, weathering and soil formation,
transport of materials, flora and fauna and the use of natural resources, (Bertram and
Broman, 1999). Erongo region climate is predominantly arid and characterized by:
• Very low rainfall, averaging about 300mm in the north eastern parts of the
region and less than 15mm to the coast;
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• Very high variability in total annual rainfall;
• A steep rainfall gradient from the coast towards the eastern parts of the region
(wetter / receives more rainfall).
3.3. Wind Field
The wind regimes are characterized by southerly and south westerly winds during
summer, and the north easterly winds during winter. The data was obtained from the
weather station: Coastal Met (Station ID: E7631) comprised of the following
specifications:
Table 3: Coastal Met weather station specifications.
Parameter Sensor Type Height
Temperature/Humidity Campbell CS 215 2 m
Wind Young Model 05103 Wind Monitor 9 m
Radiation Campbell NR-Lite 2 m
Ground Temperature and Moisture Campbell CS 655 n.a.
Barometric Pressure Setra 100 n.a.
Leaf Wetness Campbell CS 237 0.1 m
Rain Young Model 52202 Tipping Bucket Rain Gauge 1.5 m
Data Logger Campbell CR1000 n.a.
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Figure 5: Wind directions and speeds from the nearest weather station in Erongo Region.
3.4. Topography
The topography rises from the sea level in the western coast line of the country towards
the east and north eastern parts of the region. The study area lies in the Namib Desert
which is characterized by open sandy plains and rising mountains and dry river beds
heavily silted with sand. Soils become coarser into gravel in the foot of the hills. The
variability in plant substrates in chemical composition and texture dictates the
occurrence of differing plants in these areas.
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Figure 6: The Rossing Mountain view to the North West of ML 152.
Figure 7: The Eastern entrance to ML 152 using D1992.
Figure 8: Goanekontes road, South West view from ML 152.
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3.5. Soils and geology
The Swakop Group in the southern part of the study area (Central Zone) is subdivided
into the Rössing, Chuos, Arandis, Karibib and Kuiseb Formations. The marble-
dominated Karibib Formation is widely distributed in the study area and underlies large
parts of the flat, poorly exposed coastal region.
Figure 9: An eroded dolerite ridge passing through the study area.
3.6. Radiation (safety issues)
Ionising radiation on the other hand is associated with high-energy x-rays and gamma
rays, and the various types of radiation emitted by radioactive elements. Ionising
radiation has sufficient energy to strip electrons from atoms, resulting in electrically
charged particles which are called ions. It has long been recognised that large doses
of ionising radiation can damage human cells and tissue: free-roaming ions created at
the cellular level are highly reactive and may trigger or participate in chemical
reactions, some of which may bring about molecular bonds which are harmful to the
cell. For example, chemical reactions that are activated by ions generated by ionising
radiation can alter the chemical balance of natural processes, which may give rise to
undesirable chemical products and thereby negatively affect living cells. In addition,
ionising radiation can change the make-up of cells by changing the genetic building
blocks of cells and in this way bring about cancerous cell multiplication and growth.
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Not all atomic nuclei found in nature are stable. When unstable nuclei undergo a
process of nuclear rearrangement they emit particles and radiation. The process
whereby radiation is emitted from atomic nuclei as a result of nuclear instability is
called radioactivity. The most common types of sub-atomic particles and radiation
emitted during radioactive decays of atomic nuclei are alpha particles, beta particles
and gamma radiation. Radioactivity is a natural phenomenon, and elements such as
uranium, thorium and potassium are naturally occurring radioactive substances.
Radioactivity and the effects of ionising radiation on living tissue have been studied
for many decades. Today it is well recognised that an exposure to large doses of
ionising radiation may have potentially damaging effects on humans. Natural sources
of ionising radiation include radiation of extra-terrestrial origin, i.e. cosmic radiation,
and radiation emitted by soils, rocks and groundwater, i.e. terrestrial radiation, as well
as radiation from radioactive dust and radioactive gases such as radon and thoron.
Humans are continuously exposed to ionising radiation of natural and man-made
origin. Such exposure is location- and time-dependent, and any potential effects
depend on the exposure dose received by an individual person. To quantify the total
exposure to ionising radiation that members of the public are exposed to one has to
determine the magnitude of the exposure to the prevailing natural background
radiation and add to it the incremental contribution of additional sources, such as a
uranium mine.
3.7. Flora and Fauna
Plant communities in the study area are influenced by numerous factors: soil type,
climate, topography etc. Main habitats visible on ML512 are gravel plains, flood or
drainage plains and watershed dolerites. One ephemeral river drains through the study
area.
One ridge was identified and it cuts through at a SW to NE orientation with visible
weathered dolerite boulders. Plants of conservation importance are the aloes (Aloe
sperrfolia and Aloe namibensis), stone plants (Lithops gracilidelimeata and Lithops
ruschiorum). The Trichocaulou peclicellatum is also common in these grounds. It is
not surprising to find lichens on the weathered dolerite ridges being the pioneer
colonizers in newly available habitats. These are an ecologically important group of
species: food for the beetles and springboks, protection to insects and mites though
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they are very sensitive to damage and climatic changes. Over and above they offer
very unique aesthetics.
Table 4: Some of the plant species observed in the study site.
Image Name
Caloplaca spp Lichens
Aloe asiperifolia
Zygophyllum stapffii
Zygophyllum sp.
33
Pencil bush
Acacia sp.
Euphorbia gregaria
Zygophyllum sp.
34
Table 5: Some of the plant species expected to occur in the study area and their conservation status.
Scientific name Common name Status
Heliotropium curassavicum Seaside heliotrope DD
Aristida adscensionis Sixweeks threeawn DD
Cyperus marginatus Desert sedge DD
Sarcocornia natalensis No known common name DD
Zygophyllum simplex Brakkies DD
Acacia reficiens Red bark acacia / Red thorn DD
Citrullus ecirrhosus Desert gourd / Wild melon DD
Orthanthera albida Sandmelketou DD
Blepharis grossa Little desert thistle NE
Stipagrostis obtusa growwe twa LC
Stipagrotis ciliata Tall bushman’s grass DD
Adenolobus pechuellii Namib neat’s foot DD
Pechuel – Loeschea leubnitziae
Wild sage DD
Hermannia amabilis
Dream catcher DD
Tribulus zeyheri Large – flowered devil thorns /
Calthrop
DD
Heliotropium tubulosum Erysipela plant DD
Acacia erioloba Camelthorn Protected (F)
Acacia albida , White thorn Protected (F)
Faidherbia albida Apple ring acacia Protected (F)
Acanthosicyos horrida Nara bush DD
Commiphora saxicola Rock cockwood E
Commiphora virgata Slender cockwood E
Sarcocaulon marlothii Bushman’s candle DD
Schmidtia kalihariensis Kalahari sour grass LC
Aloe asperifolia E, P, LC, C2
Ipomea adenioides Morning Glory DD
Parkinsonia Africana Green hair thorn DD
Ophioglussum polyphyllum Large adderstongue DD
3.8. Culture and Heritage
Cultural heritage refers to the legacy of phsical artifacts and intangible attributes of the
Namibian society that are inherited from past generations, maintained in the present
and bestowed for the benefit of future generations. Cultural heritage includes tangible
culture (such as buildings, monuments, landscapes, books, works of art, and artifacts),
35
intangible culture (such as folklore, traditions, language, and knowledge), and natural
heritage (including culturally-significant landscapes, and biodiversity).
Cultural heritage is often unique and irreplaceable, which places the responsibility of
preservation on the current generation. Smaller objects such as artworks and other
cultural masterpieces are collected in museums and art galleries. One such piece of
history that is of cultural and heritage importance is the old railway line that cuts
through parts of the mining licence area.
Figure 10: Remains of the 100 year old "staats lyn" or railway line route and mound that runs through ML 152. Source: Own photographs.
3.9. Existing Mine Infrastructure and Operational Activities as already
in Existence
There is an existing mine pit from which granite blocks were extracted over the years.
In addition there is a granite cutting and polishing plant mounted on concrete
foundations and shaded under a roof constructed from corrugated iron sheets fixed on
iron beams. Concrete floors serve as storage, value addition and general maintenance
areas. Water and electricity are available onsite as detailed under sections 3.10 and
3.11 below.
36
3.10. Water
Water is tapped from the main pipeline supplying the Uranium mines in the area. Daily
water consumption during full production would be ten cubic meters per day. However,
most of this water is recycled, and up to 80 % of the water used for cutting can be
retained, so that water consumption is reduced significantly. Water is mainly used for
the cutting process with diamond cutting blades and diamond wires. It is also used to
completely suppress any dust development during the cutting process. Water loss is
predominantly through evaporation, no infiltration is expected since the pond was cut
out from the solid granite formation.
Figure 11: Stakeholders infrastructure, NAMWATER pipeline running through ML 152 and NAMPOWER substation adjacent to the site.
3.11. Energy
All the electrical equipment at the mine is powered by diesel generated electricity.
Diesel is stored on-site using an above ground storage tank from which other mobile
equipment also fuels. Should there be need to get electricity connection to the national
grid in the future then the necessary procedures will have to be followed. It is an option
that cannot be ruled out if there is need and the powerline is within reach. The
Proponent does not plan a connection to the grid at the moment.
3.11.1. Potential Challenge
37
The EIA study will investigate the suitability of the fuel storage site in relation to other
mining operations taking into consideration the environment, occupational health and
safety. Spills and leaks of hydrocarbons impact negatively on the environment.
3.12. Accommodation and toilet facilities
Mine and processing plant workers will be accommodated in Arandis and
Swakopmund. Accommodation facilities in the form of movable containers on the mine
site are solely for accommodating security personnel and site managers if required.
The following facilities will be erected on the mine site for the well-being of the
employees:
a. Staff canteen: The staff canteen will comprise of a pantry for storing food
stocks, a kitchen and seating hall.
b. Ablutions and showers: Dixy toilets catering for twenty people will be used and
serviced by an external contractor. Showers will be installed to serve the same
number of people but the grey water will be used to feed a sypon growing
melons and other vegetables.
3.13. Current Land use, Stakeholder infrastructure / No go zones and
the Unimpacted areas in ML 152.
As can be shown on the map below: areas containing NAMWATER and NAMPOWER
infrastructure will not be disturbed in any way during mining and / or associated
activities. In addition the dolerite ridges are weathered and for that reason are not
suitable mining target and as a result will not be affected.
38
Figure 12: Mining target area, long -term future mining reserve and areas and no-go areas.
39
4. ANALYSIS OF PROJECT ALTERNATIVES
4.1. The ‘No – Go’ Option
The “no-go” option means maintaining the status quo were neither the mining licence
is renewed nor upgrading of the cutting and polishing facility takes place. This would
mean decommissioning the mine and stopping operations. Such a situation is not
favoured as it means no development and lack of employment opportunities for the
local people. All the blocks that were rendered waste would remain as an eyesore to
passers-by. As a result this is not in favour of the environment. This option was also
not studied more since the mine was commissioned and has been kept active in the
market during the past 9 years with a strong focus on developing the market interest
for future processed goods.
4.2. Alternative Sites
No alternative mining sites were considered in this study except for the current site
where ML152 was issued and contains the existing facilities.
4.3. Strategic Alternatives
4.3.1. Road
The proposed site is very accessible through a gravel road branching off from the B2
Highway. The site is accessible using this existing road and as a result no new access
road will be built.
4.3.2. Water
The site is connected to the main pipeline supplying water to the Uranium Mines.
4.3.3. Electricity
The Proponent uses diesel generators, but there is an electricity sub-station close-by
that brings electricity to the Uranium mines. In the event that the Proponent decides
to use this source to complement the generators in-future, then relevant permits
should be obtained from MME as well as from NAMPOWER.
40
5. LEGAL AND POLICY REVIEW Describes Legal and Policy Instruments Regulating the Proposed Project Activities.
41
LEGAL / POLICY INSTRUMENT INTERPRETATION
Constitution of the Republic of Namibia, 1990.
The Constitution is the supreme law in Namibia, providing for the establishment of the main
organs of state as well as guaranteeing various fundamental rights and freedoms. Provisions
relating to the environment are contained in Chapter 11, article 95, which is entitled “promotion
of the Welfare of the People”. This article states that the Republic of Namibia shall – “actively
promote and maintain the welfare of the people by adopting, inter alia, policies aimed at …
maintenance of ecosystems, essential ecological processes and biological diversity of Namibia
and utilisation of living natural resources on a sustainable basis for all Namibians, both present
and future; in particular, the Government shall provide measures against the dumping or recycling
of foreign nuclear waste on Namibian territory.”
Minerals (Prospecting and Mining) Act, 1992.
The Minerals Act governs minerals prospecting and mining. The Act provides for the
reconnaissance, prospecting and mining for, and disposal of, and the exercise of control over
minerals in Namibia; and to provide for matters incidental thereto. A new Minerals Bills is
currently under preparation.
Minerals Policy 2004. The Minerals Policy is developed to ensure long-term sustainable growth in the mining sector of
Namibia. One of the objectives of the Policy, relevant to EIAs is to ensure compliance with
national environmental policy and other relevant policies to develop a sustainable mining
industry.
Environmental Management Act (2007)
The purpose of the Act is to give effect to Article 95(l) and 91(c) of the Namibian Constitution by
establishing general principles for the management of the environment and natural resources;
to promote the co-ordinated and integrated management of the environment; to give statutory
42
effect to Namibia’s Environmental Assessment Policy; to enable the Minister of Environment
and Tourism to give effect to Namibia’s obligations under international conventions. In terms of
the legislation it will be possible to exercise control over certain listed development activities
and activities within defined sensitive areas. The listed activities in sensitive areas require an
Environmental Assessment to be completed before a decision to permit development can be
taken. The legislation describes the circumstances requiring Environmental Assessments.
Hazardous Substance Ordinance 14 of 1974.
Provisions for hazardous waste are amended in this act as it provides “for the control of
substances which may cause injury or ill-health to or death of human beings by reason of their
toxic, corrosive, irritant, strongly sensitizing or flammable nature or the generation of pressure
thereby in certain circumstances; to provide for the prohibition and control of the importation,
sale, use, operation, application, modification, disposal or dumping of such substance; and to
provide for matters connected therewith”
Atmospheric Pollution Prevention Ordinance
11 of 1976.
This regulation sets out principles for the prevention of the pollution of the atmosphere and for
matters incidental thereto. Preventative measures for dust atmospheric pollution are outlined in
Part IV and Part V outlines provisions for Atmospheric pollution by gases emitted by vehicles.
The Nature Conservation Ordinance,
Ordinance 4 of 1975.
This Ordinance covers game parks and nature reserves, the hunting and protection of wild
animals (including game birds), problem animals, fish and the protection of indigenous plants.
Parks and Wildlife Management Bill of 2006.
The act enacts the legal framework, to provide for and promote the maintenance of ecosystems,
essential ecological processes and the biological diversity of Namibia, and the utilisation of living
natural resources on a sustainable basis for the benefit of Namibians, both present and future,
43
and to promote harmonious and mutually beneficial co-existence of humans with wildlife, to give
effect to Namibian’s obligations under relevant international legal instruments including the
Convention of Biological Diversity. Provisions with regard to declaration of protected areas, entry
into and residence are made in chapter V. Regulations on the protection of species of wildlife and
plants are provided in Chapter VII of the Act.
The Labour Act, 2007 (Act No. 11 of 2007)
The labour Act gives effect to the constitutional commitment of Article 95 (11), to promote and
maintain the welfare of the people. This Act is aimed at establishing a comprehensive labour
law for all employees; to entrench fundamental labour rights and protections; to regulate basic
terms and conditions of employment; to ensure the health, safety and welfare of employees
under which provisions are made in chapter 4. Chapter 5 of the act improvises on the protection
of employees from unfair labour practice.
Petroleum (Exploration and Production) Act
1991 (Act 2 of 1991)
This Act provides provisions for possible petroleum exploration as to provide for the
reconnaissance, exploration, production and disposal of, and the exercise of control over storage
of refined petroleum products; and to provide for matters incidental thereto.
Pollution Control and Waste Management Bill
The purpose of this Bill is to regulate and prevent discharge of pollutants to the air, water and
land in Namibia, and to enable the country to fulfil its international obligations in the regard. The
draft Bill forbids any person from discharging or disposing of pollutants into any water or water
course without a water pollution licence (aside from the discharge of domestic waste from a
private dwelling or the discharge of pollutants or waste to a sewer or sewage treatment works).
44
5.1. Summary of Regulatory Authorities and Permits Applicable to the
Proposed Project
The environmental regulatory authorities responsible for environmental protection and
management in relation to marble mining including their role in regulating
environmental protection are presented below. The table shows an extract from the
legal instruments of the regulating authorities with respect to relevant permits and / or
licences required for the renewal of the mining licence and the upgrading of the cutting
and polishing facility.
Table 6: Applicable Legal Instruments, Permitting Authority and Current Status /
Legal Instrument Authority Status
Ministry of Mines &
Energy (MME)
To apply for renewal of Mining
Licence when the
Environmental Clearance
Certificate has been issued.
Forestry Act, 12 of 2001. Ministry of Agriculture,
Water & Forestry
(MAWF).
Removal, disturbance of
Protected plants. Not
anticipated since the targeted
areas have no plant cover.
Petroleum (Exploration &
Production) Act 1991 (Act
2 of 1991).
Ministry of Mines and
Energy (MME).
Discarding or
disposing of used oil.
To Apply when
Required
Regulation 16 (2001)
Petroleum Regulations.
Operating a petroleum
consumer installation.
To apply when EIA clearance
certificate is issued.
45
6. IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES
6.1. Hierarchy of hazards control measures
Hazard controls should be applied in this order:
a. Elimination— remove the hazard, or the need to perform the hazardous activity;
b. Substitution— substitute with a safer alternative;
c. Separation/isolation— isolate or separate people from the hazard by use of
barriers, distance or time;
d. Engineering controls— redesign or modify tools or equipment and / or process
flow;.
e. Administrative controls— se training, rules, procedures to reduce the risk of the
hazard and;
f. Personal protective equipment— provide fit-for-purpose protective equipment.
More than one control may need to be used to adequately control the hazard. Controls
used must be maintained to ensure they continue to remain effective.
6.1.1. Habitat Loss
If the entire current project area is developed, combined with land preparation
destructive methods there would be a very high loss, which virtually guarantees some
extinction.
Proposed Mitigation Measures
However, if plans are built to prevent substrate / habitat destruction, the direct habitat
loss will be greatly reduced. Destruction is avoidable since the targeted mining area
and the extension of the processing area is on a previously disturbed area, that
comprises mainly of barren solid stone outcrops.. This impact is rated as High
negative, which can be mitigated to low negative. Importantly the mining targets intact
dimension stone and the weathered dolerite which are the primary lichen habitats are
not suitable for mining, see fig. 12, above.
46
6.1.2. Visual Impacts
Although the mining facility is located on a fairly flat land it is not intrusively visible from
the B 2 and Goanekontes road due to distance.
Proposed Mitigation Measures
The colour of the cut stone blends well with the local environment to reduce contrast.
Over time the processing of all blocks that are not exported as well as waste blocks
will eliminate the visual impact permanently.
6.1.3. Solid Waste
Major composition of solid waste generated from the mining process is blocks that fail
to meet the quality due to inconsistent strength arising from cracks and inconsistent
colour etc.
Proposed Mitigation Measures
Process all the blocks that could not sold during the previous mining operations and
was rendered waste due to quality inconsistencies.
Perform test cuts before cutting out entire blocks in order to avoid mining unusable
rock material.
6.1.4. Occupational Health – Exposure to Dust
Proposed Mitigation Measures
6.1.4.1. Elimination
• Adopt production processes that generate less dust (any wet method is
likely to generate less dust than a dry one).
• Treat the dust at its point of generation, as this is more effective than
capturing airborne dust.
• Treat the dust on its transmission path using dust suppression techniques
(e.g. water sprays, chemical additives, local exhaust ventilation (LEV),
vacuum).
47
6.1.4.2. Engineering controls
• Choose appropriate equipment (e.g. correct cutting blades for ore body).
• Replace and maintain equipment regularly to ensure cutting blades and
picks remain sharp.
• Suppress dust by using water sprays on work area, roads, and when using
machinery and cutting equipment. Use additive in water sprays to suppress
dust and adjust the droplet size of the spray according to dust particle size.
• Use enclosures (e.g. covered conveyors, enclosed cabs on vehicles, plant
and equipment).
• Rehabilitate exposed mine land to reduce environmental dust load.
• Enclose cabins where possible, ensure seals are well-maintained, provide
inlet air filtration for respirable particles, and use positive pressure air inside
cabs to prevent dust penetration.
• Cover product conveyors.
• Cover loads for road haulage where practicable.
6.1.4.3. Administrative controls
• Ensure regular maintenance and housekeeping of vehicles and mine
workings.
• Position personnel away from dust-generating activity by establishing
exclusion zones.
• Maintain unmade roads and ensure ground conditions throughout sites are
appropriate to the machines using them.
• Provide training and information to workers on the hazards, risks and
controls of dusty tasks, as well as supervision for workers.
• Limit the duration and magnitude of exposure to dust (e.g. worker rotation,
job task changes).
• Ensure work schedules have adequate rest periods to limit exposure.
• Change the location of dumping operations or modify blasting programs to
suit weather conditions.
• Provide adequate signage.
48
6.1.4.4. Personal protective equipment (PPE)
• Ensure higher-order controls are adopted before resorting to PPE.
• Select the most appropriate respiratory protection for the task (e.g. full face,
half face, powered air, purifying).
• Ensure training, comfort and fit testing is provided before use. Respirators
should not be shared.
• Maintain and store respiratory protective equipment properly.
6.1.5. Occupational Health and Safety – Incidents, Accidents / Injuries / Loss of Life
Proposed Mitigation Measures
There are multiple factors that influence the effectiveness of your work health and
safety and injury management systems, including:
• your employees;
• your organisation's safety culture and safety management systems;
• the type of hazards in your workplace;
• How your organisation manages risks.
6.1.5.1. Consultation with employees and other participatory action methods
Consultation between employer and workers is a legal requirement under the Labour
Act (2012), and an essential part of managing health and safety risks. A safe
workplace is more easily achieved when everyone involved communicates with each
other to identify hazards and risks, talks about health and safety concerns and works
together to find solutions. By enabling workers to share their knowledge and
experience, better informed decisions can be made about work safety.
Other benefits from worker health and safety involvement / consultations are:
• greater awareness and commitment – workers who have been actively involved
in how health and safety decisions are made understand the decisions better.
• positive relationships – understanding the views of others leads to greater
cooperation and trust.
6.1.5.2. Safety culture
49
Safety culture embodies the value placed on safety and the extent to which people
take personal responsibility for safety in an organisation. A positive safety culture
means a safer, healthier and more productive workplace. Like any aspect of an
effective organisation, growing a positive safety culture requires a commitment of time,
resources and focused actions from the Proponents / Management and the employees
too. The Proponent should champion the importance and in-still rich value in
workplace occupational health and safety.
50
7. ENVIRONMENTAL MANAGEMENT PLAN
The Environmental Management Plan (EMP) presents a summary of management initiatives
that will be required to ensure the identified negative and positive impacts are mitigated and
maximized respectively. However, this EMP will be focussing on negative impacts presented
earlier. Indicators are suggested for each identified impact, and this is followed by the assigned
responsible implementing agent and the monitoring frequency. Where there are budgetary
implications besides the common project costs, they will be indicated specifically.
The chapter also lays down the plan for monitoring the impacts during project life cycle stages.
The EMP is also aimed at ensuring continued compliance even after the duration of project.
In some cases the implementing agencies would need the assistance of the consultant to
adequately formulate local area and more specific implementation strategies. It is important
that the proponent implements this EMP with reference to the impact analysis and evaluation
chapters which have more detail on the impacts and the suggested mitigation measures. The
EMP summarized the impacts and configured them into objectives that can be pursued
sustainably.
51
Table 7: Environmental Management Plan
ACTIVITY ENVIRONMENTAL
ASPECT
IDENTIFIED
IMPACT
POSITIVE
\NEGATIVE
SOURCE MITIGATION INDICATOR(S) IMPLEMENTING
AGENT
RESPONSIBLE
AGENT
MONITORING
AGENT
MONITORING
FREQUENCY
DESIGN AND PLANNING PHASE
Inadequate
mining
design
Noise Noise pollution -ve Mining
operation /
running
equipment
Incorporating low-
noise equipment
in the mine
design.
Maintaining trees
around the plant
to serve as
barriers.
Acoustic levels
measured in
decibels
Design Engineer Savanna Marble
CC
DEA
Ministry of
Labour
At the design
stage and
commissioning
phase.
Occupational hazards Injuries / loss
of life
-ve Plant
operation /
running
equipment.
Rock falls
during
mining
Carrying standard
hazard
assessment and
operation
procedures at the
commissioning
stage.
Occupational
health and safety
training of the
operators.
Employ qualified
Miner with the
ability to use
Uncovered moving
parts, lack of
safety or warning
signs.
Dangerous
unsupported rocks
and walls
Design Engineer Savanna Marble
CC
Ministry of
Labour and
Social Welfare
Ministry of Mines
& Energy
At commissioning
stage and
thereafter
Monthly
52
ACTIVITY ENVIRONMENTAL
ASPECT
IDENTIFIED
IMPACT
POSITIVE
\NEGATIVE
SOURCE MITIGATION INDICATOR(S) IMPLEMENTING
AGENT
RESPONSIBLE
AGENT
MONITORING
AGENT
MONITORING
FREQUENCY
support
effectively.
ACTIVITY ENVIRONMENTAL
ASPECT
IDENTIFIED
IMPACT
POSITIVE
\NEGATIVE
SOURCE MITIGATION INDICATOR(S) IMPLEMENTING
AGENT
RESPONSIBLE
AGENT
MONITORING
AGENT
MONITORING FREQUENCY
DESIGN AND PLANNING PHASE
Inadequate mining design
Noise Noise
pollution
-ve Mining
operation /
running
equipment
Incorporating
low-noise
equipment in
the mine
design.
Maintaining
trees around
the plant to
serve as
barriers.
Acoustic levels
measured in
decibels
Design Engineer Savanna
Marble CC
DEA
Ministry of
Labour
At the design stage and
commissioning phase.
Occupational
hazards
Injuries /
loss of life
-ve Plant
operation /
running
equipment.
Carrying
standard
hazard
assessment
and operation
procedures at
the
Uncovered
moving parts,
lack of safety
or warning
signs.
Design Engineer Savanna
Marble CC
Ministry of
Labour and
Social Welfare
Ministry of
Mines &
Energy
At commissioning stage and
thereafter Monthly
53
ACTIVITY ENVIRONMENTAL
ASPECT
IDENTIFIED
IMPACT
POSITIVE
\NEGATIVE
SOURCE MITIGATION INDICATOR(S) IMPLEMENTING
AGENT
RESPONSIBLE
AGENT
MONITORING
AGENT
MONITORING FREQUENCY
Rock falls
during
mining
commissioning
stage.
Occupational
health and
safety training
of the
operators.
Employ
qualified Miner
with the ability
to use support
effectively.
Dangerous
unsupported
rocks and walls
ACTIVITY ENVIRONMENTAL
ASPECT
IMPACT POSITIVE
\NEGATIV
E
SOURCE MITIGATION INDICATOR IMPLEMENTIN
G AGENT
RESPONSIBLE
AGENT
MONITORING
AGENT
MONITORING FREQUENCY
OPERATIONAL PHASE (Mining)
Dimension stone cutting Safety hazards Accidents -ve Rock falls Put supports and rocks
should be well
balanced on the
ground or well secured
on the trailer or on the
fork lift.
No. of block fall
incidents and
accidents
Mine Manager
Occupational
Health & Safety
Officer
Savanna
Marble CC
Ministry of
Labour
Daily
54
ACTIVITY ENVIRONMENTAL
ASPECT
IMPACT POSITIVE
\NEGATIV
E
SOURCE MITIGATION INDICATOR IMPLEMENTIN
G AGENT
RESPONSIBLE
AGENT
MONITORING
AGENT
MONITORING FREQUENCY
Mining operation Occupational
health
Diseases such as
diarrhoea
-ve Poor and
inadequate
sanitation
facilities
Build on-site sanitation
facilities.
Provide on-site clean
drinking water and
promote hygienic
practices.
Number of
people falling
sick due to
unhygienic
practices
Mine Manager
Occupational
Health & Safety
Savanna
Marble CC
Ministry of
Labour
Ministry of
Health &
Social Services
Quarterly
Blocks conveyance Safety hazards Accidents -ve Rock falls from
fork lift or
truck
Loads should be well
secured on the moving
fork lift or truck.
Rock fall
accidents
Mine Manager
Occupational
Health & Safety
Officer
Savanna
Marble CC
Ministry of
Labour
Daily when the plant is in
operation
Mining operation Health and safety
hazards
Occupational
accidents.
-ve Machinery and
moving
equipment;
Workers should be
provided with personal
protective equipment
and be trained on
safety and health
issues. Warning signs
to be posted to
indicate dangerous
areas and risks
associated.
Number of
incidences and
accidents
Mine Manager
Occupational
Health & Safety
Officer
Savanna
Marble CC
Ministry of
Labour
Every six months
Mining operation Noise pollution
(See detailed
analysis below)
Noise is a
nuisance and
long exposure
times can cause
hearing
impairment.
-ve Plant
operations
Workers should be
provided with personal
protective equipment
and be trained on safety
and health issues.
Warning signs to be
posted to indicate
dangerous areas and
risks associated.
Noise exposure
measurement in
decibels
Mine Manager
Occupational
Health & Safety
Officer
Savanna
Marble CC
Ministry of
Labour
Daily during crusher operation
55
ACTIVITY ENVIRONMENTAL
ASPECT
IMPACT POSITIVE
\NEGATIV
E
SOURCE MITIGATION INDICATOR IMPLEMENTIN
G AGENT
RESPONSIBLE
AGENT
MONITORING
AGENT
MONITORING FREQUENCY
Mining operation Dust emissions Irritates and
causes lung
diseases
-ve Dust
generated
from the
cutting of
granite
blocks. Dust
generated
from the
movement of
trucks and
fork lifts on
the mine site
Provide workers with
appropriate protective
clothing and also use
water to suppress dust.
Dust deposition Mine Manager
Occupational
Health & Safety
Officer
Savanna
Marble CC
Ministry of
Labour
Hourly during mining
operations.
Mining operation Air pollution Irritates and
causes lung
diseases over
long exposure
periods
-ve Vehicle and
machinery
exhaust
fumes
Use efficient vehicles
and machinery and
ensure they are well
serviced and
maintained
Carbon
monoxide and
SO2
Mine Manager
Occupational
Health & Safety
Officer
Savanna
Marble CC
Ministry of
Labour
Quarterly
Mining operation Accidents Injuries to
domestic
animals and
passers by
-ve Livestock
being
trapped in
mine water
ponds.
Fence off the mining
area to restrict
entrance.
Number of
accidents
Mine Manager
Occupational
Health & Safety
Officer
Savanna
Marble CC
Ministry of
Labour
Quarterly
ENVIRONMENTAL ASPECT IMPACT POSITIVE
\NEGATIVE
SOURCE MITIGATION INDICATOR IMPLEMENTING
AGENT
RESPONSIBLE
AGENT
MONITORIN
G AGENT
MONITORING FREQUENCY
DECOMMISSIONING PHASE
56
ACTIVITY ENVIRONMENTAL
ASPECT
IMPACT POSITIVE
\NEGATIV
E
SOURCE MITIGATION INDICATOR IMPLEMENTIN
G AGENT
RESPONSIBLE
AGENT
MONITORING
AGENT
MONITORING FREQUENCY
Land degradation Scarred earth and bare
ground
-ve Destruction and
removal of overburden
and rocks during
mining
Make sure the pit walls are not
steep to allow wildlife to drink
water collected with easy.
Number of un-
rehabilitated pits
Mine Manager Savanna
Marble CC
DEA Twice / once a
year
Land degradation Solid waste and loss of
aesthetic value
-ve Indiscriminate
dumping of waste rock
and poor grade blocks
as well as domestic
waste.
Waste rock should be kept
properly for rehabilitation
exercise.
Reusable or recyclable
materials should be separated
and treated as such.
Area of un-
rehabilitated
land surface, and
waste dumps
Mine Manager Savanna
Marble CC
DEA Twice / once a
year
DECOMMISSIONING PHASE
Land degradation Scarred earth and bare
ground
-ve Destruction of trees
and removal of
overburden and rocks
during mining
Refill all dug out pits and
replace topsoil.
This should be followed by
planting of trees and grass.
Borehole water can be used to
water them until they have
established well.
Land cover, tree
population and
number of un-
rehabilitated pits
Mine Manager Savanna
Marble CC
DEA Twice / once a
year
Land degradation Solid waste and loss of
aesthetic value
-ve Indiscriminate
dumping of waste rock
and poor grade blocks
as well as domestic
waste.
Waste rock should be kept
properly for rehabilitation
exercise.
Reusable or recyclable
materials should be separated
and treated as such.
Area of un-
rehabilitated
land surface, and
waste dumps
Mine Manager Savanna
Marble CC
DEA Twice / once a
year
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8. CONCLUSION, RECOMMENDATIONS AND WAY FORWARD
8.1. Conclusion
The mining of granite / dimension stone at ML 152 has negative environmental
impacts. The EIA study findings showed negative environmental impacts to the
environment to varying degrees depending on the nature of the activity and impacts
arising thereof. Management and corrective measures were formulated and
implementation timelines proposed depending on the gravity of threat to human life
and the environment.
The identified impacts, mitigation and monitoring activities, indicators, responsible
parties and monitoring frequency are indicated in the EMP. The EMP should form the
obligatory conditions upon which the EIA clearance certificates will be issued and non-
compliance attracts prosecution. The EMP should be implemented throughout the
project lifecycle and an Environmental Management System formulated and
implemented based on the EIA study findings. Environmental monitoring and
performance evaluations should be conducted and targets for environmental
improvement set and monitored throughout the project lifespan. It is also our
determination that the findings should be incorporated earlier and sound SHE policies
and supportive programmes implemented.
8.2. Recommendation
Recommendations were developed to guide the Proponent on the key activities that
should be done to effectively manage safety, health and environment:
• Develop SHE policies based on the study findings and use impacts evaluation
to formulate the objectives.
• Develop and implement Environmental Management Systems.
• Develop an occupational health and safety plan
• Adhere to the environmental management obligations upon which the EIA
clearance certificate will be issued by the MET: DEA.
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• The EIA clearance will not exempt the Proponent from obtaining other relevant
permits and should do as such.
• Provide relevant training to capacitate the workers with knowledge and skills to
manage safety, health and the environment.
8.3. Way Forward
The EIA will be submitted to MET: DEA. The decision made by MET: DEA will be made
known to the Proponent and I&APs.
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8.4. History of stakeholder interactions (i.e. proof of good working
relations)
All submissions to MET over the past 9 years of the mine's - at least the scanned
receipt proofs should go into an appendix. If the mine has not submitted 6 monthly
reports then this list and collated proofs will provide an alternative to the required
reporting that should have been done.
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8.5. Background Information and Invitation to Participate Document
BACKGROUND INFORMATION DOCUMENT AND INVITATION TO COMMENT.
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) FOR THE MINING AND
UPGRADING OF GRANITE VALUE ADDITION PLANT – RENEWAL OF MINING
LICENCE 152 IN ARANDIS, ERONGO REGION.
FOR
SAVANNA MARBLE CC
Prepared by
P. O. Box 70822, Khomasdal, Windhoek, Namibia.
+264 812 683 578
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1. PURPOSE OF THE DOCUMENT AND CONTENTS
The purpose of this Background Information Document (BID) is to provide
stakeholders with the opportunity to register as Interested and Affected Parties
(I&APs) in the scoping exercise for the Environmental Impact Assessment (EIA) Study
for the mining and processing of granite on Mining Licence 152 held by Savanna
Marble CC. We will share with you the process being followed and also obtain your
initial comments on the granite mining project. The document also gives you
information on the benefits of the proposed project, potential impacts of the project
and proposed environmental studies needed. Further to that we advise you on how
you can become involved in the project, raise concerns which you may have or receive
information which may be of interest to you. This is the core of public participation
during the EIA process. Information sharing is the cornerstone of successful Public
Participation and your input will help ensure that all potential issues are taken into
consideration before critical decisions are made.
2. PROJECT DESCRIPTION
The applicant, Savanna Marble CC is the mining licence holder of ML 152 granted for
a period running from the 5th of June in 2009 to June 2019. At the time of the granting
of the licence only an internal EIA was done as all such projects were cleared based
on an environmental questionnaire submitted to the Ministry of Environment and
Tourism (MET) who would then issue an environmental contract. Over the years
Savanna Marble CC (Proponent) has been involved in mining and exporting of granite
blocks and partially processing slabs and tiles for further value addition. Slabs were
mostly transformed into table tops through further value addition in Windhoek. It is in
the Proponent’s plans to upgrade the value addition plant and make finished products
such as tiles, slabs, curbstones, windowsills etc, which would form the basis for the
expansion of existing stone manufacturers, as well as for the development of various
new downstream businesses that can add further value to Savanna Marble CC’s
products.
Most significantly this processing activity will enable the Proponent to make use of a
large number of blocks that were rendered waste due to inconsistent colour or cracks
or any other reason that compromised the overall quality of the blocks. In a nutshell
this EIA study has been necessitated by the following:
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d. Renewal of mining licence ML 152.
e. Change of operations due to the inclusion of Processing and Manufacturing
activities for the purpose of local value addition and reduction of waste.
f. Development of a comprehensive Environmental Management Plan in
compliance with the Environmental Management Act (2007) which covers both
the mining operations and value addition activities.
Figure 13: The location of ML152 in relation to Swakopmund, Arandis, Namib Desert Nation Park and the existing water, road, rail and electricity infrastructure.
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3. DESCRIPTION OF THE ENVIRONMENT
3.1. Existing mine infrastructure
There is an existing mine pit from which granite blocks were extracted over the years.
In addition there is a granite cutting and polishing plant mounted on concrete
foundations and shaded under a roof constructed from corrugated iron sheets fixed on
iron beams. Concrete floors serve as storage, value addition and general maintenance
areas). Water and electricity are available onsite and details are presented below.
3.1.1. Water
Water is tapped from the main pipeline supplying the Uranium mines in the area. Daily
water consumption during full production would be ten cubic meters per day. However,
water is recycled retaining up to 80 % of the water used for cutting, so that water
consumption is reduced significantly. Water is mainly used for the cutting process with
diamond cutting blades and diamond wires. It also serves to completely suppress any
dust development during the cutting process. Water loss is predominantly through
evaporation, no infiltration is expected since the pond was cut out from the solid granite
formation.
3.1.2. Energy
All the electrical equipment at the mine is powered by diesel generated electricity.
Diesel is stored on-site using an above ground storage tank from which other mobile
equipment also fuels. Should there be need to get electricity connection to the national
grid in the future then the necessary procedures will have to be followed. It is an option
that cannot be ruled out if there is need and the powerline is within reach. The
Proponent does not plan a connection to the grid.
Potential Challenge
The EIA study will investigate the suitability of the fuel storage site in relation to other
mining operations taking into consideration the environment, occupational health and
safety. Spills and leaks of hydrocarbons impact negatively on the environment.
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3.1.3. Accommodation and toilet facilities
Mine and processing plant workers will be accommodated in Arandis and
Swakopmund. Accommodation facilities in the form of movable containers on the mine
site are solely for accommodating security personnel and site managers if required.
The following facilities will be erected on the mine site for the well-being of the
employees:
c. Staff canteen: The staff canteen will comprise of a pantry for storing food
stocks, a kitchen and eating / dining hall.
d. Ablutions and showers: Dixy toilets catering for twenty people will be used and
serviced by an external contractor. Showers will be installed to serve the same
number of people but the grey water will be used to feed a sypon growing
melons and other vegetables.
Potential Challenge
The ablutions and toilet facilities should be designed to the correct capacity and
appropriate technologies used to safeguard the environment and the health of the
employees.
3.2. The project
The project is focused on upgrading the granite cutting and polishing facility. This
entails extending the floor line for the various product lines as well as a packing and
dispatch area. Associated activities will be of course the construction of the ablutions,
showers and canteen described earlier.
Figure 14: Block cutter used in the value addition facility.
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3.3. The need for the project
The benefits of upgrading the granite cutting and polishing plant are among others:
• Reduction and partial elimination of granite waste
• Employment creation and thus improve the well being of the local people.
Employment preference will be afforded to previously disadvantaged
Namibians.
• Supply of raw materials and processed materials to downstream industry for
economic growth. Such industries include but are not limited to the construction
industries etc.
• A contribution to the balance of payments through exports.
• Local Value addition allowing for the processing of blocks (waste) that cannot
be sold as complete blocks.
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4. PROPOSED STUDIES
A baseline environmental study will be done covering the following aspects:
4.1. Biodiversity Scoping study
A flora and faunal study is proposed given the likelihood of vegetation destruction
during mining operations and land clearing during construction activities. A baseline
map showing area covered by protected flora will be generated indicating no go areas
as well.
4.2. Culture and Heritage Scoping
A culture and heritage scoping will be done to investigate the occurrence and
significance of historical heritage sites.
4.3. Assessment Of Alternatives
4.3.1. No-Go Option
The “no-go” option means maintaining the status quo. This option will be explored to
assess the implications of not implementing the project.
4.3.2. Sites
Sites within the mining licence that pose minimal impact on the environment will be
chosen for mining. Similarly access routes will be assessed and those with minimal
environmental impacts chosen. The same will be done with the fencing of the mining
area.
4.3.3. Strategic Alternatives
Strategic alternatives will be explored to see the best way to exploit the targeted
mineral reserves in terms of mining techniques, transportation and marketing.
4.3.4. Technological Alternatives
There are different technologies available that are used in the mining and
environmental monitoring. The various options will be explored and appropriate
recommendations made to enhance sustainability.
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5. THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS
An EIA is the process of identifying, predicting, evaluating and mitigating the
biophysical, social, health and other relevant effects of development projects prior to
major decisions being taken and commitments made.
The objectives of the EIA will be to:
• Provide you with adequate information to understand the potential
environmental and socio-economic impacts of the proposed project and
opportunities to comment on the project and the process.
• Provide information that will assist the consultants to incorporate effective
mitigatory measures into the design and implementation of the project.
• Provide the regulatory authorities with sufficient information to serve as a basis
for sound decision making.
5.1. Project elements to be covered by the EMP.
The EIA will cover the following elements:
• Operation and maintenance of the mine and processing plant.
• Decommissioning
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PHASE 1: SCOPING
• Determine scoping of EIA
• Policy, regulatory review
• Desk review of previous studies
• Reconnaissance site visit
• Scoping workshop
• Draft scoping report with terms of reference & work plan for phase 2
•
PHASE 2: Environmental Impact Aseessment
• Biophysical, Socio-economic and Specialist Studies
• Impact Assessment
• Mitigation Plan
• Draft EIA Report
Decision making
Implementation
On-going consultations
Including Public Meetings
Public Consultation & Disclosure
• Includes community
consultation & Public Meeting
• Draft Public Consultation &
Disclosure Plan (PCDP)
Development not approved
Environmental Impact Aseessment
Development not approved
Development approved
Figure 15: The EIA process that will be followed. Figure 16: The EIA process to be followed.
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5.2. Scope Of The Work
The Environmental Impact Assessment scope will focus on the issues related to fauna
with respect to land clearing, waste management (solid and liquid), operation and
management of the mine and processing area, construction of the canteen, ablution
and toilets, sites of national heritage significance and policy and legislation review.
The EIA will be done in 2 phases (See Figure.2).
PHASE 1 – SCOPING
It is a formal requirement during the EIA process to carry out a scoping study and this
is in-line with the Namibian Environmental Management Act (2007). The purpose of
this study is to direct the assessment on the key issues for assessment and at the
same time eliminate those that do not require detailed intensive studies.
5.3. Scoping Activities
• Consultations with key stakeholders, government departments etc.
• Advertising and carrying out public meetings.
• Distribution of project information to the public.
• Producing draft scoping report.
• Gathering public comments on draft scoping report.
• Submission of final scoping report to Ministry of Environment & Tourism
(MET).
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PHASE 2
Issues that are raised during the scoping study will be used to develop terms of
reference for specialist studies. Experts within the Consultancy Team will be assigned
to carry out the specialist studies. The results from the specialist studies will be
incorporated into the Draft EIA report.
5.4. Draft EIA Report
The draft EIA report will reflect all the identified issues, mitigation measures and the
proposed environmental management plan. The draft EIA document will be made
available to the public for comments on issues of interest and can also raise any
concerns they may feel require further attention.
5.5. Legal Framework
The Namibian Government gazzeted the Environmental Management Act in 2007 and
is supported by a set of guidelines and regulations. The EIA process will follow the EIA
Policy and the Environmental Management Act & its regulations. The EIA will also take
cognizance of applicable international standards and guidelines, conventions and
treaties.
6. PUBLIC CONSULTATION AND DISCLOSURE PLAN
According to the Environmental Management Act (2007), public participation forms an
integral part of the EIA process. Adequate public consultation is important to identify
issues relevant to the project, evaluating their significance and deciding measures to
mitigate these impacts. A public consultation plan has been developed in line with the
Environmental Management Act (2007) and seeks to achieve the following objectives:
• To ensure all stakeholders are included in the consultation and disclosure
process;
• To ensure initial information disclosure about the project is appropriate and
understandable to the non-technical stakeholders and the local population;
• To ensure that adequate and timely information is provided to the public;
• To ensure that all stakeholders are given sufficient opportunity to express their
issues, concerns and opinions;
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• To ensure that stakeholders’ opinions and concerns influence project decisions;
• To ensure regular feedback is given to the public;
• To ensure that effective communication will continue during the construction
and operational phases of the project;
Savanna Marble CC and the Outrun Team are committed to active and ongoing
communication and consultation of all members of the public with regards to the
granite mining project at ML 152 in the Arandis Area.
6.1. How you can be involved?
• Attend public meetings that will be advertised in the local media.
• Contact the EIA consultants for further information.
• Review the draft reports when you are invited to do so within the timeframes
provided.
Please ensure that you are registered on the project database by providing your
contact details to the EIA Consultants. Registration will ensure that you receive on-
going communication about the EIA process, meeting invitations, project updates and
invitations to review the draft reports.
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SAVANNA MARBLE CC
REGISTRATION AND COMMENTS FORM
Please register me as an Interested and Affected Party (I&AP) to
receive ongoing communication about the EIA process and the
proposed project.
NAME: TELEPHONE:
ORGANIZATION: FAX:
DESIGNATION: E-MAIL:
ADDRESS:
COMMENTS AND ISSUES OF CONCERNS
PLEASE SUBMIT REGISTRATION AND COMMENTS TO:
JOSIAH T. MUKUTIRI AND PHILLIP HOOKS
P. O. Box 70822
Khomasdal
Windhoek
Namibia
Mobile: +264 – 812 683 578.
E-Mail: [email protected]
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EXISTING ENVIRONMENT IN PICTURES
Figure 17: Dolerite ridge. Figure 18: Granite blocks awaiting processing.
Figure 19: Eroded dolerite forming microhabitat for Caloplaca spp Lichens.
Figure 20: Aloe Asperifolia
Figure 21: Remains of the 100 years old railway line damaged during movie production of Mad Max.