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NEW CHLORALKALI PLANT IN ARANDIS Environmental Scoping, Impact Assessment and Management Plan Report Prepared for: Calculus Commodities (Pty) Ltd Prepared by: Knight Piésold Ltd. Project Number: 301-00845/02 Revision Number: Final Submission Date: 10 December 2019

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Page 1: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

NEW CHLORALKALI PLANT IN ARANDIS Environmental Scoping, Impact Assessment and Management Plan Report

Prepared for: Calculus Commodities (Pty) Ltd

Prepared by: Knight Piésold Ltd.

Project Number: 301-00845/02

Revision Number: Final Submission

Date: 10 December 2019

Page 2: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

Prepared for

Calculus Commodities (Pty) Ltd

973 Kupfer Street

Tsumeb

Namibia, 1054

Prepared by

Knight Piésold (Pty) Ltd.

Corner 43 Nelson Mandela Ave and Hugo Hahn Street

Klein Windhoek, Windhoek,

Namibia

Project Number

RI 301-00845/02

NEW CHLORALKALI PLANT IN ARANDIS

ENVIRONMENTAL SCOPING, IMPACT

ASSESSMENT AND MANAGEMENT PLAN

REPORT

Rev Description Date

A Issued in Final 10 December 2019

Page 3: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

I of I RI 301-00845/02 Rev A

10 December 2019

EXECUTIVE SUMMARY

Calculus Commodities (Pty) Ltd, a holding company of Calculus Industries (Pty) Ltd, proposes to

construct a new chloralkali plant within the Arandis Town municipality. Calculus Industries is a private

limited company, incorporated in the Republic of Namibia. The company was registered in 2017 and

is 100% Namibian owned, through Calculus Commodities (Pty) Ltd and Vigor Group (Pty) Ltd. The

Arandis Town Council zoned the property allocated to Calculus Commodities as industrial prior to the

commencement of the EIA process. The proposed plant will operate to produce industrial grade

chemicals, such as caustic soda (both lye and solid flakes), liquid chlorine, liquified carbon dioxide

and calcium chloride granules for supply to industries within Namibia and the rest of Africa. The plant

will require additional road, water, sewage and electrical support infrastructure as follows:

• Access road connected to Aloe Road in Arandis

• Water derived from a connection with the Arandis municipal line

• Sewage line connected to the manhole feeding to the nearby oxidation ponds

• Electrical supply line connected to the nearby Erongo Regional Electricity Distributor Company

(Pty) Ltd. substation

Knight Piésold Consulting (Pty) Ltd were appointed as independent environmental assessment

practitioners for the Environmental and Social Impact Assessment (ESIA) for the proposed project.

The Environmental Impact Assessment (EIA) is being undertaken in terms of the Namibian EIA

Regulations (2012), and the following listed activities (numbering as per the Regulations) are being

applied for:

• 1(b) the construction of facilities for the transmission and supply of electricity.

• 3.3 Resource extraction, manipulation, conservation and related activities.

• 8.6 Construction of industrial and domestic wastewater treatment plants and related pipeline

systems.

• 9.1 The manufacturing, storage, handling or processing of a hazardous substance defined in the

Hazardous Substances Ordinance, 1974.

• 10.1(a) The construction of oil, water, gas, petrochemical and other bulk supply pipelines.

• 10.1(b) The construction of public roads.

A public participation process was undertaken which included site notices, town notices, newspaper

advertisements, individual notifications and a public review period for the EIA.

The environmental and social impacts of the proposed plant were assessed, with potential negative

impacts being able to be reduced to low significance ratings with appropriate mitigation measures

followed. Negative impacts which were identified include, but are not limited to, contamination of

soils, localised habitat fragmentation, increased vehicular movements and increased noise and air

emission generation. Potential positive impacts were identified, such as opportunities for employment

and economic growth within Arandis as well as economic input towards the Namibian gross domestic

product.

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

i of iv RI 301-00845/02 Rev A

10 December 2019

TABLE OF CONTENTS

PAGE

Executive Summary ..................................................................................................................................... I

Table of Contents ......................................................................................................................................... i

1.0 INTRODUCTION .............................................................................................................................. 1

1.1 Project Location ............................................................................................................................... 1

2.0 EIA ROADMAP ................................................................................................................................ 3

3.0 DETAILS OF THE APPLICANT AND CONSULTANT ................................................................. 11 3.1 Details of the applicant ................................................................................................................... 11 3.2 Details of the environmental consultants ....................................................................................... 11

4.0 POLICY AND LEGAL FRAMEWORK .......................................................................................... 12

5.0 PROJECT DESCRIPTION............................................................................................................. 16 5.1 Project Overview ............................................................................................................................ 16

5.2 Project Programme and Activities .................................................................................................. 16 5.3 Project Design ................................................................................................................................ 17

5.3.1 Construction Activities ................................................................................................ 17

5.3.2 Operational Activities .................................................................................................. 17

5.3.3 Decommissioning Activities ........................................................................................ 20

5.4 Ancilliary infrastructure ................................................................................................................... 20 5.5 Waste Management ....................................................................................................................... 20

5.5.1 Solid Waste ................................................................................................................ 20 5.5.2 Gaseous Particulate Emissions .................................................................................. 21 5.5.3 Liquid Effluent ............................................................................................................. 21

5.6 Project Alternatives ........................................................................................................................ 21

5.6.1 No-Project ................................................................................................................... 21 5.6.2 Site Alternatives .......................................................................................................... 21 5.6.3 Process Alternatives ................................................................................................... 21 5.6.4 Water Supply Alternative ............................................................................................ 22 5.6.5 Electrical Supply Alternative: ...................................................................................... 22

5.6.6 Sewage Line Alternative: ............................................................................................ 22

6.0 BASELINE ENVIRONMENT ......................................................................................................... 23

6.1 Topography & Drainage ................................................................................................................. 23 6.2 Geology .......................................................................................................................................... 23 6.3 Soils................................................................................................................................................ 24 6.4 Climate ........................................................................................................................................... 24 6.5 Land Use ........................................................................................................................................ 24 6.6 Biodiversity ..................................................................................................................................... 24

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

ii of iv RI 301-00845/02 Rev A

10 December 2019

6.6.1 Flora ............................................................................................................................ 25 6.6.2 Fauna .......................................................................................................................... 25

6.7 Air Quality ....................................................................................................................................... 27

6.8 Noise .............................................................................................................................................. 27 6.9 Water Quality/Sources ................................................................................................................... 27

6.9.1 Surface Water ............................................................................................................. 27 6.9.2 Groundwater ............................................................................................................... 27

6.10 Socio-economic .............................................................................................................................. 28

6.10.1 Erongo Region ............................................................................................................ 28 6.10.2 Arandis Town .............................................................................................................. 28

6.11 Heritage .......................................................................................................................................... 28 6.11.1 Desktop Assessment: ................................................................................................. 29 6.11.2 Field Survey: ............................................................................................................... 31

7.0 PUBLIC CONSULTATION ............................................................................................................ 33 7.1 Methodology ................................................................................................................................... 33

7.1.1 Notification .................................................................................................................. 33 7.1.2 Media Coverage ......................................................................................................... 33

7.1.3 Review Period ............................................................................................................ 33 7.1.4 Interested and Affected Parties .................................................................................. 33

7.2 Comments and Responses ............................................................................................................ 33

8.0 IMPACT ASSESSMENT................................................................................................................ 34 8.1 Defining the nature of the impact ................................................................................................... 34

8.1.1 Assessing Significance ............................................................................................... 34 8.2 Impact Assessment per Environmental Aspect ............................................................................. 40

8.2.1 Topography & Drainage ............................................................................................. 40

8.2.2 Geology ...................................................................................................................... 40

8.2.3 Climate ........................................................................................................................ 40 8.2.4 Land Use .................................................................................................................... 40

8.2.5 Biodiversity ................................................................................................................. 40 8.2.6 Air Quality ................................................................................................................... 41 8.2.7 Noise ........................................................................................................................... 41

8.2.8 Water Quality .............................................................................................................. 41 8.2.9 Socio-Economic .......................................................................................................... 41

8.2.10 Heritage ...................................................................................................................... 42

9.0 ENVIRONMENTAL MANAGEMENT PLAN.................................................................................. 43

10.0 CONCLUSION ............................................................................................................................... 53

11.0 REFERENCES ............................................................................................................................... 54

12.0 CERTIFICATION ........................................................................................................................... 55

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

iii of iv RI 301-00845/02 Rev A

10 December 2019

TABLES

Table 1: EIA Roadmap (using MET Reporting Guideline) ............................................................................ 3 Table 2: Details of the Applicant and Environmental Assessment Practitioner .......................................... 11 Table 3: Listed activities being applied for .................................................................................................. 12

Table 4: Other potentially relevant legislation (Dr Lima Maartens) ............................................................. 14 Table 5: Proposed Project Schedule (Calculus Industries (Pty) Ltd, 2019) ................................................ 16 Table 6: Table of Fauna Expected to occur within the vicinity of the Project Area (Speiser, 2012) ........... 26 Table 7: Impact Nature ................................................................................................................................ 34 Table 8: Ranking Criteria ............................................................................................................................ 35

Table 9: Significance Definitions ................................................................................................................. 36 Table 10: Impact Significance ..................................................................................................................... 37 Table 11: Environmental Management Plan - Construction Phase ............................................................ 44

Table 12: Environmental Management Plan - Operation Phase ................................................................ 47 Table 13: Environmental Management Plan - Closure Phase .................................................................... 51

FIGURES

Figure 1: Locality map of the proposed Chloralkali Plant ............................................................................. 2

Figure 2: Verification received from MET .................................................................................................... 13 Figure 3: Simplified production process anticipated for the proposed Chloralkali plant ............................. 19 Figure 4: Landscape of the proposed project site ....................................................................................... 23

Figure 5: Photograph of floral community present on the site .................................................................... 25 Figure 6: Archaeological sites in the vicinity of Arandis, Erongo Region, shown as black dots (data

from Namib Desert Archaeological Survey), in relation to the Arandis town limits and

the footprint area of the proposed Arandis Chloralkali Plant and its related..................... 30

Figure 7: Mid-Pleistocene stone artefacts from the footprint area of the proposed Arandis Chloralkali

Plant (scale 1:5), dorsal view on left with obverse on right. .............................................. 31

Figure 8: The layout of the proposed Arandis Chloralkali Plant and its related linear infrastructure

corridors, indicating the distribution of archaeological sites located during the field

survey. ............................................................................................................................... 32

APPENDICES

Annexure A: Arandis Town Planning Map

Annexure B: Curriculum Vitae

Annexure C: Plant and Services Layout Map

Annexure D: Prefeasibility Study: Technical Extract

Annexure E: Letter from Arandis Town Council

Annexure F: Heritage Specialist Report

Annexure G: Public Participation

Annexure H: Proof of Payment

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

iv of iv RI 301-00845/02 Rev A

10 December 2019

ABBREVIATIONS

AIDS ................................................................................................. Acquired Immune Deficiency Syndrome

BID .......................................................................................................... Background Information Document

EPC ........................................................................................... Engineering, Procurement and Construction

ESIA .......................................................................................Environmental and Social Impact Assessment

EIA ........................................................................................................... Environmental Impact Assessment

EMP ............................................................................................................ Environmental Management Plan

Erongo RED ....................................................... Erongo Regional Electricity Distributor Company (Pty) Ltd

ESA ....................................................................................................................................... Early Stone Age

GN .................................................................................................................................... Government Notice

HIV ............................................................................................................... Human Immunodeficiency Virus

I&APs ............................................................................................................ Interested and Affected Parties

MET ...................................................................................................... Ministry of Environment and Tourism

MSA ..................................................................................................................................... Middle Stone Age

MVA ................................................................................................................................... megavolt amperes

mtpa ........................................................................................................................ metric tonnes per annum

PPE ............................................................................................................... Personal Protective Equipment

SADC ..........................................................................................Southern African Development Community

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

1

RI 301-00845/02 Rev A

10 December 2019

1.0 INTRODUCTION

Calculus Commodities (Pty) Ltd, a holding company of Calculus Industries (Pty) Ltd, hereafter

referred to as Calculus Commodities, has identified a gap within the manufacturing industry, whereby

industrial users currently need to import specialty materials and chemicals for production processes

from overseas. Calculus proposes to bridge the aforementioned gap by producing and supplying

specialty chemicals to industry within Namibia, and in doing so, promote further industrialization within

the Namibian- as well as within the South African Development Community (SADC) economy. In

order to achieve this, Calculus Commodities proposes the development of a new chloralkali plant.

1.1 PROJECT LOCATION

The proposed site for the new chloralkali plant is in Arandis, within the Erongo Region of Namibia.

The proposed location is highlighted in Figure 1 below.

The demarcated site is located south-west of the town of Arandis and encompasses a total area of

15 hectares (ha). The plant is anticipated to have a footprint of 11.2 ha.

The Arandis Town Council has demarcated the site and zoned the land as “Industrial”, for the

intended purpose of the chloralkali plant in a commissioned town planning study undertaken by

Stubenrauch Planning Consultants (2016), with the layout provided as Annexure A.

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Calculus Commodities (Pty) Ltd

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Environmental Scoping, Impact Assessment And Management Plan Report

2

RI 301-00845/02 Rev A

10 December 2019

Figure 1: Locality map of the proposed Chloralkali Plant

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

3

RI 301-00845/02 Rev A

10 December 2019

2.0 EIA ROADMAP

The EIA was prepared using the requirements of the Namibian EIA Regulations (2012) as well as the

Reporting Guideline for Environmental Assessment issued by the MET in 2018. The latter includes a

review checklist which is used in this section as a roadmap to locate the sections within the EIA in

which the aspects are addressed, as applicable.

Table 1: EIA Roadmap (using MET Reporting Guideline)

Aspect to be addressed Section of EIA

1. Description of the Project

The Objectives and Physical Characteristics of the Project

1.1 Are the need for and objectives of the project explained? 1.0

1.2 Is the programme for implementation of the project described, detailing the estimated length of time and start and finish dates for construction, operation and decommissioning?

5.2

1.3 Are all the main components of the project described? 5.0

1.4 Is the location of each project component identified, using maps, plans and diagrams as necessary?

1.1

Annexure C

1.5 Is the layout of the site (or sites) occupied by the project described? (including ground levels, buildings, other physical structures, underground works, coastal works, storage facilities, water features, planting, access corridors, boundaries)

5.1

5.3.1

1.6 For linear projects, are the route corridor, the vertical and horizontal alignment and any tunnelling and earthworks described?

5.3.1

5.4

1.7 Are the activities involved in construction of the project all described? 5.3.1

1.8 Are the activities involved in operation of the project all described? 5.3.2

1.9 Are the activities involved in decommissioning the project all described? (e.g. closure, dismantling, demolition, clearance, site restoration, site re-use, etc.)

5.3.3

1.10 Are any additional services required for the project all described? (e.g. transport access, water, sewerage, waste disposal, electricity, telecoms) or developments (e.g. roads, harbours, powerlines, pipelines)

5.3.1

5.4

1.11 Are any developments likely to occur as a consequence of the project identified? (e.g. new housing, roads, water or sewerage infrastructure, aggregate extraction)

5.3

5.4

1.12 Are any existing activities which will alter or cease as a consequence of the project identified?

N/A

1.13 Are any other existing or planned developments with which the project could have cumulative effects identified? Project is associated with a road and pipeline. Cumulative impacts to air quality and noise have been noted.

5.1

8.2.6

8.2.7

The Size of the Project

1.14 Is the area of land occupied by each of the permanent project components quantified and shown on a scaled map? (including any associated access arrangements, landscaping and ancillary facilities).

1.1

Annexure C

1.15 Is the area of land required temporarily for construction quantified and mapped? 5.3.1

1.16 Is the reinstatement and after use of land occupied temporarily for operation of the project described? (e.g. land used for mining or quarrying)

5.3.3

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

4

RI 301-00845/02 Rev A

10 December 2019

Aspect to be addressed Section of EIA

1. Description of the Project

1.17 Is the size of any structures or other works developed as part of the project identified? 5.3.1

5.4

1.18 Is the form and appearance of any structures or other works developed as part of the project described?

5.3.1

5.4

1.19 For urban or similar development projects, are the numbers and other characteristics of new populations or business communities described?

N/A

1.20 For projects involving the displacement of people or businesses, are the numbers and other characteristics of those displaced described?

N/A

1.21

For new transport infrastructure or projects generating substantial traffic flows, is the type, volume, temporal pattern and geographical distribution of new traffic generated or diverted as a consequence of the project described? It is recommended that a Traffic Impact Assessment and Management Plan be undertaken during the Feasibility Study

No

1.22 Are all the processes involved in operating the project described? (e.g. manufacturing or engineering processes, primary raw material production, agricultural or forestry production methods, extraction processes)

5.3.2.2

1.23 Are the types and quantities of outputs produced by the project described? 5.3.2.3

1.24 Are the types and quantities of raw materials and energy needed for construction and operation discussed?

5.3.2.1

1.25 Are the environmental implications of the sourcing of raw materials discussed?

No, as the raw materials are sourced from pre-existing industrial suppliers. No

1.26 Is efficiency in use of energy and raw materials discussed? 5.6.3

1.27 Are any hazardous materials used, stored, handled or produced by the project identified and quantified?

Annexure D

1.28

Are the transport of raw materials to the project and the number of traffic movements involved discussed? (including road, rail and sea transport)

• during construction • during operation • during decommissioning

It is recommended that a Traffic Impact Assessment and Management Plan be undertaken during the Feasibility Study

5.3

1.29

Is employment created or lost as a result of the project discussed?

• during construction • during operation • during decommissioning

8.2.9

1.30

Are the access arrangements and the number of traffic movements involved in bringing workers and visitors to the project estimated?

• during construction • during operation • during decommissioning

It is recommended that a Traffic Impact Assessment and Management Plan be undertaken during the Feasibility Study

5.3

1.32 Is the housing and provision of services for any temporary or permanent employees for the project discussed? (relevant for projects requiring migration of a substantial new workforce into the area for either construction or the long term)

5.3.1

Residues and Emissions

1.33

Are the types and quantities of solid waste generated by the project identified?

• during construction • during operation • during decommissioning

5.5

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Environmental Scoping, Impact Assessment And Management Plan Report

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RI 301-00845/02 Rev A

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Aspect to be addressed Section of EIA

1. Description of the Project

1.34 Are the composition and toxicity or other hazards of all solid wastes produced by the project discussed?

5.5.1

1.35 Are the methods for collecting, storing, treating, transporting and finally disposing of these solid wastes described?

5.5.1

1.36 Are the locations for final disposal of all solid wastes discussed? 5.5.1

1.37

Are the types and quantities of liquid effluents generated by the project identified? (including site drainage and run-off, process wastes, cooling water, treated effluents, sewerage)

• during construction • during operation • during decommissioning

5.5.3

1.38 Are the composition and toxicity or other hazards of all liquid effluents produced by the project discussed?

5.5.3

1.39 Are the methods for collecting, storing, treating, transporting and finally disposing of these liquid effluents described?

5.5.3

1.40 Are the locations for final disposal of all liquid effluents discussed? 5.5.3

1.41

Are the types and quantities of gaseous and particulate emissions generated by the project identified? (including process emissions, fugitive emissions, emissions from combustion of fossil fuels in stationary and mobile plant, emissions from traffic, dust from materials handling, odours)

• during construction • during operation • during decommissioning.

5.5.2

1.42 Are the composition and toxicity or other hazards of all emissions to air produced by the project discussed?

5.5.2

1.43 Are the methods for collecting, treating and finally discharging these emissions to air described?

5.5.2

1.44 Are the locations for discharge of all emissions to air identified and the characteristics of the discharges identified? (e.g. height of stack, velocity and temperature of release)

5.5.2

1.45 Is the potential for resource recovery from wastes and residues discussed? 5.5.2

1.46 Are any sources of noise, heat, light or electromagnetic radiation from the project identified and quantified? (including equipment, processes, construction works, traffic, lighting, etc.

6.8

1.47 Are the methods for estimating the quantities and composition of all residues and emissions identified and any difficulties discussed?

6.7

1.48 Is the uncertainty attached to estimates of residues and emissions discussed? N/A

1.49

Are any risks associated with the project discussed?

• risks from handling of hazardous materials • risks from spills fire, explosion • risks of traffic accidents • risks from breakdown or failure of processes or facilities • risks from exposure of the project to natural disasters (earthquake, flood, etc.)

A detailed health and safety plan (including emergency response) must be compiled by the client

8.2

9.0

1.50 Are measures to prevent and respond to accidents and abnormal events described? (preventive measures, training, contingency plans, emergency plans, etc.)

2. Consideration of Alternatives

2.1 Is the process by which the project was developed described and are alternatives 5.6.3

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Aspect to be addressed Section of EIA

1. Description of the Project

considered during this process described?

2.2 Is the baseline situation in the No Project situation described? 5.6.1

2.3 Are the alternatives realistic and genuine alternatives to the project? 5.6

2.4 Are the main reasons for choice of the proposed project explained, including any environmental reasons for the choice?

5.6

2.5 Are the main environmental effects of the alternatives compared with those of the proposed project?

5.6

3. Description of Environment Likely to be Affected by the Project

Aspects of Environment

3.1

Are the existing land uses of the land to be occupied by the project and the surrounding area described and are any people living on or using the land identified? (including residential, commercial, industrial, agricultural, recreational and amenity land uses and any buildings, structures or other property)

6.5

3.2 Are the topography, geology and soils of the land to be occupied by the project and the surrounding area described? 6.1

6.2 3.3

Are any significant features of the topography or geology of the area described and are the conditions and use of soils described?

3.4 Are the fauna and flora and habitats of the land to be occupied by the project and the surrounding area described and illustrated on appropriate maps?

6.6

3.5 Are species populations and characteristics of habitats that may be affected by the project described and are any designated or protected species or areas defined?

3.6 Is the water environment of the area described? (including running and static surface waters, groundwaters, estuaries, coastal waters and the sea and including run off and drainage. NB not relevant if water environment will not be affected by the project)

6.9

3.7 Are the hydrology, water quality and use of any water resources that may be affected by the project described? (including use for water supply, fisheries, angling, bathing, amenity, navigation, effluent disposal)

6.9

3.8 Are local climatic and meteorological conditions and existing air quality in the area described? (NB not relevant if the atmospheric environment will not be affected by the project)

6.4

6.7

3.9 Is the existing noise climate described? (NB not relevant if acoustic environment will not be affected by the project)

6.8

3.10 Is the existing situation regarding light, heat and electromagnetic radiation described? (NB not relevant if these characteristics of the environment will not be affected by the project)

N/A

3.11 Are any material assets in the area that may be affected by the project described? (including buildings, other structures, mineral resources, water resources)

6.9

3.12 Are any locations or features of archaeological, historic, architectural or other community or cultural importance in the area that may be bisected the project described, including any designated or protected sites?

6.11

3.13 Is the landscape or townscape of the area that may be affected by the project described, including any designated or protected landscapes and any important views or viewpoints?

6.1

3.14 Are demographic, social and socio-economic conditions (e.g. employment) in the area described?

6.10

3.15 Are any future changes in any of the above aspects of the environment that may occur in the absence of the project described? (the so- called Moving Baseline or No Project situation)

5.6.1

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Aspect to be addressed Section of EIA

1. Description of the Project

Data Collection and Survey Methods

3.16 Has the study area been defined widely enough to include all the area likely to be significantly affected by the project?

1.1

5.0

3.17 Have all relevant national and local agencies been contacted to collect information on the baseline environment?

Annexure F

3.18 Have sources of data and information on the existing environment been adequately referenced?

11.0

3.19

Where surveys have been undertaken as part of the Environmental Studies to characterise the baseline environment are the methods used, any difficulties encountered and any uncertainties in the data described?

No difficulties or uncertainties were noted by the heritage specialist

6.11

3.20 Were the methods used appropriate for the purpose? Annexure

F

3.21

Are any important gaps in the data on the existing environment identified and the means used to deal with these gaps during the assessment explained?

No gaps in data were noted by the heritage specialist

N/A

3.22

If surveys would be required to adequately characterise the baseline environment but they have not been practicable for any reason, are the reasons explained and proposals set out for the surveys to be undertaken at a later stage?

Physical surveys were undertaken for the heritage study.

N/A

4. Description of the Likely Significant Effects of the Project

Scoping of Effects

4.1 Is the process by which the scope of the Environmental Studies was defined described? 4.0

4.2 Is it evident that a systematic approach to scoping was adopted?

4.3 Is it evident that full consultation was carried out during scoping? Annexure

G

4.4 Are the comments and views of consultees presented? Annexure

G

Prediction of Direct Effects

4.5 Are direct, primary effects on land uses, people and property described and where appropriate quantified?

8.2.4

4.6 Are direct, primary effects on geological features and characteristics of soils described and where appropriate quantified?

8.2.1

8.2.2

4.7 Are direct, primary effects on fauna and flora and habitats described and where appropriate quantified?

8.2.5

4.8 Are direct, primary effects on the hydrology and water quality of water features described and where appropriate quantified?

8.2.8

4.9 Are direct, primary effects on uses of the water environment described and where appropriate quantified?

8.2.8

4.10 Are direct, primary effects on air quality and climatic conditions described and where appropriate quantified?

8.2.3

8.2.6

4.11 Are direct, primary effects on the acoustic environment (noise or vibration) described and where appropriate quantified?

8.2.7

4.12 Are direct, primary effects on heat, light or electromagnetic radiation described and where N/A

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appropriate quantified?

4.13 Are direct, primary effects on material assets and depletion of non-renewable natural resources (e.g. fossil fuels, minerals) described?

N/A

4.14 Are direct, primary effects on locations or features of cultural importance described? 8.2.10

4.15 Are direct, primary effects on the quality of the landscape and on views and viewpoints described and where appropriate illustrated?

8.2.4

4.16 Are direct, primary effects on demography, social and socio-economic condition in the area described and where appropriate quantified?

8.2.9

Prediction of Secondary, Temporary, Short Term, Long Term, Accidental, Indirect, Cumulative Effects

4.17

Are secondary effects on any of the above aspects of the environment caused by primary effects on other aspects described and where appropriate quantified? (e.g. effects on fauna, flora or habitats caused by soil, air or water pollution or noise; effects on uses of water caused by changes in hydrology or water quality; effects on archaeological remains caused by desiccation of soils)

8.0

4.18 Are temporary, short term effects caused during construction or during time limited phases of project operation or decommissioning described?

4.19 Are permanent effects on the environment caused by construction, operation or decommissioning of the project described?

4.20 Are long-term effects on the environment caused over the lifetime of project operations or caused by build-up of pollutants in the environment described?

4.21 Are effects which could result from accidents, abnormal events or exposure of the project to natural or man-made disasters described and where appropriate quantified?

4.22 Are effects on the environment caused by activities ancillary to the main project described?

4.25 Are indirect effects on the environment caused by consequential development described?

4.24 Are cumulative effects on the environment off the project together with other existing or planned developments in the locality described?

4.25 Are the geographic extent, duration, frequency, reversibility and probability of occurrence of each effect identified as appropriate?

Prediction of Effects on Human Health and Sustainable Development Issues

4.26 Are primary and secondary effects on human health and welfare described and where appropriate quantified?

8.2.9

4.27 Are impacts on issues such as biodiversity, global climate change and sustainable development discussed where appropriate?

8.2.5

8.2.3

Evaluation of the Significance of Effects

4.28 Is the significance or importance of each predicted effect discussed in terms of its compliance with legal requirement and the number, importance and sensitivity of people, resources or other receptors affected?

8.0

4.29 Where effects are evaluated against legal standards or requirements are appropriate local, national or international standards used and relevant guidance followed?

4.30 Are positive effects on the environment described as well as negative effects?

4.31 Is the significance of each effect clearly explained?

4.32 Are methods used to predict effects described and are the reasons for their choice, any difficulties encountered and uncertainties in the results discussed?

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4.33 Where there is uncertainty about the precise details of the project and its impact on the environment are worst case predictions described?

Yes

4.34 Where there have been difficulties in compiling the data needed to predict or evaluate effects are these difficulties acknowledged and their implications for the results discussed?

N/A

4.35 Is the basis for evaluating the significance or importance of impacts clearly described? 8.0

4.36 Are impacts described on the basis that all proposed mitigation has been implemented i.e. are residual impacts described?

8.0

4.47 Is the level of treatment of each effect appropriate to its importance for the development consent decision? Does the discussion focus on the key issues and avoid irrelevant or unnecessary information?

8.0

4.48 Is appropriate emphasis given to the most severe, adverse effects of the project with lesser emphasis given to less significant effects?

8.0

5. DESCRIPTION OF MITIGATION

5.1 Where there are significant adverse effects on any aspect of the environment is the potential for mitigation of these effects discussed?

9.0

5.2 Are any measures which the Developer proposes to implement to mitigate effects clearly described and their effect on the magnitude and significance of impacts clearly explained?

5.3 If the effect of mitigation measures on the magnitude and significance of impacts is uncertain is this explained?

5.4 Is it clear whether the Developer has made a binding commitment to implement the proposed mitigation or that the mitigation measures are just suggestions or recommendations?

5.5 Are the Developer's reasons for choosing the proposed mitigation explained?

5.6 Are responsibilities for implementation of mitigation including funding clearly defined?

5.7 Where mitigation of significant adverse effects is not practicable, or the Developer has chosen not to propose any mitigation are the reasons for this clearly explained?

5.8

Is it evident that the EIA Team and the Developer have considered the full range of possible approaches to mitigation including measures to reduce or avoid impacts by alternative strategies or locations, changes to the project design and layout, changes to methods and processes, "end of pipe" treatment, changes to implementation plans and management practices, measures to repair or remedy impacts and measures to compensate impacts?

5.9 Are arrangements proposed to monitor and manage residual impacts?

5.10 Are any negative effects of the proposed mitigation described?

6. NON-TECHNICAL SUMMARY

6.1 Does the Environmental information include a Non-Technical Summary?

Exe

cu

tive

Su

mm

ary

6.2 Does the Summary provide a concise but comprehensive description of the project, its environment, the effects of the project on the environment and the proposed mitigation?

6.3 Does the Summary highlight any significant uncertainties about the project and its environmental effects?

6.4 Does the Summary explain the development consent process for the project and the role of EIA in this process?

6.5 Does the Summary provide an overview of the approach to the assessment?

6.6 Is the Summary written in non-technical language, avoiding technical terms, detailed data

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and scientific discussion?

6.7 Would it be comprehensible to a lay member of the public?

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3.0 DETAILS OF THE APPLICANT AND

CONSULTANT

3.1 DETAILS OF THE APPLICANT

Table 2: Details of the Applicant and Environmental Assessment Practitioner

Applicant Environmental Assessment

Practitioner

Name of company / organization

Calculus Commodities (Pty) Ltd Knight Piésold Consulting (Pty) Ltd

Contact person Elias Sipunga Lloyd Lynch / Tania Oosthuizen

Telephone

Email

+264 67 227 574

[email protected]

+264 61 307 297

+27 11 806 7111

[email protected]

[email protected]

Physical address 973 Kupfer street

Tsumeb

Namibia

Corner 45 Nelson Mandela Ave and Hugo Hann Street,

Klein Windhoek

Windhoek

Postal address PO Box 1504

Tsumeb

Namibia

PO Box 86062

Eros

Windhoek

3.2 DETAILS OF THE ENVIRONMENTAL CONSULTANTS

Knight Piésold is an international consulting company providing engineering and environmental services

for the mining, power, water, transportation and construction sectors. Knight Piésold was founded in

South Africa in 1921 and has expanded over the world in response to project requirements, with 30

offices established in 15 countries, namely Argentina, Australia, Botswana, Canada, Chile, China,

Colombia, Ghana, Namibia, Peru, South Africa, Swaziland, the USA, and Vietnam.

Knight Piésold has an office in Windhoek, Namibia and provide engineering and environmental services

to the transportation, mining and water sectors. The team has been involved in various environmental

projects across Namibia. Knight Piésold Consulting (Pty) Ltd has been appointed as environmental

practitioners to undertake the Environmental study for the proposed new chloralkali plant in Arandis.

Curriculum vitae of Lloyd Lynch and Tania Oosthuizen are available in Annexure B.

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4.0 POLICY AND LEGAL FRAMEWORK

The overarching legislative requirements for this EIA report are contained within the Environmental

Management Act. The regulations under section 56 of the Environmental Management Act (GN No. 30

of 2012) and the “List of activities that may not be undertaken without Environmental Clearance” under

section 27 of the Environmental Management Act were published (GN No. 29 and 30 of 2012;

Government of the Republic of Namibia, 2012). Table 3 below lists the activities that cannot be

undertaken without an Environmental Clearance Certificate (ECC), and which are relevant to the

proposed project.

Table 3: Listed activities being applied for

Listed activity Expected activity

Energy Generation, Transmission and Storage

1.(b) The construction of facilities for the transmission and supply of electricity

New powerlines to be constructed to service the proposed site

Mining and Quarrying Activities

3.3 Resource extraction, manipulation, conservation and related activities.

Processing of input materials on the plant site to develop end products

Water resources development

8.6 Construction of industrial and domestic wastewater treatment plants and related pipeline systems

Development of a sewer pump scheme and line from the proposed site to the nearby oxidation ponds

Infrastructure

9.1 The manufacturing, storage, handling or processing of a hazardous substance defined in the Hazardous Substances Ordinance, 1974.

Utilisation, storage and production of hydrochloric acid

Infrastructure

10.1(a) The construction of oil, water, gas,

petrochemical and other bulk supply pipelines.

New water pipeline to provide the proposed site

with water

10.1(b) The construction of public roads. Development of a new access road to the

proposed site

Knight Piésold submitted an online application to the MET on 13 September 2019, and received the

confirmation presented in Figure 2 below, which advised that an EIA/EMP process need be undertaken.

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Figure 2: Verification received from MET

This EIA also recognises that the project is proposed within the context of numerous other legislations,

policies and international agreements. Such potentially relevant legislation is listed below. This

information has been compiled by Dr Lima Maartens based on her experience as a lead environmental

practitioner in Namibia.

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Table 4: Other potentially relevant legislation (Dr Lima Maartens)

National Law

Acts of Parliament, Regulations, Ordinances, Proclamations

The Constitution of the Republic of Namibia 1990

Employees’ Compensation Act 30 of 1941 (and General Regulations 1961) (Amendment Act 5 of 1995, that came into force on 1 March 1995, amends the Act substantially and changes its name from the Workmen’s Compensation Act to the Employees’ Compensation Act)

Water Act 54 of 1956 (as made applicable in Namibia)

Soil Conservation Act 76 of 1969 (as amended; Section 13 is amended by the Forest Act 12 of 2001) (and the Regulations 1973))

General Health Regulations (Government Notice 121 of 14 October 1969 as amended)

Hazardous Substance Ordinance 14 of 1974 (and the General Regulations 1979)

Nature Conservation Ordinance 4 of 1975 (and the Regulations Relating to Nature Conservation 1976 and the Amendment of Regulations 2010)

Atmospheric Pollution Prevention Ordinance 11 of 1976 (and the Regulations concerning the Form of an Application for a Registration Certificate or Provisional Registration Certificate and the Form of the Registration Certificate and Provisional Registration Certificate 1976)

Regional Councils Act 22 of 1992 (and Amendment Acts 17 of 1997, 30 of 2000, 12 of 2002, 12 of 2010 and the Second Regional Councils Amendment Act 16 of 2010)

Local Authorities Act 23 of 1992 (and Local Authorities Amendment Act 3 of 1997 and Second Amendment Act 14 of 1997, and the Local Authorities Amendment Acts 24 of 2000, 17 of 2002, 14 of 2004, and 2 of 2009) (and the Model Water Supply Regulations 1996, the Model Sewerage and Drainage Regulations 1996, and the Model Electricity Supply Regulations 1996)

Social Security Act 34 of 1994 (as amended by the State-owned Enterprises Governance Act 2 of 2006 and the Labour Act 11 of 2007 (and the General Regulations 1995))

Nature Conservation Amendment Act 5 of 1996

Affirmative Action (Employment) Act 29 of 1998 (as amended by Act 6 of 2007 and the Labour Act 11 of 2007) (and the General Regulations 1999)

Roads Authority Act 17 of 1999 (and the Roads Authority Amendment Act 20 of 2004)

National Heritage Act 27 of 2004 (as amended by the State-owned Enterprises Governance Act 2 of 2006) (and the National Heritage Regulations 2005)

Environmental Management Act 7 of 2007 (and the Environmental Impact Assessment Regulations 2012)

Labour Act 11 of 2007 (and the Labour Amendment Act 2 of 2012) (and the Regulations relating to the Health and Safety of Employees at Work 1997; and Labour General Regulations 2008)

Plant Quarantine Act 7 of 2008

Disaster Risk Management Act 10 of 2012 (and the Disaster Risk Management Regulations 2013)

Water Resources Management Act 11 of 2013 (promulgated, but not yet implemented)

Public and Environmental Health Act 1 of 2015 (promulgated, but not yet implemented)

Policies, Guidelines, National Strategies & Action Plans

Policies

Conservation of Biotic Diversity and Habitat Protection 1994

Namibia: National Code on HIV/AIDS in Employment 2000

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National Policy on HIV/AIDS 2007

National Policy on Human-Wildlife Conflict Management 2009

National Gender Policy 2010 - 2020

National Health Policy Framework 2010-2020 - “towards quality health and social welfare services”

National Policy on Climate Change for Namibia 2011

Guidelines

Draft Water Quality Guidelines and Standards for Potable Water, as well as Water Quality Standards for Effluent 2008

Petroleum Products Regulations, 2000 Guidelines for Consumer Installations

National Strategies & Action Plans

Namibia’s Green Plan 1992

Vision 2030 2004

Namibia’s 5th National Development Plan (NDP5) – Working together towards prosperity (2017/18 – 2021/22)

International Law

African Union (AU)

African Charter on Human and Peoples' Rights 1981

Revised (Algiers) Convention on the Conservation of Nature and Natural Resources 2003

United Nations (UN) / International Conventions

International Plant Protection Convention (IPPC) 1951 (as last amended in 1997)

Declaration of the United Nations Conference on the Human Environment 1972

Vienna Convention for the Protection of the Ozone Layer 1985 and Montreal Protocol on Substances that Deplete the Ozone Layer 1987; Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer, Adopted at the Fourth Meeting of the Parties at Copenhagen on 25 November 1992; Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer, Adopted by the Ninth Meeting of the Parties at Montreal on 17 September 1997; and Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer, Beijing, 3 December 1999

Convention on Biological Diversity (CBD) 1992

United Nations (UN) Framework Convention on Climate Change 1992; Kyoto Protocol to the UN Framework Convention on Climate Change 1997; Paris Agreement (United Nations Framework Convention on Climate Change) 2016

Convention for the Safeguarding of the Intangible Cultural Heritage 2003

Convention on the Protection and Promotion of the Diversity of Cultural Expressions 2005

International Best Practice

International Finance Corporation (IFC) Environmental Health and Safety (EHS) Guidelines 2007

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5.0 PROJECT DESCRIPTION

The information provided within this chapter was obtained from the Calculus Chloralkali Plant:

Prefeasibility Study (Calculus Industries (Pty) Ltd, 2019) and the Design and Cost Estimate Report:

Proposed Chlor-Alkali Plant in Arandis, Erongo Region (Ambo Consulting Engineers (Pty) Ltd, 2019)

reports.

5.1 PROJECT OVERVIEW

The proposed project will entail the construction of a new chloralkali plant within the Arandis Town

municipality, and associated infrastructure required to service the plant (road, water, sewage and

electrical lines). The site layout will be that of a standard chloralkali plant, comprised of several chemical

storage areas, processing areas, offices and parking (Annexure C). Access to the plant will be provided

by a new road, to be constructed as part of the ancillary infrastructure leading off from Aloe Road.

5.2 PROJECT PROGRAMME AND ACTIVITIES

Upon completion of the bankable feasibility studies and once the financial closure is determined, it is

anticipated that the plant will be delivered within a 22-24-month period. The proposed project schedule

for the proposed chloralkali plant is described in Table 5 below:

Table 5: Proposed Project Schedule (Calculus Industries (Pty) Ltd, 2019)

Task Expected Duration

Estimated Start Estimated Finish

Design and construction

of chloralkali plant

1120 days 1 December 2017 17 March 2022

Concept studies 6 months 1 December 2017 17 May 2018

Prefeasibility studies 12 months 18 May 2018 18 April 2019

Feasibility studies 6 months 02 April 2019 12 December 2019

Basic engineering 5 months 20 March 2020 17 July 2020

Detailed engineering 10.5 months 20 July 2020 07 May 2021

Procurement 330 days 20 July 2020 21 October 2021

Construction 285 days 29 October 2020 01 December 2021

Pre-commissioning 55 days 02 December 2021 16 February 2022

Commissioning and start-

up

10 days 17 February 2022 02 March 2022

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5.3 PROJECT DESIGN

5.3.1 CONSTRUCTION ACTIVITIES

The construction phase is anticipated to take approximately 13 months, from July 2020 to August 2021.

The construction activities will entail the building of the plant and associated ancillary infrastructure on the

site utilising local Namibian construction contractors (Calculus Industries (Pty) Ltd, 2019).

The initial phase of the project will entail providing bulk services to the site, as the site is currently un-

serviced. This will involve providing the site with infrastructural services such as water, electricity, sewer

and road infrastructure. In addition to the service infrastructure, this phase will also include the

construction of the plant offices (Ambo Consulting Engineers, 2019).

Water infrastructure: A new water line will be constructed to service the site. The proposed water line will

be connected to the Arandis town’s water network, which will provide domestic water to service the site.

Road infrastructure: A new road will be required for servicing the site, and it is proposed that the new

road be constructed in accordance with the Roads Authority Typical Drawing No. N2635 (Ambo

Consulting Engineers, 2019). The new road will be designed to carry large load transporting vehicles to

and from the site. Further details on the additional road are available in Section 5.4.

Sewer infrastructure: Following consultations with the Arandis Town Council, a new sewer reticulation

system will be developed, comprising of a sewer pump station with a rising main consisting of 160 mm

uPVC piping to pump sewerage from the site to the existing screening pit located within the town of

Arandis. This will allow for the treated wastewater to be used for irrigation purposes.

Electrical infrastructure: Electricity will be supplied from the nearby Erongo RED 22 kilovolt substation,

which will be connected to the proposed site through a new electrical line.

Containerized offices and ablution facilities will be provided for the construction workers. No housing for

workers will be provided.

5.3.2 OPERATIONAL ACTIVITIES

The operational process, highlighting chemical inputs and outputs is simplified and provided in Figure 3,

and further discussed in sections 5.3.2.1, 5.3.2.2 and 5.3.2.3 below.

5.3.2.1 PROCESS INPUTS

The primary inputs into the production process include the following (Calculus Industries (Pty) Ltd, 2019):

Chemical Grade Salt:

Chemical grade salt serves as the primary raw material for the chloralkali process and is required at an

input amount of 26 400 metric tonnes per annum (mtpa). The input salt will be obtained from a solar salt

mine at Cape Cross and transported 180 km to site via road. The salt will be offloaded on site and stored

on a salt storage patio with a storage capacity of 2 000 metric tonnes.

Industrial Grade Calcium Carbonate:

Calcium carbonate serves as the primary input for the production of both calcium chloride and carbon

dioxide. Industrial grade calcium carbonate will be sourced from the SwaCa quarry mine located outside

of Swakopmund. An estimated total of 18 000 tonnes will be required per annum, which will be

transported by road and a minimum of 2 000 tonnes will be stored on site.

Water:

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Water will be supplied by means of the new water line and will be obtained from the Arandis Town’s

water network. The new waterline will tie into the 160 mm dead end line at the end of Aloe Road. A

nominal flowrate of 38 m3/hour is required for plant operations. Water will be utilised for a variety of

purposes, such as operational purposes (demineralised water, chilled water, cooling water) as well as

firefighting, ablution facilities and drinking purposes.

Electricity:

It is anticipated that the plant will operate 24 hours a day, for 350 days per annum and will require a

maximum of 10 megavolt amperes (MVA). The electrical supply will be supplied from the nearby Erongo

Red substation located within the town of Arandis.

Other Chemical Inputs:

Additional process input chemicals and materials which will be required in smaller quantities will be

imported from China and India via the Walvis Bay port. A dedicated inhouse truck will be used to

transport the supplies from the port to the proposed site. These include:

• Active carbon

• Barium carbonate

• Caustic soda (for commissioning)

• Chelating resins

• Ethanol amine

• Flocculant

• Hydrogen peroxide

• Sodium carbonate

• Sulphuric acid.

5.3.2.2 PRODUCTION PROCESS

The production process for the proposed plant can be simplified as per Figure 3 below. The processes

will utilise input chemicals, as well as chemicals produced on site to create the final products for sale. A

detailed process can be found within the technical extract provided as Annexure D.

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Figure 3: Simplified production process anticipated for the proposed Chloralkali plant

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5.3.2.3 PRODUCTION OUTPUTS

The primary production outputs for market purposes are:

• Caustic soda (Lye)

• Caustic soda (Solid Flakes)

• Chlorine liquid

• Calcium chloride granules

• Liquified carbon dioxide (Calculus Industries (Pty) Ltd, 2019).

5.3.3 DECOMMISSIONING ACTIVITIES

The proposed chloralkali plant will be skid mounted, which will allow for the facility to be dismantled and

shipped to another site once the end of life of the facility has been reached. At that point, the facility will

undergo decontamination in an effort to remove any remaining chemical residues within the process

facilities on site. If the local community do not wish to keep the infrastructure developed on the site, such

as roads, pipelines, and electrical lines once the project comes to an end, these will be dismantled, while

the water pipelines will be sealed off with dead ends for future potential tie ins. Once all infrastructure

has been dismantled, all potential resources will be salvaged for resale, while non-salvageable waste

produced will be transported to relevant waste disposal facilities. The surface terrain will be leveled off,

and rehabilitation of the land will commence. A rehabilitation specialist will be consulted at the

decommission stage of the project.

5.4 ANCILLIARY INFRASTRUCTURE

An additional road will be required to access the proposed site and will be designed for large vehicles

transporting materials to and from the site. The proposed new road will connect with Aloe Road in

Arandis and lead directly to the site. The road will be comprised of the following:

• Base course material: G4 natural gravels

• Road sub-surface material: G5 natural gravels

• Selected layers: G7 Natural gravels.

The road design will conform to the Roads Authority Typical Drawing No. N2635, as well as the Annual

Average Daily Equivalent Vehicle Units expected travelling on the new road for the first year of the design

life (Ambo Consulting Engineers, 2019).

The pavement will be designed to conform with the Structural Design on Interurban and Rural Road

Pavements, with light vehicle influence ignored due to negligible damage on the pavement. Heavy

vehicle traffic volumes will be determined and used for the pavement design.

5.5 WASTE MANAGEMENT

5.5.1 SOLID WASTE

The sludge produced by the proposed chloralkali plant will go be sent to a licenced waste disposal site.

quantity of the sludge produced by the plant is anticipated to be approximately 2.5 tons per week.

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General waste will be sent to the landfill that is just 700 m away from proposed site.

Suitable waste storage and separation facilities which are fully enclosed and inaccessible by any wildlife

will be provided on site. Storage Containers will have proper lids to prevent wind dispersal of waste.

5.5.2 Gaseous Particulate Emissions

Gaseous emissions will be prohibited by all feasible and practical means, and the plant will be designed

to include emergency vents for the safe release of carbon dioxide, chlorine, hydrogen and hydrogen

chloride gasses.

The carbon dioxide produced will be captured, concentrated and liquified during the production process

to produce liquified carbon dioxide for sale. All the hydrogen and chlorine gas generated will be required

and utilised for the production of the hydrochloric acid required for calcium chloride production. The

chlorine gas will be vented into an emergency chlorine tower containing caustic soda, wherein a 12 %

sodium hypochlorite solution will be produced, and sold off as bleach. The maximum emergency venting

rate for the other gasses will be 100Nm3/hour at concentrations of 15 mg/m3 (Sipunga, 2019).

5.5.3 LIQUID EFFLUENT

Liquid effluent will be generated both during construction and operation phases of the project.

Operational phase liquid effluent originating from the chelating resin towers, cooling towers, brine purge

and carbon filter backwashing will require offsite disposal.

Liquid effluent will be diverted to wastewater drains and transferred to the wastewater treatment section

of the plant. The liquid effluent is expected to consist of an amalgamation of chlorates, chlorides, sulfates

and trace elements from the limestone and salt sources, such as Aluminium, Iron, Nickel and Zinc. The

post-treatment flow rate is expected to be 3 m3/hour and will be discharged into the municipal sewer

network.

5.6 PROJECT ALTERNATIVES

5.6.1 NO-PROJECT

If the project does not proceed, the potential economic benefits of the project will not be realised. In this

event, the additional potential jobs will not be created, nor will the financial and infrastructural investment

in the town come to fruition. The potential supply of industrial chemicals to the mining, production, oil and

minerals industries will require importation instead of local production, therefore not returning investment

within the Namibian and SADC economies.

On the other hand, the potential negative environmental impacts as described in Section 8.0 will not

occur.

5.6.2 SITE ALTERNATIVES

An alternative site located within Walvis bay was identified by Calculus Commodities. To use the

alternative site would have lowered transportation costs of materials brought in from the harbour.

However, the site was deemed non-feasible due to the cost of land as well as the regulatory constraints

associated with the alternative site being located within Namib-Naukluft national park.

5.6.3 PROCESS ALTERNATIVES

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An alternative to the membrane cell used during the electrolysis process was identified by Calculus

Commodities. The alternative method involved the use of a mercury cell for the electrolysis, which would

utilise liquid mercury as the cathode for the reaction. This would yield a 50 % caustic soda solution,

greater than the 32 % caustic soda solution yielded by the membrane cell, however, the use of mercury

cells is being phased out due to the potential toxicity of the use of mercury.

5.6.4 WATER SUPPLY ALTERNATIVE

It was proposed that the new water line be connected to the NamWater bulk line which supplies Husab

Mine. The bulk line is located south of the B2 Trunk Road, requiring the new line to cross the road, which

could be achieved through running the new line underneath the national road by means of horizontal

drilling. This however was considered non-feasible and more expensive, therefore the preferred option of

running a water supply line in parallel with the new road was selected.

5.6.5 ELECTRICAL SUPPLY ALTERNATIVE:

An alternative electrical supply was considered, whereby a supply line would have run northwards to the

nearby 220 kV NamPower electrical line. However, the use of a line directly to the Erongo RED Arandis

substation was preferred, due to the financial costs for the voltage step-down from 220 kV to 11 kV.

5.6.6 SEWAGE LINE ALTERNATIVE:

An alternative sewage line was considered, whereby the site would be connected to a manhole leading to

the nearby oxidation ponds. Consultation between the project proponent and the Arandis Town Council

found this to be less favourable, as the town council would prefer to re-use the wastewater for irrigation

purposes. Furthermore, the necessity for the additional construction works route would have required

additional costs, whereas the favoured route leading to the connection point will be more feasible.

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6.0 BASELINE ENVIRONMENT

6.1 TOPOGRAPHY & DRAINAGE

The proposed project is located to the west of the town of Arandis, in an area of relatively flat topography

within the Namib Desert biome. The site visit conducted on the 3rd of September 2019 confirmed the

proposed location for the site to be flat, with small koppies observed northwest of the site. An aerial view

of the site reveals the presence of drainage channels draining in a westerly direction across the proposed

project site.

Figure 4: Landscape of the proposed project site

6.2 GEOLOGY

The town of Arandis is situated within the Namib Desert, which falls within the southern Central Zone of

the Neo-Proterozoic Damara Orogenic Belt (Speiser, 2012). The characteristic feature of the zone is the

basement zone structures, which elongates in a northeastern direction and possesses numerous post-

tectonic granite plutons. A series of regional scale antiforms and synforms which trend in a northeast

direction, dominate the project area. The Damara Sequence is dominated by the Swakop and Nossib

groups, with the Swakop group being the dominant type within the area of the project. The Chuos and

Karibib formations of the Swakop group, creating a composition of mixtite and pebbly quartzite as well as

marble and quartz-biotite schist (Speiser, 2012).

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6.3 SOILS

The soils occurring around the town of Arandis are considered sensitive to both wind and water erosion.

The soils are characterised by shallow to moderately deep (400 – 600 mm) silty sands, with or without

the calcrete “C” horizon and/or surface crusting (Speiser, 2012). They are generally single grained to

apedal in structure, with association to distinctive individual tufts of grass cover.

6.4 CLIMATE

The town of Arandis is located within a desert climate, whereby the town experiences warm days

followed by cooler nights, with low ambient humidity. The town is situated approximately 55 km from the

coast and is therefore influenced by both the desert as well as the coast. The town experiences an

average annual temperature of 19°C, with temperatures tending to peak in March at around 21.8°C

(Climate-Data.Org, 2019). Low rainfall is experienced within the region, with an annual rainfall of 44 mm.

Rainfall occurs predominantly over the summer months, with the peak monthly rainfall of 15 mm

occurring in March (Climate-Data.Org, 2019).

6.5 LAND USE

The project will be located to the west of the town of Arandis, in an area demarcated specifically for the

proposed chloralkali plant by the Arandis Town Council. The Arandis Town Council rezoned the

proposed land to industrial, under resolution No: 13.7 as per the letter dated 22 November 2018

(Annexure E). The allocated portion of land is highlighted in the Arandis zoning map (Annexure A).

Nearby infrastructure to the proposed site include:

• Solar Plant – southwest of proposed location

• Cemetery – south-southwest of proposed location

• Arandis Soccer Stadium – located southwest of the proposed site location

• NamPower Power Lines – north of proposed location

• Unnamed access road – potential extension of the Aloe Road, which will be extended to the site

• NamWater bulk supply line – located south of the site alongside the B2 Trunk Road

6.6 BIODIVERSITY

The proposed site is located within the Namib Desert ecoregion, which extends along the western coast

of Namibia, and inland towards Namib Escarpment. The ecoregion can be further subdivided into the

Southern Namib and the Central Namib, in which the proposed site location falls. The Central Namib

extends from the Kuiseb river to the Uniab river, both of which are ephemeral rivers which are normally

dry (Spriggs, 2019). The Namib Desert is considered the oldest desert on Earth, with an arid climate that

has resulted in a unique biodiversity comprising of numerous desert adaptations and high levels of

endemism. The proposed site yielded minimal faunal presence during the site visit, with an established,

yet sparse and scattered floral community present comprised predominantly of small shrubs and desert

grasses (Spriggs, 2019).

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6.6.1 FLORA

Within the Central Namib ecoregion exists distinct vegetative areas. A narrow vegetation strip of

approximately 200 m wide runs along the coastline north of the Swakop River. Inland of the strip exist

vast gravel plains which are predominantly barren of flora except for lichens. Further inland, towards the

extreme east of the Central Namib, the gravel plains become increasingly vegetated with annuals,

predominantly with members of the Stipagrostis genus and scattered shrub individuals of Moringa

ovalifolia and Euphorbia virosa (Spriggs, 2019).

The most notable plant to occur within the Central Namib ecoregion is Welwitschia mirabilis. The plants

possess two fibrous leaves which persist throughout the entire life of the plant and are considered the

longest-lived leaves of the plant kingdom. These plants are often found in broad, flat channels on gravel

plains and scattered more than 20 m apart, with a distribution ranging from the Kuiseb river to the

Namibe in southern Angola (Spriggs, 2019).

The proposed site has a sparse, scattered floral community established, as presented in Figure 5 below.

Figure 5: Photograph of floral community present on the site

6.6.2 FAUNA

Reptiles have high species richness and endemism within the Namib Desert, as they have evolved

adaptations to survive in this harsh environment more efficiently than most birds and large mammals that

may occur within the biome. Approximately 70 reptile species occur within the ecoregion, including

several endemic reptiles including the two desert lizards, the wedge-snouted sand lizard (Meroles

cuneirostris) and the small-scaled sand lizard (M. micropholidotus), the barking gecko (Ptenopus kochi)

and the day gecko (Rhoptropus bradfieldi) (Spriggs, 2019).

The Namib Desert is home to a large number of small rodent species that occur among the rocky habitats

in the western deserts, in the sand dunes and in the vegetation of the gravel plains. The larger ungulates

found in the Namib Desert include gemsbok (Oryx gazella) (most widespread ungulates in the desert

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habitat), springbok (Antidorcas marsupialis) and Hartmann’s zebra (Equus zebra hartmannae).

Klipspringers (Oreotragus oreotragus), steenboks (Raphicerus campestris), baboons and leopards occur

along the courses of the Kuiseb and Swakop Rivers. The predators of the Namib Desert include

cheetahs, brown hyenas, spotted hyenas, Cape foxes and bat-eared foxes (Spriggs, 2019).

The desert does not have a very high level of avian richness, with the most prominent bird found in the

desert is the ostrich (Struthio camelus). Six birds are considered endemic to the Namib Desert, namely,

the dune lark (Certhilauda erythrochalamys), Benguela long-billed lark (C. benguelensis), Gray’s lark

(Ammomanes grayi), bank cormorant (Phalacrocorax neglectus), tractrac chat (Cercomela tractrac), and

Rüppell’s korhaan (Eupodotis rueppellii) (Spriggs, 2019). A summary of animal species which may

potentially occur within the vicinity of the project area is provided in Table 6 below. However, during the

site visit, a single lizard was observed, and a single pile of animal scat was noted, indicating that the

faunal presence at the proposed site is rather low.

Table 6: Table of Fauna Expected to occur within the vicinity of the Project Area (Speiser, 2012)

Common Name Scientific Name

Avifauna

Dikkop Burhinum xapensis

Ostrich Struthio camelus

Benguela long-billed lark Certhilauda benguelensis

Dune Lark Certhilauda erythrochalamys

Gray’s lark Ammomanes grayi

Bank Cormorant Phalacrocorax neglectus

Rock Kestrel Falco tinnunculus

Rϋppel’s Korhaan Eupodotis rueppellii

Tractrac Chat Cercomela tractrac

Mammals

Eyptian free-tailed bat Tadarida aegyptiaca

Egyptian slit-faced bat Nycteris thebaica

Long-tailed serotine Eptesicus hottentotus

Dassie rat Petromus tpyicus

Cape hare Lepus capensis

Rock dassie Procavia capensis

Gemsbok Oryx gazella

Hartmann’s zebra Equus zebra hartmannae

Springbok Antidorcas marsupialis

Klipspringer Oreotragus oreotragus

Aardwolf Proteles cristatus

Black-backed jackal Canis mesomelas

Brown hyaena Hyaena brunnea

Reptiles

Barking gecko Ptenopus species

Bradfield’s Namib day gecko Rhoptropus bradfieldi

Shovel-snouted lizard Meroles anchietae

Waterberg sand lizard Pedioplanis rubens

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Common Name Scientific Name

Hoeschi skink Mabuya hoesci

Husab sand lizard Pedioplanis husabensis

6.7 AIR QUALITY

No ambient air quality data exists for the proposed site, however specialist surveys have been

undertaken within the municipality and surrounding areas. Nearby contributions to gaseous emissions

and dust fallout include the generation of fugitive dust fallout associated with mining activities such as

blasting and drilling at the nearby open pit of Rössing Mine (Speiser, 2012). Gaseous emissions of CO2,

SO2, NOx, hydrocarbons as well as fine particulates associated with vehicular movements along the B2

trunk road as well as within the town of Arandis contribute to the ambient air quality around the project

site (Speiser, 2012). Releases from the proposed Arandis Thermal Power Generation and Waste Oil

Recycling plants, should they be approved, would further contribute to the deterioration of the air quality

of the town and proposed chloralkali plant site.

6.8 NOISE

The receptors of noise are the local townspeople of Arandis and tourists visiting the town, with an

increased receptor sensitivity anticipated at night when ambient noise levels are low. Several sources of

noise exist within the vicinity of the proposed site, which include:

• Natural noise generated from both animals and wind

• Noise generated from daily activities within the town

• Vehicle movements within the town and along the B2 Trunk Road.

6.9 WATER QUALITY/SOURCES

6.9.1 SURFACE WATER

Due to the desert nature of the region, the rivers within proximity to the project area are generally dry,

with surface water flow provided as a result of storm water entering from upland within the catchment

areas. The major rivers within the vicinity of the project are the Khan river, approximately 14 km from the

site and Swakop river, approximately 30 km from the site, both of which are ephemeral in nature and

westward flowing (Speiser, 2012).

6.9.2 GROUNDWATER

Groundwater within the area of the Erongo Region is comprised of three different aquifer systems, being:

• Saturated alluvium associated with major rivers

• Saturated alluvium associated with the plains

• Fractured/weathered bedrock aquifers.

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The geology of the vicinity of the project area categorises two main aquifer types, being the fractured

bedrock and the saturated alluvium associated with a major river, namely the Khan river. The bedrock

aquifer is considered to have low storage potential, with potential for increased localised storage within

faults and fractures (Speiser, 2012). The alluvial aquifer associated with the Khan River provides

moderate storage potential and provides water which is considered saline in nature in the vicinity of

Arandis. Water from the aquifer is considered unsuitable for human consumption and is utilised by

Rössing Mine for dust suppression (Speiser, 2012).

6.10 SOCIO-ECONOMIC

6.10.1 ERONGO REGION

The Erongo region hosts a population of 182 402 people based on the 2016 national census (Namibia

Statistics Agency, 2017). The population distribution within the region indicates a favour towards urban

areas, with 92 % of the population residing within urban areas, and a density of 2.9 people per km2

across the region. The region has a crude birth rate of 22.5 per 1000 population and a crude death rate

of 9.9 per 1000 population.

The report (Namibia Statistics Agency, 2017) further indicates that the majority (62 %) of households are

headed by males, whilst female headed households constitute 38 % of surveyed households. The

average size of households within the Erongo region is 3.1 people per household, with the predominant

source of income from salaries and wages (78 %). A total of 98 % of households have safe water, while

76 % receive electricity.

6.10.2 ARANDIS TOWN

The town of Arandis was established in 1976 by the Rössing Uranium Mine, primarily to house the

workers’ community and families. The towns initial infrastructure was provided by Rössing, including the

construction of a hospital, sport facilities, recreational facilities and schools within the town. The

developments resulted in an influx of family members of Rössing employees into the town (Hoadley,

2009). In 1994, Arandis was proclaimed as an independent town, with an elected local authority, the

Arandis Town Council, which took over the management and provision of municipal services from

Rössing. The Arandis Town Council relies on the collection of rates and sewage charges primarily for

revenue, whilst electricity is provided by the Erongo Regional Electricity Distributor (Hoadley, 2009).

Further economic opportunities within the mining sector were established with the development of the

Husab and Trekkopje mines, and the extension of the Rössing Uranium mine. The Arandis Town Council

contracted Stubenrauch Planning Consultant to develop a town-planning scheme which illustrates

various land use areas for further development of the town, including a solar plant, residential and

industrial expansions, and, the proposed Chloralkali plant, as presented in Annexure A.

6.11 HERITAGE

Dr. John Kinahan was appointed to conduct a heritage specialist study of the area for the proposed new

chloralkali plant. The sections below are taken from Dr. Kinahan’s report (Kinahan, 2019), Annexure F.

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6.11.1 DESKTOP ASSESSMENT:

The modern settlement of Arandis is situated approximately 54 km northeast of Swakopmund, on the

central western plains of the Namib Desert. The Arandis area receives between 50 and 100 mm annual

precipitation, with a degree of variation approaching 90 %.

Despite its extreme aridity, there is archaeological evidence for the human occupation of the Namib

Desert throughout much of the last one million years, including periods of intense human activity and

periods in which the desert environment was inimical to human occupation. Detailed archaeological

surveys have been carried out over large parts of the Namib Desert during the last few decades and in

many areas, providing a firm basis for the estimation of likely impacts resulting from industrial and

infrastructural developments.

The earliest evidence of human occupation in the Arandis area occurs in the form of isolated Early Stone

Age (ESA) artefacts dating to approximately half a million years which are found on gravel outwash

surfaces rather than in their original context. More dense concentrations of Middle Stone Age (MSA)

artefacts dating to within the last 200 000 years which occur mainly as surface finds but their context,

such as quarrying sites and tool fabrication sites, provide valuable evidence of early modern Homo

sapiens behaviour in the desert environment.

A major MSA site in the Arandis area is located at Panner Gorge where detailed evidence of quarrying

activity is associated with a large outcrop of chert. This particular material, which has superior flaking

properties, was in high demand over the last 100 000 years and chert from Panner Gorge was distributed

over a radius of almost 100 km in the Namib Desert, thus including the location of the proposed new

chloralkali plant. The distribution of chert artefacts and waste material allows for detailed mapping of

hunting activities and settlement of early modern Homo sapiens.

A second component of the local archaeological sequence that is of particular importance is evidence

from within the last one thousand years, of systematic human exploitation of wild grass seeds. This

activity, which is associated with the acquisition of pottery and a range of important social changes, was

the foundation of human food security in the desert and enabled a significant growth in population.

Evidence of wild grass seed exploitation is widespread mainly along the eastern edges of the Namib

Desert and thus also near Arandis.

Finally, the Arandis area was an important theatre of conflict during the 1915 South African invasion

which has left a uniquely well preserved archaeological record. The capture of the railway line via

Arandis by Col. Skinner involved large numbers of South African and British troops who encamped along

the railway line and established a communication network based on a series of heliograph signaling

stations. Several important sites relating to this campaign have been documented in the Arandis area.

Figure 6 below illustrates the distribution of archaeological documented during in previous studies in the

Arandis area.

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Figure 6: Archaeological sites in the vicinity of Arandis, Erongo Region, shown as black dots

(data from Namib Desert Archaeological Survey), in relation to the Arandis town limits and the

footprint area of the proposed Arandis Chloralkali Plant and its related

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6.11.2 FIELD SURVEY:

The footprint area of the proposed chloralkali plant and its related linear infrastructure corridors were

examined on foot by means of parallel transects. The archaeological site locations were recorded by

hand-held GPS and the visible surface remains were described according to commonly used criteria. The

ground surface of the survey area has almost no vegetation cover and the visibility of archaeological

materials was therefore relatively high. The area covered by the survey showed a noticeable degree of

legacy disturbance which is probably attributable to the proximity of Arandis. Disturbances included a

high density of vehicle tracks (ranging between 10 and 70 % of surface), refuse dumps and excavations

for building sand.

Within the footprint area of the proposed chloralkali plant, three examples of mid-Pleistocene stone

artefacts were found on the surface. These are illustrated in Figure 7, with the upper piece being a

bifacial handaxe, the middle piece a unifacial cleaver, and the lower piece being a polyhedral core

fragment. The artefacts all indicated advanced surface abrasion possibly due to sand-blasting, such that

the evidence of their manufacture was to some degree obscured. The finds appear to have moved over

the surface as a result of sheetwash and are therefore of negligible research value.

Figure 7: Mid-Pleistocene stone artefacts from the footprint area of the proposed Arandis

Chloralkali Plant (scale 1:5), dorsal view on left with obverse on right.

Figure 8 presents the distribution of archaeological sites in relation to the proposed chloralkali plant. The

infrastructure corridor approaching the footprint site from the east and southeast yielded no

archaeological remains. This area which is closest to the edge of the town also yielded the highest

density of disturbances. A short western corridor was described as a proposed sewerage line, similarly

yielded no archaeological remains. The final version of the water supply pipeline was provided as a

sketch when fieldwork had already commenced; the sketch could not be projected as a spatial file and so

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was used for general orientation to carry out a foot survey of the area concerned. No archaeological

remains were found in the area covered.

Figure 8: The layout of the proposed Arandis Chloralkali Plant and its related linear infrastructure

corridors, indicating the distribution of archaeological sites located during the field survey.

A general reconnaissance of the western outskirts of Arandis yielded a number of isolated finds that are

consistent with the results of previous surveys undertaken in the surrounding area. These finds included

a single MSA flake tool of yellow chert such as is found at Panner Gorge about 10 km to the south. The

vicinity of the dolerite ridge to the south of the proposed chloralkali plant also revealed a number of sites

related to wild grass seed exploitation in the last one thousand years. These sites consist of small areas

of disturbed ground approximately 2-3 m in diameter and usually on weathered granite. The disturbed

ground indicates areas where the underground nests of harvester ants were excavated to remove stored

caches of grass seed. Usually such excavations occur in groups (as here) and are also associated with

large hammer stones brought from neighbouring outcrops to break open the weather granite. These

sites are extremely common in the Namib Desert and are of high research value when they occur as

integrated local settlement patterns (unlike here). The Arandis sites are therefore of negligible research

value.

Prior to the survey described here, earlier work in the Arandis area contributed to a cumulative record of

archaeological settlement and occupation over the last half a million years. The high density of

archaeological sites in this area, and the fact that several of them have yielded important new evidence,

means that direct field surveys are advisable where developments are proposed on ground that has not

been surveyed before. In the present case, the field survey of the proposed new chloralkali plant and its

related linear infrastructure corridors did not yield any sites of high research value, although the sites

located in the course of the field survey generally confirm the results of previous surveys.

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7.0 PUBLIC CONSULTATION

A public participation process was undertaken in accordance with regulation 21 of the EIA Regulations

(GN No. 30 of 2012). Relevant proof is contained in Annexure G.

7.1 METHODOLOGY

7.1.1 NOTIFICATION

The project notification comprised of the following actions:

• A notice board was fixed on site on the 3rd September 2019

• Notifications were placed on noticeboards within Arandis on the 3rd September 2019

• Advertisements were placed within both The Republikein and The Namibian newspapers once a

week for two consecutive weeks, published on the 16th and 24th October 2019

• Pre-identified and registered Interested and Affected Parties (I&APs) were emailed copies of the

Background Information Document (BID) on 21 October 2019.

7.1.2 MEDIA COVERAGE

Advertisements were placed in both The Namibian and The Republikein newspapers for two weeks, with

the adverts published on the 16th and 24th October 2019 to inform the public of the application. Refer to

Annexure G for photographs of the adverts.

7.1.3 REVIEW PERIOD

The Draft EIA Report was made available for public review from the 20th November – 4th December 2019.

It was placed on the Knight Piésold website and registered I&APs were notified of the availability by

means of e-mail. I&APs were also notified on 5 December 2019 that the commenting period was closed.

7.1.4 INTERESTED AND AFFECTED PARTIES

Refer to Annexure G for the complete database of Interested and Affected Parties.

7.2 COMMENTS AND RESPONSES

Following the public review period, no technical comments were received. Refer to Annexure G for

comments received and responses provided.

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8.0 IMPACT ASSESSMENT

8.1 DEFINING THE NATURE OF THE IMPACT

An impact is essentially any change to a resource or receptor brought about by the presence of the

proposed project component or by the execution of a proposed project related activity. The terminology

used to define the nature of an impact is detailed in Table 7 below.

Table 7: Impact Nature

Term Definition

Positive (+) An impact that is considered to represent an improvement on the baseline or introduces a positive change.

Negative (-) An impact that is considered to represent an adverse change from the baseline or introduces a new undesirable factor.

Direct impact (D) Impacts that result from a direct interaction between a planned project activity and the receiving environment/receptors (e.g. between occupation of a site and the pre-existing habitats or between an effluent discharge and receiving water quality).

Indirect impact (I) Impacts that result from other activities that are encouraged to happen as a consequence of the project (e.g. in-migration for employment placing a demand on resources).

Cumulative impact (C)

Impacts that act together with other impacts (including those from concurrent or planned future third-party activities) to affect the same resources and/or receptors as the Project.

Residual impact Those impacts that remain following the implementation of the mitigation measures proposed.

8.1.1 ASSESSING SIGNIFICANCE

The Knight Piésold impact significance rating system is based on the following equation:

Significance of Environmental / Social Impact = Consequence x Probability

The consequence of an impact can be derived from the following factors:

• Severity / Magnitude – the degree of change brought about in the environment;

• Reversibility - the ability of the receptor to recover after an impact has occurred;

• Duration - how long the impact may be prevalent; and

• Spatial Extent - the physical area which could be affected by an impact.

The severity, reversibility, duration, and spatial extent are ranked using the criteria indicated in Table 8

and then the overall consequence is determined by adding up the individual scores and multiplying it by

the overall probability (the likelihood of such an impact occurring). Once a score has been determined,

this is checked against the significance descriptions indicated in Table 9. The impacts identified and

relative significances are presented in Table 10 below.

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Table 8: Ranking Criteria

Severity / magnitude (M) Reversibility (R) Duration (D) Spatial extent (S) Probability (P)

5 – Very high – The impact causes the characteristics of the receiving environment/ social receptor to be altered by a factor of 80 – 100%

5 – Irreversible – Environmental - where natural functions or ecological processes are altered to the extent that it will permanently cease.

Social - Those affected will not be able to adapt to changes and continue to maintain-pre impact livelihoods.

5 – Permanent - Impacts that cause a permanent change in the affected receptor or resource (e.g. removal or destruction of ecological habitat) that endures substantially beyond the Project lifetime.

5 – International - Impacts that affect internationally important resources such as areas protected by international conventions, international waters etc.

5 – Definite - The impact will occur

4 – High – The impact alters the characteristics of the receiving environment/ social receptor by a factor of 60 – 80%

4 – Long term - impacts that will continue for the life of the Project but ceases when the Project stops operating.

4 – National - Impacts that affect nationally important environmental resources or affect an area that is nationally important/ or have macro-economic consequences.

4 – High probability – 80% likelihood that the impact will occur

3 – Moderate – The impact alters the characteristics of the receiving environment/ social receptor by a factor of 40 – 60%

3 – Recoverable Environmental - where the affected environment is altered but natural functions and ecological processes may continue or recover with human input.

Social - Able to adapt with some difficulty and maintain pre-impact livelihoods but only with a degree of support or intervention.

3 – Medium term - Impacts are predicted to be of medium duration (5 – 15 years)

3 – Regional - Impacts that affect regionally important environmental resources or are experienced at a regional scale as determined by administrative boundaries, habitat type/ecosystem.

3 – Medium probability – 60% likelihood that the impact will occur

2 – Low – The impact alters the characteristics of the receiving environment/ social receptor by a factor of 20 – 40%

2 – Short term - Impacts are predicted to be of short duration (0 – 5 years)

2 – Local - Impacts that affect an area in a radius of 2 km around the site.

2 – Low probability - 40% likelihood that the impact will occur

1 – Minor – The impact causes very little change to the characteristics of the receiving environment/ social receptor and the alteration is less than 20%

1 – Reversible

Environmental - The impact affects the environment in such a way that natural functions and ecological processes are able to regenerate naturally.

Social - People/ communities are able to adapt with relative ease and maintain pre-impact livelihoods.

1 – Temporary - Impacts are predicted to intermittent/ occasional over a short period.

1 – Site only - Impacts that are limited to the site boundaries.

1 – Improbable - 20% likelihood that the impact will occur

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Table 9: Significance Definitions

Score According to Impact Assessment Matrix

Significance Definitions

Colour Scale Ratings

Negative Ratings

Positive Ratings

Between 0 and 29 significance points indicate Low Significance

An impact of low significance is one where an effect will be experienced, but the impact magnitude is sufficiently small and well within accepted standards, and/or the receptor is of low sensitivity/value.

Low Low

Between 30 and 59 significance points indicate Moderate Significance

An impact of moderate significance is one within accepted limits and standards. The impact on the receptor will be noticeable and the normal functioning is altered, but the baseline conditions prevail, albeit in a modified state. The emphasis for moderate impacts is on demonstrating that the impact has been reduced to a level that is As Low as Reasonably Practicable (ALARP). This does not necessarily mean that “moderate” impacts have to be reduced to “low” impacts, but that moderate impacts are being managed effectively and efficiently to not exceed accepted standards.

Moderate Moderate

60 to 100 significance points indicate High Significance

An impact of high significance is one where an accepted limit or standard may be exceeded, or large magnitude impacts occur to highly valued/sensitive resource/receptors. An impact with high significance will completely modify the baseline conditions. A goal of the EIA process is to get to a position where the project does not have any high negative residual impacts, certainly not ones that would endure into the long term or extend over a large area. However, for some aspects there may be high residual impacts after all practicable mitigation options have been exhausted (i.e. ALARP has been applied). It is then the function of regulators and stakeholders to weigh such negative factors against the positive factors, such as employment, in coming to a decision on the project.

High High

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Table 10: Impact Significance

Project activity or issue

Potential impact

Nature of impact

Significance before mitigation Significance after mitigation as per EMP

+ / -

D/I/C M R D S P TOTAL SP M R D S P TOTAL SP

Topography & Drainage

Construction of chloralkali plant

Alteration in drainage patterns

- D 1 3 4 1 5 45 M 1 1 4 1 5 35 M

Geology

No impacts expected

Soil

Construction of chloralkali plant

Loss / Disturbance of soil crust

- D 2 3 5 1 2 22 L 2 1 5 1 2 18 L

Construction of new road, water pipeline and sewage pipeline

Disturbance of soil / Loss of topsoil

- D 1 1 5 1 3 24 L 1 1 5 1 2 16 L

Hazardous chemical spills (e.g. fuel, process chemicals, etc.)

Contamination of Soil - D 1 1 1 1 1 4 L 1 1 1 1 1 4 L

Climate

No impacts expected

Land use

No impacts expected

Flora

Construction of chloralkali plant

Loss / Disturbance of flora - D 2 1 3 2 5 40 M 2 1 2 1 5 30 M

Construction of new road

Loss / Disturbance of flora - D 1 1 1 2 5 25 L 1 1 1 2 5 25 L

Operation of chloralkali plant

Loss / Disturbance of flora - D 1 1 1 1 5 20 L 1 1 1 1 5 20 L

Decommissioning Loss / Disturbance of flora - D 1 1 1 1 5 20 L 1 1 1 1 5 20 L

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Project activity or issue

Potential impact

Nature of impact

Significance before mitigation Significance after mitigation as per EMP

+ / -

D/I/C M R D S P TOTAL SP M R D S P TOTAL SP

Hazardous chemical spills (e.g. fuel, process chemicals, etc.)

Plant dieback due to contamination of immediate environment

- I 3 3 4 2 3 36 M 1 3 2 2 2 16 L

Fauna

Construction of chloralkali plant

Loss / Disturbance of faunal habitat / Habitat fragmentation

- D 2 1 1 2 5 30 M 1 1 1 2 2 10 L

Construction of new road

Loss / Disturbance of faunal habitat / Habitat fragmentation

- D 1 1 1 2 5 25 L 1 1 1 2 2 10 L

Operation of chloralkali plant

Loss / Disturbance of fauna - D 1 3 2 1 5 35 M 1 3 2 2 2 16 L

Decommissioning Loss / Disturbance of fauna - D 1 1 1 1 5 20 L 1 1 1 1 2 8 L

Transport of materials and product

Road Fatalities - I 3 3 4 2 3 36 M 1 3 4 2 1 10 L

Hazardous chemical spills (e.g. fuel, process chemicals, etc.)

Animals dying or moving away due to contamination of immediate environment

- I 3 3 4 2 3 36 M 2 3 4 2 1 11 L

Air quality

Construction and Operation of chloralkali plant

Increase in carbon emissions from trucks carrying construction and processing materials

- D 2 1 4 3 3 30 M 2 1 4 3 2 20 L

Operation of chloralkali plant

Accidental release of gaseous waste (chlorine, carbon dioxide)

- I 2 3 2 2 1 9 L 2 3 1 2 1 8 L

Construction and Operation of chloralkali plant

Increase in dust from vehicle entrainment on gravel roads and construction activities

- D 1 1 3 2 3 21 L 1 1 3 2 3 21 L

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Project activity or issue

Potential impact

Nature of impact

Significance before mitigation Significance after mitigation as per EMP

+ / -

D/I/C M R D S P TOTAL SP M R D S P TOTAL SP

Noise

Construction and Operation of chloralkali plant

Generation of noise (e.g vehicle and equipment noise)

- D 2 1 1 1 5 25 L 1 1 1 1 5 20 L

Groundwater

Hazardous chemical spills (e.g. fuel)

Groundwater Contamination - D 2 3 4 2 2 22 L 2 3 4 2 1 11 L

Socio-Economics

Construction of chloralkali plant and ancillary infrastructure

Employment opportunities + D 2 1 2 3 5 40 M 0 L

Operation of chloralkali plant

Employment opportunities + D 2 1 3 3 5 45 M 0 L

Construction and Operation of chloralkali plant

Increased vehicular traffic - D 1 3 4 3 3 33 M 1 3 4 3 2 22 L

Transportation of materials and products

Potential for vehicle collisions

- I 1 1 4 3 1 9 L 1 1 4 3 1 9 L

Operation of chloralkali plant - Procurement of input materials

Input into national economy + I 1 1 4 5 5 55 M 0 L

Heritage

Construction of chloralkali plant and ancillary infrastructure

Loss of localised archaeological sites

- D 4 5 5 1 4 60 H 4 5 5 1 4 60 H

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8.2 IMPACT ASSESSMENT PER ENVIRONMENTAL

ASPECT

8.2.1 TOPOGRAPHY & DRAINAGE

An impact on the drainage channels running through the site is to be expected following the

construction of the plant. The impact will be of moderate significance before and after mitigation

given its high likelihood of occurrence. However, because of the severely low rainfall in this area, this

impact can also be considered negligible.

8.2.2 GEOLOGY

No impacts on the geology are expected to occur.

8.2.2.1 SOILS

Disturbances of the topsoil and soil composition are expected to occur during the construction of the

plant and associated ancillary infrastructure. The potential loss of topsoil as a result of wind erosion

following the disturbances expected during construction is also a possible negative impact, however it

can be mitigated through sufficient management during both the construction and operational phases.

Contamination of soils by means of hazardous spills is a potential impact on soil, which too can be

prevented through proper care and mitigation measures during both construction and operation

phases. All the aforementioned impacts relating to the soil can be considered as having a low

significance, which can be reduced to even lower significance with the application of appropriate

mitigation measures.

8.2.3 CLIMATE

No impacts on the climate are expected to occur.

8.2.4 LAND USE

No impacts on the change in land use are expected to occur, as the land has already been rezoned

as “Industrial” by the Arandis Town Council.

8.2.5 BIODIVERSITY

8.2.5.1 FLORA

The construction of the plant and associated ancillary infrastructure will require the clearing of the

existing vegetation along the proposed site, which will disturb the existing flora, and may lead to

specimen loss. These can be considered as localised impacts of moderate to low significance before

mitigation measures are in place. The impact of the construction activities will result in some habitat

loss for flora, which will continue through the life of the project. Potential hazardous chemical spills,

both on site and whilst materials are in transit, can result in floral loss in the immediate vicinity of

possible spills, an indirect impact of low significance, which can be mitigated.

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8.2.5.2 FAUNA

The construction activities will disturb nearby fauna, through the generation of sound which may

frighten nearby animals, increased human presence within the area, and through habitat loss along

the construction routes. This is considered to be a short-term localised impact, with a low to

moderate significance. The dominant faunal species within the vicinity of the construction activities,

predominantly reptiles and certain smaller mammals, are expected to recolonise the area after

construction activities have been completed.

Potential faunal loss may occur as a result of road fatalities and potential hazardous chemical spills,

which are considered as indirect impacts of moderate to low significance prior to mitigation measures.

8.2.6 AIR QUALITY

Carbon emissions may increase as a result of increased vehicular activity within the area through the

use of trucks transporting construction materials, process materials and product. Because of the

existing air quality impacts in the area, this impact has a cumulative affect. The impact of increased

carbon emissions is considered moderate prior to mitigation measures. Dust generation as a result of

the construction and vehicular entrainment is anticipated, however, the impact thereof is rated as

having a low significance before and after mitigation. The potential release of hazardous gasses

during the operation of the plant exists (as explained in 5.5.2), however sufficient mitigation measures

will minimise the impact thereof.

8.2.7 NOISE

During the construction and operation phases, noise may be generated. However, this activity will

remain localised to the vicinity of the project area. Therefore, the impact is rated as having a low

significance before and after mitigation.

Cumulative impacts will be created as the project is proposed adjacent to an existing town and near

the B2 Trunk Road.

8.2.8 WATER QUALITY

8.2.8.1 SURFACE WATER

No direct surface water impacts are expected due to the desert nature of the area. However, the

additional strain to the Namibian water supply can be expected through the processing requirement of

water during the operational phase.

8.2.8.2 GROUNDWATER

Potential groundwater contamination as a result of hazardous chemical spillages is a potential impact,

which is considered to have a low rating prior to mitigation measures.

8.2.9 SOCIO-ECONOMIC

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Both positive and negative impacts are envisioned for the project. Positive impacts include the

creation of jobs during the construction and operational phases of the plant, while the local production

of industrial grade chemicals, and sale thereof will contribute towards the national economy. The

project will have strong gender equality policies that are meant to endorse women empowerment.

This will better help challenge or eradicate gender biased socio-economics. These are considered as

impacts of moderate rating.

Negative impacts envisioned for the project include increased traffic, as a result of the influx of

vehicles during construction activities, and transport trucks carrying processing materials and product.

This is considered to be an impact of moderate significance. The increased traffic volumes may

indirectly lead to increased traffic collisions within the vicinity of the project, which in turn, may lead to

potential chemical spillages from load carrying trucks. This impact is considered to be of low

significance, and adequate mitigation measures can further reduce the potential of this impact from

occurring.

8.2.10 HERITAGE

Impact on archaeological sites in these circumstances is always high to very high. Impacts on

archaeological sites are never reversible. Likewise, the duration of impact is always permanent in the

case of archaeological sites. Because the sites described here from the proposed chloralkali plant

and its related linear infrastructure corridors do not represent an integrated local distribution the

spatial extent of impact is therefore at the lowest value. Based on the observations presented by the

specialist survey, it is suggested that implementation of the proposed project will not have significant

consequences for the heritage value of the area. It is therefore recommended that no further

mitigation work should be required but that the National Heritage Council should be notified of the

project.

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9.0 ENVIRONMENTAL MANAGEMENT PLAN

This section provides an Environmental Management Plan (EMP) to summarise the mitigation and

management actions outlined in the previous sections. This is done in order to streamline the

implementation and monitoring thereof.

The applicant is to ensure full compliance not only with this EMP but also with all Namibian

Legislation, and as far as possible all best practice guidelines.

The EMP is split into a Construction, Operation and Decommissioning Phase, as presented in Table

11, Table 12 and Table 13 below.

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Table 11: Environmental Management Plan - Construction Phase

Project activity or issue Potential impact Mitigating action

Topography

Construction activities Alteration in drainage patterns

• Designs should take the existing drainage channels into consideration to ensure that storm water flows in the natural direction.

Soil

Construction activities Loss / Disturbance of soils • Erect artificial wind barriers around excavated soils to minimise soil loss through wind

• Rehabilitate/replace soils after construction work is completed

Hazardous chemical spills Contamination of soils

• Store hazardous substances in appropriately bunded areas.

• Use a drip-tray when refuelling vehicles or machinery.

• If a spillage occurs, clean it up immediately and dispose soil at an appropriate site as hazardous waste.

Flora

Construction activities Loss / Disturbance of flora

• Translocate pre-existing floral community to nearby area to minimise specimen loss.

• Prevent and discourage illegal collection of flora (e.g. unique bulbs potentially occur in the area and only visible of periodic rain showers) as this would diminish and negatively affect the local flora.

• Make use of existing tracks/roads as much as possible throughout the area.

• Avoid off road driving in areas to prevent floral specimen loss.

• Prevent the planting of potentially alien invasive plant species for ornamental purposes as part of the plant site landscaping, should this be thought necessary. Alien species often “escape” and become invasive causing further ecological damage.

• Implement a policy of “no tolerance” towards any invasive alien plant species encountered in future in the area. This should include the removal and destruction of these species throughout the proposed development areas. Such activity would be beneficial to the overall ecology of the areas.

• Incorporate indigenous vegetation into the overall rehabilitation of the disturbed areas –

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Project activity or issue Potential impact Mitigating action

i.e. initial development access route “scars” and associated tracks and other infrastructure developments. Such rehabilitation would not only confirm the company’s environmental integrity, but also show true local commitment to the environment.

• Educate/inform contractors and staff on protected species to avoid and the consequences of illegal collection of such species.

• Prohibit the use of any pesticides.

Hazardous chemical spills Plant dieback due to contamination of immediate environment

• Store hazardous substances in appropriately bunded areas.

• Use a drip-tray when refuelling vehicles or machinery.

• Clean up potential spills immediately and dispose contaminated soils at an appropriate site as hazardous waste.

Fauna

Construction activities Loss / Disturbance of fauna

• The envisaged development site is a sparsely vegetated area and the impact on the vertebrate fauna is expected to be minimal.

• Prevent and discourage indiscriminate killing of perceived dangerous species (e.g. snakes, etc.) as this would diminish and negatively affect the local fauna. No form of poaching, illegal collecting of veld foods (e.g. bird eggs, etc.), etc. should be tolerated, especially during the construction phase.

• Remove and relocate perceived dangerous species (e.g. snakes) to similar undisturbed habitats in the general area.

• Make use of existing roads as much as possible throughout the area.

• Implement and maintain speed discipline limited to the pre-determined maximum speed limits within the area in an effort to faunal road mortalities.

• Avoid off road driving in areas to avoid habitat destruction. Nocturnal driving should also be avoided as this result in the destruction of slow-moving fauna – e.g. various reptiles and other nocturnal species.

• Rehabilitate all construction areas upon completion of construction activities.

• Use portable toilets to avoid faecal pollution during the construction phase(s).

• Initiate a suitable and appropriate refuse removal policy as littering could result in

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Project activity or issue Potential impact Mitigating action

certain animals becoming accustomed to humans and associated activity and resulting typical problem animal scenarios, such as habitat creation for pest rodent species.

• Educate/inform contractors and staff on dangerous and protected species (to avoid and the consequences of killing and/or illegal collection of such species.

Hazardous chemical spills Faunal fatalities or migration due to chemical spills

• Store hazardous substances in appropriately bunded areas.

• Use a drip-tray when refuelling vehicles or machinery.

• Clean up potential spills immediately and dispose contaminated soils at an appropriate site as hazardous waste.

Air Quality

Construction activities

Increase in carbon emissions from construction vehicles

• Undertake necessary maintenance on vehicles and equipment and keep a maintenance record.

Increase in dust

• Implement dust control mechanisms during the construction phase.

• Erect artificial wind barriers around construction sites minimise dust generation.

• Provide personal protective equipment (PPE) to construction workers to prevent or minimise dust inhalation from construction activities.

Noise

Construction activities Generation of noise (e.g. vehicle and building noise)

• Limit construction activities to specific times to restrict noise generation periods.

• Ensure no construction activities occur after hours or at night.

• Undertake necessary maintenance on vehicles and equipment and keep a maintenance record.

Surface and Groundwater

Hazardous chemical spillages Faunal fatalities or migration due to chemical spills

• The impact of liquid waste on the natural environment in general, and on both potential surface and groundwater resources in particular, must be minimised.

• Store hazardous substances in appropriately bunded areas.

• Use a drip-tray when refuelling vehicles or machinery.

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Project activity or issue Potential impact Mitigating action

• Implement proper pollution control mechanisms

• Clean up potential spills immediately and dispose contaminated soils at an appropriate site as hazardous waste.

Socio-economic

Operational activities

Job opportunities • Namibian citizens should be employed for construction phase jobs as far as possible.

Input into national economy • Ensure input materials are sourced locally as far as feasibly possible.

Increased vehicular traffic • Undertake a Traffic Impact Assessment and develop a Traffic Management Plan to minimise the potential impacts of traffic within the town of Arandis during the construction phase.

Potential vehicular collisions

Health and Safety of Construction workers

• Ensure proper maintenance of all plant infrastructure and equipment to ensure employee safety.

• The project should be executed to be in full compliance with the Labour Act 11 of 2007 (as amended) to ensure the health and safety of workers and visitors. It is recommended that a Health and Safety Plan be prepared, and training be provided to all workers prior to starting work.

• Ensure that the contractor has a Human Immunodeficiency Virus (HIV) / Acquired Immune Deficiency Syndrome (AIDS) Policy and Programme and Health and Safety Plan is in place for their workers.

Heritage

Construction activities Loss of archaeological sites • Notify the National Heritage Council of the project and the conclusions presented by the

heritage specialist study.

Table 12: Environmental Management Plan - Operation Phase

Project activity or issue Potential impact Mitigating action

Soil

Hazardous chemical spills Contamination of soils • Store hazardous substances in appropriately bunded areas.

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Project activity or issue Potential impact Mitigating action

• Use a drip-tray when refuelling vehicles or machinery.

• If a spillage occurs, clean it up immediately and dispose soil at an appropriate site as hazardous waste.

Flora

Operational activities Loss / Disturbance of flora

• Prevent and discourage illegal collection of flora (e.g. unique bulbs potentially occur in the area and only visible of periodic rain showers) as this would diminish and negatively affect the local flora.

• Make use of existing tracks/roads as much as possible throughout the area.

• Avoid off road driving in areas to prevent floral specimen loss.

• Prevent the planting of potentially alien invasive plant species for ornamental purposes as part of the plant site landscaping, should this be thought necessary. Alien species often “escape” and become invasive causing further ecological damage.

• Implement a policy of “no tolerance” towards any invasive alien plant species encountered in future in the area. This should include the removal and destruction of these species throughout the proposed development areas. Such activity would be beneficial to the overall ecology of the areas.

• Educate/inform contractors and staff on protected species to avoid and the consequences of illegal collection of such species.

Hazardous chemical spills Plant dieback due to contamination of immediate environment

• Prohibit the use of any pesticides.

• Store hazardous substances in appropriately bunded areas.

• Use a drip-tray when refuelling vehicles or machinery.

• Clean up potential spills immediately and dispose contaminated soils at an appropriate site as hazardous waste.

Fauna

Operational activities Loss / Disturbance of fauna

• Prevent and discourage indiscriminate killing of perceived dangerous species (e.g. snakes, etc.) as this would diminish and negatively affect the local fauna. No form of poaching, illegal collecting of veld foods (e.g. bird eggs, etc.), etc. should be tolerated, especially during the construction phase.

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Project activity or issue Potential impact Mitigating action

• Remove and relocate perceived dangerous species (e.g. snakes) to similar undisturbed habitats in the general area.

• Make use of existing roads as much as possible throughout the area.

• Implement and maintain speed discipline limited to the pre-determined maximum speed limits within the area in an effort to faunal road mortalities.

• Avoid off road driving in areas to avoid habitat destruction. Nocturnal driving should also be avoided as this result in the destruction of slow-moving fauna – e.g. various reptiles and other nocturnal species.

• Initiate a suitable and appropriate refuse removal policy as littering could result in certain animals becoming accustomed to humans and associated activity and resulting typical problem animal scenarios, such as habitat creation for pest rodent species.

• Educate/inform contractors and staff on dangerous and protected species (to avoid and the consequences of killing and/or illegal collection of such species.

Hazardous chemical spills Faunal fatalities or migration due to chemical spills

• Store hazardous substances in appropriately bunded areas.

• Use a drip-tray when refuelling vehicles or machinery.

• Clean up potential spills immediately and dispose contaminated soils at an appropriate site as hazardous waste.

Air Quality

Operational activities

Increase in carbon emissions from material/product transport vehicles

• Undertake necessary maintenance on vehicles and equipment and keep a maintenance record.

Accidental release of gaseous waste (chlorine, carbon dioxide)

• Ensure maintenance of plant infrastructure.

• Identify potential leaks within the processing infrastructure and repair/replace damaged equipment.

• The chlorine emergency towers will be lined with caustic soda to ensure that chlorine gas does not get released in the air.

Increase in dust • Implement dust control mechanisms during the operational phase.

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Environmental Scoping, Impact Assessment And Management Plan Report

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Project activity or issue Potential impact Mitigating action

• Provide personal protective equipment (PPE) to construction workers to prevent or minimise dust inhalation from construction activities.

Noise

Operational activities Generation of noise (e.g. vehicle and building noise)

• Limit material/product transport activities to specific times to restrict noise generation periods.

• Undertake necessary maintenance on vehicles and equipment and keep a maintenance record.

Surface and Groundwater

Hazardous chemical spillages Contamination of groundwater

• The impact of liquid waste on the natural environment in general, and on both potential surface and groundwater resources in particular, must be minimised.

• Store hazardous substances in appropriately bunded areas.

• Use a drip-tray when refuelling vehicles or machinery.

• Implement proper pollution control mechanisms

• Clean up potential spills immediately and dispose contaminated soils at an appropriate site as hazardous waste.

Socio-economic

Operational activities

Job opportunities • Local contractor(s) and workers should be used for the operational activities.

Increased vehicular traffic • Develop a Traffic Management Plan to minimise the potential impacts of traffic within

the town of Arandis during the operational phase

Health and Safety of Construction workers

• The project should be executed to be in full compliance with the Labour Act 11 of 2007 (as amended) to ensure the health and safety of workers and visitors. It is recommended that a Health and Safety Plan be prepared, and training be provided to all workers prior to starting work.

• Ensure that the contractor has a Human Immunodeficiency Virus (HIV) / Acquired Immune Deficiency Syndrome (AIDS) Policy and Programme and Health and Safety Plan is in place for their workers.

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10 December 2019

Table 13: Environmental Management Plan - Closure Phase

Project activity or issue Potential impact Mitigating action

Topography

Decommissioning activities Alteration in drainage patterns

• Natural drainage systems should be reinstated during the decommissioning activities.

Soil

Decommissioning activities Contamination of soils

• Store hazardous substances in appropriately bunded areas.

• Use a drip-tray when refuelling vehicles or machinery.

• If a spillage occurs, clean it up immediately and dispose soil at an appropriate site as hazardous waste.

Flora

Decommissioning activities Loss / Disturbance of flora

• Rehabilitation of area through re-introductions of specimens of local floral community

• Refer to the mitigation measures of the construction and operational phases relating to flora.

Fauna

Decommissioning activities Loss / Disturbance of fauna • Refer to the mitigation measures of the construction and operational phases relating to

fauna.

Air Quality

Decommissioning activities

Increase in carbon emissions from construction vehicles

• Undertake necessary maintenance on vehicles and equipment and keep a maintenance record.

Increase in dust

• Implement dust control mechanisms during the closure phase.

• Erect artificial wind barriers around decommissioning sites minimise dust generation.

• Provide personal protective equipment (PPE) to construction workers to prevent or minimise dust inhalation from construction activities.

Noise

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New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

52 RI 301-00845/02 Rev A

10 December 2019

Project activity or issue Potential impact Mitigating action

Decommissioning activities Generation of noise (e.g. vehicle and building noise)

• Limit construction activities to specific times to restrict noise generation periods.

• Undertake necessary maintenance on vehicles and equipment and keep a maintenance record.

Surface and Groundwater

Decommissioning activities Contamination of groundwater

• The impact of liquid waste on the natural environment in general, and on both potential surface and groundwater resources in particular, must be minimised.

• Store hazardous substances in appropriately bunded areas.

• Use a drip-tray when refuelling vehicles or machinery.

• Implement proper pollution control mechanisms

• Clean up potential spills immediately and dispose contaminated soils at an appropriate site as hazardous waste.

Socio-economic

Decommissioning activities Job opportunities • Namibian citizens should be employed to undertake the decommissioning process as

far as possible.

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Environmental Scoping, Impact Assessment And Management Plan Report

53 RI 301-00845/02 Rev A

10 December 2019

10.0 CONCLUSION

Calculus Commodities (Pty) Ltd, a holding company of Calculus Industries (Pty) Ltd, proposes to

construct a new chloralkali plant within the Arandis Town municipality. The proposed plant will

operate to produce industrial grade chemicals, such as caustic soda (both lye and solid flakes), liquid

chlorine and calcium carbonate granules for supply to industries within Namibia. The plant will require

additional road, water, sewage and electrical support infrastructure as follows:

• Access road connected to Aloe Road in Arandis

• Water derived from a connection with the Arandis Town municipal supply line

• Sewage line connected to the manhole feeding to the nearby oxidation ponds

• Electrical supply line connected to the NamPower substation located in Arandis.

Knight Piésold Consulting (Pty) Ltd were appointed as independent environmental assessment

practitioners for the EIA for the proposed project. The environmental and social impacts of the

proposed plant were assessed, with potential negative impacts being able to be reduced to low

significance ratings with appropriate mitigation measures followed. Negative impacts which were

identified include, but are not limited to, contamination of soils, localised habitat fragmentation,

increased vehicular movements and increased noise and air emission generation. Potential positive

impacts were identified, such as opportunities for employment and economic growth within Arandis as

well as economic input towards the Namibian gross domestic product.

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New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

54 RI 301-00845/02 Rev A

10 December 2019

11.0 REFERENCES

Ambo Consulting Engineers (Ambo). 2019. Design and Cost Report: Proposed Chlor-Alkali Plant in

Arandis, Erongo Region

Calculus Industries (Pty) Ltd. 2019. Calculus Chloralkali Plant: Prefeasibility Study

Climate-Data.Org. 2019. Climate Arandis Available at: https://en.climate-

data.org/africa/namibia/erongo-region/arandis-1326/. Accessed September 2019

Hoadley, M. 2009. Socio-Economic Component of the Social and Environmental Impact Assessment

Report for the Rio Tinto Rössing Uranium Limited Mine Expansion Project, Socio-Economic

Baseline Study

Kinahan, J. 2019. Arandis Chloralkali Plant, Erongo Region: Baseline heritage assessment

Ministry of Environment and Tourism (MET). 2012. GN No. 29 List of activities that may not be

undertaken without Environmental Clearance Certificate and GN No 30. Environmental

Impact Assessment Regulations: Environmental Management Act, 2007

Ministry of Environment and Tourism (MET). 2018. Reporting Guideline for Environmental

Assessment

Namibia Statistics Agency (NSA). 2017. Namibia Inter-censal Demographic Survey 2016 Report.

NSA, Windhoek.

Sipunga, E. 2019. RE:Queries. Received by Lloyd Lynch, 23 August 2019.

Speiser, A. and Mulder, S. 2012. Scoping Report for the proposed Arandis Thermal Power

Generation and Waste Oil Recycling Plants

Strubenrauch Planning Consultants. 2016. Arandis Basemap

World Wildlife Fund (WWF). 2019. Africa: Namibia Available at:

https://www.worldwildlife.org/ecoregions/at1315. Accessed September 2019

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Environmental Scoping, Impact Assessment And Management Plan Report

55 RI 301-00845/02 Rev A

10 December 2019

12.0 CERTIFICATION

This report was prepared and reviewed by the undersigned.

Prepared:

Lloyd Lynch, Pr.Sci.Nat.

Aquatic Scientist

Reviewed:

Tania Oosthuizen, Pr.Sci.Nat.

Senior Environmental Scientist

This report was prepared by Knight Piésold (Pty) Ltd. for the account of Calculus Commodities (Pty) Ltd. Report content reflects Knight Piésold’s best judgement based on the information available at the time of preparation. Any use a third party makes of this report, or any reliance on or decisions made based on it is the responsibility of such third parties. Knight Piésold Ltd. accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this report. Any reproductions of this report are uncontrolled and might not be the most recent revision.

Approval that this document adheres to Knight Piésold Quality Systems:

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RI 301-00845/02 Rev A

10 December 2019

ANNEXURE A

Arandis Town Planning Map

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B2 (T0202) to Okahandja

B2 (T0202) to Swako

pmund

D1911

Planned ArandisExtension 9

Planned ArandisExtension 10

ArandisExtension 6

ArandisExtension 4

ArandisExtension 3

ArandisExtension 5

ArandisProper

ArandisExtension 1

Planned ArandisExtension 8

ArandisExtension 7

ArandisExtension 2

REMAINDER OFTHE FARM ARANDIS

TOWNLANDS NO. 170

REMAINDER OFTHE FARM ARANDIS

TOWNLANDS NO. 170

REMAINDER OFTHE FARM ARANDIS

TOWNLANDS NO. 170

ProposedSolar Plant

ProposedSolar Plant

STUBENRAUCHPLANNING CONSULTANTS

TOWN AND REGIONAL PLANNERS

A R A N D I SA R A N D I SS e p t e m b e r 2 0 1 6

BASEMAP

1 : 7 000

A R A N D I SA R A N D I S

PO Box 41404WindhoekNamibiaemail: [email protected]

tel: 061-251189tel: 061-252490fax: 061-252157

0 175 350 525 70087.5Meters

L E G E N DL E G E N DZ O N I N GZ O N I N G

R E S E R V A T I O NR E S E R V A T I O N

R O A D SR O A D SDistrict RoadsTrunk Roads

Informal Residential

Business

Residential

InstitutionalF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFF

General IndustrialLight Industrial

F FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFFF FFFF FFFF FFFF Service Station

General ResidentialOffice

ParastatalUndeterminedAgriculturalPrivate Open SpaceSpecial

Local Authority

Existing Streets

Government

New Streets / Proposed Street WideningProposed Road

Public Open SpaceCemetery

E E E E E E E E E E E E EE E E E E E E E E E E E EE E E E E E E E E E E E E

E E E E E E E E E E E E EE E E E E E E E E E E E EE E E E E E E E E E E E EE E E E E E E E E E E E E

E E E E E E E E E E E E E

Local Authority/ Scheme BoundaryExtension BoundaryNampower Lines! !

Railway ReserveNampower Servitude

A

BC

D

Proposed Chloralkali Plant

User
Sticky Note
Lat: -22.42665 Long: 14.95947
User
Sticky Note
Lat: -22.42434 Long: 14.95948
User
Sticky Note
Lat: -22.42434 Long: 14.95380
User
Sticky Note
Lat: -22.42665 Long: 14.95380
User
Distance Measurement
258.64 m
User
Distance Measurement
579.23 m
User
Distance Measurement
258.66 m
User
Distance Measurement
587.86 m
Page 65: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

RI 301-00845/02 Rev A

10 December 2019

ANNEXURE B

Curriculum Vitae

Page 66: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

CONSULTANT PROFILE

TANIA OOSTHUIZEN, (Pr. Sci. Nat) SENIOR ENVIRONMENTAL SCIENTIST

20190904 1 of 8

Mrs. Tania Oosthuizen is a Senior Environmental Scientist at Knight Piesold’s

Rivonia office. She is registered as a Professional Natural Scientist (Pr. Sci. Nat.

114500) with the South African Council for Natural Scientific Professionals

(SACNASP). She is also registered with the Environmental Assessment

Professionals of Namibia (EAPAN). Tania holds a master’s degree in

Environmental Management from the North-West University. Her B.Sc. and B.Sc.

Honours degrees were obtained from the Rand Afrikaans University. She gained

considerable experience over the years in managing complex environmental

authorisation projects. In recent years, she has focused specifically on water use

license applications and has presented a course on the topic in March 2018.

EDUCATION

• 2010 Masters Environmental Management, NWU (cum laude)

• 2003 B.Sc. Natural and Environmental Science, RAU

• 2004 B.Sc. Honours Geography, RAU

REGISTRATION/CERTIFICATIONS

• Professional Natural Scientist with the South African Council for Natural Scientific Professions, Member

No 114500

AFFILIATIONS

• International Association for Impact Assessment (South Africa)

TRAINING

• 2005: Wetland Delineation, Legislation and Rehabilitation, UP

• 2006: Tree Identification Course, Sappi Brett

• 2006: Bird Identification Course, Sappi Brett

• 2006: NEMA EIA Regulations, CEM, Potchefstroom

• 2008: DWAF Best Practice Guidelines Mining, WISA

• 2008: Legal Liability Training, Greengain Consulting

• 2009: Acid Rock Drainage / Waste Characterization, Knight Piésold Denver

• 2010: Water Use License Applications – Procedures, Guidelines and Pitfalls, CBSS

• 2010: The National Water Act and Regulations – Practical Understanding, CBSS

• 2010: The National Environmental Management Waste Act (59 of 2009) and its regulations, CBSS

• 2011: ISO 14001:2004 Module 1, SABS

• 2014: Integrated Water Management in South Africa, CEM, Potchefstroom

• 2015: Environmental Law, Business Success Solutions

• 2016: ISO 14001:2015 Awareness and Implementation, Advantage Act

• 2017: ISO 14001:2015 Lead Auditors; WTH Management and Training

• 2017: Environmental law update workshop, IMBEWU

• 2018: Ecological Rehabilitation and Mine Closure, CEM, Potchefstroom

NATIONALITY

South African

Page 67: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

CONSULTANT PROFILE

TANIA OOSTHUIZEN, (Pr. Sci. Nat) SENIOR ENVIRONMENTAL SCIENTIST

20190904 2 of 8

DATE OF BIRTH

31 December 1981

YEARS OF EXPERIENCE

15 Years

COUNTRIES OF WORK EXPERIENCE

South Africa, Swaziland, Namibia, Malawi, Tanzania, Zambia, Ghana, Zimbabwe

LANGUAGES

Speaking Reading Writing

English Excellent Excellent Excellent

Afrikaans Excellent Excellent Excellent

PROFESSIONAL EXPERIENCE

2019 Project: Lower Maguga Hydropower Project

Client: Eswatini Electricity Company

Contact: Seluleko Fakudze

Position: Project Manager

Description: Scoping Report

Activities Performed: Undertook a full Scoping Process including categorisation process and public meetings

Project Value: R 800 000 (for the Scoping component)

2018 -2019 Project: Wessels Mine EMP Amendment and IWULA

Client: Hotazel Manganese Mines

Contact: Sylvia Makoele

Position: Mentor / reviewer (EMP), Project Manager (IWULA)

Description: Scoping Report

Activities Performed: Assisted in the finalisation of the EMP through mentoring and review. Project Managed the IWULA / IWWMP.

Project Value: ±R 350 000 (for the IWULA component)

2018 Project: Lesedi and Lestatsi Solar Project

Client: Lesedi Solar Project

Contact: Cornell Mouton

Position: Project Manager

Description: Two solar farms (Northern Cape and Free state)

Activities Performed: Operational Phase EMPs for two solar farms, and water use licence application for river crossing.

Project Value: R 200 000 (for the IWULA component)

2018 Project: Redstone Concentrated Solar Plant

Client: AWCA SolarReserve

Contact: Leanna Jansen van Rensburg

Page 68: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

CONSULTANT PROFILE

TANIA OOSTHUIZEN, (Pr. Sci. Nat) SENIOR ENVIRONMENTAL SCIENTIST

20190904 3 of 8

Position: Project Manager

Description: Integrated Water and Waste Management Plan (IWWMP)

Activities Performed: Compilation of WWMP

2018 Project: IWULA course

Client: Knight Piésold

Contact: Vishal Haripasad

Position: Co-developer and co-presenter

Description: IWULA course

Activities Performed: Developed and presented a course on water use licencing and water

use charges

2016-2017 Project: Duvha Power Station

Client: Department of Water Affairs

Contact: Simthandile Mpondo

Position: Project Manager

Description: Duvha Water Use Licence

Activities Performed: Project Manager for the gap analysis and amendment of the

Integrated Water Use License Application (IWULA) and Integrated

Water and Waste Management Plan (IWWMP) for the Duvha Power

Station.

Project Value: R300 000.00

2016 Project: Arnot Power Station IWULA Audit

Client: Eskom Arnot Power Station

Contact:

Position: Project Manager

Description: Annual IWULA audit is a condition of the power station’s water

licence

Activities Performed: Undertook annual IWULA audit for Arnot Power Station.

Project Value: R46 000.00

2016 Project: Glencore Goedgevonden Colliery Audit

Client: Golder Associates

Contact: Rianna Munnik

Position: Team Member

Description: Goedgevonden Colliery is required to undertake annual reviews of their Environmental Management Programme (EMPr)

Activities Performed: Undertook annual EMPr audit at Glencore Coal Mine.

R30 000.00

2015-2016 Project: Camden Biodiversity Management Plan

Client: Eskom Camden Power Station

Contact: Thabiso Mpongo

Position: Project Manager

Description: Eskom required the development of a Biodiversity Management Plan (BMP) as part of their ISO14001 continual improvement plan.

Activities Performed: Project Managing the compilation of a BMP for the Camden Power Station.

Project Value: R350 000.00

Page 69: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

CONSULTANT PROFILE

TANIA OOSTHUIZEN, (Pr. Sci. Nat) SENIOR ENVIRONMENTAL SCIENTIST

20190904 4 of 8

2013-2017 Project: Kendal 30-year Ash Disposal Facility

Client: Eskom Kendal Power Station

Contact: Emmy Molepo

Position: Project Manager

Description: Eskom must develop an additional Ash Disposal Facility (ADF) to accommodate more ash, as the life of the power station had been extended.

Activities Performed: Project Manager for the environmental authorization processes (EIA, WMLA and IWULA) for a new ADF for Kendal Power Station near Ogies in Mpumalanga.

Project Value: R6.500 000.00

2015 Project: Camden Grave Relocation Process

Client: Tobile Bokwe

Contact: Project Manager

Position: As part of the development of a new ADF for Camden Power Station, several graves had to be relocated.

Description: Project Manager for the grave relocation process for 45 graves situated on the area earmarked for the new Camden Ash Disposal Facility.

Activities Performed: R350 000.00

Project Value: Project Manager

2015 Project: Kusile 60-year Ash Disposal Facility

Client: Eskom Kusile Power Station

Contact: Mari Kotze

Position: Project Reviewer

Description: Eskom needed an additional ash disposal facility (ADF) at Kusile Power Station to accommodate ash for the full life of the station. One of the environmental authorisation processes required to develop this 60-year facility was a Water Use Licence.

Activities Performed: Project reviewer for the IWULA and IWWMP reports for the Kusile 60-year Ash Disposal Project near Balmoral in Mpumalanga.

Project Value: R1 000 000.00

2013-2015 Project: EIA Kendal Continuous Ash Disposal Facility

Client: Eskom Kendal Power Station

Contact: Emmy Molepo

Position: Project Manager

Description: Eskom must expand their existing Ash Disposal Facility (ADF) to accommodate more ash, as the life of the power station has been extended.

Activities Performed: Project Managed the IWULA process for the continuation of ash disposal on new footprint for the Kendal Power Station near Ogies in Mpumalanga.

Project Value: R100 000.00

2014-2016 Project: Camden New Ash Disposal Facility

Client: Eskom Camden Power Station

Contact: Tobile Bokwe

Position: Project Manager (from 2014-2016)

Description: Eskom needed an additional ash disposal facility (ADF) at Camden

Page 70: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

CONSULTANT PROFILE

TANIA OOSTHUIZEN, (Pr. Sci. Nat) SENIOR ENVIRONMENTAL SCIENTIST

20190904 5 of 8

Power Station to accommodate ash for the full life of the station. Activities Performed: Project Managed the environmental authorization processes (EIA,

WMLA and IWULA) for a new Ash Disposal Facility for Camden Power Station near Ermelo in Mpumalanga. I took over the project in 2014 and saw it to completion.

Project Value: R4.500 000.00

2014-2015 Project: Grootvlei Power Station

Client: Eskom Grootvlei Power Station

Contact: Felicia Sono

Position: Project Manager

Description: Eskom developed a Solar PV project as a pilot project for alternative energy.

Activities Performed: IWULA project for a Solar PV project in Grootvlei Power Station in Mpumalanga.

Project Value: R200 000.00

2012-2013 Project: Wallmannsthal Fluorspar Mine, Gauteng, South Africa

Client: Sephaku Holdings

Contact: Elvis Rabohale

Position: Project Manager

Description: Proposed new Fluorspar mine in Gauteng

Activities Performed: Project Manager (during this period) on the environmental authorization processes (EIA, EMPR, IWULA, IWWMP and waste license) for a greenfields fluorspar mine in Gauteng. Tania also managed the public participation and GIS components of the study.

Project Value: R 2.800 000.00

2012-2013 Project: Eureka Mine, Zimbabwe

Client: Delta Gold

Contact: Barris van Houten

Position: Project Manager

Description: Gold mine, which was under, care and maintenance required a due diligence audit before going back into operation.

Activities Performed: I completed a due diligence audit for this gold mine in Zimbabwe.

Project Value: R200 000.00

2012-2013 Project: Marsfontein Mine, Limpopo, South Africa

Client: Mwana Africa

Contact: Project Manager

Position: Natasha Gibson

Description: The DMR had issued instruction for a decommissioned diamond Mine in Limpopo to undergo closure.

Activities Performed: Completed a closure Plan for this decommissioned diamond Mine in Limpopo.

Project Value: R50 000.00

2012-2013 Project: Wayland Iron Ore Mine, Limpopo, South Africa

Client: Sekoko Resources

Contact: Nthabeleng Ledwaba

Position: Project Manager

Description: Proposed iron-ore mine in Limpopo

Page 71: NEW CHLORALKALI PLANT IN ARANDIS - Gov · 2019. 12. 11. · New Chloralkali Plant In Arandis Environmental Scoping, Impact Assessment And Management Plan Report EXECUTIVE I of I RI

CONSULTANT PROFILE

TANIA OOSTHUIZEN, (Pr. Sci. Nat) SENIOR ENVIRONMENTAL SCIENTIST

20190904 6 of 8

Activities Performed: During this period, I was the Project Manager on the environmental authorisation processes (EIA, EMPR, IWULA, IWWMP and waste license) for a greenfields iron ore mine in Limpopo. I also managed the public participation and GIS components of the study.

Project Value: R2.800 000.00

2011-2012 Project: Middelburg Ferrochrome, Mpumalanga, South Africa

Client: Middelburg Ferrochrome

Contact: Liesel Ehlers

Position: Project Manager

Description: To undertake an annual IWULA audit is a condition of the facilities’ water use licence

Activities Performed: She undertook an audit on facility’s compliance to their water use license and GN704.

Project Value: > R 600 000.00

2009-2011 Project: Burnstone Gold Mine, Mpumalanga South Africa

Client: Great Basin Gold

Contact: Willie Beckman

Position: Project Manager

Description: Proposed gold mine in Mpumalanga

Activities Performed: Project Manager for the compilation of a new EIA, EMPR update, and IWULA update for proposed expansions to the mine. The project included a full public participation programme.

Project Value: R 3 000 000, Various assignments

2010-2011 Project: Grootvlei - Burnstone Power Line, Mpumalanga

Client: Great Basin Gold

Contact: Gerrie van Schalkwyk

Position: Project Manager

Description: A power line was required to provide power from the Grootvlei Power Station to the proposed Burnstone Mine

Activities Performed: Project Manager in the compilation of two Basic Assessment Reports and Environmental Management Plans as well as an S21(c) and (i) water use license for the crossings of wetlands.

Project Value: R 3 000 000, Various assignments

2010-2011 Project: Kusile Power Station, Mpumalanga

Client: Eskom Kusile Power Station

Contact: Leon Stapelberg

Position: Project Manager

Description: Kusile Power Station required a Water Use licence for its 10 year Ash Disposal Facility.

Activities Performed: Project Manager for the water use license update process for the Kusile power station. I also managed a Section 21 (c) and (i) water use license for the ash dump.

Project Value: R 1 500 000

2010 Project: Neckartal Dam, Namibia

Client: Ministry of Water and Forestry, Namibia

Contact: Harold Koch

Position: Part of project team

Description: A new dam (Neckartal) was proposed to be built in the Karas Region

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CONSULTANT PROFILE

TANIA OOSTHUIZEN, (Pr. Sci. Nat) SENIOR ENVIRONMENTAL SCIENTIST

20190904 7 of 8

in Namibia. Activities Performed: Facilitator for the public meetings held in Namibia. I reviewed the

ESIA. Project Value: R 1 500 000

2007-2011 Project: Gauteng Freeway Improvement Project, Gauteng

Client: South African National Roads Agency Limited (SANRAL)

Contact: Mpati Makoa

Position: Project Manager

Description: SANRAL undertook to upgrade the national road network in Gauteng

Activities Performed: Project Manager for the compilation of three Basic Assessment Reports and Environmental Management Plans. I was also appointed as the Environmental Control Officer (ECO) on six other work packages which comprised quarterly environmental site inspections and reports for three years.

Project Value: > R1 000 000

2007 Project: Luwumbu and Mibango Exploration Projects

Position: Project Manager

Description: Client wanted to undertake exploration activities in Tanzania

Activities Performed: Project Manager for the development of EMPs for exploration activities in Tanzania. I undertook site visits and made recommendations regarding environmental issues and risks and future environmental applications.

2008 Project: Swaziland mini-hydropower stations

Client: Ministry of Water Swaziland

Contact: Shaun Finlay

Position: Part of Project Team

Description: Ministry of Water in Swaziland was assessing possible sources of energy in the form of mini-hydropower stations

Activities Performed: I undertook site visits to develop alternatives analysis of the environmental viability of different sites for mini-hydropower options.

2007-2008 Project: Lumwana Uranium Project, Zambia

Client: Barrick

Position: Part of Project Team

Description: Cooper and Uranium Mine, Zambia

Activities Performed: I was part of the team who undertook the environmental assessments for the uranium component of the Lumwana project. I was responsible for the site visit, baseline chapters and to undertake the alternatives assessment for the siting of the Tailings Storage Facility and uranium processing plant.

2006-2007 Project: Kayelekera Uranium Mine, Malawi

Client: Paladin Resources

Position: Part of Project Team

Description: Uranium Mine in Malawi

Activities Performed: I was part of the team who undertook the World Bank EIA for the Kayelekera Uranium Project in Malawi. I assisted with day to day aspects of the EIA and was specifically responsible for the water quality monitoring and analysis, the sensitivity mapping and certain aspects of the public participation.

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CONSULTANT PROFILE

TANIA OOSTHUIZEN, (Pr. Sci. Nat) SENIOR ENVIRONMENTAL SCIENTIST

20190904 8 of 8

2004-2005 Project: Cullinan Diamond Mine, Gauteng

Client: Cullinan Diamond Mine

Contact: Marietjie Reynecke

Position: Environmental Officer

Description: Day to day Environmental work on the mine.

Activities Performed: She was sub-contracted to Cullinan Diamond Mine to work as Environmental Officer. There, she was part of a team who were responsible to maintain an Environmental Management System. She was responsible to give environmental induction training and to set up a GIS system for the mine.

Project Value: n/a

WORK HISTORY

Dates Company Name Position

Aug 2017 - current Knight Piésold (Pty) Ltd. South Africa Senior Environmental Scientist

June 2013 – Aug 2017 Zitholele Consulting Senior Environmental Consultant

2012 - 2013 AGES Senior Environmental Consultant

2005 - 2012 Knight Piésold (Pty) Ltd. South Africa (Senior) Environmental Scientist

2004 - 2005 Information Decision Systems GIS and Environmental Scientist

PUBLICATIONS AND PRESENTATIONS

Oosthuizen, T. Mining Review Africa. Environmental Legislation Development: Mining Sector Take Note. June

2018

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CONSULTANT PROFILE

LLOYD LYNCH (Pr.Sci.Nat), AQUATIC SCIENTIST

20180831ENV 1 of 5

Lloyd Lynch has worked for Knight Piésold as an Aquatic Scientist for four years

with a focus on aquatic science. Lloyd has an aquatic science background, a

registered professional scientist and an accredited SWA: SASS version 5

practitioner. During his career, Lloyd has conducted aquatic specialist assessments

across South Africa, both for standalone assessments as well as scheduled bio-

monitoring, making use of both SASS and FAII. Lloyd has also assisted with a

variety of other tasks ranging from public participation consultations, ESIA baseline

input, both air and water quality reporting and project management. Lloyd has also

been part of various other projects such as conducting the Riparian Vegetation

Response Assessment Index (VEGRAI) for the state of rivers for the Johannesburg

Metropolitan.

EDUCATION

• MSc Aquatic Health, University of Johannesburg, South Africa (2014)

• BSc Honours Zoology, University of Johannesburg, South Africa (2012)

• BSc Zoology and Botany, University of Johannesburg, South Africa (2011)

REGISTRATION/CERTIFICATIONS

• SACNASP, South African Council for Natural Scientific Professions, Pr.Sci.Nat. No. 116026

• Department of Water and Sanitation: SASS 5 Accredited Practitioner, 2017

AFFILIATIONS

• SACNASP, South African Council for Natural Scientific Professions, Pr.Sci.Nat. No.116026

TRAINING

• Department of Water and Sanitation: SASS 5 Accreditation, 2017

• Centre for Environmental Management: Environmental Law (Introduction), 2018

NATIONALITY

South African

DATE OF BIRTH

13 June 1988

YEARS OF EXPERIENCE

4 years

COUNTRIES OF WORK EXPERIENCE

South Africa, Swaziland, Democratic Republic of Congo

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CONSULTANT PROFILE

LLOYD LYNCH (Pr.Sci.Nat), AQUATIC SCIENTIST

20180831ENV 2 of 5

LANGUAGES

Speaking Reading Writing

English Excellent Excellent Excellent

Afrikaans Good Good Good

PROFESSIONAL EXPERIENCE

2017- Present

Project: ERWAT Aquatic Bio-Monitoring

Client: East Rand Water Care Company (ERWAT) Position: Jnr. Environmental Scientist Description: Knight Piésold (Pty) Ltd was appointed by the East Rand Water Care

Company (ERWAT) to conduct aquatic bio-monitoring at 19 Wastewater Care Works (WCW) on a quarterly basis. The aim of the bio-monitoring is to assess the impact of the WCW on the receiving aquatic environment. To comply with the Water Use Licence conditions from the Department of Water and Sanitation (DWS) aquatic bio-monitoring and toxicity testing needs to be conducted downstream and upstream of each WCW.

Activities Performed: Lloyd performed aquatic bio-monitoring (SASS, IHAS and FAII) at all the river sites, as well as collecting diatom samples at specific sites and collecting water samples for chemical and toxicity analysis, captured and interpreted the data and wrote the reports based on the data.

Project Value: > R 12 000 000.00 various assignments

2016- Present

Project: MMG Kinsevere – Air Quality Monitoring

Client: MMG Kinsevere Copper Mine Position: Jnr. Environmental Scientist Description: The Kinsevere Copper Mine is located in the Kipushi territory in the Katanga

province of the Democratic Republic of the Congo (DRC), approximately 30 km north, northwest from Lubumbashi. The copper oxide from three mineralised zones will be exploited during the life of the project. Knight Piésold is responsible for providing equipment, monthly data analysis, specialist studies and reports on a monthly and annual basis.

Activities Performed: Lloyd assisted with capturing the monthly air quality data and writing reports thereof. As of 2017, Lloyd became project manager for this project, handling all aspects such as liaising with sub-consultants and arranging transport of equipment through to writing the reports.

Project Value: > R 12 000 000.00 various assignments 2017 Project: Kinsevere Copper Mine: EIS Update 2017 Client: MMG Kinsevere Position: Jnr. Environmental Scientist Description: The mine site is located in the Kipushi territory in the Katanga province of the

Democratic Republic of the Congo (DRC), approximately 30km north, northwest from Lubumbashi. Copper oxide was exploited from three mineralised zones namely, Central Pit, Mashi Pit and Kinsevere Hill. The 2017 Environmental Impact Study (EIS) aims to fulfil the requirements of Article 463 of the Regulations in terms of the Mining Code (Decree No 038 / 2003 of 26 March 2003), thereby serving as an update of the 2012 EIS.

Activities Performed: Lloyd assisted with the compilation of various chapters of the EIS Update. Project Value: 727 084.11 (USD)

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CONSULTANT PROFILE

LLOYD LYNCH (Pr.Sci.Nat), AQUATIC SCIENTIST

20180831ENV 3 of 5

2017 Project: Sterkspruit Aquatic Bio-monitoring 2017 Client: Sterkspruit Aggregates (Pty) Ltd Position: Jnr. Environmental Scientist Description: Sterkspruit Aggregates (Pty) Ltd is located in KwaZulu Natal close to the town

of Ntshongweni. The Sterkspruit flows adjacent to Sterkspruit Aggregates along the quarry premises. As part of the Water Use Licence (WUL) conditions and Integrated Water and Waste Management Plan (IWWMP) aquatic bio-monitoring needs to be conducted bi-annually to determine the potential impact of the Sterkspruit quarry activities on the Sterkspruit.Knight Piésold (Pty) Ltd was appointed by Sterkspruit Aggregates (Pty) Ltd to conduct the aquatic bio-monitoring on the Sterkspruit that flows adjacent to the operation.

Activities Performed: Lloyd performed SASS version 5, IHAS and FAII at 5 sites. In-situ parameters were recorded at each site and diatom samples were collected for further analysis. He then drafted the report following data analysis.

Project Value: R 101 700.00

2016-Present Project: MMG Kinsevere – Water Quality Monitoring – D.R.C. Client: MMG Kinsevere Copper Mine Position: Jnr. Environmental Scientist Description: The Kinsevere Copper Mine is located in the Kipushi territory in the Katanga

province of the Democratic Republic of the Congo (DRC), approximately 30 km north, northwest from Lubumbashi. The copper oxide from three mineralised zones will be exploited during the life of the project. Knight Piésold is responsible for conducting water and bio- monitoring of the area.

Activities Performed: Lloyd attended multiple site visits to MMG Kinsevere Copper Mine in the DRC where he assisted in the collection of water samples and in situ data at a multitude of sites. Furthermore, he assists with monthly memos on water quality data and both sample and equipment logistics.

Project Value: > R 12 000 000.00 various assignments

2016-Present Project: Johannesburg Water Aquatic Monitoring of Waste Water Treatment Works

Client: Johannesburg Water Position: Jnr. Environmental Scientist Description: Aquatic Monitoring services for four waste water treatment works in the

Johannesburg region. Two additional WWTW were included into the project as of 2017. As the WWTW discharge the final effluent into the aquatic environment these aquatic systems need to be monitored and potential impacts identified.

Activities Performed: Lloyd collected water samples from all sites for analysis for toxicity screening on a bi-monthly basis. Aquatic bio-monitoring was performed at all river points on a bi-annual basis. He also analysed in situ water quality parameters at each site.

Project Value: > R 1,200,000.00 Various contracts

2016-Present Project: City of Johannesburg – State of Rivers Client: City of Johannesburg Position: Jnr. Environmental Scientist Description: Knight Piésold (Pty) Ltd was appointed by the City of Johannesburg (CoJ) to

conduct the State of Rivers report for the Klip River and Jukskei catchments within the Johannesburg Metropolitan region.

Activities Performed: Lloyd performed VEGRAI analysis at each location, identifying plants within the respective zones and determining impacts on the vegetation at each location. He also assisted with SASS (invertebrate) sampling, and analysis of in situ water quality parameters for each site.

Project Value: R 307,850.00 (Est)

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CONSULTANT PROFILE

LLOYD LYNCH (Pr.Sci.Nat), AQUATIC SCIENTIST

20180831ENV 4 of 5

2016-Present Project: Two Rivers Platinum Mine

Client: Two Rivers Platinum Mine Position: Description: The Two Rivers Platinum Mine is a joint venture between African Rainbow

Minerals and Impala Platinum Holdings Limited. The operation is situated on the farm Dwarsrivier on the southern part of the eastern limb of the Bushveld Igneous Complex in Mpumalanga, South Africa.

Activities Performed: Lloyd was trained in performing SASS sampling and identification at sites within this location. Lloyd performs the aquatic bio-monitoring (SASS and FAII) for this project. He assisted in analysis of in situ water quality parameters and collected samples for toxicity screening. He drafts the reports based on the analysis of all data.

Project Value: R 212 300.00 2016 Project: IEE and ESMP for Ezulwini water supply project - Swaziland Client: Swaziland Water Services Corporation Position: Description: The Initial Environmental Evaluation (IEE) follows the categorisation of the

project by Swaziland Environmental Authority (SEA) as a category 2 project. The Swaziland Water Services Corporation (SWSC) is the Ezulwini Sustainable Water Supply project co-ordinator and applicant. Knight Piésold Consulting Swaziland was appointed by the SWSC to undertake the IEE for this project.

Activities Performed: Lloyd assisted with the public participation process and meetings of this project.

Project Value: R 180 300.00 2016 Project: Glendale Distillery - Aquatic bio-monitoring survey Client: Glendale Distillery Position: Jnr. Environmental Scientist Description: Knight Piésold (Pty) Ltd was appointed by WSP Group Africa (Pty) Ltd to

conduct the aquatic bio-monitoring for the Illovo Distillery in Glendale to comply with their Water Use Licence (WUL) conditions.

Activities Performed: Lloyd performed aquatic bio-monitoring (SASS, IHAS and FAII) at the three sites, captured and interpreted the data and wrote the draft report based on the data.

Project Value: R 110 000.00 2016 Project: Feasibility Study for the Ethemba Dam Project - Swaziland Client: The Ministry of Natural Resources and energy (MNRE) Position: Jnr. Environmental Scientist Description: Completion of the Ethemba Dam feasibility study: Environmental and Social

Impact Assessment, geotechnical investigation and Resettlement Action Plan.

Activities Performed: Lloyd assisted with the public participation process, with regards to compilation of documents for the public, visiting the villages and attending public meetings and capturing minutes of all meetings. He further assisted in the compilation of the ESIA for the project.

Project Value: R 10 130 350.00

2016 Project: Ingula Pumped Storage Scheme - Aquatic bio-monitoring survey Client: WSP|Parsons Brinckerhoff Position: Jnr. Environmental Scientist Description: Knight Piésold (Pty) Ltd was appointed by WSP|Parsons Brinckerhoff to

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CONSULTANT PROFILE

LLOYD LYNCH (Pr.Sci.Nat), AQUATIC SCIENTIST

20180831ENV 5 of 5

Conduct the aquatic bio-monitoring for the Eskom Ingula Pump Storage Scheme to comply with their Water Use Licence (WUL) conditions.

Activities Performed: Lloyd performed two aquatic bio-monitoring surveys (SASS, IHAS and FAII) at the twelve sites, captured and interpreted the data and wrote the draft reports based on the data.

Project Value: R 197,440.00

WORK HISTORY

Dates Company Name Position

2016-Date Knight Piésold (Pty) Ltd Junior Environmental Scientist

2015 University of Johannesburg Contract Lecturer

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

RI 301-00845/02 Rev A

10 December 2019

ANNEXURE C

Plant and Services Layout Map

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

RI 301-00845/02 Rev A

10 December 2019

ANNEXURE D

Prefeasibility Study: Technical Extract

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Water and sewerage

Effluent discharge

Power supply

Offices and workshops

Grounding and fencing

Environmental studies

Plant lighting and CCTV

Network and comms

Roads, paving, pipe racks, and other process equipment supports.

Ambo consulting engineers will scope and design the items outside the battery limit, and

Namibian construction firms will be appointed to carry out the work under Ambo and Nuberg.

During the construction period, it is estimated that over 400 people will be employed at the site,

for two years.

3.1.2. Process design

3.1.2.1. Process feed

The primary inputs into the production process are:

Chemical grade salt

Industrial grade calcium chloride

Water

Electricity

3.1.2.1.1. Salt

Salt is the primary raw material for the chloralkali process. Chemical grade salt (99%) is required as

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an input into the process at 26,400 metric tons per annum (tpa). The salt will be purchased from a

solar salt mine at Cape Cross, and transported to site via road (180 km). The salt will be off-loaded

from road trucks onto a salt storage patio with the capacity to store 2,000 metric tons of salt. Two

dedicated trucks, with a combined payload of 57.4 tonnes will be purchased for the collection of

salt from the mine. Each truck will make two round trips per day.

3.1.2.1.2. Calcium carbonate

Calcium carbonate will be used to produce calcium chloride and carbon dioxide. Industrial grade

calcium carbonate (96%) will be sourced from the SwaCa quarry mine outside Swakopmund. A

minimum of 2,000 tonnes will be stored at the plant site. One dedicated truck with a payload of

28.7 tonnes will be purchased to collect calcium carbonate from the quarry. A total of 18,000

tonnes is required per annum.

3.1.2.1.3. Water supply

Domestic water will be obtained from the Arandis Town water network. The water will be used for

the following purposes:

Demineralized water

Chilled water

Cooling water

Fire-fighting

Drinking

Ablution facilities.

A nominal flowrate of 38m3/hr of water supply is required for the operation of the plant.

3.1.2.1.4. Power supply

The maximum power requirement for the plant is 10 megavolt amperes (MVA). The plant will

operate for 350 days per annum, as per design criteria. It is assumed that the plant will carry on

operating during shift changes, effectively operating 24 hours a day.

The true power consumption, based on an apparent power of 8 MVA and utilizing a power factor

correction of 0.9, is 7.2 megawatts (MW).

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The required power will be supplied from the nearby 220 Kv line. Electricity supply is currently

being discussed with NamPower. Light fuel oil will be utilized as fuel for steam boilers.

3.1.2.1.5. Other chemicals and consumables

Other process chemicals and consumables are required in small quantities and they will be

obtained from China and India via the port of Walvis Bay. These materials will be transported to

site by a dedicated inhouse truck.

These materials are:

Ethanol amine for carbon dioxide absorption

Sulfuric acid (98%) for chlorine drying

Caustic soda (sodium hydroxide - 32%) for first filling of the electrolyser

Sodium carbonate (soda ash) for brine treatment and neutralization of crude CO2.

Barium carbonate for brine treatment

Flocculent for brine settling

Pre-coat and filter aid (alpha-cellulose) for brine filtration

Active carbon for brine filtration

Chelating resins for secondary brine treatment

Hydrogen peroxide (50%) for final brine dichlorination

3.1.2.2. Production process

3.1.2.2.1. Brine manufacturing and treatment

Salt is added to the brine saturation vessel by bucket elevator twice a day, for three hours. From

the saturators, the saturated brine outflows to a combined precipitation and sedimentation tank.

At this stage, soda ash and caustic soda are added. In the lower part of the sedimentation tank,

sedimentation and agglomeration takes place. The agglomeration is completed after

approximately 10 hours. The sludge from the bottom of the sedimentation tank is removed

periodically to a sludge tank. The brine is then filtered to obtain an entirely pure solution. At this

stage the brine is free of impurities such as magnesium and calcium. The purified brine is then

stored in a brine storage tank.

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3.1.2.2.2. Electrolysis

From the brine storage tank, the brine is pumped to a brine polishing filter and then to an ion

exchange column. This is to ensure that any newly generated or unremoved impurities are

stripped.

The brine is then sent to the electrolyzers. Chlorine and hydrogen are released from the cells at a

pressure slightly above atmospheric pressure, in order to ensure that they do not escape.

Approximately half the amount of chlorides in the brine feed to cells, is converted to chlorine. The

spent brine is therefore sent to a brine dichlorination tower, where chlorine is stripped with air.

The chlorine and air mixture is sent to the chlorine tower, whilst the brine is sent back to the brine

saturation vessel. Caustic soda produced directly in the membrane cell electrolyzers is of about

32% NaOH concentration. A portion of the stream is cooled and stored, whilst the remainder is

transferred to the caustic soda evaporator.

3.1.2.2.3. Caustic soda evaporation and concentration

The evaporation system consists of three falling film evaporator units. In falling film evaporator,

the liquid product enters the evaporator at the head of the evaporator. In the head, the product is

evenly distributed into the heating tubes. The liquid enters the heating tube and forms a thin film

on the tube wall where it flows downwards at boiling temperature and is partially evaporated.

Steam is used for heating the evaporator. The product and the vapor both flow downwards in a

parallel flow. This gravity-induced downward movement is increasingly augmented by the co-

current vapor flow. The separation of the concentrated product from its vapor takes place in the

lower part of the heat exchanger and the vapor/liquid separator. The heat necessary to evaporate

the water is obtained from an LFO burner.

The caustic soda feed from the electrolyzer passes through the first evaporator and is

concentrated from 32% to 38%. The 38% caustic soda liquor is then pumped to the second

evaporator and 50% caustic soda is produced at the discharge. A portion of the concentrated 50%

product is pumped to the product cooler, where it is cooled by cooling water to the required

outlet temperature and stored in storage tanks. The remainder of the liquor is fed to the third

evaporator and the caustic soda is dehydrated from 50% to 99% caustic soda melt.

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The 99% caustic soda melt is fed via a seal pot by gravity flow to a flaking machine, where it is

processed into flakes. The flakes are bagged and stored as final product.

3.1.2.2.4. Sodium hypochlorite production

The chlorine production tower will be fitted with a secondary tower containing caustic soda for

emergency absorption of chlorine gas venting. Annually or semi-annually, this tower may be

purged and replaced with clean caustic soda.

Before purging, the solution is strengthened with chlorine to provide 12% chlorine solution of

sodium hypochlorite. The solution is bottled and stored.

3.1.2.2.5. Hydrochloric acid production

Combustion of hydrogen and chlorine to produce hydrogen chloride gas takes place in the burner

section of the synthesis unit. The gas is then contacted with absorption water to produce

hydrochloric acid, as a 33% HCl solution. A packed tail gas scrubber is mounted above the

absorber. Absorption water is used to eliminate any traces of gaseous hydrogen chloride, before

venting to the atmosphere. Hydrochloric acid received from the absorber is fed by gravity to the

collection tank and then pumped to the storage tank. Figure 3 depicts the entire process from

brine treatment to hydrochloric acid production.

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Figure 3. Caustic soda, chlorine and hypochlorite sections.

3.1.2.2.6. Calcium chloride production

Limestone (calcium carbonate) of 20- 80 mm size is unloaded in limestone storage yard/go down

from trucks. The limestone is charged in to hopper with the help of a front-end loader. Limestone

from bottom of hopper is charged in to winch trolley, using a discharge feeder and then

transferred at the top of the limestone distribution hopper above dissolver. Concentrated

hydrochloric acid from the HCl storage tank is fed into the dissolver with help of feed pump.

During reaction of limestone with hydrochloric acid, CO2 gas exits with acid fumes and entrained

particles to the waste gas scrubbing system.

The overflow calcium chloride solution with some excess acid goes to the neutralization section.

This system shall contain 3 neutralization reactors and a circulation and transfer system. The

overflow solution passes through the first reactor and the neutralizing chemical, calcium

hydroxide solution (Lime milk) is mixed with first reactor feed. Overflow of first reactor enters into

the second reactor and overflow of second enters into the third reactor.

Calcium chloride solution from neutralization section is sent to the clarifier. Flocculant is added to

the clarifier feed to improve the settling of impurities.

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From clarifier overflow, clear liquid calcium chloride solution (34-35%) is obtained and stored in

the intermediate storage tanks. The slurry discharge from bottom of the clarifier is fed to the

sludge filtration system.

The liquid calcium chloride of 34-35% concentration is fed to the concentration section from the

storage tank. Liquid calcium chloride first enters into the waste /dust scrubbing section as a

circulation liquid. Here all calcium chloride dust gets absorbed into this solution. The solution is

concentrated to 44-48%. The concentrated calcium chloride solution is fed to a fluidized bed dryer

granulator, where it is dried and converted into granules. In this system hot air with help of blower

and hot air generator (LFO fired) is fed from bottom of dryer/granulator, for drying and fluidization

purposes.

Calcium chloride granules from the fluidized bed dryer, is transferred to the product cooling

system using a bucket elevator. From the cooling system calcium chloride is fed over a triple

decker screen. The undersize and oversized material are recycled back to plant for reprocessing

and desired sized is stored in the product silo. Figure 4 depicts the calcium chloride section.

Figure 4. Calcium chloride section.

3.1.2.2.7. Carbon dioxide production

The off gas from the limestone dissolver enters the washing scrubber system. The system consists

of three equal capacity scrubbers. The crude CO2 gas is fed to the first scrubber where scrubbing

will be done by fresh process water.

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Chloralkali Plant Prefeasibility

© CALCULUS INDUSTRIES (PTY) LTD 2019 20

During the water wash most of the acidic impurities will be washed out and the cleaner gas flows

into the second scrubber, where washing is done by soda ash solution, thereby neutralizing acidic

gases and organic impurities. The CO2 gas from second scrubber flows to the third scrubber for

additional water washing of the neutralized impurities.

The scrubbed gas from the scrubbing system is stored in a CO2 gas buffer tank in order to provide

continuous feed to the compressor. The compressor will compress the CO2 to a volume of up to 18

kg/cm2.

The compressed gas is then sent to a dual tower deodorizer, where odour causing impurities (non-

water soluble) that may be present in the CO2 are removed. The CO2 gas is then liquefied by

cooling with ammonia to approximately -22 ºC, at this temperature it changes into liquid CO2.

Liquefied CO2 received from CO2 liquefier is stored in three storage tanks. These tanks are specially

insulated & equipped with refrigeration units, maintaining the temperature of CO2 to be in liquid

form.

3.1.3. Products and volumes

3.1.3.1. Typical Specification for Caustic Soda (Lye)

Sodium Hydroxide: 32 – 50%% w/w

Sodium Chloride: < 30 PPM w/w

Sodium Chlorate: < 20 PPM w/w

Appearance: Clear like water

3.1.3.2. Typical Specification for Caustic Soda (Solids flakes)

Hydroxide Alkalinity as NaOH: 98.5 ± 1% w/w

Sodium Carbonate as CO32-:< 0.2 w/w

Sodium Chloride as Cl-: < 0.04 w/w

Sodium Chlorate as ClO32-: < 0.002 w/w

Sodium Sulfate as SO42-: <0.02 w/w

Iron as Fe3+: <0.002 w/w

Water Insolubles: <0.002 w/w

Appearance: White flakes

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

RI 301-00845/02 Rev A

10 December 2019

ANNEXURE E

Letter from Arandis Town Council

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

RI 301-00845/02 Rev A

10 December 2019

ANNEXURE F

Heritage Specialist Report

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J.KINAHAN, Archaeologist

P.O. Box 22407, Windhoek, Namibia Tel. 061-236216 Cell: 081-3320832

Email [email protected]

29th October, 2019

Knight Piésold (Pty) Ltd. 4 De la Rey Road, Rivonia, Gauteng,

South Africa 2128 For attention: Mr Lloyd Lynch, Junior Environmental Scientist

Arandis Chloralkali Plant, Erongo Region: Baseline heritage assessment

Introduction

Calculus Commodities (Pty) Ltd proposes to establish a chloralkali plant at Arandis, in the Erongo Region. The

plant will be located on the western perimeter of the town and served by power and water supply corridors as

well as road access. The site and linear corridors are on undeveloped land although there is a degree of legacy

disturbance in the form of refuse dumps, sand-winning pits and vehicle tracks.

In terms of the Environmental Management Act (No. 7 of 2007, section 27(3)), projects such as the Arandis

Chloralkali Plant are listed activities (GN. No. 29 of 2012) requiring an Environmental Clearance Certificate (ECC)

before implementation. Knight Piésold (Pty) Ltd has accordingly been appointed to undertake the environmental

assessment, as specified by the Environmental Impact Assessment Regulations (GN. No. 30 of 2012).

Archaeological sites and remains in Namibia are protected in terms of both the Environmental Management Act

(No. 7 of 2007) and the National Heritage Act (27 of 2004). Part V Section 46 of the Heritage Act prohibits

removal, damage, alteration or excavation of heritage sites or remains (defined in Part 1, Definitions 1). Section

51 (3) sets out the requirements for impact assessment.

A series of detailed studies has identified large concentrations of archaeological sites in the central Namib Desert

centering on Arandis. These sites contain evidence of human settlement in the area dating to within the last half

million years. Periods that are particularly well represented in the archaeology of this area include the last inter-

glacial (approximately 120 000 years ago), the mid- to recent Holocene (approximately 5 000 years ago) and the

early colonial era, including important evidence of the 1915 South African invasion.

Knight Piésold (Pty) Ltd has appointed J. Kinahan, Archaeologist, to prepare a heritage impact assessment for an

Environmental Assessment of the proposed Arandis Chloralkali Plant. The Terms of Reference for the baseline

study are set out in a letter from Knight Piésold (Pty) Ltd dated 9th October 2019. These comprise:

1. A heritage baseline assessment of the proposed site and any potential impacts on heritage resources. 2. The report should describe any permits required and measures to avoid or mitigate impacts.

Knight Piésold (Pty) Ltd has furnished geographical corner-points for the proposed Arandis Chloralkali Plant site.

Final information on the linear infrastructure was furnished as a sketch and could not be projected as a spatial

file.

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Desk assessment:

The modern settlement of Arandis lies approximately 54km northeast of Swakopmund, on the central western

plains of the Namib Desert. The terrain is generally subdued as a result of erosional cutback of the prevailing

geology characterized by outcropping Damara schist, marble and ortho-amphibolite. The Arandis area receives

between 50 and 100mm annual precipitation, with a degree of variation approaching 90%. Consequently,

vegetation within the Namib Desert biome is extremely sparse1.

Despite its extreme aridity, there is archaeological evidence for the human occupation of the Namib Desert

throughout much of the last one million years, including periods of intense human activity and periods in which

the desert environment was inimical to human occupation2. Detailed archaeological surveys have been carried

out over large parts of the Namib Desert during the last few decades and in many areas these provide a firm

basis for the estimation of likely impacts due to industrial and infrastructural developments3.

The earliest evidence of human occupation in the Arandis area occurs in the form of isolated Early Stone Age

(ESA) artefacts dating to approximately half a million years which are found on gravel outwash surfaces rather

than in their original context. More dense concentrations of Middle Stone Age (MSA) artefacts dating to within

the last 200 000 years also occur mainly as surface finds but their context, such as quarrying sites and tool

fabrication sites provides valuable evidence of early modern Homo sapiens behaviour in the desert environment.

A major MSA site in the Arandis area is located at Panner Gorge where detailed evidence of quarrying activity is

associated with a large outcrop of chert 4. This particular material which has superior flaking properties was in

high demand over the last 100 000 years and chert from Panner Gorge was distributed over a radius of almost

100km in the Namib Desert, thus including the location of the Arandis Chloralkali Plant. The distribution of chert

artefacts and waste material allows detailed mapping of hunting activity and settlement by early modern Homo

sapiens.

A second component of the local archaeological sequence that is of particular importance is evidence from

within the last one thousand years, of systematic human exploitation of wild grass seeds. This activity which is

associated with the acquisition of pottery and a range of important social changes, was the foundation of human

food security in the desert and enabled a significant growth in population. Evidence of wild grass seed

exploitation is widespread mainly along the eastern edges of the Namib Desert and thus also near Arandis.

Finally, the Arandis area was an important theatre of conflict during the 1915 South African invasion which has

left a uniquely well preserved archaeological record. The capture of the railway line via Arandis by Col. Skinner

involved large numbers of South African and British troops who encamped along the railway line and established

a communication network based on a series of heliograph signaling stations5. Several important sites relating

1 Background environmental data from Mendelsohn, J., Jarvis, A., Roberts, C. and Robertson, T. eds. 2002. Atlas

of Namibia: a portrait of the Land and its People. Cape Town, David Philip. 2 Kinahan, J. 2011. From the beginning: the archaeological evidence. In Wallace, M. and Kinahan, J. A history of

Namibia: from the beginning to 1990. London: Hurst & Co., pp 15-44.

3 Kinahan, J. and Kinahan, J.H.A. Namib Desert Archaeological Survey

http://antiquity.ac.uk/projgall/kinahan325/

4 Kinahan, J. and Kinahan, J.H.A. 2009. Archaeological investigation of a Late Pleistocene chert quarry and

workshop site QRS 72/48. Quaternary Research Services, Namibia: Report commissioned by Rössing Uranium

Limited.

5 L’Ange, G. 1991. Urgent Imperial Service: South African forces in German South West Africa 1914-1915. Rivonia:

Ashanti.

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to this campaign have been documented in the Arandis area6. Figure 1, below, shows the distribution of

archaeological documented during in previous studies in the Arandis area.

Figure 1: Archaeological sites in the vicinity of Arandis, Erongo Region, shown as black dots (data from Namib

Desert Archaeological Survey), in relation to the Arandis town limits and the footprint area of the proposed

Arandis Chloralkali Plant.

6 e.g. Kinahan, J. 2013. Archaeological field survey of a site for the proposed Arandis Thermal Power Generation

and Waste Oil Recycling Plant. Report commissioned by SLR Consulting (Africa) (Pty) Ltd.

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Field survey:

The footprint area and setting of the proposed Arandis Chloralkali Plant were examined on foot by means of

parallel transects. The location of archaeological sites was recorded by hand-held GPS and the visible surface

remains described according to commonly used criteria. The ground surface of the survey area has almost no

vegetation cover and the visibility of archaeological materials was therefore relatively high. The area covered by

the survey showed a noticeable degree of legacy disturbance which is probably attributable to the proximity of

Arandis. Disturbance included a high density of vehicle tracks (ranging between 10 and 70% of surface), refuse

dumps and excavations for building sand.

Within the footprint area of the proposed Arandis Chloralkali Plant, three examples of mid-Pleistocene stone

artefacts were found on the surface. These are illustrated in Figure 2. The artefacts all showed advanced surface

abrasion probably due to sand-blasting, such that the evidence of their manufacture was to some degree

obscured. The finds appear to have moved over the surface as a result of sheetwash and are therefore of

negligible research value.

Figure 2: Mid-Pleistocene stone artefacts from the footprint area of the proposed Arandis Chloralkali Plant (scale

1:5), dorsal view on left with obverse on right. The upper piece is a bifacial handaxe, the middle piece is a

unifacial cleaver, and the lower piece is a polyhedral core fragment.

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Figure 3 shows the distribution of archaeological sites in relation to the proposed Arandis Chloralkali Plant.

Geographical co-ordinates for the sites are set out in Table 1. The corridor approaching the footprint site from

the east and southeast yielded no archaeological remains. This area which is closest to the edge of the town also

had the highest density of disturbance. A short western corridor (not indicated on the map but shown on

accompanying documentation) was described as a proposed sewerage line; this, too, yielded no archaeological

remains. The final version of the water supply pipeline was provided as a sketch when fieldwork had already

commenced; the sketch could not be projected as a spatial file and so was used for general orientation to carry

out a foot survey of the area concerned. No archaeological remains were found in the area covered.

Figure 3: The footprint of the proposed Arandis Chloralkali Plant, indicating the distribution of archaeological

sites located during the field survey.

Table 1: Geographical co-ordinates of archaeological sites associated with the proposed Arandis Chloralkali

Plant.

Wpt S. Latitude E. Longitude Description

422 -22,424549 14,959411 ESA cleaver isolated find

423 -22,426298 14,956055 ESA biface isolated find

424 -22,427499 14,958526 ESA polyhedral isolated find

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A general reconnaissance of the western outskirts of Arandis yielded a number of isolated finds that are

consistent with the results of previous surveys undertaken in the surrounding area. These finds included a single

MSA flake tool of yellow chert such as is found at Panner Gorge about 10km to the south. The vicinity of the

dolerite ridge to the south of the proposed Arandis Chloralkali Plant also revealed a number of sites related to

wild grass seed exploitation in the last one thousand years. These sites consist of small areas of disturbed ground

approximately 2-3m in diameter and usually on weathered granite. The disturbed ground indicates areas where

the underground nests of harvester ants were excavated to remove stored caches of grass seed. Usually such

excavations occur in groups (as here) and are also associated with large hammer stones brought from

neighbouring outcrops to break open the weather granite. These sites are extremely common in the Namib

Desert and are of high research value when they occur as integrated local settlement patterns (unlike here). The

Arandis sites are therefore of negligible research value.

Prior to the survey described here earlier work in the Arandis area contributed to a cumulative record of

archaeological settlement and occupation over the last half a million years. The high density of archaeological

sites in this area and the fact that several of them have yielded important new evidence means that direct field

survey is advisable where development is proposed on ground that has not been covered before. In the present

case, the field survey of the proposed Arandis Chloralkali Plant and its related linear infrastructure corridors did

not yield any sites of high research value although the sites located in the course of the field survey generally

confirm the results of previous surveys.

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Impact assessment:

Nature of impact = DIRECT

Ranking (without mitigation):

SEVERITY= 4-5;

REVERSIBILITY= 5 (Irreversible);

DURATION= 5 (Permanent);

SPATIAL EXTENT= 1 (Site only);

PROBABILITY= 4;

SIGNIFICANCE 60 (all negative)

Notes on impact assessment: Impact on archaeological sites in these circumstances is always high to very high.

Impacts on archaeological sites are never reversible. Likewise, the duration of impact is always permanent in the

case of archaeological sites. Because the sites described here from the proposed Arandis Chloralkali Plant and

its related linear infrastructure corridors do not represent an integrated local distribution the spatial extent of

impact is therefore at the lowest value.

Conclusions and recommendations:

The proposed Arandis Chloralkali Plant will have an impact on a small number of archaeological sites that are of

negligible research value. The area covered by the survey is also extensively disturbed which further reduces its

heritage value. On the basis of the observations presented here it is suggested that implementation of the

proposed project will not have significant consequences for the heritage value of the area. It is therefore

recommended that no further mitigation work should be required but that the National Heritage Council should

be notified of the project and the conclusions presented here.

I hope you will find this report satisfactory and look forward to your further instructions.

Yours sincerely

J. Kinahan PhD

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

RI 301-00845/02 Rev A

10 December 2019

ANNEXURE G

Public Participation

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Annexure G- Public Participation

G - 1 - Notice Board Placed on Site

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Annexure G- Public Participation

G – 1 Notice Boards Placed Around Arandis

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G – 2 Newspaper Advertisements

Namibian 16 October 2019 Namibian 24 October 2019

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Republikein 16 October 2019 Republikein 24 October 2019

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G – 3 I&AP Database

ORGANISATION / KEY STAKEHOLDER

CONTACT PERSON NOTIFIED BID SENT

Regional Council

Erongo Regional Council Hon Cleophas Mutjavikua 21/10/2019 21/10/2019

Erongo Regional Council Anette Kapapu 21/10/2019 21/10/2019

Arandis Town Council

Environmental Affairs Mr Paulus Moses 21/10/2019 21/10/2019

Property Mr Jan Strauss 21/10/2019 21/10/2019

CEO Mr Stanley Norris 21/10/2019 21/10/2019

Town Planning Officer Mr Silvanus Makili 21/10/2019 21/10/2019

Procurement Officer Ananias Imbangu 21/10/2019 21/10/2019

Ministry of Environment and Tourism

Directorate of Wildlife and Natural Parks

Mr C. Sikopo 21/10/2019 21/10/2019

Department of Environmental Affairs Ms. Rikka Shikongo 21/10/2019 21/10/2019

The National Heritage Council of Namibia

Archaeologist & Rock Art Specialist Dr. Alma Nankela 21/10/2019 21/10/2019

Ministry of Industrialisation, Trade and SME Development

Namibia Investment Centre Ms. Mbolioshili Amoomo 21/10/2019 21/10/2019

Industrial Development Directorate Ms. Ilona Nkandi Asino 21/10/2019 21/10/2019

Department of Trade and Commerce Ms. Ndiitah Nghipondoka Robiati 21/10/2019 21/10/2019

Ministry of Agriculture, Water and Forestry

Executive Director Mr Percy Misika 21/10/2019 21/10/2019

Public Relations Office Margaret Kalo 21/10/2019 21/10/2019

NamPower

Namibia Power Corporation (Proprietary) Limited Mr Simson Haulofu 21/10/2019 21/10/2019

NamWater

Namibia Water Corporation Ltd Nicolaas du Plessis 21/10/2019 21/10/2019

Erongo Red

Erongo Red Mr Nico Niemand 21/10/2019 21/10/2019

Gaingu Conservancy

Mr. J.B Gaomab 21/10/2019 21/10/2019

Other

Sagit Energy Ventures Mich Nieuwoudt 21/10/2019 21/10/2019

Private Sackaria Hafeni Kanalelo 22/10/2019 22/10/2019

Zero Effluent Technologies Malcolm Grant 21/10/2019 21/10/2019

Zambezi Consulting Engineers Abel Mashoko 21/10/2019 21/10/2019

GALEN Absalom Kapenda 21/10/2019 21/10/2019

Sentratek Namibia Ernst Schnaitmann 21/10/2019 21/10/2019

Hada Hoada Investment CC Kevin Hoaeb 21/10/2019 21/10/2019

Private Floris Diergaardt 21/10/2019 21/10/2019

AECI Mining Solutions Namibia

Managing Director Ritzema Nel 22/10/2019

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ORGANISATION / KEY STAKEHOLDER

CONTACT PERSON NOTIFIED BID SENT

Chemical Engineer Grant van der Merwe 22/10/2019

Metswako Chemicals Shanin Marks 21/10/2019 21/10/2019

Walvis Bay Salt holdings

SHERQ Manager Vazembua Tjizoo 22/10/2019

Technical Director Corrie Botha 22/10/2019

Rocla Pipes

Sales Consultant Snyman Van Wyk 24/10/2019

Namibia Media Holdings

Coordinator: Investigative Unit Catherine Sasman 24/10/2019

Mr. Stanley Norris – Arandis Town Council CEO:

Mr Norris enquired via email (dated 21 October 2019) whether the town’s project application process was

followed. KP responded via phone call, confirming that a meeting was held with the then acting CEO, and KP

provided the letter issued by Mr. Jan Strauss confirming the property, as well as the inclusion into a town

planning study undertaken by the town planning consultants. KP provided further information about the project

to Mr. Norris as presented on the Calculus website.

Mr. Corrie Botha – Walvis Bay Salt Refiners Technical Consultant:

Mr. Botha sent an email (dated 22 November 2019) in which he expressed interest in exploring a potential

project which may require chlorine from the proposed chloralkali plant, as well as potentially being a supplier

of chemical grade salt to the proposed chloralkali plant. Mr. Botha also requested the contact details of either

the Calculus project leader or marketing manager. KP responded via email providing Mr. Botha with the

contact details of the relevant representative of Calculus who can further assist him.

G - 4 Comments Received

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Calculus Commodities (Pty) Ltd

New Chloralkali Plant In Arandis

Environmental Scoping, Impact Assessment And Management Plan Report

RI 301-00845/02 Rev A

10 December 2019

ANNEXURE H

PROOF OF PAYMENT

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