ORANO MINING NAMIBIA · 2019. 12. 12. · Aveng Water is also responsible for maintenance of the...

ORANO MINING NAMIBIA

2018 ENVIRONMENTAL (EMP) COMPLIANCE AUDIT OF

ORANO's TREKKOPJE MINE AND DESALINATION PLANT

Project No: NSP201801

Report No.: 01

October 2018

DOCUMENT CONTROL

Report Title 2018 ENVIRONMENTAL (EMP) COMPLIANCE AUDIT OF ORANO's TREKKOPJE MINE AND DESALINATION PLANT (2017)

Report Author Werner Petrick

Client Orano Mining Namibia

Project Number NSP201801

Report Number 1

Status Draft for client review

Issue Date October 2018

Orano Mining Namibian – 2018 EMP Audit

NAMISUN Report No.1 Ref NSP201801

2018 ENVIRONMENTAL (EMP) COMPLIANCE AUDIT OF ORANO's TREKKOPJE MINE AND

DESALINATION PLANT

October 2018

Page i

ANNUAL AUDIT OF THE TREKKOPJE MINE AND DESALINATION PLANT

ENVIRONMENTAL MANAGEMENT PLANS (2017)

CONTENTS

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

1.1 ENVIRONMENTAL POLICIES ................................................................................................................ 3

2 AUDIT FINDINGS .................................................................................................................................. 3

2.1 TREKKOPJE MINE AUDIT FINDINGS..................................................................................................... 4 2.1.1 STATUS OF NON-COMPLIANCES FOUND IN THE 2017 AUDIT REPORT ................................................................. 4 2.1.1 ENVIRONMENTAL ACTION PLAN ..................................................................................................................... 9 2.1.3 SUMMARY OF AUDIT FINDINGS – TREKKOPJE MINE ........................................................................................ 27

2.2 ERONGO DESALINATION PLANT AUDIT FINDINGS ............................................................................... 28 2.2.1 ERONGO DESALINATION PLANT EMP AUDIT FINDINGS ................................................................................... 28 2.2.2 SPECIFIC ISSUES FOUND DURING THE SITE INSPECTION .................................................................................. 37 2.1.3 SUMMARY OF AUDIT FINDINGS – DESALINATION PLANT .................................................................................. 38

3 CONCLUSION ..................................................................................................................................... 39

APPENDIX A: ORANO AND AVENG’S ENVIRONMENTAL POLICIES




DESALINATION PLANT

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ACRONYMS AND ABBREVIATIONS

Below a list of acronyms and abbreviations used in this report.

Acronyms / Abbreviations

Definition

C Conformance

C&M Care and Maintenance

EIA Environmental Impacts Assessment

EMP Environmental Management Plan

MET Ministry of Environment and Tourism

NA Not Applicable

NC Non-conformance




DESALINATION PLANT

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2018 ENVIRONMENTAL (EMP) COMPLIANCE AUDIT OF ORANO'S TREKKOPJE MINE AND DESALINATION PLANT (2017)

1 INTRODUCTION

Orano Mining Namibia’s (Orano) Trekkopje Mine is located approximately 70 km north-east of

Swakopmund. The Project was placed on ‘Care and Maintenance’ in 2013, with Orano

postponing the launch of the Trekkopje Mine indefinitely, depending the future recovery of the

uranium price.

Further metallurgical testing work through test facilities (i.e. columns and test boxes) at the Mini

plant were however undertaken, on new processing methods, until June 2017. Since that time,

the only activities conducted at the mine relate to general Care and Maintenance of infrastructure.

Orano currently employs 17 permanent people and 4 people on a ‘long term contract basis’, as

part of the Care and Maintenance programme. Out of the 21 people, 14 perform duties on site

and the remaining 7 are based in the Swakopmund offices. There are also a number of

contractors on site but these numbers change occasionally depending on the type of

maintenance related projects being implemented.

In order to supply the water required by the heap leach process of the Trekkopje Mine, a

desalination plant was constructed. The plant, which is located ±3.5 km north of Wlotzkasbaken,

approximately 30 km north of Swakopmund, is owned by Orano and operated by Aveng Water.

Aveng Water is also responsible for maintenance of the plant, as well as ensuring legal

compliance of the operations of the plant.

The plant was designed to produce 20 million cubic metres of potable water per year, at full

capacity. Due to an increasing regional demand for water relating to some of the central coastal

towns and the mining activities in the Erongo Region, as well as the pressure put on the Omdel

aquifer (Omaruru Delta) during recent years, the Erongo Desalination Plant was not placed on

‘care and maintenance’ but keeps operating and supplying water, through NamWater, to other

bulk water users.

The current desalinated water supply of the plant ranges between ±750,000 to 900,000 m3 per

month, which is a reduction of the supply reported in the 2017 audit report, i.e. 1 to 1.2 million m3

per month. Currently, 34 people are permanently employed at the desalination plant. At the time

of the audit, there were eight NIMT trainees on job attachment at the plant.




DESALINATION PLANT

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Orano is required to conduct annual independent environmental audits of the Environmental

Management Plans (EMPs) for both the Trekkopje Mine and the Desalination Plant, in terms of

their license conditions and relevant Namibian legislation. The previous independent EMP audit

was conducted by SLR Environmental Consulting (Namibia) (Pty) Ltd in November 2016, which

focused on both the Trekkopje mine and the Desalination plant.

Orano appointed Namisun Environmental Projects and Development (Namisun) to conduct the

2018 environmental audit. Namisun’s scope for the audit entailed assessing compliance with the

Environmental Management Plan (EMP) for the Erongo Desalination Plant and the

Environmental Action Plan for the Trekkopje Mine. Orano developed the Environmental Action

Plan in 2017, which summarises the mitigation measures stipulated in the Trekkopje Mine EMP.

The Desalination Plant EMP and the Trekkopje Mine Environmental Action Plan were therefore

used as the basis for the audit. The audit was conducted as follows:

Namisun (Werner Petrick) conducted a desktop audit of the Trekkopje Mine

Environmental Action Plan on the 3rd of October 2018. No site inspection to the mine site

was conducted. Namisun also audited the findings (i.e. specifically Non-Compliances,

Partial Compliances, recommendations and improvement notes) from the 2017 Trekkopje

Mine EMP audit.

On the 4th of October 2018 Namisun undertook a site visit to the desalination plant and

audited the Erongo Desalination Plant EMP.

The following people were present at the audit and were consulted as part of the audit process

during various stages of the audit:

Kaarina Nkandi (Orano QHSE Specialist) – 3 and 4 October 2018

Sandra Muller (Orano QHSE Manager) at the Swakopmund Town office – 3 October (and

again briefly after the site inspection to the desalination plant, on the 4th of October)

David Baillie (Erongo Desalination Plant Manager – Aveng Water) – 4 October 2018

Lazi Gariseb (Production Supervisor) – 4 October 2018

(Apologies were received from Quinta Nendongo (Erongo Desalination SHEQ – Aveng Water)

who could not attend the audit on 4 October 2018).




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Please note:

The Care and Maintenance status of the Trekkopje Mine at the date of the audit was an important

consideration as it impacts the relevance of various commitments in the Environmental Action

Plan. Also, the audit scope excluded a site visit to the mine and other than the desktop review,

onsite activities could not be verified by the auditor. This was however not regarded an important

consideration of the audit due to the limited activities currently being undertaken on site.

1.1 ENVIRONMENTAL POLICIES

Orano and Aveng Water each have their own environmental policy (Aveng Engineering has an

integrated “Occupational Safety & Health and Environmental Policy”). The auditor took

cognizance of these Policies during the audit to ensure the Environmental Action Plan and EMP

and audit findings are placed in context with these policies. Refer to Appendix A for a copy of the

two above mentioned Policies.

2 AUDIT FINDINGS

The findings from the audit are presented in the sections below, as follows:

Section 2.1 - Trekkopje Mine audit findings

o Section 2.1.1 – Summary of the 2017 (SLR) Audit findings based on all EMP

mitigations measures: Status of Non-Compliances (NCs) found in the 2017

report and actions taken in 2018 regarding recommendations

o Section 2.1.2 – Trekkopje Mine Environmental Action Plan audit findings

o Section 2.1.3 – Summary of Environmental Action Plan audit findings

Section 2.2 – Erongo Desalination Plant audit findings

o Section 2.2.1 – Erongo Desalination Plant EMP audit findings

o Section 2.2.2 – Erongo Desalination Plant site visit findings

o Section 2.2.3 – Summary of audit findings.



2018 ENVIRONMENTAL (EMP) COMPLIANCE AUDIT OF ORANO's TREKKOPJE MINE AND DESALINATION PLANT

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2.1 TREKKOPJE MINE AUDIT FINDINGS

2.1.1 STATUS OF NON-COMPLIANCES FOUND IN THE 2017 AUDIT REPORT

Table 1 below provides the findings from the audit relating to status of NCs (only) found in the 2017 (SLR) audit and actions taken by Orano in

2018 to address these and other recommendations made.

Table 1: Status of NCs found in the 2017 Audit Report

ID Aspect Impact Mitigation 2017 Audit findings 2018 Audit findings

Compliance Comments

Yes (C)

No (NC)

NA

General Mitigation Measures to be applied throughout the life of mine

1

Environmental management system

Legal compliance

Local regulations and Orano directives are enforced and potential modifications are anticipated. A legal register is maintained when the mine is in operation (i.e. not during care and maintenance).

No “Legal Register” exists. There are currently no funds available for preparing a “Legal Register”. However, the following activities are implemented:

The “legal folder” is maintained by the QHSE Department.

Government Gazettes are obtained and inspected for significant / relevant changes

Recommendation: Prepare a specific “Legal Register” in line with the “Environmental Code of Practice” prior to commissioning.

Similar to the 2017 audit findings and the same recommendation applies.

3 EMP compliance

A consolidated environmental action plan is drawn up and each action is monitored quarterly.

The Action Plan was updated for 2017. Recommendation:

The next annual audit (2018) should not only focus on the EMP

The Environmental Action Plan was (primarily) used as the basis for the audit in 2018. The findings from the 2017 Trekkopje Mine EMP audit was however also audited.




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Compliance Comments

Yes (C)

No (NC)

NA

commitments but also on the detailed action plan.

12 Environmental awareness

EMP compliance

Managers at all levels carry out participatory environmental inspections as part of HSE inspections.

Improvement notes:

Review the effectiveness of current checklist (with input from supervisors) and update where relevant. Supervisors to be trained on using the checklist and implement. A signature (signoff) should be included on the inspection sheet by the Area owner.

Improvement note from the 2017 audit still not implemented. The note therefore remains relevant and the action to be implemented.

20 Remove contaminated soil to an approved facility or treat on site by bioremediation.

Partial compliance (repeat from previous audits)

Procedures are in place. Contaminated soil was placed on bioremediation area – still requires procedure to be followed.

Even though a site visit was not conducted by the auditor to confirm this action, the Orano QHSE Specialist confirmed that this action still needs to be implemented. The “Partial Compliance” therefore remains applicable and the action neds to be implemented.

21 Provide bunding at fuel storage and transfer sites large enough to contain 110% of the volume of the largest tank. The tanks must stand on a concrete slab.

Recommendation (from previous audits):

Provide bunding for the refuelling area to prevent run-off of hydrocarbons from the surfaced area – prior to commissioning the refuelling activities again.

The area (i.e. activities) has been closed down until commissioning of the mine. The recommendation therefore remains applicable but only to be implemented prior to commissioning (of the refuelling activities).




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Compliance Comments

Yes (C)

No (NC)

NA

23 Limit the radiation exposure of workers on the mine plant and waste areas to as low as reasonably achievable. Ensure that the requirements of the RMP are implemented and exposures are kept below the dose limits set by the NRPA.

Currently, there are no employees subject to radiation exposure since the mine is under care and maintenance. Monitoring being conducted and also included in the training and inductions – questionnaires/forms are completed, etc. However, no completed radiation induction forms could be provided during the audit (and the auditor could not verify this). No inspection was done by the Ministry of Health and Social Services (National Radiation Protection Agency) in 2017. Recommendation: The Environmental Department to keep electronic copies of completed forms.

Similar findings to the 2017 Audit. Also, no inspection done by the National Radiation Protection Agency in 2018. Hard copies of the forms are kept on site by the Orano QHSE Specialist. Recommendation remains applicable.

25 Soil pollution

Train employees in spill response (every three years) and provide clean-up material.

Partial compliance (repeat finding from previous audit)

Ongoing training (i.e. hydrocarbon spillages, etc.) is not provided to both employees and the contractors.

The risk of (significant) hydrocarbon spillages as a result of the current activities being conducted are low. Minor hydrocarbon spillages could however still occur from graders, etc. and the need for ‘refresher training’ (i.e. annually) and to new




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Compliance Comments

Yes (C)

No (NC)

NA

employees/ contractors) remains applicable.

28 Pollution control measures should include proper storage and bunding of areas that contain chemicals and oils. Regular inspection and maintenance of containers, bunding, storage tanks, and oil separation systems must be undertaken.

The full ‘Resin Drums at the Salvage yard next to the Mini Plant, previously stored incorrectly (not in closed or bunded area) were removed and placed inside a locked shipping container that is designed for radioactive material storage. Non-Conformance (repeat finding from previous audit)

The following issues were found that constitutes a NC:

It was found that plastic lining was placed around the area where sandblasting (and painting) is taking place. However some of the sandblast material spilled over this lining into the environment. Also, paint spills were noted on the ground.

The auditor was informed that resin recently spilled from the drums and out of the container. The area (soil) was cleaned up and the resin and contaminated soil safely stored (in a secure area) on site. Orano personnel is however still investigating options for safe disposal of the resin. No further sandblasting / painting activities are currently being undertaken. The spillages from the previous sandblasting activities was also not yet cleaned up. Therefore, taking the above mentioned into consideration, this remains a NC and clean up measures and safe disposal to be implemented soonest.

31 Closure planning

Long-term impacts, land use

Compile a decommissioning plan for exploration and production sites, provide sufficient budget for closure and aftercare. Consult stakeholders about future land use options and expectations. Consider

Partial compliance

No change from previous audit findings. Internal report completed but not ready for stakeholder consultation. Orano is still optimizing the process and will only at a later stage update the Closure Plan (at the end of the care and maintenance phase).

No Change from previous audit findings.




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Compliance Comments

Yes (C)

No (NC)

NA

retrenchment plan and sustainable development issues.

Provision is made for the closure budget and put in the required amounts on an annual basis.

Mitigation measures relating to social activities to be applied throughout the life-of-mine

2 Local employment

High rate of unemployment

Develop a recruitment strategy that prioritises employment from communities in Arandis and the #Gaingu Conservancy, and ensure equitable employment opportunities for marginalised groups.

Recommendation (remains from previous audit):

Update Environmental Policy to include these requirements.

No Change from previous audit findings. However, only to be implemented prior to commissioning of the mine.

3 Inward migration of job seekers

Advertise recruitment processes, avoid use of casual labour, advise local authorities of employment needs and get their help in identifying local candidates.

Not in employment policy. But are currently not employing. Recommendation (remains from previous audit:

Update Employment Policy to include these requirements.

5 Sustainability of local economy

Benefits for local communities

Implement mechanisms to promote local procurement, use of local service providers and assist where capacity is lacking, promote the incorporation of women into the local economy and facilitate funding for SMEs.

Partial compliance

Requirement not included in the (draft) procurement policy. Currently mine under care and maintenance. The Employment policy gives preference to local people. Contractors on site are all local




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2.1.1 ENVIRONMENTAL ACTION PLAN

Tables 2 to 10 below provides the findings from the audit relating to relevant commitments (i.e. ‘actions/tasks’) in the Environmental Action Plan.

(Take Note: Actions / tasks that were identified in the Action Plan as not applicable during care and maintenance, as highlighted in grey in the

Action plan, are omitted from the tables below).

Table 2: Environmental Strategy and Action Pan

Themes Actions Status at end of 2017 2018 Audit findings

Compliance Comments

Yes (C)

No (NC)

NA

Integrated Management System

Maintain a legal register/database and keep informed about proposed legislation changes in Namibia

Obtain directives and policy changes from Orano head office

Identify environmental aspects and risks, update EMPs

Set up a QHSE action plan for 2018 and monitor progress annually

Conduct internal environmental assessments for projects with significant impact and prioritize remedial actions

Full legal register to be implemented at start-up, meanwhile subscribing to Gov. Gazette and checking for applicable acts

Updated documents are available on Orano intranet

Aspects in EMPs were updated in 2016, no new risks identified this year

Environmental action database to be in place at mine start-up, until then tracking progress in QHSE action plan

No significant projects in 2017 (PV plant outside of Orano responsibility)

No changes in 2018. No changes in 2018. No new risks identified in 2018. Action plan tracked. No project in 2018.

Awareness Training

New employees and contractors attend environmental induction before starting work

Environmental issues are presented at monthly HSE meetings and discussed at shift start talks (weekly)

Managers include environmental aspects in their HSE inspections

Re-induction for employees in early 2017, induction given to all new contractors during the year

Refer to minutes of monthly HSE meetings and records of weekly safety talks

Managers conducted HSE inspections as planned, environmental findings were mainly waste-related

Re-induction in 2018. Record of monthly meetings in place. Proof of only one environmental topic (i.e. snake bites) during weekly toolbox talks provided to the auditor. Similar in 2018.




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Compliance Comments

Yes (C)

No (NC)

NA

Improvement note:

Ensure Environmental issues are included in the weekly talks and keep record of topics discussed.

Internal Communication

Update policy annually and display on notice on the mine and in offices

Investigate and report significant environmental incidents according to procedure, inform employees of events and action taken

Environmental improvement ideas are recorded in monthly reports and exchanged within Orano and with other mines

Policy updated in 2017 and displayed, objectives and indicators tracked in monthly reports

All environmental incidents in 2017 were reported in the AHEAD database and monthly reports

There were no specific improvement ideas, but good practices were exchanged within Orano and with Namibian Uranium Association members, e.g. in the water and radiation working groups

Policy changed to the Orano ‘branding’. Policy attached as Appendix A to this report. Partial Compliance

Incidences are reported in the AHEAD database. However, records of ALL incidences (i.e. waste management issues not reported (see Table 9). Only safety improvement ideas recorded at this stage. Workshop on “Environmental and Radiation” to be held in France in November (to be attended by Orano QHSE Manager). Record any significant possible improvement ideas relating to C&M activities.

Improvement note:

Ensure that all (significant) incidences are recorded on AHEAD. Agree and record what should be regarded as ‘significant’ during C&M.

External Communication

Compile a report at least every two years, either publish on company website or send printed copies to local stakeholders

Hold meetings with stakeholders

Published a report for 2017 in April 2018 and distributed printed copies to stakeholders, not possible to place on Orano website

Community consultant held meetings, stakeholders did not raise environmental concerns

2018 report still to be developed (for distribution in 2019).




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Compliance Comments

Yes (C)

No (NC)

NA

Chemical Accident Risks

Carry out chemical risk assessment, review MSDS and emergency procedure when new chemicals are introduced

Assess the risk of each new project phase, modify the design if required

Maintain effective emergency response procedures and equipment

No new chemicals were added in 2017

Still in care and maintenance phase, no chemical risk assessments done

New emergency response procedures were compiled in 2016 and updated after retrenchments in 2017; trained employees and contractors, equipment and response team are in place

No changes in 2018. No changes in 2018. Updated in 2018 (new names / responsible people added).

Chemical Health Risks

Asbestos and asbestos-containing materials are not permitted on site

A legionnaire’s disease risk assessment is carried out and a monitoring schedule is implemented if required

CMR substances are identified and replaced with less hazardous alternatives if these are available

Implemented, refer to Environmental Code of Practice

Legionella risk has been assessed and found to be low, no monitoring needed

Completed CMR hazard assessment study in 2009; did not identify any chemicals that should be replaced. No CMRs are used during care and maintenance

No changes in 2018. No changes in 2018.

Soil and Groundwater

Establish baseline conditions before exploration or production work begins

Compile procedures for activities that may cause pollution, train employees in spill response, provide clean-up material

Monitor the groundwater quality annually

Baseline survey (2007) did not identify any pre-existing polluted sites

Procedures in place, employees trained in spill response, restocked spill kits

Implemented, refer to annual reports

No changes in 2018. Training is however conducted once-off. Report submitted to relevant authorities. Improvement note:

Annual training on spill response procedure to relevant employees / contractors.

Monitoring Implement the: o Radiological monitoring

programme

Using TLDs and alpha dosimeters for radiation monitoring (see reports)

Monitoring dust emission and climate

Annual monitoring conducted and reported to relevant authorities (i.e. NRPA and MET).




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Compliance Comments

Yes (C)

No (NC)

NA

o Air quality monitoring programme

o Water monitoring programme

Analysing potable water, groundwater and sewage effluent quality

Decommissioning Prepare an end of mine-life closure plan and a plan for premature closure, include closure cost in the budget

Closure plan and cost estimates prepared in 2010, updated 2012-2013 and included in budget.

Improvement note:

Closure Plan (and cost estimates) to be updated in 2018. Consult with key stakeholders to obtain input on the draft closure plan once updated.

Water, Energy, GHG

Monitor consumption and releases as required and report to Orano

Publish results in the annual environmental and social report

Set site-specific targets for GHG emissions, water, fuel and power consumption

Monitoring and reporting as required

Figures are included in 2017 stakeholder report

Site-specific targets are set every year and performance is tracked in monthly operations reports

2018 report still to be developed (for distribution in 2019).

Waste Keep a waste register specifying waste types and volumes

Waste register with estimated volumes kept for domestic, mineral and hazardous waste (annual report)

Included in the 2017 Stakeholder report. 2018 report still to be developed

Innovation Identify options, e.g. solar energy and power-demand reduction measures

Geochemical modelling to assess long-term behaviour of contaminants released from backfilled tailings

Solar energy plant constructed on site not used for Orano supply, low power consumption during care and maintenance

Modelling done in 2012, closure plan adjusted according to outcome, no further work needed in 2017

Not applicable during C&M. No further work foreseen during C&M.




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Table 3: Air Quality Strategy and Action Pan

Objectives Tasks Status at end of 2017 2018 Audit findings

Compliance Comments

Yes (C)

No (NC)

NA

Emission sources are identified, documented and monitored

Use dust buckets and PM10 samplers to determine dust emission

Monitor radon emission

Operate and maintain weather stations

Make air quality data available to the SEMP office and the public

Investigate feasibility of equipment standardisation with other mines

Dust buckets and PM10 sampling in place

Alpha dosimeters for radon in place

Two weather stations operating

Provided data for 2017 SEMP report that will be published in 2018

Most mines use E-samplers, but not standardised for all

SEMP Report not published yet. No further investigation at this stage.

No impact on community health

Determine possible impacts based on air quality models

Monitor air quality at Arandis and other critical group locations (if any)

Communicate with stakeholders about assessment results

Public health risk assessment carried out in 2011, no update needed in C&M

Monitoring at Arandis and on the mine, though no critical groups are present on or near the mine site

Results included in SEMP reports which are published on the MME/GSN website

No further updated during C&M. No changes in 2018. SEMP Report not yet published.

Nuisance dust from the uranium mines is within acceptable thresholds (SEMP)

Provide dust fallout data to the SEMP Office to be included in annual SEMP reports

Measure air quality at Arandis

Monitoring results for 2017 were provided to the SEMP Office

Dust monitoring at Arandis and on the mine (but not at the boundaries) continued in 2017

Monitoring results for 2017 were provided to the SEMP Office. GSN is currently working on the 2017 SEMP report (i.e. not yet published). Info for the 2018 report will only be collected in 2019. Dust monitoring continued in 2018.

Annual human exposures to particulate concentrations are acceptable (SEMP)

Ambient PM10 monitoring at Arandis by Orano

Assist SEMP office with ambient PM10 monitoring at Swakopmund or other sites, if requested

Data are evaluated and PM10 emissions reduced through dust

Readings at Arandis for 2017 did not exceed the WHO IT-3 limit of 75 µg/m3

Provided an E-sampler to MME for use at Henties Bay for the duration of the advanced air quality study

PM10 values were below the WHO limit (no need for dust control measures)

Readings at Arandis for 2018 did not exceed the WHO IT-3 limit of 75 µg/m3 No changes in 2018.




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Compliance Comments

Yes (C)

No (NC)

NA

control measures if limits are exceeded

Contribute to the discussion about suitable limits for the region

The SEA recommended using the WHO IT-3 guideline of 75 µg/m3 for the Erongo region, current MME/SEMP study will propose suitable limits

Table 4: Biodiversity Strategy and Action Pan


Compliance Comments

Yes (C)

No (NC)

NA

Develop a Biodiversity Management Plan

Undertake desk studies and review status of protected areas and legal requirements

Conduct consultations with conservation groups and communities, integrate differing perspectives into the assessment of biodiversity

Carry out field surveys and regular monitoring at specific sites

Baseline studies and reviews done in 2006-7 as part of EIA (2008). EIA evaluated BD importance, determined impact of operations and mitigation measures

Strategic environmental assessment of uranium mining in the Erongo region (2010) included wide consultation and differing perspectives of all stakeholders

Field surveys done 2009-11, annual monitoring of vegetation transects ongoing

No changes in 2018. No further work foreseen during C&M. No changes in 2018. No further work foreseen during C&M. Monitoring ongoing. However, due to the poor rainfall during the last few years no inspections conducted by the appointed botanist in 2018.

Minimise Biodiversity Impacts

Use appropriate rehabilitation methods developed and tested in the Namib

Identify acceptable offsets in consultation with stakeholders, implement approved actions

Established own rehab trial plots to test different methods, monitoring them annually

Offset system to be agreed with Government, continued discussion with MET in 2017, currently no policy in place

Not applicable for implementation at this stage. No clear answer yet. However, the GIZ is working with MET on the NBSAP (national biodiversity strategy




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Compliance Comments

Yes (C)

No (NC)

NA

and action plan) which has offsets as a goal. GIZ asked a Biodiversity expert to prepare a background paper and proposed inclusion of offsets in the revised EMA and EIA regulations. Still to be finalised.

Integrate Biodiversity into Operating Plans (most of this objective does not apply during care and maintenance but is kept in the plan for reference)

Arrange for EMP training modules and present to engineers and contractors

Include biodiversity aspects in the EMS, rehabilitation and offsets in the closure plan

All contractors on care and maintenance projects receive environmental induction

Closure plan (2013) includes rehabilitation measures and cost, update closure plan in 2018

Partial Compliance.

Closure Plan not yet updated. Improvement note.

Closure Plan (and cost estimates) to be updated in 2018. Consult with key stakeholders to obtain input on the draft closure plan once updated.




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Table 5: Hazardous Materials Strategy and Action Pan 1


Compliance Comments

Yes (C)

No (NC)

NA

Plans are in place before hazardous materials are purchased and used

Document the environmental hazards of materials brought to site, site products, intermediates and by-products

Consider impacts associated with transport, storage and use, including failure of secondary containment structures

Internal criteria must be in line with internationally accepted regulations, guidelines, definitions and methodologies if government regulations are absent or incomplete

Inventory of hazardous materials brought to site or produced on site documents their storage, usage and final destination

Identify existing contamination and assess its environmental impact, record contaminated sites in a register

Apply risk assessment and set up procedures for safe use, storage and transport

Collected MSDS of all materials and assessed their risks, to be documented in health risk assessment in 2018

Assessment done by Orano HQ in 2010, recommendations implemented as far as possible, no issues in 2017

Internal criteria only developed for radioactive materials which are regulated by government (refer to RMP), other materials to be addressed before mine start-up

Inventory of hazardous materials kept on the purchasing system, but this does not include details of storage and final destination

Baseline survey did not identify any pre-existing polluted sites, any new spills that could cause contamination were cleaned up

Procedure for safe use, storage and transport is in place (HSE ENV PR 11)

Partial Compliance:

The Health Risk Assessment was not done in 2018 to document collected MSDSs of all materials and assessments thereof. No changes in 2018 NA for C&M. NA for C&M. No changes in 2018. Only chemical currently being used is for the RO plant next to the sewerage treatment facility.

Hazardous materials management is

Include handling and use of hazardous materials in job-specific inductions; give job-specific training

General induction includes basic information about hazardous materials; supervisors give job-specific training to new employees and

Ongoing in 2018.

1 These tasks could not all be verified by the auditor




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Compliance Comments

Yes (C)

No (NC)

NA

integrated into mine operations

in routine activities and emergency response training in remediation of contamination

Implement a permit system to allow only those new hazardous materials on site that do not adversely impact the environment

Procedure to prescribe storage conditions and containment, securely protected from contact with non-authorised personnel and wildlife

Above-ground tanks, drum storages and pipelines that contain hazardous material must have properly designed secondary barriers to contain 110% of the volume of the largest container

If storage tanks or pipelines cannot be above ground the exception must be authorised by the Mine Manager

Inspect storage tanks and pipelines containing hazardous materials to detect leakages and take appropriate remedial action according to procedure

Implement selection criteria and control procedures for third parties;

contractors; QHSE department trains emergency response teams

System in place and described in procedure HSE ENV PR 11, but up to now not applied to contractors

Procedure in place; user departments are responsible for secure containment and access control; currently mostly kept at Warehouse and not accessible to wildlife

Secondary containments at the pilot plants were not designed with the necessary capacity, but they are currently not in use anymore; the fuel depot has sufficient containment.

Storage tanks and pipelines at Trekkopje mine are all above ground

Inspections are currently part of the C&M scope of work.

No changes in 2018. Ongoing in 2018. With reference to the 2017 audit findings (see section 2.1.1), the refuelling area (i.e. activities) has been closed down until commissioning of the mine. The recommendation to provide bunding for the refuelling area to prevent run-off of hydrocarbons from the surfaced area remains applicable but only to be implemented prior to commissioning (of the refuelling activities).




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Compliance Comments

Yes (C)

No (NC)

NA

implement follow-up procedures for any hazardous material sent off-site, e.g. for disposal

Maintain emergency response procedures, equipment and response team

Develop and implement a remediation strategy for existing contaminated sites, if any are present

Transport company for radioactive materials selected according to RMP requirements; hazardous waste is transported to the Walvis Bay hazardous waste facility by Orano personnel, disposal certificates are not always issued

Response team in place and trained, procedure updated

No pre-existing polluted sites were identified at Trekkopje mine

Partial compliance

Safe disposal certificates for disposal of all Hazardous waste not always received and kept on record Partial compliance

The auditor was informed that the resin drums placed inside a locked shipping container recently spilled resin, which flowed out of the container. The area (soil) was cleaned2 and the resin and cleaned up soil safely stored in a secured area on site. Orano is however still investigating options for safe disposal of the resin.

The hazardous materials management system is inspected and audited

Inspect, test and monitor storage tanks and pipelines for leaks or deterioration at a frequency and methodology commensurate with the environmental hazards

Implement a systematic auditing procedure for hazardous materials management on site to verify its adequacy and performance

Storage tanks are inspected as per care and maintenance schedule on PRAGMA, leaks are repaired when detected, bunding is in place

Internal and external audits of hazardous material storage and handling are carried out.

Recorded on the AHEAD system. No audit however conducted in 2018.




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Table 6: Sustainable development Strategy and Action Pan

Commitments Activities Status at end of 2017 2018 Audit findings

Compliance Comments

Yes (C)

No (NC)

NA

Financial performance: Significant contribution to the economy

Use local suppliers

Invest in community economic development

99% local procurement in 2017

Community projects in 2017 focussed on SME development and education

2018 report not finalised. Likely to be similar to 2017 2.

Environment and biodiversity: Reduce and mitigate the unavoidable impact of the mine

Set annual targets and track performance

Prepare a biodiversity action plan, plan for land use after closure

Set targets to reduce emissions and waste

Prevent or mitigate hazardous material releases

Setting targets and tracking consumption of fuel, electricity and water

Biodiversity impact areas identified, BD plan to be prepared at start-up

Tracking greenhouse gas emissions and waste volumes

Gave training and provided spill kits to clean up accidental spills

Reporting in the 2017 Stakeholder Report See previous comments on spill training.

Occupational health and radiation protection: No exposure to unacceptable harm

Medical surveillance of employees and contractors

Monitor and manage employee exposure

Maintain effective security and emergency systems

All medicals done, no new cases of occupational disease identified

No worker was exposed to over 8 mSv over 12 months in 2017

Product stored according to procedure; security and emergency systems in place, but spent resin spilled from container in Midi plant area in 2018

No changes in 2018. No changes in 2018. See comments on the resin spill in Table 5.

Occupational safety: Zero accidents

Implement the safety roadmap

Improve near-miss reporting

Safety roadmap >90% implemented

No fatality or lost-time injury in 2017

All incident frequency rate = 0

Six year LTI free.

Community involvement and

Employ local staff

Use local suppliers

Compliant with Namibian AA legislation

99% local procurement in 2017

No changes in 2018.

2 No verified by the auditor




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Compliance Comments

Yes (C)

No (NC)

NA

relations with stakeholders: Sustainable improvement of community conditions

Identify sustainable projects in consultation with stakeholders

Partner with government to improve social services (health, schools, training)

Financed an SME micro-credit scheme to support sustainable economic development in the Erongo region

Supported education projects

2018 figure not yet available but likely to be similar 3. Similar in 2018 3 Community projects in 2018 relating to SMEs, education and sport events)

Commitment to employees: Skills and diversity

Retain the current workforce

Develop skills by training employees and contractors

26% women on management committee

Reduced through retrenchments in 2017

Employee training continued, contractors included in HSE and first aid in 2017

40% women on management committee in 2017 (plus one female contractor)

No retrenchments in 2018 Ongoing in 2018 4. The following training was conducted (most of these covered during the ‘Safety Day’ in June 2018):

Re-induction

Water saving

Radiation refresher

Emergency procedure

Various other H&S topics Similar in 2018 5

Innovation: Optimise mining processes

Conduct metallurgical test work to optimise the heap leaching process

Research ended in 2017 with some testing at NUST and documentation of results

No further test work in 2018 (C&M)

High standard of corporate governance is maintained

Maintain external communication and complaints procedures

Issue annual reports to stakeholders

Offer employees and contractors an anonymous tip-off service

Procedures in place, only one complaint received in 2017 (waste at Wlotzka)

Collected information and GRI data for 2017 report, issued in 2018

Introduced a fraud hotline in October 2014, received no calls in 2017

No complaints received in 2018 2017 Stakeholder report issued. 2018 report not yet finalised – to be issued in 2019. Similar in 2018

3 Not verified 4 Training schedule provided to the auditor 5 Not verified.




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Table 7: Water Strategy and Action Pan

Commitments Tasks Status at end of 2017 2018 Audit findings

Compliance Comments

Yes (C)

No (NC)

NA

Optimised water use efficiency

Manage seawater desalination as specified in contract

Operator managed the plant as specified and supplied sufficient water to the mine

Ongoing in 2018 4

Minimal adverse impact on water quality and the environment

Monitor boreholes and extend the network as required

Monitor and evaluate water quality trends, implement control measures in case of spills or leakages

Compile biannual reports on permit compliance, water management and water quality monitoring

Current monitoring borehole network is sampled annually (March 2017)

Trends evaluated in annual report on environmental management, no significant spills occurred in 2017

Reports compiled for 2017 and submitted to DWAF, permits were last renewed in June 2016

Sampled in April 2018 Similar findings in 2018. Report submitted to DWAF in mid-2018.

Awareness of internal and external stakeholders’ issues associated with water

Identify community expectations and perceptions in relation to water

Include water awareness training in inductions for employees and contractors

Compile internal and external reports on the operation’s water performance

Be active in industry and civil organisations, e.g. Namibian Uranium Association (NUA), basin management committees

Participate in discussions with regulators to ensure that the industry’s concerns are considered

Had meetings with stakeholder groups, e.g. NUA Swakop farmers working group

Water conservation is included in inductions that are given to all new workers

Annual environmental and stakeholder reports contain water use data

Orano is a member of the NUA Sustainable Development committee and the Omaruru Basin Management Committee

No discussions held in 2017, workshops about the Water Act and regulations are planned when it commences (MAWF)

Ongoing in 2018 (last meeting in June 2018). Training provided in July 2018. 2018 report to be, however, still to be developed. Ongoing in 2018. No discussion however in 2018.




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Table 8: Public Health Strategy and Action Pan (SEMP Objectives)


Compliance Comments

Yes (C)

No (NC)

NA

Increments in the concentrations of uranium, thorium and health-relevant nuclides of their decay chains (e.g. Ra-226 and Ra-228) in air and water that originate from uranium mines, must be constrained so that the cumulative public radiation dose does not exceed 1 mSv/a above background

Monitor pathways by which radiation emissions may reach the public

Inform the public about results

Monitoring on site and at Arandis, results reported to SEMP Office

Public is informed about results by means of annual SEMP reports

See previous comments. See previous comments.

The cumulative radiation dose to members of the public and radiation workers does not exceed the legal limit

Measure radiation doses of occupationally exposed and non-exposed workers

Report results to affected workers

Measure radiation doses of occupationally exposed workers

Results are reported to workers in HSE meetings

Ongoing in 2018 Partial compliance

Results however not reported in HSE meetings. Results are included in some of the Internal Monthly Reports.

No measurable increase, directly attributable to uranium mining in the incidence

Identify and record incidences of industrial diseases amongst uranium mine workers through medical surveillance

To date Medixx has not identified any industrial diseases at annual medical examinations of Orano employees or contractors

Similar in 2018. Fitness certificates issues to each person.




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Compliance Comments

Yes (C)

No (NC)

NA

rates of industrial lung disease (including pneumoconiosis), lung and other industrial-related cancers, industrial-induced renal damage, tuberculosis, dermatitis

Table 9: Waste Management Strategy and Action Pan


Compliance Comments

Yes (C)

No (NC)

NA

Waste is characterised and risks are assessed

Carry out environmental risk assessment

Research suitable disposal methods

Identify hazardous waste types that need special storage and disposal

Compile a waste management plan based on the waste management hierarchy

RA was included in ESIA (2008)

Research and identification completed, waste management plan documented in procedure HSE ENV PR 19

No further action required during C&M Similar for 2018. Not relevant to C&M. (Procedure is however in place)

Waste is avoided and reduced at source

Compile a list of substances that can cause cancer or mutations or that are reprotoxic

Report data as required

CMR assessment carried out in 2009, no CMR substances are used in C&M

Data are included in annual environmental reports

NA to C&M




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Compliance Comments

Yes (C)

No (NC)

NA

Waste disposal follows good practice

Provide colour-coded and/or labelled bins or skips at waste sources

Train employees in correct waste separation and handling

Waste from site needs radiation clearance

Use Swakopmund or Walvis Bay landfills, not Arandis

Inspect and audit waste separation and storage

Report cases of non-compliance and follow up on corrective action

Carry out inspections at the landfill(s) and audit contractors’ compliance with procedures

Keep records of waste disposal

Colour-coded bins for domestic, hazardous and contaminated waste are in place

Training is part of induction and annual re-induction

Clearance given by Paramedic

Stopped using Wesbank to remove waste; Engineering decided to use Arandis landfill in 2017 due to low waste volume without QHSE approval

Deviations found during inspections and audit are addressed

Filing system in place for Walvis Bay hazardous waste certificates, general waste landfills do not issue certificates

Separate drums for steel, rubber and wood also provided at Engineering However, no further annual re-training is provided – except during some toolbox talks6. According to Orano this is not relevant at this stage (C&M) Non-Compliance

Continued to use Arandis (informal) landfill site to dispose of general waste. Ongoing in 2018 Partial compliance

The disposal of Waste at Arandis not reported as a NC and corrected. Inspection conducted in 2017 Partial compliance

Not all hazardous waste (and no general waste) safe disposal certificates obtained and kept on record Improvement Notes:

Stop using Arandis (informal) landfill site to dispose waste.

6 Not verified.




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Compliance Comments

Yes (C)

No (NC)

NA

Evaluate waste management practices on site and determine when (and how often) waste management re-training to be provided. Keep record of all safe disposal of waste – i.e. safe disposal certificates.

Table 10: Environmental Radiation Strategy and Action Pan


Compliance Comments

Yes (C)

No (NC)

NA

Exposures are reduced to as low as reasonably achievable (ALARA)

Identify radiation sources and document in the Radiation Management Plan (RMP)

Identify public exposure pathways and assess dose rates

Maintain exposure and medical monitoring programmes

Radiation Management Plan was updated in 2016 for C&M identifies all sources and pathways

Medical examinations and radiation monitoring carried out as scheduled in 2017

Nothing further in 2018 Ongoing in 2018

An effective radiation management system is established at the mine

Define and document duties and responsibilities

Survey radiation areas, identify sources and measure exposure

Demarcate areas >5 mSv/a and restrict access

Assess and monitor impacts on air, water, waste, food chain

Duties and responsibilities are defined in the 2016 RMP

Mine-wide surveys suspended, but dosimeters measure exposure

Completed and documented in RMP

Monitoring of air and water continued in 2017 (see annual report)

Procedures are in place and updated

Nothing further in 2018 NA to C&M NA to C&M NA to C&M, However, Uranium and Thorium are measured as part of the water monitoring programme.




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Compliance Comments

Yes (C)

No (NC)

NA

Optimise water management, air emission control, waste disposal procedures

Increments in the concentrations of uranium, thorium and health-relevant nuclides of their decay chains (e.g. Ra-226 and Ra-228) in air and water that originate from uranium mines, are constrained so that the cumulative public radiation dose does not exceed 1 mSv/a above background (SEMP)

Monitor pathways by which radiation emissions may reach the public

Inform the public about results

Monitoring on site and at Arandis, results reported to SEMP Office

Public is informed about results by means of annual SEMP reports

Radon measured in the dust See earlier comments regarding the SEMP report.

The cumulative radiation dose to members of the public and designated radiation workers does not exceed the legal limit (SEMP)

Measure radiation doses of occupationally exposed and non-exposed workers

Report results to affected workers

Measure radiation doses of occupationally exposed workers

Results are reported to all workers in HSE meetings




DESALINATION PLANT

October 2018

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2.1.3 SUMMARY OF AUDIT FINDINGS – TREKKOPJE MINE

Indicative percentages of Cs, NCs and NAs for the Environmental Action Plan commitments were

determined, as summarised below7:

Cs = 80%

NC = 1%

NA = 19%

Eight (8) “partial conformances” were noted as “conformance” and comments/reasons were

provided.

7 Please note that these are all indicative percentages and no weighting factors in terms of the relevance of a specific issue was

taken into account




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2.2 ERONGO DESALINATION PLANT AUDIT FINDINGS

2.2.1 ERONGO DESALINATION PLANT EMP AUDIT FINDINGS

Tables 11 to 12 below provide the findings from the audit relating to the commitments as stipulated in the 2016 Erongo Desalination EMP.

Table 11: General mitigation measures to be applied throughout the life-of-plant

ID Activity Aspect Impact Mitigation Compliance Comment

Y N N/A

1 All

Environmental awareness

All site personnel will be inducted prior to commencing work and sign acknowledgement of the induction. In addition to health and safety the induction will include the main points of this EMP to ensure that all workers are trained in good environmental practices and made aware that the plant is operating within the Dorob National Park. Therefore all activities are confined to within the fenced plant area and along the service track.

All employees, contractors and visitors receive induction training. Reference to Environmental Awareness in the Dorob National Park. Environmental issues are discussed in toolbox talks.

2 All employees are familiar with the emergency response plans and trained in emergency response through regular drills.

Emergency response drills are held once every ±3 months. The following drills were, amongst others done: - Chlorine leak, bomb threat, small fire. No environmental related drills are however conducted. Improvement Note:

Include environmental related emergency drills.

3 Strict access control is maintained and no visitors are allowed on site without the express permission of the plant manager.

Similar to 2017 audit finding: G4S is the contracted security company on site, controlling access, etc.

4 Resource use Wastage of water

Ensure that the ‘reduce, reuse and recycle’ philosophy is applied to minimise wastage of water resources.

Ongoing water monitoring programme (Potable and Groundwater)




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Y N N/A

Chemical and biological monitoring of the sewerage conducted by NSI.

5 Waste management

Incorrect management of waste and effluent

Apply the waste hierarchy in order of preference, i.e. waste avoidance, waste reuse, waste recycling or reclamation, waste treatment and waste disposal.

General waste and hazardous waste (i.e. empty chemical bags) get removed by Rent-a-Mess. Wesco collects the waste oil. Only one ‘safe disposal certificate was provided as proof (i.e. chemical waste to WvB hazardous waste site)8.

2 Skips are available for general waste.

A Scrap yard is used for temporary storage of waste that may be reused i.e. filters.

Non-Conformance: (similar findings as 2017)

Waste collection area

Skips (and all bins) are not labelled.

Recyclable waste and non-recyclable (and possibly some hazardous) waste all gets mixed, emptied and (apparently) disposed off by the contractors on the general Swakopmund landfill site.

No proof that the waste gets disposed of at the landfill.

Improvement Notes:

Separation of waste required (label skips and bin on site) to ensure different waste types are dealt with separately and correctly. Ensure the waste contractor disposes the waste correctly by obtaining safe disposal certificates and/or doing random spot checks. Also, ensure that all recyclable waste is taken to Rent-A-Drum and

8 Safe disposal of others – i.e. waste oil not verified by the auditor




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Y N N/A

Hazardous waste disposed off at Walvis Bay hazardous waste facility.

6 Littering, burying or burning of waste on site is prohibited. Domestic waste disposal bins are used and emptied at appropriate intervals. Waste is disposed of at the Swakopmund landfill. Use of the Wlotzkasbaken landfill is prohibited.

No safe disposal certificates (due to the fact that these do not get issued by the Swakopmund Municipality). See notes above regarding mixing and disposal of waste.

7 Storage tanks provided for domestic effluent will be pumped out regularly to avoid overflow. The sewage will be transported to the municipal treatment plant at Swakopmund.

Thanks are emptied twice per week. The level meter (transmitter) was moved from the 3rd tank to the second tank to ensure early waning notification when tanks fill up. An on-site Sewerage Treatment Plant is being investigated.

8 The required domestic and industrial effluent disposal exemption permit will be applied for and kept up to date

Similar to 2017 audit finding: Effluent Disposal Exemption permit was renewed as of 24th of May 2016.

9 Hazardous

substances

management

Hydrocarbon pollution of soil and water

Store hydrocarbons (if required on site) in bunded areas and check tanks for leaks. Vehicles to be regularly serviced to reduce oil leaks. Used solvents, oils and grease to be kept in sealed containers and recycled or disposed of at the Walvis Bay hazardous waste site. A suitable spill kit will be available and at least one person trained in hazmat response will be on site at all times. Contaminated soil or absorbent must be taken to a registered hazardous waste site and disposal certificates must be kept on file.




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Y N N/A

10 Chemical pollution of soil and water

Chemicals used for conditioning sea water for membrane treatment and for cleaning the membrane elements (antiscalant Vitec SR, hydrochloric acid, sulphuric acid, chlorine gas, caustic soda, sodium hypochlorite and sodium metabisulphite) are stored securely in dedicated areas and handled in accordance with standards and legislation. MSDS are readily available and employees are aware of their content, especially first aid and spill response measures. Periodic checks for leaks from storage tanks or containers are carried out.

Partial compliance (repeat finding from previous

audits)

When caustic is off-loaded, there are some spillage outside the lined area. This happens regularly. This does however get cleaned up9.

Sodium Hypo-chloride spillage inside the bunded area appears to be washed into the drains which get drained to the environment.

Issues not recorded on the site inspections as NCs.

Recommendation:

Construct proper bunding / increase concrete apron to avoid caustic spillage outside the bunded/lined area.

Ensure all chemical spills are properly cleaned up and (if not re-used) disposed of as hazardous waste (if rated as hazardous).

Finalise and implement an onsite checklist to track all NCs and corrective actions. This needs to be made site specific to incorporate the commitments from the EMP.

9 Not verified.




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Y N N/A

11 Visual management

Visual intrusion

Keep buildings well maintained to ensure that visual intrusion is kept to a minimum. Fencing will be inspected and maintained to ensure that it remains intact. Lighting to be maintained so that directionality is not affected by wear-and-tear and that adequate lighting is available at all times.

Buildings are being renovated after some impacts from strong winds. The fence around the site has recently been replaced. Partial Compliance (repeat from previous audits):

Environmental inspections are being undertaken and included on the Inspection checklist.

The Corrective Action Register does not have an entry for Environmental issues.

Recommendation:

Develop a site specific Corrective Action’s checklist to include all the environmental Issues from this EMP.

12 Undertake external monitoring of the visual impact as part of the Environmental Control Officer’s audit (or external EMP audit).

Refer to Partial Compliance notes in ID 11 regarding the site inspections. (An illumination survey was conducted in April 2017 as part of an Occupational Hygiene assessment).

13 Air quality – dust

Soil, flora and fauna impacts

Dust monitoring implemented during construction to continue at an adequate number of sites and monthly frequency to determine fallout dust levels.

Dust buckets all functional.

14 Noise Public nuisance

Ensure equipment is properly maintained and fitted with the necessary silencers and mufflers to avoid noise impact on residents and visitors.

Similar to 2017 audit findings: Equipment is enclosed in buildings. No complaints from Wlotzkasbaken residents.

15 Biodiversity (fauna and flora)

Impact on marine fauna and flora

To reduce the cost of chlorine as a marine growth inhibitor, pigging of intake and discharge pipelines should be regularly undertaken.

Pigging as well as divers checking chlorine dosing is conducted at least once every 6 months. Previously done in June and the next dive scheduled for October 2018.




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Y N N/A

16 The oceanic water quality monitoring programme will be maintained throughout the desalination plant operation period according to a schedule determined in the contract between Orano Namibia and the desalination plant operator. This should involve continuous monitoring of the marine environment for changes. Results should be reported on an annual basis and action taken if negative impacts are detected.

Partial compliance

Ocean water quality monitoring program includes:

Daily samples (brine) done by one laboratory on site.

Twice a year (grab sample) sent to an independent lab for full analysis including microbiology

Weekly composite sample (independent lab) – full analysis. However, all parameter (as required in the permit conditions are not analysed. Also, the standards specified in the contract are not always met (i.e. TSP higher for sample audited)

Product sample monitored automatically on SCADA

Marine environment:

Photos of outfall pipeline by divers (annually).

Marine impact monitoring was done in 2014 (i.e. the first full year of supply to NamWater), as part of an external Master’s thesis, while the plant was still producing <50% of capacity. It involved measuring the salinity of water samples taken at background sites and at various distances from the brine outlet pipe. The distribution of species under water was not part of the study.

This monitoring campaign has not been repeated yet.

Improvement notes:

Redo the monitoring on the Marine Environment ASAP (and expand the study scope where possible to include species distribution under water).




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Y N N/A

Consider to amending (improving) the EMP to include specific limits to the various parameters being monitored.

17 Impact on terrestrial fauna and flora

Avoid the presence of open water as this could attract wildlife and insects. Fix water leaks promptly. Poaching and setting of traps is strictly prohibited and anyone found poaching will be prosecuted.

Similar to 2017 audit findings: Inspect pipelines weekly for leaks. The PRAMA checklist is used for this type of inspection and incorporates commitment from EMP. Recommendation (Repeat from previous audits): Refer to Partial Compliance notes in ID 11 regarding the site inspections.

18 Snakes, scorpions and bees are not to be killed, unless they pose an immediate and unavoidable danger to human safety. The area must be vacated until the wildlife has been

moved to a safe place and released.

Similar to 2017 audit findings: Snakes and scorpions are released by trained snake handler. These are logged as incidences.

19 Traffic management

Impact on land surface, fauna and flora

Only the designated service track along the pipeline may be used for inspection of the pipe and power lines. Enforce the speed limit of 70 km/h.

20 Traffic safety and access control

Signage will be inspected periodically and maintained to ensure that it is visible and legible.

Recommendation (Repeat from previous audits): Refer to Partial Compliance notes in ID 11 regarding the site inspections.




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Table 12: Mitigation measures relating to social activities to be applied throughout the Operation phase


Y N N/A

1

Employment and retrenchment

Local employment

Benefits for local communities

Give preference to locals when filling vacancies. Abide by the conditions stipulated in the Labour Act (No. 6 of 1992) and the Affirmative Action (Employment) Act No. 29 of 1998.

One expat, the rest of the employees are all are Namibians. Local suppliers are used. (Local casual are used as and when required. Apprentices swop annually)10 . Aveng has developed and implements a “Recruitment and Selection Policy”

2 Capacity and quality of labour

Promote development of the workforce through training. Make programmes for skills development available to all workers.

Training in place. Personal development plans are completed each year.

3 Economic, psychological and social impacts of retrenchment

Develop a retrenchment policy to deal with these impacts. If possible provide counselling services three months before departure, assess training needs, and provide voluntary after-hours training programmes in appropriate alternative fields of employment.

Partial-compliance (Repeat from previous audits)

The HR office indicated that, the Retrenchment Policy is available but written in the South African context. The recruitment policy is however currently being updated to include the Namibian legislative context.

4

Local economic development

Sustainability of local economy

Dependence Implement mechanisms to promote local procurement and give preference to local service providers.

Local service providers are used 11.

5 Health and welfare

Health and radiation awareness

Spread of disease

Implement wellness programmes to ensure comprehensive HIV/AIDS and TB awareness and testing, toolbox talks or peer educator initiatives, maternal health awareness.

Annual “Wellness day” provided by NHP – attended by employees. Further details on the 2018 event could not be not verified by the auditor.

10 Not verified. 11 Not verified by the auditor




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Y N N/A

Tool Box talks - Each employee gets a chance to share info at the toolbox talks, with overall direction in terms of topics from the SHEQ department. Environmental aspects are not covered during these talks. Improvement Note:

The SHEQ department to assist with environmental topics, specifically relating to issues in the EMP.

6 Community and stakeholder relations

Promote transparency and build relationships

Lack of trust Implement a stakeholder engagement strategy to monitor relations with stakeholders, record grievances and partnerships, keep regular contact with all stakeholder groups.

Communication procedure in place. (Also part of Orano Communications). Complaints register (AVENG Group Grievances), SHEQ Incidence Register and communication register in place. No complaints received during 2018 12

7 Stakeholder concerns

Keep a register of public complaints, address and follow up complaints and give feedback to members of the public. Any grievances raised should be responded to promptly. The register for the desalination plant is kept at the Orano office in Swakopmund under the authority of the Communications Specialist.

See above comment.

The mitigating requirements relating to the closure operations (Table 4.3 of the EMP) are not applicable at this stage and were not audited.

12 Not verified by the auditor




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October 2018

Page 37

2.2.2 SPECIFIC ISSUES FOUND DURING THE SITE INSPECTION

In general, the site appeared tidy and to be clear of waste, spillages, etc. and very few activities

were taking place that could cause potentially negative environmental impacts. However a few

issues were found, as follows:

Waste management

Skips are not labelled.

Recyclable waste and non-recyclable (and possibly some hazardous) waste all gets

mixed, emptied and (apparently) disposed of by the contractors on the general

Swakopmund landfill site.

Skip does not have.

Chemical spillage

When caustic is off-loaded, there are some spillage outside the lined area. This happens

regularly.

Sodium Hypo-chloride spillage inside the bunded area appears to be washed into the

drains which get drained to the environment.

Paint storage

Paint stored in container. Any spillage of paint has the risk of flowing out of the container into the

drainage line.




DESALINATION PLANT

October 2018

Page 38

2.1.3 SUMMARY OF AUDIT FINDINGS – DESALINATION PLANT

Indicative percentages of Cs, NCs and NAs for the Desalination Plant EMP mitigation measures

were determined, as summarised below13:

Cs = 96%

NC = 4%

NA = 0

Four (4) “partial conformances” were noted as “conformance” and comments/reasons were

provided.

13 Please note that these are all indicative percentages and no weighting factors in terms of the relevance of a specific issue was

taken into account




DESALINATION PLANT

October 2018

Page 39

3 CONCLUSION

Namisun’s Werner Petrick conducted the 2018 environmental audit at the beginning of October

2018. Namisun’s scope for the audit entailed assessing compliance with the Environmental

Management Plan (EMP) for the Erongo Desalination Plant and the Environmental Action Plan

for the Trekkopje Mine. Orano developed the Environmental Action Plan in 2017, which

summarises the mitigation measures stipulated in the Trekkopje Mine EMP.

The Desalination Plant EMP and the Trekkopje Mine Environmental Action Plan were therefore

used as the basis for the audit. Namisun also audited the findings (i.e. specifically Non-

Compliances, Partial Compliances, recommendations and improvement notes) from the 2017

Trekkopje Mine EMP audit. The Care and Maintenance status of the Trekkopje Mine at the date

of the audit was an however an important consideration as it impacts the relevance of various

commitments in the Environmental Action Plan.

The following was found during the audit:

The score regarding compliance with all the commitments contained in the Trekkopje Mine

Environmental Action Plan is as follows:

Conformance: 80%

Non-conformance: 1%

Not Applicable: 19%

The score regarding compliance with all the mitigation measures contained in the desalination

plant EMP is as follows:

Conformance: 96%

Non-conformance: 4%

Not Applicable: 0%

The following should be noted:

The previous independent EMP audit was conducted by SLR Environmental Consulting

(Namibia) (Pty) Ltd in November 2016, which focused on both the Trekkopje mine and

the Desalination plant EMPs.




DESALINATION PLANT

October 2018

Page 40

The 2018 audit scope excluded a site visit to the mine and other than the desktop review,

onsite activities could not be verified by the auditor.

A number of the activities are not applicable and cannot be audited (the Trekkopje Mine

is currently in ‘Care and Maintenance’).

A total of eight “partial conformances” were noted as “conformance” for the Trekkopje

Mine audit and four for the desalination plant.

The non-conformances relate to the following issues:

Trekkopje Mine

General waste is disposed of at the Arandis (informal) landfill site.

Desalination plant

Waste management issues

o Skips are not labelled.

o Recyclable waste and non-recyclable (and possibly some hazardous) waste all gets

mixed, emptied and (apparently) disposed of by the contractors on the general

Swakopmund landfill site.

o No proof that the waste gets disposed of at the landfill.

General comments:

A number of audit findings (NCs and Partial Compliances) are repeated every year, specifically

relating to the Desalination Plant EMP. Partial Compliance issues require the same level of

attention to ensure these issues are addressed.

All issues raised in the audit therefore need to be addressed due the likely impacts being caused

to the environment. ‘Partial Compliances’ not addressed before the next Annual audit should be

recorded as NCs in the next audit report.




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APPENDIX A – ORANO AND AVENG WATER ENVIRONMENTAL POLICIES




DESALINATION PLANT

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DESALINATION PLANT

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DESALINATION PLANT

October 2018

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DESALINATION PLANT

October 2018

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ORANO MINING NAMIBIA · 2019. 12. 12. · Aveng Water is also responsible for maintenance of the...

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