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2018 Annual Environmental Management Report i

2018 Annual Environmental Management Report ii

TABLE OF CONTENTS

No. Description Page No 1 INTRODUCTION 1 1.1 Orano Mining Namibia 1 1.2 Update on Activities 1 1.3 Objectives of the Annual Report 3

2 ENVIRONMENTAL POLICY 3 3 ENVIRONMENTAL ASPECTS AND IMPACTS 4 3.1 Aspects and Impacts of Orano Mining Namibia 4

4 LEGAL AND OTHER COMPLIANCE 6 4.1 National Legislation 6 4.2 Environmental Legislation Review 6 4.3 Licences and Permits 6 4.4 Government Inspections 6 4.5 Interaction with Government Institutions 7

5 OBJECTIVES AND TARGETS 7 6 ENVIRONMENTAL MANAGEMENT PROGRAMME 8 6.1 Overview 8 6.2 Policies and Procedures 8

7 STRUCTURE AND RESPONSIBILITIES 9 8 TRAINING, AWARENESS AND COMPETENCE 10 9 MONITORING AND FEEDBACK 10 9.1 Environmental Incidents 11 9.2 Environmental Monitoring Network 11 9.3 Climate and Air Quality Monitoring 11 9.4 Environmental Radiation Monitoring 18 9.5 Land Surface 21 9.6 Biodiversity 21 9.7 Water Quality Monitoring 24 9.8 Erongo Desalination Plant Monitoring 31

10 NATURAL RESOURCE CONSUMPTION 31 10.1 Electricity Consumption 31 10.2 Fuel Consumption 31 10.3 Water Consumption 32

11 EMISSIONS AND WASTE MANAGEMENT 33 11.1 Greenhouse Gas Emissions 33 11.2 Waste Management 34

12 RESEARCH AND DEVELOPMENT 34 12.1 Restoration Testing and Monitoring 34

13 AUDITING 34 14 REFERENCES 35

ATTACHMENTS

1 ENVIRONMENTAL STRATEGY AND ACTION PLAN PROGRESS REPORT 2017 37

2018 Annual Environmental Management Report iii

LIST OF FIGURES

No. Description Page No 1.1 Locality Map 1 1.2 Examples of C&M Activities in 2018 2 2.1 Orano Mining Namibia Environmental Policy 3 7.1 QHSE Department Structure in 2018 10 9.1 Used Resin Stored in Shipping Container 11 9.2 Weather Stations: Campbell at Midi and Davis at Maxi 13 9.3 Monthly Rainfall at Trekkopje Weather Stations 14 9.4 Annual A-pan Evaporation Data 2009-2018n 14 9.5 Average and Maximum Wind Speed at the Midi Station in 2018 15 9.6 Dust Fallout Bucket and PM10 Monitor 15 9.7 Monthly Dust Fallout Results in 2018 16 9.8 Average Annual PM10 Dust at Arandis 17 9.9 Average Annual PM10 Dust at the Midi Offices 18

9.10 Thermoluminescent Dosimeter Results 2010-2018 19 9.11 Annual Exposure Doses from Inhalation of Dust at Monitoring Sites 20 9.12 Average Annual Radon Exposure Doses at PSVOL Monitoring Sites 21 9.13 Average Plant Condition over Time 22 9.14 Survival Rates of Transplanted Namib Corkwood 23 9.15 Number of Animal Fatalities in 2013-2018 24 9.16 Water Quality Monitoring Boreholes 25 9.17 Main Water Quality Parameters at Borehole M1 in 2007-2018 25 9.18 Main Water Quality Parameters at Borehole M2 in 2007-2018 26 9.19 Sewage Effluent Quality in 2018 30 9.20 Water Level Trends 30 10.1 Trekkopje Mine Monthly Electricity Consumption 31 10.2 Trekkopje Mine Monthly Diesel Consumption 32 10.3 Trekkopje Mine Monthly Water Consumption 32 11.1 Direct and Indirect Greenhouse Gas Emissions 33

LIST OF TABLES

No. Description Page No 3.1 Summary of Environmental Impacts and Significance Ratings for Trekkopje Mine 4 3.2 Summary of Environmental Impacts and Significance Ratings for the Erongo Desali-

nation Plant 5

6.1 List of Policies, Strategies and Procedures 8 8.1 Training of QHSE Section Staff 10 9.1 Summary of Weather Data 2018 13 9.2 Rainfall Data at Annaberg and Midi Stations 14 9.3 Dust Fallout Monitoring Sites and Average Dust Concentration in 2018 16 9.4 PM10 Dust Monitoring Results 17 9.5 Thermoluminescent Dosimeter Coordinates and 2018 Results 19 9.6 PSVOL2 Dosimeter Coordinates and 2018 LLRD Results 19 9.7 Inferred Radon Exposure Doses from PSVOL Monitors 20 9.8 Vegetation Monitoring Transects 22 9.9 Groundwater Quality Analysis Results 2018 27

9.10 Microbiological Analysis of Potable Water 28 9.11 Sewage Analysis Results 2018 29

2018 Annual Environmental Management Report iv

Glossary ˚C Degrees Celsius APN Orano Mining Namibia Processing Namibia ARN Orano Mining Namibia Resources Namibia DEA Directorate of Environmental Assessment (MET) DWAF Department of Water Affairs and Forestry (MAWF) EIA Environmental impact assessment EMP Environmental Management Plan or Programme EPZ Export processing zone ESIA Environmental and social impact assessment GDP Gross domestic product GIS Geographical information system HSE Health, safety and environment HSE ENV PO Health, Safety and Environment – Environmental Section - Policy HSE ENV PR Health, Safety and Environment – Environmental Section - Procedure HSE ENV ST Health, Safety and Environment – Environmental Section - Strategy km kilometre km/h kilometre per hour m metre m2 square metre m3 cubic metre mg/L milligrams per litre mm millimetre Mm3/a million cubic metres per annum mS/m millisiemens per metre MAWF Ministry of Agriculture, Water and Forestry MET Ministry of Environment and Tourism MME Ministry of Mines and Energy NACOMA Namibian Coastal Management Project NBSAP National Biodiversity Strategy and Action Plan NERMU Namib Ecological and Rehabilitation Monitoring Unit NIMT Namibian Institute of Mining and Technology NHC National Heritage Council NRPA National Radiation Protection Authority PM10 Inhalable dust fraction smaller than 10 microns PPE Personal Protection Equipment RMP Radiation Management Plan SEA Strategic environmental assessment SEMP Strategic environmental management plan t tonne TDS Total dissolved solids

2018 Annual Environmental Management Report Page 1

2018 ANNUAL REPORT ON ENVIRONMENTAL MANAGEMENT AT ORANO MINING NAMIBIA

1 INTRODUCTION

1.1 Orano Mining Namibia The French nuclear energy concern that owns the Trekkopje uranium project has changed its name from AREVA to Orano in January 2018 and the local subsidiary became Orano Mining Namibia in April. Orano’s Trekkopje mine is situated within the Erongo region of Namibia, 70 kilometres (km) north-east of Swakopmund (Figure 1.1). Orano also owns the Erongo Desalination Plant at Wlotzkas-baken, 30 km north of Swakopmund, which was built to supply the mine, but at present mainly pro-duces water for the Namibia Water Corporation (NamWater).

Figure 1.1: Locality Map

1.2 Update on Activities The Trekkopje project was put under care and maintenance (C&M) in July 2013. Since then, Orano has been monitoring the uranium market to re-assess the feasibility of the mine and be prepared to start up as soon as it becomes feasible. However, uranium spot market prices around US$25 in 2018 did not suggest an imminent upswing. The company had 17 employed in 2018, including administration and services. The Engineering de-partment protected and maintained all equipment and structures on site to keep them in working condition. C&M includes activities such as testing and servicing of equipment and treatment against


corrosion. A computerised maintenance schedule has been compiled according to the manufactur-ers’ specifications and job cards are issued on a daily basis. The photos in Figure 1.2 show some ex-amples of work done in 2018.

Installed stairs and handrails Maintained power supply system

Repainted prefab buildings and sealed roofs Rotated conveyor pulleys and idlers

Sealed corroded roofs of workshop containers (photos before – after)

Figure 1.2: Examples of C&M Activities in 2018

The Quality, Health, Safety & Environment (QHSE) section is in charge of all compliance-related issues which include reporting on environmental management. Environmental monitoring continues during C&M at a reduced scale, including air quality, radiation, groundwater and effluent quality, as well as annual monitoring of vegetation transects and rehabilitation trial areas. EMP compliance audits are carried out and reports are prepared as per statutory requirements. Orano Mining Namibia remains an active member of the mining community and continues to support sustainable development pro-jects in the community.


1.3 Objectives of the Annual Environmental Report The main objective of this annual report is to give Orano management in France and regulators in the Namibian government a comprehensive overview of all environmental management aspects related to Orano Mining Namibia’s activities. Though the main area of interest is Trekkopje mine, monitoring extends to Arandis and the Erongo Desalination Plant. The report describes the major environmental impacts (section 6) and results of monitoring and investigation programmes (section 9). Additional data tables can be found in the attachments. In addition to providing a useful summary and inter-pretation of data collected over the past year, the report documents the history of environmental management at Trekkopje and serves as a reference for comparison with future monitoring results.

2 ENVIRONMENTAL POLICY Figure 2.1 shows Orano Mining Namibia’s environmental policy that is in line with the environmental policy of the Orano Mining business unit. The company’s approach to environmental management is also guided by Namibian legislation, especially the Environmental Management Act of 2007, as well as the sustainable development principles of the International Council for Mining and Metals.

Safety of Operations

• Strictly apply operating procedures for routine and

non-routine situations, including transport.

• Pay attention to contractors’ environmental

performance at the purchasing stage and while

working on site.

• Share experience as part of standard practice and

implement identified improvement plans.

• Produce pertinent environmental assessments and

reports aligned with regulatory requirements.

Environmental Performance

• Reduce the environmental footprint of our activities to

minimise the impact on biodiversity.

• Monitor and control air, soil, groundwater and surface

water quality.

• Reduce water and energy consumption, emissions of

greenhouse gases, effluent and waste.

ENVIRONMENTAL

POLICY

>> Within the Orano group, the activities of the Mining business unit are subject to a sustainable development approach. Continuous improvement and the application of strict environmental and social standards guide us in our day-to-day actions, taking us towards the achievement of our long-term objectives.

Orano Mining Namibia acknowledges its

responsibility as custodian of land in the sensitive

central Namib Desert.

The objectives of this policy are:

• Sustainable assurance of a high level of safety of our

facilities, products and services.

• Strengthened operational discipline, a daily concern of

management and all parties involved.

• Inclusion of risk prevention and environmental

protection in all processes at our operations.

PRIORITY ACTIONS FOR 2017-202

Facility Safety

• Ensure the environmental safety of mine facilities

through proper design, construction and renovation.

• Guarantee that risk management systems comply with

standards and legislation.

• Avoid, prevent or minimise environmental impacts,

including impacts on biodiversity, by implementing the

environmental management plan and in particular by

appropriate waste management.

• Conduct site rehabilitation programmes that comply

with defined objectives and ensure that future land use

is consistent with anticipated final site conditions.

Hilifa MbakoManaging DirectorMarch 2018

Figure 2.1: Orano Mining Namibia Environmental Policy


3 ENVIRONMENTAL ASPECTS AND IMPACTS

3.1 Aspects and Impacts of Orano Mining Namibia The aspects and impacts of the mine and desalination plant are listed in Tables 3.1 and 3.2 including significance ratings with and without mitigation. The ratings originally identified in the ESIAs were reviewed in previous annual reports based on research findings and experience gained since 2008. The highest impact of the mine arises from the destruction of flora due to land surface disturbance. The high significance is explained by the potential impact on a number of plant species that are en-demic to the Namib Desert. Other impacts classified as high without mitigation can be reduced to moderate or low if appropriate measures are implemented. Table 3.1: Summary of Environmental Impacts and Significance Ratings for Trekkopje Mine

Significance Significance

Aspect Impact without mitig. with mitigation

Atmosphere Dust generation M L

Radiation Radionuclide contamination of surface water M L

Radiation Radionuclide contamination of groundwater M L

Radiation Dust-borne radionuclides M L

Radiation Radionuclide uptake by fauna L L

Radiation Radon emanation H-M M

Radiation Occupational exposure to radiation M L

Land surface Soil disturbance H H

Land surface Destruction or alteration of water courses M L

Soils Water quality degradation due to land surface impacts L L

Soils Erosion/compaction L L

Soils Pollution/salinization L L

Pollution risk Pollution from chemicals/reagents L L

Pollution risk Pollution from organic matter/sewage L L

Pollution risk Pollution from other waste streams L L

Land use Land-use change through land surface disturbance M L

Water Groundwater pollution by spent rinse water M L

Water Seepage from spent leach heaps M L

Water Water consumption H H+

Water Groundwater drawdown and flow disruption L L

Flora Destruction through land surface disturbance H H-M

Flora Destruction through dust generation or pollution L L

Fauna General impacts H M

Traffic Increased traffic volume L L

Traffic Habitat destruction due to road development M L

Traffic Increased access L L

Noise Noise generated by blasting L L

Visual Visual intrusion of infrastructure L L

Archaeology Cultural/archaeological site pollution and damage H L

Key: H = high, M = moderate, L = low, + = positive impact


Though the desalination plant is a separate entity operated by AVENG Water Treatment, the respon-sibility to ensure compliance with the desalination plant EMP remains with Orano Mining Namibia. The highest impact of the desalination plant is positive, i.e. assuring the water supply for socio-economic development of the Erongo region. On the negative side a previously not identified impact only appeared after the power line to the desalination plant was constructed: collisions of migrating birds such as flamingos with the power cables (refer to section 9.6.3 for details). NamPower is plan-ning to install mitigation measures in 2019. Local residents are most concerned about the impact of brine salinity and chemicals on marine life, but monitoring has confirmed the original ESIA’s low sig-nificance rating of this aspect (refer to section 9.8 for details). Table 3.2: Summary of Environmental Impacts and Significance Ratings for the Desalination Plant

Significance Significance

Aspect Impact without mitig. with mitigation

Atmosphere Dust generation from site maintenance and traffic L VL

Atmosphere Fume emission from transport and commuting L VL

Atmosphere Air emissions from hazardous materials (e.g. chlorine) L VL

Soils Pollution by sewage, hazardous materials or waste M L

Water Water pollution from accidental spills L VL

Fauna Impacts from noise or pollution M VL

Fauna Bird collision with power lines (not in 2008 ESIA) H M

Flora Habitat destruction through plant construction H L

Visual Visual intrusion of plant infrastructure M-H L

Land use Preclusion of other land use L L

Noise Sound transmission to Wlotzkasbaken or tourists M VL

Marine life Water quality impacts caused by brine salinity L L

Marine life Entrainment of organisms at the intake structure M L

Marine life Flow distortion at discharge, effects of pipeline on natural sediment dynamics

L L

Marine life Impact of chemicals discharged with brine M L

Social Change of lifestyle at Wlotzkasbaken H L

Social Alteration of tourists’ desert heritage experience H L

Social Increased traffic from commuting and deliveries M VL

Social Positive impact of plant on water availability +M +H

Key: H = high, M = moderate, L = low, VL = very low, + = positive impact

Based on the 2008 ESIA reports and environmental management programmes (EMPs) environmental clearances were issued by the Ministry of Environment and Tourism (MET). The original EMPs were updated in 2012 and 2016 to take into account operational changes and to revise the mitigation measures that proved to be impractical or unnecessary (Ref. 3 and 4). Environmental clearance cer-tificates valid for three years were issued in April 2013 and renewed in September 2016. A further review of the desalination plant EIA and EMP started at the end of 2018 to obtain approval for the construction of a small sewage treatment plant. This project is expected to begin towards the end of 2019 or in 2020.


4 LEGAL AND OTHER COMPLIANCE

4.1 National Legislation Acts and policies that may be applicable to environmental management or to the business of Orano Mining Namibia in general have been identified in previous annual reports. A review of the Govern-ment Gazette did not reveal any new relevant legislation enacted in 2018.

4.2 Environmental Legislation Review MET appointed consultants to amend the Environmental Management Act and EIA regulations and to draft new SEA regulations. Several stakeholder consultation workshops were held during the year to discuss the proposed changes. Orano Mining Namibia was represented at these workshops and provided copious written feedback on the draft legislation.

4.3 Licences and Permits MAWF/DWAF: The effluent discharge exemption permit number 688 for Trekkopje mine is valid until 31 May 2021. The objectives of the permit as stated by the Department of Water Affairs and Forest-ry (DWAF) are to regulate the disposal of effluents produced by the mine and to prevent the spread of groundwater pollution from effluent or waste disposal sites into the environment. The permit stipulates that regular and adequate groundwater quality monitoring has to be carried out according to a prescribed schedule and according to a list of parameters to be determined. Water manage-ment reports have to be submitted to the DWAF biannually or on request. Permit number 10529 to extract up to 120 000 m3/a of groundwater from three boreholes on the mine is valid until 2 May 2021. The company is however only using one production borehole, apply-ing the saline water for road maintenance. The Erongo Desalination plant’s permit for seawater abstraction (number 10535) was extended for three years until 31 August 2020. The quota was at the same time increased to 60 Mm3 per annum so that the plant will be able to produce the contracted volume of 12 Mm3 for NamWater. Domestic wastewater and effluent disposal exemption permit 687 for the desalination plant is valid until 31 May 2021. An important condition of this permit is that “the quality of brine from the desal-ination plant that will be disposed into the marine environment should not have an effect and impact on the marine ecosystem and therefore the fishing industry.” MET/DEA: Orano Mining Namibia’s environmental clearances were renewed in September 2016, which means they are valid until 2019. MHSS/NRPA: The National Radiation Protection Authority (NRPA) approved Orano Mining Namibia’s Radiation Management Plan (RMP) for phase 2 of the care and maintenance phase in 2017. NRPA licences that are needed for equipment that emits ionising radiation (XRF machines, sealed sources) were kept current for 2018. An annual report on the implementation of the RMP and the results of exposure dose monitoring was produced according to NRPA specifications.

4.4 Government Inspections The Department of Water Affairs and Forestry did not inspect the mine or the desalination plant in 2018, but was kept informed by means of biannual monitoring reports. The National Radiation Pro-


tection Authority decided not to visit Trekkopje mine in 2018 because the site is under care and maintenance; they did however review the annual report for 2017 and commented on RMP compli-ance, occupational and environmental monitoring results.

4.5 Interaction with Government Institutions 4.5.1 Ministry of Mines and Energy – Geological Survey Following the completion of the Strategic Environmental Assessment of uranium mining in the Eron-go region in 2010 the Ministry of Mines & Energy (MME) established an office to monitor progress and compliance with the Strategic Environmental Management Plan (SEMP). The SEMP office in the Geological Survey reports to a steering committee comprised of government institutions, parastatals, mining industry and NGOs. The SEMP Office compiles an annual report based on its own monitoring results and information provided by others. The Namibian Uranium Association (NUA) is responsible for input from the uranium mines and exploration companies. Orano Mining Namibia’s QHSE Con-sultant collected data on behalf of NUA and assisted with the compilation and editing of the 2017 SEMP report, which was completed in December 2018. 4.5.2 Ministry of Agriculture, Water & Forestry – Water Basin Management MAWF has established basin management committees in terms of the Water Resources Manage-ment Act to improve community participation in water management. Namibia was subdivided into river catchment areas (basins) and Basin Management Committees (BMC) are being established ac-cording to the basin’s priority. Orano Mining Namibia was involved in the Omaruru BMC from its inception and nominated to represent the Namibian Uranium Association. No BMC meetings were held in 2018 due to GRN budget constraints. 4.5.3 Ministry of Environment & Tourism – National Biodiversity Strategy and Action Plan Orano Mining Namibia is representing the Namibian Chamber of Mines on the steering committee that oversees the implementation of the second National Biodiversity Strategy and Action Plan (NBSAP 2). Actions specifically assigned to the Chamber fall under Strategic Goal 4: Enhance the ben-efits to all from biodiversity and ecosystem services. By 2022, ecosystems that provide essential ser-vices and contribute to health, livelihoods and well-being are safeguarded, and restoration pro-grammes have been initiated for degraded ecosystems covering at least 15 per cent of the priority areas. The specific objective applicable to the mining industry is Strategic Initiative 4.1.3: Undertake the rehabilitation and restoration of land degraded through unsustainable land management practic-es and establish biodiversity offsets. The steering committee met four times in 2018. Not much pro-gress was made with the restoration of degraded land, but biodiversity offsets may be included in the latest amendment of the Environmental Management Act.

5 ENVIRONMENTAL OBJECTIVES AND TARGETS Orano Mining Namibia has been implementing its EMPs since 2008 and has appointed suitably quali-fied environmental personnel to guide and monitor the process. Environmental objectives and tar-gets are set to ensure that the company complies with the environmental policy and environmental management plan and that progress can be tracked. The objectives are documented in Orano Min-ing Namibia’s policies, strategies and procedures, and in the environmental action plan which con-tains a summary of all the objectives and targets (Attachment 1). The tables in Attachment 1 contain a status report on progress made with the implementation of the action plan in 2018.


The health, environment, radiation safety and security standards developed by the Namibian Urani-um Association (Ref. 5) and the relevant objectives of the Strategic Environmental Management Plan (SEMP) that was developed as part of the “Strategic Environmental Assessment of the central Namib Uranium Rush” (Ref. 6) are fully incorporated in the company’s strategy documents, environmental procedures and action plans.

6 ENVIRONMENTAL MANAGEMENT PROGRAMME

6.1 Overview The 2016 version of the EMPs for Trekkopje mine and the desalination plant currently form the basis of the company’s environmental management programme. Policies, strategies and procedures de-veloped by Orano Mining Namibia (Table 6.1) specify how the actions recommended in the EMPs are translated into practice and thus provide an important tool for environmental management. The table in Attachment 1 provides a summary of progress with the achievement of objectives, targets and mitigation measures. Details on specific management measures and monitoring results are de-scribed in section 9 of this report. Compliance with the EMPs is audited annually; audit reports and ECO reports on the status of the environment are submitted to Government. A system is in place to report and investigate non-compliance incidents and follow up on remedial action.

6.2 Policies and Procedures Policies, strategies and procedures are reviewed every three years and updated whenever conditions change. Approved documents are filed on a central IT server according to the document control pro-cedure. Orano Mining Namibia employees are informed about the procedures relevant to their tasks, e.g. during inductions and training sessions. Before new contractors start working on the mine they are given inductions and copies of all the procedures that are applicable to their jobs. All poli-cies, strategies and procedures that were due for review in 2018 were updated and changed to the new Orano format. Table 6.1: List of Policies, Strategies and Procedures

Title Reference Application date

Latest revision

Environment policy HSE ENV PO 01 1 Jul 2009 1 Mar 2018

Social policy HSE ENV PO 03 1 Jul 2009 1 Mar 2018

Air quality strategy HSE ENV ST 01 1 Dec 2009 1 Feb 2017

Biodiversity strategy HSE ENV ST 02 1 Dec 2009 1 Feb 2017 Closure strategy HSE ENV ST 03 1 Jun 2010 1 Nov 2018 Construction camp strategy HSE ENV ST 04 1 Dec 2009 1 Nov 2018 Environmental strategy HSE ENV ST 05 1 Jun 2009 1 Feb 2017 Hazardous materials strategy HSE ENV ST 06 1 Dec 2009 1 Feb 2017 Noise and vibration strategy HSE ENV ST 07 1 Dec 2009 1 Feb 2017 Sustainable development strategy HSE ENV ST 08 1 Jul 2009 1 Feb 2017 Water strategy HSE ENV ST 09 1 Oct 2011 1 Feb 2017 Public health strategy HSE ENV ST 10 1 Oct 2011 1 Feb 2017 Waste management strategy HSE ENV ST 11 1 Oct 2011 1 Feb 2017 Radiation management strategy HSE ENV ST 12 1 Oct 2011 1 Feb 2017 Mineral waste management strategy HSE ENV ST 14 1 Oct 2011 1 Feb 2017 Visual impact management strategy HSE ENV ST 15 1 Mar 2013 1 Feb 2017


Table 6.1: List of Policies, Strategies and Procedures (continued)

Title Reference Application date

Latest revision

Procedures

Dust monitoring HSE ENV PR 01 1 Apr 2010 1 Apr 2018

Dust control HSE ENV PR 02 1 Dec 2009 1 Apr 2018 Environmental auditing HSE ENV PR 03 1 Dec 2009 1 Apr 2018 Environmental incidents HSE ENV PR 04 1 Dec 2009 1 Apr 2018 Flora protection and rescue HSE ENV PR 05 1 Dec 2009 1 Apr 2018 Ground disturbance HSE ENV PR 06 1 Dec 2009 1 Apr 2018 Historical sites HSE ENV PR 07 1 Dec 2009 1 Apr 2018 Management of EMP non-compliance HSE ENV PR 08 1 Mar 2009 cancelled

Off-road driving and track rehabilitation HSE ENV PR 09 1 Dec 2009 1 Apr 2018 Oil/diesel spill clean-up HSE ENV PR 10 1 Dec 2009 1 Apr 2018 Hazardous materials management HSE ENV PR 11 1 Jul 2009 1 Apr 2018 Wildlife interactions HSE ENV PR 12 1 Jul 2012 1 Apr 2018 Environmental aspects of road construction HSE ENV PR 13 1 Dec 2009 1 Apr 2018 Road material selection HSE ENV PR 14 1 Dec 2009 1 Apr 2018 Topsoil handling HSE ENV PR 15 1 Dec 2009 1 Apr 2018 Vegetation monitoring HSE ENV PR 16 1 Dec 2009 1 Apr 2018 Bird interactions HSE ENV PR 17 1 Oct 2011 1 Apr 2018 Waste dump guidelines HSE ENV PR 18 1 Dec 2009 cancelled

Waste management HSE ENV PR 19 1 Dec 2009 1 Apr 2018 Water quality management HSE ENV PR 20 1 Dec 2009 1 Apr 2018 Water quality monitoring HSE ENV PR 21 1 Dec 2009 1 Apr 2018 Water supply management HSE ENV PR 22 1 Dec 2009 1 Apr 2018 Weather monitoring HSE ENV PR 23 1 Jan 2010 1 Apr 2018 Groundwater supply monitoring HSE ENV PR 24 1 Dec 2009 1 Apr 2018 Environmental monitoring HSE ENV PR 25 1 Feb 2010 1 Apr 2018 Environmental code of practice HSE ENV PR 26 1 Mar 2010 1 Oct 2018 Bioremediation HSE ENV PR 27 1 Feb 2010 1 Oct 2018 Environmental indicators HSE ENV PR 29 1 Oct 2011 1 Oct 2018 Soil monitoring HSE ENV PR 30 1 Oct 2011 1 Oct 2018 Legal audit (environment) HSE ENV PR 31 1 Oct 2011 1 Oct 2018 Gas monitoring HSE ENV PR 32 1 Oct 2011 1 Oct 2018 Radiation monitoring HSE ENV PR 33 1 Oct 2011 1 Oct 2018 Rehabilitation area monitoring HSE ENV PR 34 1 Oct 2011 1 Oct 2018 Closure cost estimation HSE ENV PR 35 1 Oct 2011 1 Oct 2018

7 STRUCTURE AND RESPONSIBILITIES The Managing Director carries the overall responsibility for the mine’s legal and environmental com-pliance. From the Managing Director, responsibility devolves upon the Mine Manager (acting) who is in charge of the Quality, Health, Safety and Environment (QHSE) section (Figure 7.1). The QHSE Spe-cialist is responsible for the implementation of the environmental management plan, performance of the monitoring programme and compilation of internal and external reports. The QHSE Specialist is also the company’s officially appointed Radiation Safety Officer. The former QHSE Manager has been retained as a QHSE Consultant in an advisory capacity.


Org chart QHSE 2018

Mine Manager

FR van Dyk

QHSE Specialist Kaarina Nkandi

ILS Paramedic Jan Olivier

QHSE Consultant

Sandra Müller

Figure 7.1: QHSE Department Structure in 2018

8 TRAINING, AWARENESS AND COMPETENCE Job descriptions and skills requirements are specified for QHSE personnel to ensure that properly qualified individuals are appointed. Table 8.1 shows the qualifications and additional on-the-job training. S Müller and K Nkandi have MSc degrees in geology and marine biology, respectively, while the J Olivier is qualified in intermediate life support (ILS). In 2016, K Nkandi obtained a post-graduate diploma in applied radiation science and technology at NUST. Orano Mining Namibia has internal and external training programmes to address any knowledge gaps through on-the-job training. An environmental induction is given to all Orano Mining Namibia employees and contractors who work on the mine. Contractors’ understanding of the EMP is checked during inspections and audits of their environmental performance. Table 8.1: Training of QHSE Section Staff

Courses/Training S Müller K Nkandi J Olivier

Professional qualification MSc Geology MSc Biology ILS Param.

Paramedic refresher courses √

NOSA safety training √ √ √

First aid training, firefighting √ √

Radiation safety officer courses √ √ √

Environmental management √ √

Environmental auditing (ISO) √ √

Leadership training √ √

Post-graduate diploma applied radiation science √

9 MONITORING AND FEEDBACK The main purpose of environmental management at Orano Mining Namibia is to ensure all activities are carried out in compliance with the EMP and that impacts are reduced as far as possible. The ob-jectives of the environmental monitoring programme are to follow up on EMP implementation, inci-dents and remedial action; to determine baseline conditions before the start of mining and to track the impact of mining activities and success of mitigation measures. One of the tools used to identify and mitigate impacts is incident reporting.


9.1 Environmental Incidents Any action or event that may lead to environmental damage or does not comply with the mine’s EMP must be reported according to procedure HSE ENV PR 04. The severity of environmental incidents is rated according to the Orano Mining Namibia procedure as either non-significant (NS, very low im-pact intensity) or significant with levels ranging from moderate (S0) to serious (S1), major (S2) or cat-astrophic (S3). Numerical limits for these categories are provided in the procedure. Due to the low level of activity on site there was only one environmental incident in 2018. Inappro-priate storage of bags containing used resin in a shipping container was detected during an inspec-tion of the Midi Plant on 30 July 2018. A small portion of the resin had spilled out of the container onto unprotected ground. The spill was cleaned up and the resin was placed in sealed plastic drums.

Figure 9.1: Used Resin Stored in Shipping Container

9.2 Environmental Monitoring Network The design of the environmental monitoring network at the mine was originally based on the source terms during mining operations: open pits, ore stockpiles, crushers, heap leach pads, waste rock and tailings, as well as process water and effluent ponds (Map 1 on the next page). The pathways that have to be monitored were air, radiation, water and soil. Extent and frequency of monitoring were reduced since 2013 because C&M does not result in emissions to the environment. Details of the monitoring network and results obtained in 2018 are described in the following sections.

9.3 Climate and Air Quality Monitoring 9.3.1 Climate Orano Mining Namibia currently operates two weather stations, a Campbell station at the Midi office and a Davis station at the Maxi office (Figure 9.2). Both stations were serviced in 2018 and Campbell station was also calibrated in April 2018. Another Davis station at the Arandis gate stopped working in 2017 and was removed. It was not needed because Arandis weather data are recorded by the PM10 dust E-sampler (see Section 9.3.2). Table 9.1 shows a summary of the most relevant weather data for the year 2018.


Map 1: Trekkopje Mine Monitoring Sites (Status 2012)


Table 9.1: Summary of Weather Data 2018

Midi Temperature ˚C Rainfall Wind Speed (m/s) Dominant

Month Mean Maximum Minimum (mm) Average Maximum Direction

Jan-18 19.0 28.8 11.7 0.0 3.2 7.7

Feb-18 19.3 30.1 11.2 0.0 2.9 6.4

Mar-18 20.0 31.6 11.3 6.8 2.8 6.8

Apr-18 22.8 33.6 12.9 15.2 2.7 8.9

May-18 20.2 35.6 7.5 0.0 3.2 8.5

Jun-18 20.8 34.5 7.7 0.0 4.2 13.0

Jul-18 14.6 35.3 3.1 0.0 3.3 13.1

Aug-18 14.6 35.3 3.1 0.0 3.3 13.1

Sep-18 16.6 34.5 6.4 0.0 2.8 12.9

Oct-18 19.6 37.0 7.2 5.0 3.6 12.8

Nov-18 19.9 36.1 8.6 0.0 3.2 12.0

Dec-18 18.9 30.9 9.1 0.0 3.1 7.7

2018 18.9 37.0 3.1 27.0 3.2 13.1

Maxi Temperature ˚C Rainfall Wind Speed (m/s) Dominant

Month Mean Maximum Minimum (mm) Average Maximum Direction

Jan-18 18.8 28.4 12.3 0.0 2.4 13 W

Feb-18 19.2 29.8 11.2 0.0 - - W

Mar-18 19.2 29.0 11.7 6.0 - - W

April-18 22.8 33.9 13.6 0.0 - - SSW

May-18 - - - - - -

Jul-18 - - - - - -

Aug-18 13.4 31.9 4.1 0.0 - - N

Sep-18 16.2 34.9 4.9 0.0 2.2 17.0 SW

Oct-18 20.2 37.8 8.3 5.4 3.2 20.1 SSW

Nov-18 20.0 36.0 11.1 2.8 12.8

Jan-18 18.8 28.4 12.3 0.0 2.4 13.0 W

Dec-18 - - - - - -

2018 18.7 37.8 4.1 11.4 2.6 20.1 W

Figure 9.2: Weather Stations: Campbell at Midi (left) and Davis at Maxi (right)


Rainfall The annual precipitation in millimetres per year at the Annaberg and Midi stations for the last eleven years is shown in Table 9.2. The weather station recorded 27 mm of rain in 2018 (Table 9.1), but ac-cording to the rain gauge it was only 15 mm. The area upstream of the mine received more rainfall on 22 October 2018, so that the river in the vicinity of the Annaberg mine had some runoff. Table 9.2: Rainfall Data for the Annaberg (2007-2013) and Midi Stations (2014-2018)

Year 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Rain (mm) 4.6 58.1 139.6 32.2 133.9 24.6 29.0 53.7 18.3 17.8 15.0 15.0

A wet cycle with unusually high rainfall in 2009-2012 was followed by an ongoing period of drought with very low rainfall in 2013 and 2015-2018 (Figure 9.3). The total rainfall of only 15 mm in 2017 and 2018 was well below the average rainfall of 50 mm.

0

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60

80

100

120

Jan-07 Jan-08 Jan-09 Jan-10 Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16 Jan-17 Jan-18

mm

/mo

nth

Annaberg Midi

Figure 9.3: Monthly Rainfall at Trekkopje Weather Stations

Evaporation The average evaporation rate measured at the Midi offices in 2018 was 9.3 mm/day, which brings the average since monitoring started at the Midi plant in 2011 to 8.6 mm/day. The figure for 2016 was excluded in the average calculation because a non-standard pan was used during that year. A standard A-pan was commissioned in June 2017. The increased evaporation rate since 2013 was possibly related to the reduction in rainfall (compare Figure 9.3).

7.68.1

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8.4 8.5

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2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Evap

ora

tio

n r

ate

(m

m/d

ay)

Figure 9.4: Annual A-pan Evaporation Data 2009-2018


Wind Monthly average wind speeds at the Midi offices ranged from 2.7 to 4.2 metres per second (m/s) with an average of 3.2 m/s (Figure 9.5). A maximum speed of 13.1 m/s was recorded during east wind events in July and August 2018. The average wind speed at the Maxi station of 2.6 m/s is not statistically valid because the station was out of order from February to July. The 2018 once again confirmed that the typical pattern of predominant wind directions tends to be south-westerly in summer and north-easterly to easterly in winter with higher wind speeds during berg wind events.

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Jan-18 Feb-18 Mar-18 Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18

Win

d s

pe

ed

(m

/s)

Average wind speed Maximum wind speed

Figure 9.5: Average and Maximum Wind Speed at the Midi Station in 2018

9.3.2 Dust Monitoring Information on environmental impacts arising from dust emissions and dust monitoring methods can be found in the 2014 environmental report (Ref. 17). Dust fallout buckets and PM10 monitors (Fig-ure 9.6) were used throughout the year 2017. The two-monthly sampling frequency introduced in 2017 was maintained for the 13 buckets located at Trekkopje Mine, Arandis and the Erongo desalina-tion plant (Table 9.3). The low dust levels experienced during the care and maintenance period do not warrant the effort and expense of monthly monitoring.

Figure 9.6: Dust Fallout Bucket and PM10 Monitor


The monthly dust fallout at each site is shown in Figure 9.7. Low dust levels of 8.7-33.9 mg/m2/day were recorded with a maximum of 74.8 mg/m2/day at DM16 near the Midi offices in July-August 2018. Dust levels of 8.6-45.4 mg/m2/day were recorded at Arandis (DM33 and DM34). Dust in the town was mainly caused by traffic on unpaved roads and construction activities. Table 9.3: Dust Fallout Monitoring Sites and Average Dust Concentrations in 2018

ID Locality Description UTM33 WGS84 X UTM33 WGS84 Y Dust fallout mg/m2/day

DM07 French camp 487701 7548811 7.7

DM08 Granite quarry near TW07 482206 7545215 27.3

DM10 1000 m NE of Midi plant 485808 7545443 15.6

DM14 1000 m SW of Midi plant 483696 7543326 14.3

DM16 Midi offices next to AD02 504379 7547543 26.5

DM20 Maxi pad, on road to TW12 482186 7549715 16.6

DM27 Maxi pad, east of first cell 483550 7549356 20.3

DM29 NamWater pipeline, at TLD05 486400 7543500 11.4

DM30 Western security gate 471315 7544446 24.5

DM33 NE of Arandis 498358 7522405 15.0

DM34 SW of Arandis 497189 7519806 22.0

DS02 Desalination plant substation 442412 7525830 15.8

DS03 Desalination plant security gate 441666 7525849 12.3

0

100

200

300

400

DM07 DM08 DM10 DM14 DM16 DM20 DM27 DM29 DM30 DM33 DM34 DS02 DS03

Du

st

fall

ou

t (m

g/m

2/d

ay)

Dec/Jan 18 Feb/Mar 18 Apr/Jun 18 Jul/Aug 18 Sep/Oct 18 Nov/Dec 18

Figure 9.7: Dust Fallout Results in 2018

In the absence of a Namibian standard the results were evaluated against the South African National Dust Control Regulations (NDCR). The NDCR define “low” dust levels as 0-250 mg/m2/day. The aver-age values measured in 2018 were very low and none of the peak values exceeded the upper limit of 250 mg/m2/day. The results confirm that surfaces previously disturbed by mining and construction are stable and not prone to wind erosion. Currently, dust is mostly mobilised by vehicle traffic on gravel roads. The inhalable dust fraction (PM10) is more important than fallout dust since particles smaller than 10 micrometres have a greater impact on health. The concentration of PM10 dust is measured with monitors that pump air at a steady rate through a measuring chamber that records real-time dust levels. The dust can also pass through a fine filter that is periodically replaced and sent to a laborato-ry for analysis. The dust concentration in micrograms per cubic metre (μg/m³) is downloaded from


the instrument. For calibration, it can also be calculated from the recorded volume of air and the weight deposited on the filter. Filters have been used in 2018 to determine the calibration (k) fac-tors, which correct for the actual shape and light scattering properties of the local dust that may de-viate from the instrument’s pre-set values. The average results of three filters for each site were 2.9 for Arandis and 2.1 for the Midi area at Trekkopje mine. The annual average PM10 dust concentra-tions for the last eight years are shown in Table 9.4 with and without application of the k-factor. Table 9.4: PM10 Dust Monitoring Results

Locality Average Daily PM10 Dust Concentration (μg/m3)

Year 2011 2012 2013 2014 2015 2016 2017 2018

Arandis 11.0 6.8 10.4 9.1 9.8 9.0 9.8 10.3

Arandis corrected

31.7 22.0 30.7 26.1 27.4 26.4 29.3 29.9

Midi offices 7.0 8.0 no data - - 7.5 5.8 11.2

Midi cor-rected

14.7 16.8 no data - - 15.8 11.7 23.8

The monitor at Arandis recorded an average PM10 dust concentration of 29.9 μg/m³ (Figure 9.8), while the PM10 sampler at the Midi offices recorded a slightly lower average concentration of 23.8 μg/m³ in 2018 (Figure 9.9). The Midi instrument was installed in 2016 and worked until May 2017, when it started showing alarms. It was replaced with a newly calibrated E-sampler in early 2018.

0

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40

2011 2012 2013 2014 2015 2016 2017 2018

PM

10

du

st

co

nc

en

tra

tio

n

(ug

/m3

)

Corrected annual average WHO IT-3 limit

Figure 9.8: Annual Average PM10 Dust Concentration at Arandis

Standards for inhalable dust were developed by the World Health Organisation (WHO). The Strategic Environmental Assessment of uranium mining in the Erongo region proposed the adoption of the WHO interim target 3 (IT-3) of 75 μg/m³ for the average daily PM10 concentration and 30 μg/m³ for the average annual concentration as local standard. Now that the calibration factors have been ap-plied it has become apparent that the average annual limit of 30 μg/m³ was exceeded at Arandis in 2011 and 2013, while the average for 2018 was just below the guideline. The annual average values at the Midi offices were all below the limit. The average daily PM10 concentrations, which are not shown in the graphs, exceeded the IT-3 of 75 μg/m³ on several days when there were strong east or south-west winds.


0

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40

2011 2012 2016 2017 2018

PM

10

du

st

co

nce

ntr

ati

on

(u

g/m

3)

Corrected annual average WHO IT-3 limit

Figure 9.9: Annual Average PM10 Dust Concentration at the Midi Offices

9.4 Environmental Radiation Monitoring 9.4.1 Introduction When Trekkopje mine is in operation members of the public residing in surrounding areas could po-tentially be exposed to radiation via the following pathways:

1. Direct exposure to gamma radiation 2. Inhalation of dust containing long-lived radioactive elements (radionuclides) 3. Inhalation of radon gas resulting in exposure from solid radon progeny 4. Ingestion of contaminated food and/or water

To ensure compliance with Namibia’s Atomic Energy Act and the National Radiation Protection Au-thority’s Regulations for the Protection against Ionising Radiation, Orano Mining Namibia monitors the above exposure pathways and, once the mine is in operation, will take measures to ensure that the public exposure remains as low as reasonably achievable. The environmental radiation monitor-ing network measures alpha radiation from long-lived alpha emitters in dust and potential alpha emissions due to short-lived radon-222 and radon-220 progeny, as well as gamma radiation. The monitoring results obtained in the first three quarters of 2018 are presented in the sections below. The laboratory will only provide the data for the fourth quarter in mid-2019. The results are ex-pected to be similar to the year-to-date average. 9.4.2 Direct Exposure to Gamma Radiation Natural gamma radiation is highly variable because it is composed of cosmic radiation and gamma radiation emitted from soil and rocks. It is monitored with thermoluminescent dosimeter badges (TLD) placed at various locations across the mine site (Table 9.5). The fluctuating nature of cosmic radiation can cause substantial differences in inferred exposure doses from one year to the next. This variability is demonstrated in Figure 9.11. The doses shown in this graph were calculated under the theoretical assumption that members of the public were to spend an entire year (8760 hours) at Trekkopje mine. In reality the doses will be lower because mine employees only spend their working time on site (2000 hours per year). The average direct gamma exposure dose for all TLD sites in 2018 was 2.7 mSv, only slightly lower than the 2.8 mSv measured in 2016. These figures include the natu-ral background radiation and any additional gamma radiation that may have been caused by the mine’s activities.


Table 9.5: Thermoluminescent Dosimeter Coordinates and 2018 Results

ID Location Description X Y 2018 mSv/a

ARN TLD03 East French camp 488075 7549055 3.3

ARN TLD04 North NamPower line 481629 7552117 3.1

ARN TLD05 South Former NamWater pipeline 486400 7543500 3.4

ARN TLD07 Offices Midi offices 500846 7552454 4.2

ARN TLD09 Arandis Arandis 496886 7520722 3.4

ARN TLD10 Maxi area Former explosives magazine 480684 7547947 4.2

ARN TLD11 U plant Mini plant 484960 7545543 4.2

ARN TLD15 West Western security gate 471315 7544446 3.4

0.0

1.0

2.0

3.0

4.0

5.0

6.0

East North South Office Arandis Maxi area U plant West gate

Ex

po

su

re d

os

e (

mS

v/a

)

2010 2011 2012 2013 2014 2015 2016 2017 2018

Figure 9.11: Thermoluminescent Dosimeter Results 2010-2018

9.4.3 Inhalation of Radioactive Dust Environmental dust monitoring by means of passive dust fallout buckets and active inhalable dust samplers provides an estimate of the volume of dust emitted, but the dust itself must be analysed to determine its radioactivity. Orano Mining Namibia uses the Algade PSVOL2 mobile sampling system to measure the specific alpha activity of long-lived radionuclides in dust (LLRD). In 2018, four instru-ments were in place at the locations shown on the map in Attachment 3 and listed in Table 9.6 to-gether with the 2018 results. The average annual dose from inhalation of LLRD was 0.02 mSv/a. A table of all results since 2008 is included in Attachment 1. Table 9.6: PSVOL2 Dosimeter Coordinates and 2017 LLRD Results

ID Location Description X Y 2018 mSv/a

ARN AD02 Office Midi offices 484443 7544317 0.022

ARN AD05 Arandis Arandis, Maletz workshop 496960 7521005 0.022

ARN AD06 Maxi area BME explosives store 480684 7547947 0.015

ARN AD08 South Former NamWater pipeline 486400 7543500 0.015

The measured LLRD activities were used to calculate exposure doses for members of the public, i.e. individuals who actually (in case of Arandis) or theoretically (all other locations) live at the monitor-


ing sites. Figure 9.12 presents annual public exposure doses as a result of the inhalation of LLRD. The results for most sites showed no major deviations from previous values, except for Arandis where a slight rising trend has been observed since 2012, possibly related to the increasing height of the Rössing Uranium tailings facility. The high doses at the office and uranium plant in 2010 were a result of uranium ore crushing that took place in the Midi area. The exposure doses were lower in 2011 and following years because crushing had stopped.

0.00

0.05

0.10

0.15

0.20

Arandis Background Office Annaberg U plant Maxi area South

Exp

osu

re d

ose (

mS

v/a

) 2010 2011 2012 2013 2014 2015 2016 2017 2018

Figure 9.12: Comparison of Annual Exposure Doses from Inhalation of Dust at Monitoring Sites

The monitoring records over the last nine years confirm the findings of studies carried out in the re-gion, i.e. that dust inhalation is generally one of the lowest contributors to a person’s total exposure dose. 9.4.4 Inhalation of Radon and Progeny Environmental radon exhalations were monitored using the Algade PSVOL2 integrated monitoring system. In 2018, average atmospheric radon concentrations were monitored at four locations as shown in Table 9.7. The calculated public exposure doses due to radon and progeny varied between 0.78 and 1.02 mSv/a with an average of 0. 91 mSv/a (Table 9.7). The calculation of public exposure doses uses an equilibrium factor of 0.4 for indoor and outdoor occupation, and assumes that a per-son spends 8760 hours per year at the monitoring site. As mentioned above, the occupational radia-tion exposure is calculated on the basis that a person spends only 2000 hours per year at work. Pub-lic doses are however used here for better comparison between the results of Arandis and the mine. Table 9.7: Inferred Radon Exposure Doses from PSVOL2 Monitors (mSv/a)

Location 2011 2012 2013 2014 2015 2016 2017 2018

Offices 0.97 0.47 1.14 0.96 1.13 1.03 1.35 1.00

Arandis 0.34 0.48 0.65 0.51 0.72 0.59 0.91 0.78

Maxi area 0.67 0.69 0.61 0.71 0.79 0.76 0.78 1.02

South 0.87 0.74 0.63 0.61 0.65 0.77 0.64 0.83

During the last nine years, the readings at Arandis varied from 0.3 to 0.9 mSv/a with an average of 0.6 mSv/a (Figure 9.13). This is just above the population-weighted average of 0.5 mSv/a for the Erongo region that was published in the Strategic Environmental Assessment (SEA, Ref. 6). The radon dose of 1.0 mSv at the Midi office is similar to previous results. The office is located close to the Midi pad which is the source of higher than background radon levels. The ore on the heap leach pad was


wet during most of 2012, which may explain the lower radon emanation, unless it was caused by measurement errors. Radon levels around 0.6-1.0 mSv/a at the Maxi area and along the former pipeline to Arandis are slightly above the regional average, which can be expected for sites close to a uranium ore body.

0.0

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1.5

2.0

Arandis Background Office Annaberg U plant Maxi area South

Exp

osu

re d

ose (

mS

v/a

) 2010 2011 2012 2013 2014 2015 2016 2017 2018

Figure 9.13: Average Annual Radon Exposure Doses at PSVOL Monitoring Sites

9.4.5 Ingestion of Contaminated Food and Water Saline groundwater at Trekkopje mine is unfit for human consumption and will be avoided by most animals. The risk of ingesting radionuclides by way of drinking contaminated borehole water is therefore considered very low. Since there are no edible plants on the mine consumption of meat is the only other potential pathway to humans. It can however be disregarded because there are hard-ly any springbok present on the mine during the current drought.

9.5 Land Surface 9.5.1 Soil Monitoring The results of baseline surveys of radionuclide activities in soil carried out in 2008, 2010 and 2012 were presented in previous annual reports. Since there will be no dust emission during the care and maintenance phase the soil monitoring programme has been suspended until the mine starts up.

9.6 Biodiversity 9.6.1 Vegetation Monitoring To assess whether or not dust deposition arising from mine operation will have an impact on the vi-tality of the plants fixed vegetation transects were established in 2008. Transects are located around the main dust sources and at some distance from the centre of the mine (Table 9.8). Transect 3 was destroyed during the construction of the Maxi pad. The new Transect 7 was laid out to the west of the northern turning circle in the same habitat. Two additional transects were added in 2012 to cov-er more diverse habitats, specifically small river beds. Transect 6 is located near the western mine boundary and Transect 8 along the former Arandis pipeline south of the Midi plant. The condition of the specimens is observed annually by taking photos of each plant and noting the presence of leaves, flowers, seeds and young shoots. The average height and diameter of the plants are measured every five years as the growth rate is very slow.


Table 9.8: Vegetation Monitoring Transects

Locality X Y

1 Palaeodunes near French camp 487627 7548748

2 Riverbed south of Mini pad 485330 7545451

3 Riverbed north of Maxi pad 484087 7552671

4 Riverbed west of MCC 481306 7547428

5 Lichen field in the west 475588 7544221

6 Near western mine boundary 472508 7544996

7 Maxi pad northern turning circle 483450 7552378

8 Along former NamWater pipeline 486690 7543015

To evaluate the descriptive data in numerical terms and observe trends in plant condition, it was as-sumed that the presence of leaves, buds, flowers and seeds equals 100% vitality (Ref. 18). Each of these components is assigned 25%. This is a simplistic method, as some species do not have leaves or buds and some carry seeds only on female plants. The method just serves to compare the relative condition over the years in graphical form as shown in Figure 9.14. The survey in December 2018 found the perennial and multi-annual plant species in below average condition with an average of 33%. As shown in Figure 9.14 for the years 2008-2018, the average plant condition usually varies around 40%. The peak condition was reached in 2013 after unusually high rainfall in 2011 and 2012. Subsequent drought years caused a generally declining trend with a slight improvement in 2017.

10

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50

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70

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Pe

rce

nt

Transect 1

Transect 2

Transect 4

Transect 6

Transect 7

Transect 8

Average

Figure 9.14: Average Plant Condition over Time

Many Salsola swakopmundii shrubs (an endemic species of salt bush) carried seeds in 2018, but there were no flowers. The condition of Namib corkwood (Commiphora dinteri) was similar to previous years with few specimens carrying leaves, flowers or seeds. Under drought conditions the dollar bush (Zygophyllum stapffii) sheds its leaves in summer, which often results in low survey ratings, while the plants tend to look much better after the rainy season. The dollar bushes appeared to be in poor condition in 2018 with very few remaining leaves. 9.6.2 Plant Relocation When the Maxi leach pad was built in 2008, 82 Namib corkwood (Commiphora dinteri) shrubs were rescued from the construction site and transplanted to an area north of the Annaberg tin mine. Since then the shrubs have been monitored every year to assess their condition. It has become clear


after 10 years that the relocation exercise was not very successful. The survival rate dropped again from 22% in January 2018 to 17% in January 2019, which means that only 14 plants are still alive. The graph in Figure 9.15 gives an impression of the survival rate over time.

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40

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60

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2011 2012 2013 2014 2015 2016 2017 2018 2019

Nu

mb

er

of

tre

es

Alive

Dead

Figure 9.15: Survival Rates of Transplanted Namib Corkwood

The problem of the low survival rate was discussed in the 2015 annual report and is repeated here for reference. The question was whether or not one should attempt to relocate endemic species and how the chances of success could be improved. Orano Mining Namibia’s ESIA recommended that Commiphora dinteri should be rescued because the species is endemic to the central-western Namib. The 106 shrubs found around the Maxi leach pad were regarded as a meaningful number for this par-ticular species, making them worthy of rescue and relocation attempts, even though the species did not enjoy formal protection status and there was no legal obligation to undertake this work (Ref. 19). The attempt to rescue the Namib corkwood was useful in terms of improving the translocation method if there is a need to rescue more plants in future. The biodiversity impact of the lost Commi-phora dinteri population was limited because there are still numerous plants left in the undisturbed area around the Maxi leach pad. 9.6.3 Fauna Monitoring Orano Mining Namibia has been involved in the NamPower/Namibia Nature Foundation (NNF) part-nership project that investigates the effect of power lines on bird kills and options for the mitigation of such incidents since 2010. The NamPower/NNF Partnership was initiated to mitigate the negative effects of power lines on both birds and the electricity industry. Orano Mining Namibia’s contribu-tion consisted of occasionally inspecting the power lines, sometimes together with the researchers employed by NNF, and reporting any bird kills. Since there have been many incidents on the Trek-kopje power lines over the years, NamPower has identified the need for mitigation measures. The installation of markers on the 10.4 km Trekkopje bypass on the Khan-Trekkopje line and the 4 km section running eastwards of the Wlotzkasbaken desalination plant was postponed to 2019. Animal fatalities reported by employees on the mine are logged in a database and treated as envi-ronmental incidents. There was one animal kill on the mine roads in 2018 (Cape hare), while four bird collisions with power lines (“Birds PL” in the graph) were reported. The animal fatality numbers for 2018 are shown in Figure 9.16 in comparison with the previous five years.


0

5

10

15

20

Cape hare Jackal Birds Birds PL Springbok Aardvark Snake

Nu

mb

er

2013 2014 2015 2016 2017 2018

Figure 9.16: Number of Animal Fatalities in 2013-2018

9.7 Water Quality Monitoring The mine’s domestic and industrial effluent disposal exemption permit no. 688 requires annual re-porting on the results of the prescribed groundwater and sewage effluent quality monitoring, as well as other matters relating to water management. An annual report on water management at Trek-kopje Mine was submitted to the Directorate Resource Management of the Ministry of Agriculture, Water & Forestry (Ref. 21). This report can be consulted for additional details on water quality moni-toring and permit compliance. Groundwater quality monitoring took place in April 2018 and included comprehensive analyses of major and minor determinants at eleven monitoring sites (Figure 9.17). Samples for potable water microbiology and sewage effluent analyses were taken in April and October 2018. Water levels were measured during sampling in April and again close to the end of the year. The water quality monitor-ing results for 2018 are presented in the following text and tables. 9.7.1 Major Ions in Groundwater Groundwater at Trekkopje is brackish to saline with total dissolved solids concentrations of 10 000-26 000 milligrams per litre (mg/L). All groundwater samples are of a similar water type, i.e. sodium chloride (NaCl) waters with a range of salinity (TDS) levels and minor sulphate and calcium concen-trations. The April 2018 analysis results are shown in Table 9.9. The samples were analysed by Ana-lytical Laboratory Services in Windhoek and DD Science in Randfontein. A duplicate sample of bore-hole M6 was included for quality control (indicated as M6A in Table 9.9). An evaluation of the data showed no major changes compared to previous years. The graph of bore-hole M1 in Figure 9.18 demonstrates that typically only very slight water quality changes occur at Trekkopje. The only borehole that shows more obvious trends is M2, situated southwest of the Maxi plant (Figure 9.19). The salinity at this site increased until 2016, then started declining in 2017. The increase was probably due to soil salts flushed down to the shallow water table (8-9 m below sur-face) during heavy rains in 2009-2012. For comparison, borehole M1 where the water level is at 36 m below surface only showed rising sodium and chloride concentrations since 2016 because it takes longer for recharge to reach the deeper aquifer.


Figure 9.17: Water Quality Monitoring Boreholes (Map by SLR)

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Sep 07 Feb 08 Mar 09 Mar 10 Mar 11 Sep 11 Mar 12 Mar 13 Mar 14 Mar 15 Mar-16 Mar 17 Apr-18

Co

nce

ntr

atio

n (

mg/

L)

Total Dissolved Solids Chloride as Cl- Sodium as Na Sulphate as SO42- Total Hardness as CaCO3

Figure 9.18: Main Water Quality Parameters at Borehole M1 in 2007-2018


0

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Sep-07 Feb-08 Mar-09 Mar-10 Mar 11 Mar 12 Mar 13 Mar 14 Mar 15 Mar 15 Mar-16 Mar-17 Apr-18

Co

nce

ntr

atio

n (

mg/

L)

Total Dissolved Solids Chloride as Cl- Sodium as Na Total Hardness as CaCO3 Sulphate as SO42-

Figure 9.19: Main Water Quality Parameters at Borehole M2 in 2007-2018

9.7.2 Metals and Trace Elements in Groundwater The geochemical environment at Trekkopje Mine is characterised by a predominance of strontium, lithium and boron among the trace elements (Table 9.9). Some samples have high iron and manga-nese concentrations, probably derived from sulphide minerals in the rock. High uranium and vanadi-um concentrations are due to the presence of secondary uranium mineralisation. The main mineral carnotite is a uranium vanadate. Toxic metals such as arsenic, cadmium, mercury, lead and nickel are only present at low concentrations. Most sites showed little variation in trace elements compared to previous analyses. The only exception is borehole TW07A where the salinity declined and the uranium concentration increased from 0.16 mg/L in 2008 to 0.35 mg/L in 2018. The change was caused by the storage of high-chloride wash water from the Midi pad in the granite quarry, which is close to borehole TW07A. In addition to high levels of chloride and sulphate the wash water contained 0.4-2.9 mg/L of uranium. The granite quarry was selected as a temporary storage site because large volumes of wash water were produced within a short period and could only be reused for construction at a much slower rate. The permeability of the granite was assessed to be very low, but it later appeared that some fracturing created a hydraulic connection to the adjacent marble band on which borehole TW07A is located. Small volumes of wash water seeped into the marble aquifer which contains brackish groundwater. The contaminated water is being removed by pumping the adjacent production bore-hole TW07 and using the water for dust suppression on the mine roads. The water quality is ex-pected to return to the natural background composition in the next few years.


Table 9.9: Groundwater Analysis Results 2018 Sampling point TW01 TW05 TW07 TW10 TW12 OO-18 M1 M2 M6 M6A M14

Date of sampling Unit 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17

pH 7.1 7.2 7.5 7.4 7.4 7.1 7.3 7.0 7.6 7.7 7.4

Electrical conductivity mS/m 2620 1563 2072 2330 1518 1630 2590 3400 1474 1473 3340

Turbidity NTU 178 0.65 18 0.25 197 39 4.7 37 50 46 13

Total dissolved solids (det.) mg/L 18304 10692 14892 16138 10177 11355 18099 23805 10016 10092 23459

P-Alkalinity as CaCO3 mg/L 0 0 0 0 0 0 0 0 0 0 0

Total alkalinity as CaCO3 mg/L 240 210 150 98 142 225 125 175 90 90 82

Total hardness as CaCO3 mg/L 3761 2163 2678 2796 2198 1955 3141 4189 1457 1476 3715

Ca-hardness as CaCO3 mg/L 1805 1718 1895 1865 1745 1531 2247 3201 1086 1101 2117

Mg-hardness as CaCO3 mg/L 1956 445 782 931 453 424 894 988 371 375 1598

Chloride as Cl- mg/L 9908 4954 6682 7834 4954 5185 9447 11291 4609 4493 11752

Fluoride as F- mg/L 1.8 2.4 2.9 2.6 2.1 2.3 2.4 2.1 2.7 2.8 3.2

Sulphate as SO42- mg/L 2773 2000 3496 2995 2045 2264 3433 3527 2405 2343 4310

Nitrate as N mg/L 5.4 29 57 43 25 25 49 38 25 24 87

Nitrite as N mg/L 0.01 <0.01 0.02 <0.01 0.29 <0.01 <0.01 0.01 0.01 0.01 0.01

Silica as SiO2 mg/L 11 15 17 12 9 14 15 18 14 14 9

o-Phosphate as PO4 mg/L <0.03 <0.03 <0.03 <0.03 <0.03 0.03 <0.03 0.03 0.06 0.06 0.12

Sodium as Na mg/L 5702 3240 4694 5277 3122 3508 5866 6969 3331 3284 7848

Potassium as K mg/L 136 76 137 137 72 83 161 166 107 107 227

Magnesium as Mg mg/L 475 108 190 226 110 103 217 240 90 91 388

Calcium as Ca mg/L 723 688 759 747 699 613 900 1282 435 441 848

Al aluminium µg/l 752 6.1 24 12 11 302 85 447 811 791 193

As arsenic µg/l 0.1 1.4 15 8.5 0.2 1.1 4.2 1.1 2.8 2.5 2.3

B boron µg/l 3930 7280 5890 8510 3510 4530 7040 6790 5060 5220 6980

Ba barium µg/l 44 20 15 15 19 15 19 23 26 27 17

Be beryllium µg/l 0.7 0.2 0.2 0.1 0.1 0.2 0.1 0.2 0.2 0.2 0.09

Cd cadmium µg/l 0.1 0.1 0.2 0.2 0.1 0.1 0.1 0.1 0.2 0.1 0.3

Cr chromium µg/l 1.6 0.3 6.7 3.7 0.1 1.4 0.7 0.6 1.8 2.6 11

Cu copper µg/l 7.4 1.0 2.9 1.1 0.7 7.8 5.7 9.5 12 12 6.4

Fe iron µg/l 2263 13 2677 18 8681 174 82 264 417 365 225

Hg mercury µg/l 0.1 0.7 0.4 0.5 <0.001 0.4 0.5 0.4 0.4 0.5 0.3

Li lithium µg/l 853 239 445 544 228 250 523 593 221 232 775

Mn manganese µg/l 934 0.4 5.8 0.6 81 4.4 3.9 10 53 51 20

Mo molybdenum µg/l 17 25 59 56 17 26 40 25 33 34 73

Ni nickel µg/l 5.9 0.4 1.7 0.2 0.7 0.5 0.7 1.5 1.9 1.8 1.6

Pb lead µg/l 5.4 0.5 1.0 0.5 1.0 1.6 5.7 2.8 25 26 9.6

Sb antimony µg/l 0.08 0.03 0.1 0.06 0.05 0.05 0.08 0.1 0.05 0.07 0.1

Se selenium µg/l 5.2 12 17 17 8.2 14 27 32 17 8.6 27

Sn Tin µg/l 0.07 0.07 0.08 0.04 0.1 0.05 0.1 0.06 0.08 0.1

Sr strontium µg/l 19312 10421 15024 15971 11322 9415 18477 25594 6483 6834 18139

Ti titanium µg/l 4.2 0.4 14 0.6 1.1 11 4.0 14 12 11 7.0

Th thorium µg/l 4.3 0.03 0.03 0.02 0.02 0.2 0.09 0.4 0.1 0.2 0.2

U uranium µg/l 290 189 347 155 83 188 186 402 115 121 102

V vanadium µg/l 24 33 178 40 2.5 35 54 32 26 27 18

Zn zinc µg/l 6.3 2.0 4.9 4.3 3.4 13 11 27 25 25 7.9


9.7.3 Drinking Water Chemistry and Microbiology Trekkopje mine receives its drinking water from the Erongo desalination plant. The plant continuous-ly monitors the quality of its product water to ensure compliance with the Namibian potable water quality standard. Orano Mining Namibia and NamWater receive daily production reports including chemical parameters that are determined on site (pH, conductivity, turbidity, dissolved oxygen and reservoir free chlorine). Weekly samples are sent to a laboratory in Windhoek where they are ana-lysed for pH, conductivity, turbidity, alkalinity, total hardness, sodium, calcium, magnesium, potassi-um, iron, boron, chloride, sulphate, nitrate and nitrite, fluoride and TDS. The desalination plant’s water quality analyses are reported to MAWF in separate annual reports. Because the desalinated water is stored in open reservoirs Orano Mining Namibia monitors the mi-crobiological quality of the potable water supplied at various points on the mine. The NSI laboratory at Walvis Bay analysed the February, September and November samples, while one sample taken in April 2018 was analysed by ALS in Windhoek. Table 9.10 shows that the results for 2018 were in compliance with the Group B drinking water quality limits for heterotrophic plate count and coli-forms most of the time. Table 9.10: Microbiological Analysis of Potable Water

Site

Heterotrophic Plate Count, cfu/mL

Coliforms, MPN/100mL

E. coli MPN/100mL

Reservoir Feb-18 52 <1 <1

Reservoir Jul-18 12 18 <1

Reservoir Sep-18 55 26 <1

Reservoir Nov-18 15 >100 <1

Midi canteen tap Feb-18 505 <1 <1

Midi canteen tap Apr-18 2600 <1 <1

Midi canteen tap Jul-18 <1 <1 <1

Midi canteen tap Sep-18 1 <1 <1

Midi canteen tap Nov-18 <1 <1 <1

Maxi office Feb-18 11 <1 <1

Maxi office Jul-18 48 <1 <1

Maxi office Sep-18 163 <1 <1

Maxi office Nov-18 254 <1 <1 cfu/mL = Colony forming units per millilitre (mL),< = less than MPN/100mL = Most probable number per 100 mL

The sample taken at the canteen in April 2018 showed an exceptionally high heterotrophic plate count. The potable water supply system at the Midi plant was therefore cleaned in May. A review of the domestic water consumption showed that the problem of bacteria growth was caused by the long period that water is stored in three 10 000 litre tanks. It was decided that two storage tanks next to the first aid station will be bypassed because they are not required anymore. Samples were taken on 3 July 2018 to confirm that the water quality had improved. 9.7.4 Sewage Effluent Quality The Namibian water quality standard prescribes that the TDS in effluent may not increase by more than 500 mg/L based on the incoming water quality, while the upper limit for sodium is 90 mg/L in-crease. This means a maximum TDS of 1100 mg and 290 mg/L of sodium based on the average desal-inated water TDS and sodium concentrations in early 2018. Chemical oxygen demand (COD) should


not exceed 75 mg/L. The upper limit for total suspended solids concentration is 25 mg/L because particles present in effluent are a breeding ground for bacteria. An increase in suspended solids indi-cates insufficient settling time, probably because the capacity of the plant was exceeded. The am-monia concentration should be less than 10 mg/L. Excessive ammonia concentrations indicate that the conversion to nitrate was not effective, possibly due to the bacterial films in the trickle filter plants having insufficient time to interact with ammonia and nitrites. Both insufficient contact time and an overload of suspended solids can result in high ammonia levels. Incomplete conversion and the presence of suspended solids interfere with disinfection of the final effluent, resulting in the presence of E. coli. Samples of treated sewage effluent were taken in April and October 2018. The results in Table 9.11 and Figure 9.20 on the next page show that substandard effluent quality still occurred in 2018. The two sewage treatment plants at Trekkopje Mine are not operating under optimum conditions be-cause the effluent volumes are far below their design capacity (25-30 persons). The discharge to the Midi plant was reduced by more than 50% following retrenchments in 2017 and the Maxi treatment plant is only used by four security guards. The effluent from both plants is discharged into lined evaporation ponds, so that exceedances will not affect the environment. Table 9.11: Sewage Analysis Results 2018 Sampling site Proposed General Midi Maxi

Date Effluent Standard Apr-18 Apr-18

pH 6.5-9.5 6.6 6.1

Conductivity mS/m <75 mS/m increase (180) 163 365

Redox potential mV 496 590

Dissolved oxygen as O2 mg/L >75% 6.2 5.8

Total dissolved solids (meas.) mg/L <500 mg/L increase (1100) 944 2063

Total suspended solids mg/L 100 10 7

Chemical Oxygen Demand as O2 mg/L 100 62 41

Kjeldahl Nitrogen as N mg/L 33 8.0 121

Oxygen absorbed as O2 mg/L 10 15.1 6.1

Nitrate as N mg/L 20 45 5.3

Nitrite as N mg/L 3 0.08 <0.01

Free and saline ammonia as N mg/L 10 3.6 42

Sodium as Na mg/L <90 mg/L increase (290) 252 473

E. coli MPN/100ml absent in 100 mL 74 not detected

Sampling site Proposed General Midi Maxi

Date Effluent Standard Oct-18 Oct-18

pH 6.5-9.5 6.3 6.8

Conductivity mS/m <75 mS/m increase (180) 166 307

Redox potential mV 505 748

Dissolved oxygen as O2 mg/L >75% 5.4 7.4

Total dissolved solids (meas.) mg/L <500 mg/L increase (1100) 1078 1809

Total suspended solids mg/L 100 6 4

Chemical Oxygen Demand as O2 mg/L 100 64 *

Kjeldahl Nitrogen as N mg/L 33 6.0 *

Oxygen absorbed as O2 mg/L 10 10.6 *

Nitrate as N mg/L 20 35 *

Nitrite as N mg/L 3 1.30 *

Free and saline ammonia as N mg/L 10 6.0 <0.02

Sodium as Na mg/L <90 mg/L increase (290) 264 529

E. coli MPN/100ml absent in 100 mL not detected not detected Key: * could not be measured due to interference by chlorine mS/m millisiemens per metre mV millivolt mg/L milligrams per litre MPN most probable number


944 1078

252 264

62 64

105.9

3.66.0

1

10

100

1000

10000

Apr-18 Oct-18

Co

nce

ntr

atio

n (

mg/

L)Midi

TDS Sodium COD Suspended solids Ammonia as N

2063 1809

473 529

41

6.74.3

42

1

10

100

1000

10000

Apr-18 Oct-18

Co

nce

ntr

atio

n (

mg/

L)

Maxi

TDS Sodium COD Suspended solids Ammonia as N

Figure 9.20: Sewage Effluent Quality in 2018

9.7.5 Groundwater Levels Most boreholes showed little water level variation since monitoring started in 2007, for instance M1 and TW01 in Figure 9.21. Borehole TW01 in the eastern part of the mine received recharge from ma-jor rainfall events in 2011 and 2012. The very slow rise of the water table indicates a generally low permeability of the palaeochannel sediments which results in small flow rates and volumes.

-42

-40

-38

-36

-34

-32

Jan-07 Jan-08 Jan-09 Jan-10 Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16 Jan-17 Jan-18 Jan-19

m b

elo

w t

op

of

casin

g

M1

-20

-18

-16

-14

-12

-10


m b

elo

w t

op

of ca

sin

g

TW01

-26

-24

-22

-20

-18

-16

Sep-06 Sep-07 Sep-08 Sep-09 Sep-10 Sep-11 Sep-12 Sep-13 Sep-14 Sep-15 Sep-16 Sep-17 Sep-18 Sep-19

Wa

ter

Leve

l (m

be

low

co

lla

r)

TW05a

-33

-31

-29

-27

-25

-23

Nov-06 Nov-07 Nov-08 Nov-09 Nov-10 Nov-11 Nov-12 Nov-13 Nov-14 Nov-15 Nov-16 Nov-17 Nov-18

Wate

r le

vel

(m b

elo

w t

op

of

ca

sin

g)

TW12a

-38

-36

-34

-32

-30

-28

Oct-06 Feb-08 Jul-09 Nov-10 Apr-12 Aug-13 Dec-14 May-16 Sep-17 Feb-19

m b

elo

w t

op

of

casin

g

TW21

-15

-13

-11

-9

-7

-5


m b

elo

w t

op

of

casin

g

M2

Figure 9.21: Water Level Trends


Production boreholes TW05 and TW12 that intercept the marble aquifers are still recovering from groundwater extraction in 2008-2010, with water levels that are about two metres lower than before the start of pumping. Boreholes TW21 and M2 in the vicinity of the western mine gate are situated on the same marble bands, which is why their water levels were affected by pumping from the for-mer production boreholes. The recovery of the water table at these sites is very slow owing to the persistent drought conditions since 2013.

9.8 Erongo Desalination Plant Monitoring A description of water quality and environmental monitoring results obtained at the Erongo Desali-nation Plant in 2018 can be found in Ref. 26.

10 NATURAL RESOURCE CONSUMPTION Orano Mining Namibia monitors its environmental footprint by keeping track of environmental indi-cators, such as water, electricity and fuel consumption, as well as greenhouse gas emissions and pro-duction of waste. 10.1 Electricity Consumption Orano Mining Namibia’s total electricity consumption of 1175 megawatt hours (MWh) was below the limit of 1560 MWh set for 2018 (Figure 10.1). The saving was achieved by running the diesel-powered standby generators whenever the crushers and compressors have to be started to test their functionality. This serves as testing of the generators at the same time.

0

50

100

150

200

250


MW

h

Actual Planned

Figure 10.1: Trekkopje Mine Monthly Electricity Consumption

10.2 Fuel Consumption

The diesel consumption of 35 047 litres (0.36 GWh) was much lower than the expected consumption of 48 000 litres (Figure 10.2); mostly because of a further reduction in the frequency of road mainte-nance.


0

2000

4000

6000

8000

10000


Lit

res

Actual Planned

Figure 10.2: Trekkopje Mine Monthly Diesel Consumption

10.3 Water Consumption The mine’s water consumption of 24 323 m3 was well below the annual target of 66 000 m3 (Figure 10.3). The reason was the same as for the reduced diesel consumption, i.e. a reduction in road maintenance and dust suppression. The total supply consisted of 15 388 m3 of desalinated seawater and 8935 m3 of groundwater extracted on site. The reservoirs on the mine were only filled up once (to 70%) in September 2018, and remained 50% full at the end of the year.

0

5000

10000

15000

20000


Cu

bic

me

tres

Actual Planned

Figure 10.3: Trekkopje Mine Monthly Water Consumption


11 EMISSIONS AND WASTE MANAGEMENT

11.1 Greenhouse Gas Emissions The annual direct and indirect greenhouse gas (GHG) emissions related to Orano Mining Namibia’s activities in tonnes of carbon dioxide equivalent (CO2eq) are shown in Figure 11.1. Direct GHG emis-sions are calculated from the fuel consumption. In line with the reduced diesel consumption the greenhouse gas emissions were also lower than expected, i.e. 95 t CO2e compared to the limit of 130 t CO2e. The calculation converts the impact on the atmosphere of greenhouse gases such as methane (CH4) and nitrous oxide (N2O) to the impact of an equivalent tonnage of carbon dioxide (CO2). Fuel use for vehicles on the mine site and for employee transport is included in the figures. There were no direct greenhouse gas emissions from transport of materials to and from the mine. Indirect greenhouse gas emissions from the purchase of NamPower electricity are much higher than direct emissions (Figure 11.1). Namibia imports about 60% of its electricity from South Africa and other neighbouring countries, while the remainder is supplied by a local hydropower scheme. The 40% share of hydropower has zero emissions. The GHG figures for the remaining 60% are calculated from the emission factor of the South African power utility Eskom that mainly operates coal-fired power stations. Application of the Eskom factor of 0.96 kg CO2 per kilowatt hour results in direct GHG emissions of 888 483 t CO2eq for 2018 (note that the figures in the graph below are in kilotonnes and the vertical scale is logarithmic). The electricity consumed for seawater desalination by the Erongo desalination plant is defined as ‘other indirect’ emissions in accordance with the definitions of the Global Reporting Initiative. The desalination plant has been running since 2010, supplying only Trekkopje mine from 2010 to August 2013. Since then, water is mostly sold to NamWater to meet the demand of other consumers whose rising demand explains the high indirect GHG emissions.

2.4

0.6 0.7

0.2

0.2

0.1

2190

1191

1013

973

88

8

6773

392

10510

10597

16511

28933

21587

0

1

10

100

1000

10000

100000

2013 2014 2015 2016 2017 2018

Kil

oto

nn

es

of

CO

2 e

q.

Direct Indirect Other indirect

Figure 11.1: Direct and Indirect Greenhouse Gas Emissions

The indirect GHG emissions in 2018 were 21 587 000 t CO2eq. Orano Mining Namibia consumed only a minute fraction of the desalinated water that was produced with this energy, and one could argue that the GHG emissions should be split pro rata. On the other hand, water production can be re-garded as a company activity because Orano Mining Namibia benefitted from the sale of water to the national water supplier. This approach was taken here to assign the entire GHG load to Orano.


Ozone-depleting substances are released from coolants in air conditioning systems. Offices on the mine are equipped with air conditioners that use R410-a coolant with a global warming potential of 2088 relative to carbon dioxide. The mine did not refill coolants in any air conditioners in 2018, so the GHG emissions from this source are reported as zero.

11.2 Waste Management In the past, domestic and non-hazardous industrial waste from Trekkopje mine used to be taken to the municipal landfill at Swakopmund as return freight from weekly deliveries. Since these trips had stopped waste was taken to the Arandis landfill until it was decided towards the end of 2018 to sepa-rate recyclable items and burn the remaining waste on site. It was not possible to estimate the ton-nage of waste. The QHSE section transported 1074 kg of used vehicle batteries, fluorescent tubes and medical waste from the first aid station to the Walvis Bay hazardous waste facility in 2018. Some types of mineral waste, such as drill cuttings and samples, sulphate overburden and tailings are classified as low-level radioactive waste. A comprehensive inventory of radioactive waste types is included in the Trekkopje Mine Radiation Management Plan (Ref. 22). The disposal of mineral waste has been addressed in the mine closure plan. The volume of tailings stored on the leach pads is 1.587 million m3 and the volume of overburden is 1.409 million m3. The overburden consists of weathered granite removed from the quarry and sulphate-bearing conglomerate that covered the ore in the open pit. There is also low-level radioactive waste from the uranium production process, e.g. protective clothing, spare parts from the processing plants, empty SDU drums, etc. Approxi-mately 40 m3 of this waste were stored in locked shipping containers. This is an interim measure during the care and maintenance phase until a more suitable disposal site can be provided.

12 RESEARCH AND DEVELOPMENT

12.1 Restoration Testing and Monitoring The monitoring programme was suspended in 2018 because the test plots remained barren after low rainfall.

13 AUDITING Audits and inspections are carried out to ensure compliance with the environmental management plans for Trekkopje mine and the Erongo desalination plant (Ref. 25). Orano Mining Namibia ap-pointed an independent consultant to conduct the external EMP compliance audit in October 2018. The updated EMPs dated January 2016 were used as the basis for the audit. The auditor only in-spected the desalination plant, since the mine site had already been inspected by the Chamber of Mines Safety Committee in June 2018. A few environmental deviations were found during this audit were addressed immediately. The verification of relevant documents and environmental action plans took place on 3 October at the town office. The auditor found the mine 99% compliant. The only non-conformance related to waste manage-ment as the EMP does not make provision for the use of the Arandis landfill or for waste burning on site. The desalination plant achieved 96%. The auditor reported that the plant appeared generally tidy and clear of waste or spillages. Very few activities were taking place that could cause potentially negative environmental impacts. Waste management has improved since the previous audit and a


hazardous material (bunded) area has been constructed. All findings from the previous audit have been addressed. The following issues were found in 2018:

Waste management: skips were not labelled; recyclable waste and non-recyclable (and pos-sibly some hazardous) waste were mixed, emptied and (apparently) disposed of by the con-tractors on the general Swakopmund landfill site.

Chemical spillage could occur when caustic soda is off-loaded, which happens regularly. There were some spillages outside the lined area. Sodium hypochlorite spillage inside the bunded area appears to be washed into the drains which discharge to the environment.

Paint storage in container involves the risk of paint flowing out of the container into the drainage line.

An action plan to address the findings has been prepared and is being implemented by AVENG Water Treatment. Report compiled by: Sandra Müller QHSE Consultant Date: 9 April 2019


14 REFERENCES

1. Limpitlaw, D & M Hoadley (2008): Trekkopje Mine Environmental and Social Impact Assessment Report. Report prepared by Turgis Mining Consultants for UraMin Namibia.

2. Stacey, J & P Roux (2008): Report of the Environmental and Social Impact Assessment - Trekkop-je Desalination Project, Erongo Region, Namibia. Report by Turgis Mining Consultants.

3. Müller, S (2016): Environmental Management Plan – Trekkopje Mine. Document prepared by AREVA Resources Namibia.

4. Müller, S (2016): Environmental Management Plan – Erongo Desalination Plant. Document pre-pared by AREVA Resources Namibia.

5. Namibian Uranium Institute (2011): Health, Environment and Radiation Safety and Security (HERSS) Standards (on website www.namibianuranium.org).

6. SAIEA (2010): Strategic Environmental Assessment for the central Namib Uranium Rush. Ministry of Mines and Energy, Windhoek, Republic of Namibia.

7. Liebenberg-Enslin, H (2011): Air Quality Baseline Assessment for Trekkopje Mine in Namibia. Report No. APP/11/ARN-01 by Airshed Planning Professionals, Johannesburg, South Africa.

8. Blerk, JJ van & N Potgieter (2011): Radiological Public Impact Assessment for the Trekkopje Ura-nium Mine: Swakopmund (Namibia). Report No. ASC-1012B-1 prepared by AquiSim Consulting (Pty) Ltd, Pretoria, South Africa.

9. Winker, F (2012): Non-reactive transport model of Trekkopje Mine, Erongo Region. Report No. 2012-G14-V1 compiled by SLR Consulting Namibia, Windhoek.

10. Müller, S (2012): 2011 Annual Report on Environmental Management at Trekkopje Mine. Orano Mining Namibia Processing Namibia document no. HSE ENV RE 08.

11. Burke, A (2009): Biotope Assessment for AREVA Resources Namibia’s Trekkopje Mine in the Cen-tral Namib Desert. Report by EnviroScience, Windhoek.

12. Burke, A (2012): Biotope re-assessment for AREVA Resources Namibia’s Trekkopje Mine in the central Namib Desert. Report by EnviroScience, Windhoek.

13. Müller, S (2011): Rehabilitation Projects and Monitoring 2011. Orano Mining Namibia Pro-cessing Namibia internal report.

14. Hooks, P (2014): An Assessment of the Intensity and Extent of Brine Discharges from the Erongo Desalination Plant: Implications for Environmental Management. Mini-dissertation (MOB791) submitted in the partial fulfilment of the requirements for the degree Magister in Environmental Management, University of the Free State, Bloemfontein, South Africa.

15. Roux, P et al (2010): Environmental Impact Assessment Trekkopje Road. Report No. 30375 EIA compiled on behalf of Turgis Mining Consultants, Johannesburg, South Africa.

16. Kinahan, J (2006): Archaeological Assessment of a proposed open-cast uranium mine at Trek-kopje, Erongo Region, Namibia. QRS Job 73 prepared by Quaternary Research Services on be-half of Uramin (Pty) Ltd, Windhoek, Namibia.

17. Müller, S (2015): 2014 Annual Report on Environmental Management at Trekkopje Mine. Orano Mining Namibia Processing Namibia document no. HSE ENV RE 22.

18. Müller, S (2011): Results of Fixed Transect Vegetation Monitoring 2008-2010. Orano Mining Namibia Processing Namibia internal report.

19. Mannheimer, C (2008): Rescue, relocation and monitoring of Commiphora dinteri from the Maxi Leach Pad at Trekkopje Uranium Project. Unpublished report for Uramin.

20. NamPower/Namibia Nature Foundation Partnership (2016): Newsletter No. 17, October 2016.

http://www.namibianuranium.org/


21. Müller, S (2018): Biannual Report on Water Management at Trekkopje Mine, July-December 2017. Orano Mining Namibia document no. HSE ENV RE 32.

22. Oertzen, D von et al (2012): Trekkopje Mine Radiation Management Plan. Report by VO Consult-ing and Orano Mining Namibia to the National Radiation Protection Authority.

23. Burke, A (2017): Restoration Monitoring at Trekkopje - Monitoring Report of 2017. Report by EnviroScience, Windhoek.

24. Burke, A and S Müller (2012): Trekkopje Mine Closure Plan, Working document, version 2. Re-port by EnviroScience, Windhoek.

25. Petrick, W (2018): 2018 Environmental (EMP) Compliance Audit of Orano's Trekkopje Mine and Desalination Plant Project. No: NSP201801, Report No.: 01, Swakopmund.

26. Müller, S (2019): Erongo Desalination Plant 2018 Annual Report on Water Management. Orano Mining Namibia document no. HSE ENV RE 42.


ATTACHMENT 1: ENVIRONMENTAL STRATEGY AND ACTION PLAN PROGRESS REPORT 2018 The objective of this attachment is to report on progress made with the environmental action plan by the end of the year 2018 and to set document the ac-tion for 2019. The plan is based on Orano Mining Namibia’s environmental strategies each of which has separate colour-coded tables. Strategies, objectives and actions that are not applicable during the time of care and maintenance are shown in grey font. They are kept in the plan for reference and to be reac-tivated in future.

1. ENVIRONMENTAL STRATEGY AND ACTION PLAN

Themes Objectives Actions Status at end of 2018

Integrated

Management

System

Local regulations and Orano directives are enforced and potential modifica-tions are anticipated

The significant environmental aspects and risks associated with each activity are identified, assessed and prioritized

A consolidated environmental action plan is drawn up and each action is monitored at least annually

Environmental criteria are taken into account when decisions with a signifi-cant environmental impact are made

Maintain a legal register and keep in-formed about proposed legislation changes in Namibia

Obtain directives and policy changes from Orano Head Office

Identify environmental aspects and risks, update EMPs

Set up a QHSE action plan for each year and monitor progress annually

Conduct internal environmental assess-ments for projects with significant impact and prioritize remedial actions

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

Orano Head Office places updated doc-uments on intranet and e-mail

Trekkopje aspects updated in 2016 EMP, desalination plant EIA & EMP updated in 2018

Tracking progress in QHSE action plan and EMP audits

No significant projects were planned or implemented in 2018

Awareness

Training

All new hires are alerted to significant environmental aspects and risks asso-ciated with the company’s activities

The environment is discussed at meet-ings and toolbox talks

Managers at all levels carry out partici-patory HSE inspections including envi-ronmental issues

New employees and contractors attend environmental induction before starting work

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

Managers include environmental as-pects in their HSE inspections

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

Refer to minutes of monthly HSE meet-ings and records of weekly safety talks

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



Internal

Communication

The environmental policy is updated and posted, objectives and indicators are set annually and tracked

All incidents are investigated; employ-ees are informed of the corrective or preventive action taken

Improvement ideas and good practices are recorded and exchanged between business units

Update policy annually and display on notice boards

Investigate and report significant envi-ronmental incidents according to proce-dure, inform employees of events and action taken

Environmental improvement ideas are recorded in monthly reports and ex-changed within Orano Mining Namibia and with other mines

Policy updated in 2018 and displayed, objectives and indicators tracked in monthly reports

One environmental incidents was report-ed in the Orano database and monthly report

No specific improvement ideas, but good practices were exchanged within Orano and with members of the Namibian Ura-nium Association, e.g. in the water and radiation working groups

External

Communication

Publish an environmental and social report to stakeholders

Interact with the public

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

Hold meetings with stakeholders

Published a report for 2017 in 2018 and distributed printed copies to stakeholders

Community consultant held meetings, but stakeholders did not raise environmental concerns

Biodiversity Draw up a biodiversity action plan Refer to Biodiversity Strategy Refer to Biodiversity Strategy

Chemical

Accident

Risks

A hazard study is carried out and a schedule is drawn up to implement the conclusions

HAZID and/or HAZOP risk analyses are carried out prior to the launch of pro-jects or major upgrades of facilities

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

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

Maintain effective emergency response procedures and equipment

No new chemicals introduced in 2018

Still in care and maintenance phase, no new risks identified

Trained employees and contractors in emergency response procedures, equip-ment and response team are in place



Chemical

Health Risks

The group directives concerning asbes-tos, legionnaire’s disease and CMR substances are enforced

Asbestos and asbestos-containing mate-rials are not permitted on site

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

CMR substances are identified and re-placed with less hazardous alternatives if these are available

Implemented, refer to Environmental Code of Practice

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

Completed CMR hazard assessment study in 2009. No CMRs are used during care and maintenance

Soil and

Groundwater

All pre-existing pollution is assessed prior to acquisition

Compile a plan to prevent the risk of pollution and reduce potential impacts

Prevent groundwater pollution through seepage or spills

Establish baseline conditions before ex-ploration or production work begins

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

Carry out regular soil surveys to assess the mine’s impact when in operation

Monitor the groundwater quality annually

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

Procedures are in place and employees were trained in spill response, restocked spill kits in all workshops

Soil surveys have been suspended for the care and maintenance phase as no new soil pollution is being generated

Implemented, refer to annual reports

Monitoring The site has a plan for radiological, chemical and biological monitoring of the air, water and soil

Implement the:

o Radiological monitoring programme

o Air quality monitoring programme

o Water monitoring programme

o Soil monitoring programme (radionu-clide deposition from dust fallout)

Using TLDs and alpha dosimeters for ra-diation monitoring (see reports)

Monitoring dust emission and climate

Analysing potable water, groundwater and sewage effluent quality

Soil survey has been suspended

Decommissioning Compile a decommissioning plan for exploration and production sites and provide the necessary budget

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

Consult stakeholders about future land use options and expectations

Consider retrenchment plan and sus-tainable development issues

Closure plan prepared in 2010, cost esti-mates last updated in 2018, provision in-cluded in annual budget

Stakeholders will be consulted once the mine is in operation

Preliminary consideration in closure plan, to be refined in future



Water,

Energy,

GHG

Consumption and releases are moni-tored, measured and published

Annual targets are set to reduce water and fossil energy consumption, and GHG emissions

Monitor consumption and releases as required and report to Orano HQ

Publish results in the annual environ-mental and social report

Set site-specific targets for GHG emis-sions, water, fuel and power consump-tion

Monitoring and reporting as required

Figures are included in 2018 stakeholder report (data table)

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

Waste Waste materials generated by the mine are identified and quantified

Targets are set for reducing waste at source and optimising recycling

Keep a waste register specifying waste types and volumes

Investigate options for waste recycling and plan for waste reduction at source

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

No targets set in C&M as not much waste is generated; do recycle paper, wood, metal, printer cartridges

Innovation Reduce the consumption of non-renewable resources

Develop advanced technologies for the treatment of waste and effluent

Improve modelling in terms of long-term contaminant behaviour and transport

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

Re-use heap leach effluent in a closed loop to minimize effluent discharge

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

5 MW solar power station was built by independent contractor at Trekkopje, will include a small PV plant for the mine’s use as well

Implemented in water balance, also plan-ning to re-use high-chloride wash water

Modelling done in 2012, closure plan ad-justed according to outcome, no further work needed


2. AIR QUALITY STRATEGY AND ACTION PLAN

Objectives Activities Tasks Status end of 2018

1. Emission sources are identified, documented and monitored

Identify all emission sources

Monitor and record con-centrations of gases and dust

Collect climate data

Standardise equipment to compare data with other mines in the area

Identify and record emission sources

Use dust buckets and PM10 samplers to determine dust emission

Use gas samplers for SO2 and NO2

Monitor radon emission

Operate and maintain weather stations

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

Investigate feasibility of equipment stand-ardisation with other mines

Sources identified for operations phase (see air quality model)

Dust buckets and PM10 samplers in place

Suspended during care and maintenance

Alpha dosimeters for radon in place

One weather station operating

Provided data for 2017 SEMP report that was published in 2018

Most mines use E-samplers, but not stand-ardised for all

2. No impact on community health

Carry out a community health risk assessment based on air quality im-pacts

Determine possible impacts based on air quality models

Monitor air quality at Arandis and other crit-ical group locations (if any)

Communicate with stakeholders about as-sessment results

Public health risk assessment carried out in 2011

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

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

3. Emissions during con-struction are reduced as far as practical (this objec-tive does not apply during care and maintenance but is kept in the plan for ref-erence)

Set limits and monitor compliance

Determine effective miti-gation measures

Allocate responsibilities for dust control

Model and predict air quality impacts

Compare measured emissions to set limits and SA standard

Mobile crusher feed bins to be fitted with water sprays

Implement dust control procedure

Reduce dust through water spraying

Update air quality model and apply results in project design

Monitoring was done until construction ended in 2012, see annual reports

Was done, no crushing during C&M

Procedure in place and implemented during construction

Water still sprayed on the main roads

Model was updated in 2011 and results were applied during construction



4. Emissions during opera-tion comply with WHO tar-gets (this objective does not apply during care and maintenance but is kept in the plan for reference)

Include dust control measures in material transport and handling systems design

Implement operational control measures and emergency plans

Regularly update the air quality model

Monitor compliance

All material transfer points to be fitted with dust suppression or dust extraction equip-ment

Compile emission control procedures for each source and emergency plans for ex-cessive emissions

Stabilise or rehabilitate disturbed surfaces to reduce wind erosion

Update the model if conditions change

Maintain air quality monitoring network

Dust suppression equipment was fitted at primary and secondary crushers

Procedures to be compiled by operating departments when the mine starts up

Spray surfaces with water to speed up crust formation

Only applicable during mine operation

Refer to Objective 1

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

Dust fallout levels at resi-dences in towns should not exceed the recom-mended limit of 600 mg/m

2/day

Provide dust fallout data to the SEMP Of-fice to be included in annual SEMP reports

Measure air quality at Arandis

Measure dust close to mine boundaries when the mine is in operation

Monitoring results for 2017 were provided to the SEMP Office

Dust monitoring at Arandis and on the mine continued in 2018

6. Annual human expo-sures to particulate con-centrations are acceptable (SEMP)

Ambient PM10 concen-trations at public loca-tions and mines may not exceed the limits to be set for the Erongo Region

Limits to be based on international guidelines considering local envi-ronmental, social and economic conditions

Ambient PM10 monitoring at Arandis by Orano Mining Namibia

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

Data are evaluated and PM10 emissions reduced through dust control measures if limits are exceeded

Contribute to the discussion about suitable limits for the region

Readings at Arandis for 2018 did not ex-ceed the WHO IT-3 limit of 75 µg/m

3

Provided an E-sampler to MME for use at Henties Bay for the duration of the ad-vanced air quality study (2016-19)

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

The SEA recommended using the WHO IT-3 guideline of 75 µg/m

3 for the Erongo re-

gion, current MME/SEMP study proposed similar limits


3. BIODIVERSITY STRATEGY AND ACTION PLAN


1. Develop a Biodiversi-ty Management Plan

Assess and evaluate biodiversity in and around the operation

Enhance biodiversity understanding

Identify risks and op-portunities

Integrate biodiversity into the EMS (refer to Objective 3)

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

Evaluate biodiversity importance and deter-mine impact of operations

Conduct consultations with conservation groups and communities, integrate differing perspectives into the assessment of biodiver-sity

Carry out field surveys and regular monitor-ing at specific sites

Identify opportunities to protect or enhance biodiversity

Define responsibilities and boundaries

Reconcile trade-offs or offsets

Establish links to partners and local and re-gional environmental programmes

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

Strategic environmental assessment of ura-nium mining in the Erongo region (2010) in-cluded wide consultation and differing per-spectives of all stakeholders

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

Carried out biotope assessments and identi-fied important areas to be protected

Not yet documented

Method to be developed (see Obj. 2)

In progress, some links established (MET NBSAP, NERMU, NACOMA, OmBMC)

2. Minimise Biodiversity Impacts

Mitigate impacts

Rehabilitate affected areas

Document habitat dis-turbance and rehabili-tation

Implement conserva-tion and offset actions

Determine which impacts can be avoided by proper planning

Minimise unavoidable impacts, e.g. by reduc-ing the affected area, relocating plants, stor-ing topsoil

Rehabilitate areas as soon as possible after disturbance ends

Use Biotope Method to document changes in habitat disturbance

Use appropriate rehabilitation methods de-veloped and tested in the Namib

Identify acceptable offsets in consultation with stakeholders, implement approved actions

Used system of ground disturbance permits in 2008-12 to avoid unnecessary impacts

Applied these mitigation measures during the construction phase, no further disturbance in 2013-14

Did this at the end of construction in 2012, monitoring success of rehab measures

Have data for 3 years, will continue with this once the mine is in operation

Established own rehab trial plots to test differ-ent methods, monitoring them annually

Offset system to be established by Govern-ment, workshops held in 2018 to develop poli-cy



Support regional conservation groups and efforts as well as biodiversity studies

Will continue once the mine is in operation

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

Identify impacts of planned processes on biodiversity

Create awareness among contractors who implement new projects

Develop EMS and closure plan

Take part in project planning meetings and workshops to find out about new projects

Obtain plans, do risk assessments and eval-uate impacts

Arrange for EMP training modules and pre-sent to engineers and contractors

Include biodiversity aspects in the EMS, re-habilitation and offsets in the closure plan

No new projects in 2017

All contractors on care and maintenance pro-jects receive environmental induction

EMS to be established before the start of op-eration

Closure plan (2013) includes rehabilitation measures and cost


4. HAZARDOUS MATERIALS STRATEGY AND ACTION PLAN

Objectives Activities Tasks Status at end of 2018

1. Plans are in place before hazardous materials are purchased and used

Understand the environ-mental risks of hazardous materials

Identify and assess envi-ronmental aspects and potential impacts

Develop internal compli-ance criteria for hazard-ous materials and site contamination

Maintain an inventory of hazardous materials

Keep a register of con-taminated sites with geo-graphical references (if any)

Reduce the inventory of hazardous materials

Replace CMR with envi-ronmentally safer alterna-tives

Ensure the safe use, storage and transport of hazardous materials

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

Consider impacts associated with transport, storage and use, including failure of sec-ondary containment structures

Internal criteria must be in line with interna-tionally accepted regulations, guidelines, definitions and methodologies if govern-ment regulations are absent or incomplete

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

Identify existing contamination and assess its environmental impact, record contami-nated sites in a register

Control the use and inventory of hazardous materials to minimum necessary quantities

Assess and promote the use of safer alter-natives to currently used hazardous materi-als, especially those classified as CMR

Apply risk assessment and set up proce-dures for safe use, storage and transport

Carried out health risk assessment in 2017 including all hazardous materials

Assessment done by Orano HQ in 2010, recommendations implemented, no new is-sues in 2018

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

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

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

System to be put in place at mine start-up

Carried out CMR assessment in 2009, did not identify any chemicals that could be re-placed with alternatives

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



2. Hazardous materials management is integrated into mine operations

All employees and con-tractors are made aware of environmental hazards and risks and are appro-priately trained

Control new hazardous materials, including those used by contractors

Store materials in ade-quate conditions and se-cure containment within controlled areas

Operate effective con-tainment barriers for pre-venting spills of hazard-ous material from reach-ing the environment

Hazardous material stor-age tanks and pipelines must be above ground

Storage tanks and pipe-lines must have leakage identification and re-sponse procedures

Control third-party trans-porters, purchasers and other recipients of haz-ardous materials

Be prepared to respond to on-site and off-site hazardous material spills

Remediate existing con-taminated sites that show unacceptable environ-mental impacts

Include handling and use of hazardous ma-terials in job-specific inductions; give job-specific training in routine activities and emergency response training in remedia-tion of contamination

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

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

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

If storage tanks or pipelines cannot be above ground the exception must be au-thorised by the Mine Manager

Inspect storage tanks and pipelines con-taining hazardous materials to detect leak-ages and take appropriate remedial action according to procedure

Implement selection criteria and control procedures for third parties; implement fol-low-up procedures for any hazardous mate-rial sent off-site, e.g. for disposal

Maintain emergency response procedures, equipment and response team

Carry out regular drills when mine is in op-eration

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

General induction includes basic infor-mation about hazardous materials; supervi-sors give job-specific training to new em-ployees and contractors; QHSE department trains emergency response teams

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

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

Some secondary containments in pilot plants were not designed with the neces-sary capacity, but they are not in use any-more; fuel depot has sufficient containment

Storage tanks and pipelines at Trekkopje mine are all above ground

Inspections are currently only carried out at the fuel depot, but will be included in plant operating procedures one the mine starts up

Transport company for radioactive materi-als selected according to RMP require-ments; hazardous waste transported by Orano Mining Namibia staff, disposal certif-icates issued by Walvis Bay hazardous waste facility

Response team in place and trained, pro-cedure updated

No pre-existing polluted sites were identi-fied at Trekkopje mine



3. The hazardous materials management system is in-spected and audited

Implement routine inspec-tion, testing and monitor-ing procedures for stor-age tanks and pipelines

Install leakage detection equipment that is ade-quate for the risk posed by the hazardous material

Audit significant aspects of hazardous materials management

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

Leakage detection equipment to be in-stalled where needed and linked to the ap-propriate operational control and emergen-cy response unit

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

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

Leakage detection equipment or monitoring boreholes will be installed if and when re-quired during operation or before start-up

Internal and external audits of hazardous material storage and handling are carried out (see 2018 EMP audit report by SLR)


5. NOISE AND VIBRATION STRATEGY AND ACTION PLAN

(to be implemented at mine start-up, no environmental noise and vibration generated during care and maintenance)


1. Emission sources are identified, documented and monitored

Identify and record all emission sources

Monitor and record noise and vibration

Collect climate data

Manage cumulative im-pacts

Review mine plan and identify emission sources

Use sound level meters to determine noise levels; monitor blasting vibration

Operate and maintain weather stations

Cooperate with other uranium mines and compare data

Noise and vibration monitoring will be im-plemented at mine start-up, there are no significant emissions during care and maintenance

Weather stations are in place and working

See first comment above

2. No impact on community health or wellbeing

Carry out a community noise risk assessment

Include noise nuisance from traffic to the mine

Determine possible impacts based on data collected at Trekkopje

Monitor noise levels at Arandis

Communicate with stakeholders

Data will be collected and impacts will be assessed at mine start-up, also at Arandis once the new road has been built

Stakeholders will be informed

3. Noise and vibration emissions during mine op-eration are managed

Implement operational noise and vibration con-trol measures and emer-gency plans

Include control measures in the design of material transport and handling systems

Noise and vibration control through opti-mal blast loading

Material transfer systems at Arandis siding to be fitted with noise suppression equip-ment

Compile control measures for each signifi-cant source and emergency plans for ex-cessive emissions

Update the plan if conditions change

Optimal blast loading will be determined in cooperation with Mining department

Noise suppression will be considered in design

Will be done once the mine has started up


6. SUSTAINABLE DEVELOPMENT STRATEGY AND ACTION PLAN

Commitments Objectives Activities Status at end of 2018

1. Financial performance: Sig-nificant contribution to the economy

Realise financial benefits through uranium production

Contribute to the Namibian economy

Optimise the mining process to reduce production cost

Pay taxes and royalties

Use local suppliers

Invest in community economic de-velopment

Trekkopje mine was put under care and maintenance in 2013 because the project is currently not economic

99% local procurement in 2018

Community projects in 2018 focussed on SME development, education and sport

2. Environment and biodiversi-ty: Reduce and mitigate the unavoidable impact of the mine

Optimise the consumption of fuel, electricity and water

Reduce the mining footprint and biodiversity disturbance

Control pollution and waste disposal

Set annual targets and track per-formance

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

Set targets to reduce emissions and waste

Prevent or mitigate hazardous ma-terial releases

Setting targets and tracking consumption of fuel, electricity and water

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

Tracking greenhouse gas emissions and waste volumes

Gave training and provided spill kits to clean up accidental spills (four spills rec-orded in 2017)

3. Occupational health and radiation protection: No expo-sure to unacceptable harm

Workers on the mine remain fit for work

Comply with the ALARA prin-ciple

Optimise handling and secu-rity of product

Medical surveillance of employees and contractors

Monitor and manage employee exposure

Maintain effective security and emergency systems

All medicals done, no new cases of occu-pational disease identified

No worker was exposed to over 8 mSv over 12 months in 2018

Product stored according to procedure; security and emergency systems in place

4. Occupational safety: Zero accidents

Eliminate accidents at work Implement the safety roadmap

Improve near-miss reporting

2018 safety roadmap 98% implemented

No fatality or lost-time injury in 2018

All incident frequency rate = 0

Near-miss reporting in place

5. Community involvement and relations with stakehold-

Implement the social policy (HSE ENV PO 03) and com-

Employ local staff

Use local suppliers

Compliant with Namibian AA legislation

99% local procurement in 2018


Commitments Objectives Activities Status at end of 2018

ers: Sustainable improvement of community conditions

munity engagement strategy Identify sustainable projects in consultation with stakeholders

Partner with government to im-prove social services (health, schools, training)

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

Supported education projects (refer to Stakeholder Report for details)

6. Commitment to employees: Skills and diversity

Enhance employees’ careers and skills, meet diversity tar-gets

Retain the current workforce

Develop skills by training employ-ees and contractors

26% women on management committee

Employ more disabled persons

Headcount stable in 2018

Employee training continued, contractors included in HSE and first aid in 2018

50% women on management committee at the end of 2018

No recruitment permitted in C&M

7. Innovation: Optimise mining processes

Improve operational efficien-cy to reduce production cost

Conduct metallurgical test work to optimise the heap leaching process

No research projects in 2018

8. High standard of corporate governance is maintained

Operate in an accountable and transparent manner ac-cording to the Orano Mining Namibia Values Charter (or Ethics Standard)

Maintain external communication and complaints procedures

Issue annual reports to stakehold-ers

Offer employees and contractors an anonymous tip-off service

Procedure in place, but no complaints re-ceived in 2018

Report on 2017 issued in April 2018

Introduced a fraud hotline in October 2014, received no reports in 2018


7. WATER STRATEGY AND ACTION PLAN


1. Optimised water use ef-ficiency

Maintain adequate water supply

Optimise water balances

Plan and construct site infra-structure

Manage seawater desalination as speci-fied in contract

Compile monthly water balances when in operation, identify opportunities for de-mand reduction

Investigate and implement water recy-cling and treatment options

Plan correct placement of fresh and fire water pipes, effluent and recycle systems, tanks and ponds

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

Not applicable during the care and maintenance phase

New options will be investigated before mine start-up based on the outcome of metallurgical test work to optimise the heap leaching and elution processes

Done in construction phase 2010-2012, documented in as-built plans

2. Minimal adverse impact on water quality and the environment

Set up monitoring systems and check water quality, wa-ter levels and condition of vegetation

Model and predict impact of mine processes

Take action to prevent or remediate pollution

Comply with MAWF permit conditions

Monitor boreholes and extend the net-work as required

Compile groundwater flow and geochem-ical transport models to predict the impact of spent ore backfilling on the natural groundwater quality

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

Compile biannual reports on permit com-pliance, water management and water quality monitoring

Current monitoring borehole network is sampled annually (April 2018)

Groundwater flow and geochemical transport models were updated in 2011 and 2012, with the results being used to compile the mine closure plan

Trends evaluated in annual report on en-vironmental management, no significant spills occurred in 2018

Two reports for Trekkopje and one for EDP compiled for 2018 and submitted to DWAF (permits renewed in Jun 2016)



3. Awareness of internal and external stakeholders’ issues associated with wa-ter

Identify and address com-munity concerns

Create water conservation awareness

Contribute to sustainable water management initia-tives

Comment on proposed legis-lation and regulations

Identify community expectations and per-ceptions in relation to water

Include water awareness training in in-ductions for employees and contractors

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

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

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

Had meetings with individual stakehold-ers and groups, e.g. Swakop farmers

Water conservation is included in induc-tions that are given to all new workers

Annual environmental and stakeholder reports contain water use data

Orano Mining Namibia is a member of the NUA Sustainable Development Commit-tee and (dormant) Omaruru Basin Man-agement Committee

No discussions held in 2018, workshops about the Water Act and regulations are planned when it commences (according to MAWF)


8. PUBLIC HEALTH STRATEGY AND ACTION PLAN (SEMP OBJECTIVES)

Objectives Indicators Activities Status at end of 2018

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

Public dose assessments pro-duced by each new mine project include the cumulative impact of other operating mines

Modelled cumulative radiation dose to critical groups of the public does not exceed 1 mSv/a above background

Monitor pathways by which radiation emissions may reach the public

Carry out public dose assessment based on modelling

Manage emissions if they exceed the dose constraint

Inform the public about results

Update the model when conditions change and at closure

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

Public dose assessment done in 2011, update not necessary in C&M

Not applicable in C&M

Public is informed about results by means of annual SEMP reports

Model will be updated when condi-tions change and at closure

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

Measured change in absorbed radiation dose of uranium mine workers (radiation workers)

Measure radiation doses of occupa-tionally exposed and non-exposed workers

Reduce exposure if warning limit is exceeded

Report results to affected workers

Measure radiation doses of occupa-tionally exposed workers

Not applicable during C&M, no work done with highly radioactive material

Results are reported to all workers in HSE meetings

3. No measurable increase, directly attributable to uranium mining in the incidence rates of industrial lung disease (includ-ing pneumoconiosis), lung and other industrial-related can-cers, industrial-induced renal damage, tuberculosis, dermati-tis

Measured change in the inci-dence rate of industrial diseases amongst uranium mine workers

Measured change in the inci-dence rate of industrial diseases scientifically attributed to radia-tion amongst members of the public, uranium mine workers and medical personnel

Identify and record incidences of in-dustrial diseases amongst uranium mine workers through medical surveil-lance

If possible, take part in studies to iden-tify and record diseases scientifically attributed to radiation amongst mem-bers of the public

Industrial diseases are identified at annual medical examinations; to date none reported for Orano Mining Na-mibia employees or contractors

Rössing started a study to identify the incidence of cancer among workers and members of the public, other mines cannot take part

4. Exposures are reduced to as low as reasonably achieva-ble (ALARA)

All types of radiation sources that could contribute to the ex-posure limits being exceeded are adequately characterised

Radiation doses to workers and the public are monitored and minimised

Identify radiation sources and docu-ment in Radiation Management Plan

Identify public exposure pathways and assess dose rates

Maintain exposure and medical moni-toring programmes

Implement mitigation measures

RMP updated in 2016 for the care and maintenance phase identifies all sources and pathways

Medical examinations and radiation monitoring carried out as scheduled

Applicable when the mine is in oper-ation


9. WASTE MANAGEMENT STRATEGY AND ACTION PLAN


1. Waste is character-ised and risks are as-sessed

Compile a waste invento-ry

Assess and evaluate risks associated with all waste types generated on site

Identify appropriate man-agement system

Survey waste types and volumes of all de-partments and document

Carry out environmental risk assessment

Research suitable disposal methods

Identify hazardous waste types that need special storage and disposal

Compile a waste management plan based on the waste management hierarchy

Will be done when mine is in operation, currently have mostly domestic waste

RA was included in ESIA (2008)

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

2. Waste is avoided and reduced at source

Identify opportunities for waste risk reduction

Identify actions and set targets for waste volume reduction

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

Identify less hazardous alternatives and substitute if feasible

Identify reuse opportunities

Separate materials for recycling and arrange for removal and transport

Keep records of waste volumes to assess if reduction targets are met

Report data as required

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

No opportunities for replacement when mine was in operation

To be done at mine start-up

Recyclables to be separated in future

Records kept of estimated volumes, no weighbridge available

Data are included in annual environmen-tal reports

3. Waste disposal fol-lows good practice

Store waste types sepa-rately in clearly marked dedicated areas

Discard waste only at approved landfills

Audit waste removal con-tractors to ensure compli-ance

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

Train employees in correct waste separation and handling

Use Swakopmund or Walvis Bay landfills

Inspect and audit waste separation and storage

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

Keep records of waste disposal

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

Trained employees in 2018

Took some waste to Arandis landfill in 2018

Deviations found during inspections and audit are addressed

Swakopmund landfill inspected in 2016

Filing system in place for Walvis Bay hazardous waste certificates


10. ENVIRONMENTAL RADIATION MANAGEMENT STRATEGY AND ACTION PLAN


2. An effective radiation man-agement system is established at the mine

A clearly defined chain of re-sponsibility is established

Radiation areas and exposure levels are mapped

Impacts on the environment are determined, managed and miti-gated

Response to emergencies, e.g. spills in public areas is immedi-ate and effective

Define and document duties and responsibilities

Survey radiation areas, identify sources and measure exposure

Demarcate areas >5 mSv/a and restrict access

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

Optimise water management, air emission control, waste disposal procedures

Establish emergency procedures

Duties and responsibilities are de-fined in the 2016 RMP

Mine-wide surveys suspended, but dosimeters measure exposure

Completed and documented in RMP

Monitoring of air and water contin-ued in 2018 (see annual report)

Procedures are in place and up-dated

Emergency procedures included in RMP, but not relevant during C&M

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

Public dose assessments pro-duced by each new mine pro-ject include the cumulative im-pact of other operating mines

Modelled cumulative radiation dose to critical groups of the public does not exceed 1 mSv/a above background

Monitor pathways by which radiation emissions may reach the public

Carry out public dose assessment based on modelling

Manage emissions if they exceed the dose constraint

Inform the public about results

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

Public dose assessment done in 2011, update not necessary in C&M

Not applicable in C&M

Public is informed about results by means of annual SEMP reports

4. The cumulative radiation dose to members of the public and designated radiation work-ers does not exceed the legal limit (SEMP)

Measured change in absorbed radiation dose of uranium mine workers and medical profes-sionals (designated radiation workers)

Measure radiation doses of occupa-tionally exposed and non-exposed workers

Reduce exposure if limit is exceeded

Report results to affected workers

Measure radiation doses of occu-pationally exposed workers

Not applicable during C&M

Results are reported to all workers in HSE meetings


11. MINERAL WASTE MANAGEMENT STRATEGY AND ACTION PLAN (not applicable to C&M)


1. Waste is character-ised and risks are as-sessed

Compile a waste in-ventory

Characterize geo-chemical behaviour

Assess risks associat-ed with mineral waste

Monitor releases from mineral waste

Plan closure measures

Identify all mineral waste types

Commission geochemical studies and mod-elling to determine releases

Carry out environmental impact assess-ments of long-term risks

Monitor radon emanation, dust emission and leachates from waste dumps

Identify suitable disposal and rehabilitation methods

Mineral waste types have been identified

Geochemical studies done 2008/9, model-ling completed 2012

Risks assessed in 2011/12 public health risk assessment and groundwater model

Monitored radon emanation, no increased dust emission or leachates from dumps

Closure plan updated in 2013 to include best solutions for mineral waste disposal

2. The management of mines’ mineral waste sites (tailings and waste rock facilities) meets national standards (SEMP)

Mines comply with DWAF industrial efflu-ent exemption permit conditions

Comply with NRPA regulations

Comply with approved EMP

Comply with approved closure plan

Ensure that DWAF permit contains condi-tions related to mineral waste management

Update the RMP when NRPA issues regula-tions for mineral waste management

Audit compliance of mineral waste manage-ment measures with EMP (updated 2016)

Rehabilitate backfilled areas as described in the closure plan

DWAF indicated that the permit for the pro-duction phase of the mine will contain rele-vant conditions

NRPA had not yet issued regulations

Mineral waste facilities not audited in 2016

Closure plan has not yet been submitted for government approval. No backfilling done to date, but rehabilitation measures being test-ed on disturbed areas

3. Status of facilities is monitored and reported

Keep records of waste volume and monitor waste characteristics

Report to regulators and interested parties

Inspect and audit to ensure compliance

Metallurgy department to monitor and report chemical analysis results

Survey to measure mineral waste volumes

QHSE to compile statistics on mineral waste disposal, carry out inspections and arrange external audits, report to Orano Mining Na-mibia and National Radiation Protection Au-thority

Not applicable during care and maintenance


12. VISUAL IMPACT MANAGEMENT STRATEGY AND ACTION PLAN


1. Visual im-pact is man-aged

Visual impact and sense of place are in-clude in all environmental impact as-sessments

Mitigation measures are implemented as per EMP

External monitoring of compliance with visual impact mitigation measures takes place

Carry out environmental impact assess-ments including visual aspect identification and sense of place

Discuss visual impact with stakeholders at the design stage to ensure that the final design includes mitigation measures

Monitor the visual impact as part of the Environmental Control Officer’s annual ex-ternal audit

Was included in 2008 environmental im-pact assessment

Stakeholder input was not included at the design stage because the mine is not visi-ble from towns and roads

Visual impact was audited in 2015, auditor found no impact on the public because the mine is far from towns and roads

2. Visual im-pact of infra-structure is minimised

Paint colours blend into the environment

The height of plant structures is restricted

Mineral waste dumps are kept as low as possible

Dump slopes are designed to resemble natural hills

Place structures close to each other and away from areas that are visually exposed

Set structures as low as possible, keeping below 35 m above mean ground level

Paint colours should be muted earth tones or medium grey for large surfaces (roofs and storage tanks)

Bright colours should only be used for safety markings as required by industry

Height of dumps and pit backfill should not exceed 7.5 metres. The slopes should be flattened to less than 18 degrees

All structures were placed as close to each other as possible

No structures on the mine are higher than 35 m above ground level

Paint colours are mostly muted, except for the white precipitation building at the Maxi plant

No bright colours were used where they would be highly visible

Height restriction and slope angles for mineral waste dumps and backfilled tail-ings included in closure plan and mineral waste strategy

3. Light pol-lution is re-duced

Light pollution is minimised, especially in areas that are visible from the B2 main road, to reduce the impact on adjacent recreational land use

Lighting is kept to a minimum within the requirements of the law, safety and effi-ciency

Security lighting is designed to meet the objective with the least amount of light pollution

Where area lighting is needed use low-level lighting which is shielded to reduce light spillage and direct lights to work are-as by using shutters to focus the beams

Install lamps close to working surfaces and mount reflectors above the lamp to improve ground level illumination and re-duce light scatter to avoid the generation of a light halo on the horizon

Requirements mostly implemented, no lights installed on high masts, only on plant structures

Requirements mostly implemented, but a light halo from the Midi plant can be seen on the horizon from the vicinity of Arandis. The impact should end when the Midi is decommissioned



The impact of lighting on the environment (fauna) is reduced

All area lighting must shine downwards, i.e. no high mast lighting, external up-lighting of structures or lamps that shine directly up into the sky

Security and perimeter lighting must be shielded so that no light falls outside the area needing to be lit. Perimeter lights and lights in low-use areas should be con-trolled by motion sensors, ambient light sensors or light switches

Lights should be directed into the work area, i.e. shine inwards from the perimeter and not vice versa. More frequent light sources are preferable to single elevated high-wattage lights

Lighting structures used in the mining area should be mobile and placed below the level of the desert surface area if possible

Use yellow light to limit attraction of night-flying insects

Lights were installed so that they shine downwards

Security lighting is the same as area light-ing which is controlled by ambient light sensors and stays on all night

Manual switches were installed in low-use areas

Lights are only installed in areas where they are needed, e.g. for security purpos-es (CCTV)

Lights are mostly directed into work areas, there are only a few elevated high-wattage lights, e.g. at the Maxi logistics yard

No lighting structures are used in the min-ing area while the mine is under care and maintenance

Yellow lights are used everywhere


Orano Mining Namibia

PO Box 585

Swakopmund

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