ENVIRONMENTAL MANAGEMENT PLAN

(EMP)

CONTINUED OPERATION OF THE EXISTING ENGEN FUEL STORAGE

FACILITY IN KEETMANSHOOP

//KHARAS REGION

November 2019

Compiled by: Compiled for:

Matrix Consulting Services Engen Namibia (Pty) Ltd

P.O. Box 25824 Windhoek P.O. Box 201, Windhoek
Tel: +264-61 224 197 Tel: +264-61 296 9006
Fax: +264-61 212 165 [email protected]
[email protected]

This document is for the use of Shell Namibia Ltd only and may not be transmitted to any other party, in whole or in part, in any form without
written consent permission of Matrix Consulting Services
 TABLE OF CONTENTS

1. INTRODUCTION AND BACKGROUND ........................................................................................ 3

2. LEGISLATIVE FRAMEWORK ....................................................................................................... 4
3. DESCRIPTION OF THE RECEIVING ENVIRONMENT ................................................................ 8
3.1 LOCALITY AND LANDUSE ................................................................................................................... 8
3.2 TOPOGRAPHY AND DRAINAGE ........................................................................................................... 8
3.3 CLIMATE ......................................................................................................................................... 9
3.4 HYDROGEOLOGY OF THE STUDY AREA ................................................................................................ 9
3.4.1 Surface-and Groundwater use & users..............................................................................10
3.5 STORAGE DETAILS AND INSTALLATIONS............................................................................................ 10
4. ENVIRONMENTAL MANAGEMENT STRUCTURES .................................................................. 12
4.1 ROLES OF THE ENVIRONMENTAL MANAGER (EM) ............................................................................ 12
4.2 ROLES OF THE ENVIRONMENTAL CONTROL OFFICER (ECO) ............................................................... 13
4.3 ROLES OF THE ENVIRONMENTAL SITE OFFICER (ESO) ...................................................................... 14
4.4 ROLES OF CONTRACTORS (INCLUDING SUPPLIERS, AND SERVICE PROVIDERS) ....................................... 14
5. ENVIRONMENTAL MANAGEMENT PLAN ................................................................................ 16
5.1 TRAINING AND INDUCTION .............................................................................................................. 16
5.2 ENVIRONMENTAL INCIDENT REPORTING .......................................................................................... 16
5.3 ENVIRONMENTAL MONITORING ....................................................................................................... 16
5.4 EMP ADMINISTRATION .................................................................................................................. 16
5.5 EMP AMENDMENTS ....................................................................................................................... 16
5.6 NON COMPLIANCE OF THE EMP ....................................................................................................... 17
5.7 ENVIRONMENTAL REGISTER ............................................................................................................ 17
5.8 SITE MANAGEMENT ........................................................................................................................ 17
5.8.1 Fire and safety management.................................................................................................17
5.8.2 Staff management..................................................................................................................18
5.8.3 Waste management...............................................................................................................18
5.8.4 Hydrocarbons management..................................................................................................18
5.8.5 Flood management................................................................................................................18
5.8.6 Accidents on site.....................................................................................................................18
5.8.7 Emergency advisory procedures...........................................................................................18
6. MANAGEMENT OF ENVIRONMENTAL ASPECTS - OPERATIONAL AND MAINTANANCE 19
7. CONCLUSIONS ............................................................................................................................. 29

List of Tables
Table 1. Responsibility Matrix....................................................................................................12

List of Figures
Figure 1. Locality map...................................................................................................................8
Figure 2. Existing site layout plan...............................................................................................11

Appendices
Appendix A - Copy of ECC previously issued
Appendix B - Support document from relevant Authority
Appendix C - Environmental Monitoring Report

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1. INTRODUCTION AND BACKGROUND
This Environmental Management Plan (EMP) serves as a managing tool for the continued
operation and possible decommissioning of the existing Engen fuel storage facility in
Keetmanshoop, //Kharas Region. The EMP is developed to outline measures to be
implemented in order to minimise adverse environmental degradation associated with this
development.
The EMP serves as a guiding tool for the contractors and workforce on their roles and
responsibilities concerning environmental management on site, and also provides an
environmental monitoring framework for all project phases of the development. This
environmental management plan aims to take a pro-active route by addressing potential
problems before they occur. The EMP acts as a stand-alone document, which can be used
during the various phases of the development.
In this report,

a) the Contractor (its sub-contractors) refers to personnel responsible for all maintenance
activities at the fuel depot. This includes all suppliers and service providers to the
development.

b) the Proponent refers to Engen Namibia (Pty) Ltd, its employees and staff responsible for
all operational activities at the fuel depot.

The purpose of the EMP is to:

 Train employees and contractors with regard to environmental obligations.
 Promote and encourage good environmental management practices.
 Outline responsibilities and roles of Engen Namibia (Pty) Ltd and the contractor in
managing the environment.
 Describe all monitoring procedures required to identify environmental impacts.
 Minimise disturbance of the natural environment.
 Develop waste management practices.
 Prevent all forms of pollution.
 Protect the natural environment.
 Prevent soil and water erosion.
 Comply with all applicable laws, regulations and standards for environmental
protection.

The operation of the existing fuel storage facility entails:

 Transport of fuel supply with road and rail fuel tankers.
 Dispensing of fuel into road transport tanker trucks; and other approved containers.

 Maintenance of the fuel storage facility and all associated services.

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The possible decommissioning of the existing fuel storage facility entails:
 Removal of all infrastructure not reused during future use of land; and
 Rehabilitation of the land.

2. LEGISLATIVE FRAMEWORK
A. The Namibian Constitution
The Namibian Constitution has a section on principles of state policy. These principles
cannot be enforced by the courts in the same way as other sections of the Constitution.
But they are intended to guide the Government in making laws which can be enforced.
The Constitution clearly indicates that the state shall actively promote and maintain
the welfare of the people by adopting policies aimed at management of ecosystems,
essential ecological processes and biological diversity of Namibia for the benefit of all
Namibians, both present and future.

B. Environmental Management Act No.7 of 2007

This Act provides a list of projects requiring an Environmental assessment. It aims to
promote the sustainable management of the environment and the use of natural
resources and to provide for a process of assessment and control of activities which
may have significant effects on the environment; and to provide for incidental matters.

The Act defines the term “environment” as an interconnected system of natural and
human-made elements such as land, water and air; all living organisms and matter
arising from nature, cultural, historical, artistic, economic and social heritage and
values.
The Environmental Management Act has three main purposes:
(a) to make sure that people consider the impact of activities on the environment
carefully and in good time
(b) to make sure that all interested or affected people have a chance to participate in
environmental assessments
(c) to make sure that the findings of environmental assessments are considered
before any decisions are made about activities which might affect the environment.
Line Ministry: Ministry of Environment and Tourism

C. Water Resources Management Act of Namibia (2004) (Guideline only)

The Water Resource Management Act (2004) has been promulgated but not yet
implemented as the regulations are still being drafted. This act repealed the existing
South African Water Act No.54 of 1956 which was used by Namibia, however the Act
describes procedures and stipulations which are much more stringent than those
contained in the Water Amendment Act.

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This Act ensures that Namibia’s water resources are managed, developed, protected,
conserved and used in ways which are consistent with fundamental principles
depicted in section 3 of this Act. Part IX regulates the control and protection of
groundwater resources. Part XI, titled Water Pollution Control, regulates discharge of
effluent by permit.
Line Ministry: Ministry of Agriculture, Water Affairs and Forestry

D. Water Act No. 54 of 1956

This Act provides for Constitutional demands including pollution prevention,
ecological and resource conservation and sustainable utilisation. In terms of this Act,
all water resources are the property of the State and the EIA process is used as a
fundamental management tool.
A water resource includes a watercourse, surface water, estuary or aquifer, and,
where relevant, its bed and banks. A watercourse means a river or spring; a natural
channel in which water flows regularly or intermittently; a wetland lake or dam, into
which or from which water flows; and any collection of water that the Minister may
declare to be a watercourse. Permits are required in terms of the Act for the
undertaking of the following activities relevant to the proposed project:
 Discharge of waste or water containing waste into a water resource through a pipe,
canal, sewer, sea outfall or other conduit in terms of Section 21 (f); and
 Disposal of waste in a manner that may detrimentally impact on a water resource in
terms of Section 21 (g).

E. The Draft Wetland Policy (1993)

The Policy requires that any wetlands and its associated hydrological functions form a
part, to be managed in such a way that their biodiversity, vital ecological functions and
life support systems are protected for the benefit of present and future generations.

F. Sewerage and Drainage Regulations (amendments) Local authorities act,

section 23 (1992)
The regulations make provision for proper construction of pipelines in drainage lines.
The regulations also stipulate the prevention of pollution and environmental damage
caused by improper construction of sewerage and water pipelines in drainage lines.

G. Soil Conservation Act (No.76 of 1969)

The Act advocates for the Prevention and combating of soil erosion, conservation,
improvement and manner of use of soil and vegetation, and protection of water
resources.
Line Ministry: Ministry of Environment and Tourism

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H. Draft Pollution Control and Waste Management Bill
The proposed project of the fuel storage facility in Keetmanshoop, only applies to
Parts 2, 7 and 8 of the Bill.
Part 2 stipulates that no person shall discharge or cause to be discharged any
pollutant to the air from a process except under and in accordance with the provisions
of an air pollution licence issued under section 23. It further provides for procedures
to be followed in licence application, fees to be paid and required terms of conditions
for air pollution licences.
Part 7 states that any person who sells, stores, transports or uses any hazardous
substances or products containing hazardous substances shall notify the competent
authority, in accordance with sub-section (2), of the presence and quantity of those
substances.
Part 8 calls for emergency preparedness by the person handling hazardous
substances, through emergency response plans.

I. Environmental Assessment Policy of Namibia (1995)

Environmental Assessments (EA’s) seek to ensure that the environmental
consequences of development projects and policies are considered, understood and
incorporated into the planning process, and that the term ENVIRONMENT (in the
context of IEM and EA’s) is broadly interpreted to include biophysical, social,
economic, cultural, historical and political components.
Line Ministry: Ministry of Environment and Tourism
Apart from the requirements of the Environmental Assessment Policy, the following
sustainability principles needs to be taken into consideration, particularly to achieve
proper waste management and pollution control:

 Cradle to Grave Responsibility

This principle provides that those who manufacture potentially harmful products
should be liable for their safe production, use and disposal and that those who
initiate potentially polluting activities should be liable for their commissioning,
operation and decommissioning.

 Precautionary Principle
There are numerous versions of the precautionary principle. At its simplest it
provides that if there is any doubt about the effects of a potentially polluting activity,
a cautious approach should be adopted.

 The Polluter Pays Principle

A person who generates waste or causes pollution should, in theory, pay the full
costs of its treatment or of the harm, which it causes to the environment.

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  Public Participation and Access to Information
In the context of environmental management, citizens should have access to
information and the right to participate in decisions making.

J. Atmospheric Pollution Prevention Ordinance of Namibia No. 11 of 1976)

The Ordinance prohibits anyone from carrying on a scheduled process without a
registration certificate in a controlled area. A certificate must be issued if it can be
demonstrated that the best practical means are being adopted for preventing or
reducing the escape into the atmosphere of noxious or offensive gases produced by
the scheduled process. Best practice would be to notify the line Ministry about
emissions but it is not a legal requirement.
Line Ministry: Ministry of Health and Social Services

K. Hazardous Substances Ordinance No. 14 of 1974

The Ordinance applies to the manufacture, sale, use, disposal and dumping of
hazardous substances, as well as their import and export and is administered by the
Minister of Health and Social Welfare. Its primary purpose is to prevent hazardous
substances from causing injury, ill-health or the death of human beings.
Line Ministry: Ministry of Health and Social Services.

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3. DESCRIPTION OF THE RECEIVING ENVIRONMENT
3.1 Locality and Landuse
The project site (26.57178°S; 18.12789°E) is located on Erf no. 1379 Swartmodder
Street, in Keetmanshoop, //Kharas Region. See Figure 1. The fuel storage depot occupies
an approximate land size of 10,000m2. The site is situated in the industrial area of
Keetmanshoop.

Figure 1. Locality map

3.2 Topography and Drainage

The landscape in the area is characterized by the Nama Karoo Basin. This large, flat-lying
plateau dominates much of the southern Namibia. Sedimentary rocks deposited first in
the Nama Basin and, later in the same area, in the Karoo Basin form the foundations of
the landscape. The basin slopes from the north, where elevations are about 1,400 m
above sea level, to the south, where altitudes are approximately 900 m above sea level.

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The Fish, Löwen and Konkiep rivers drain the landscape, all flowing south to the Orange
River.

The relief of significant small dry river courses (streams) running in the area remain
relevant, and contribute well to the drainage of surface run-off in the area. Care should be
taken to avoid contamination of these surface water bodies in the area, especially during
rainy seasons, as water in these bodies is used for aquifer recharge.

3.3 Climate
Classification of climate: semi-arid climate
Average rainfall: Rainfall in the area is averaged between 100 to 150mm
per year.
Average evaporation: Evaporation in the area is averaged to be more than
3800mm per year.
Precipitation: The area is proned to periodic and unpredictable, high
intensity, highly localised storm events between October
and April.
Water Deficit: Water deficit in the area is averaged to be more than
2500mm/a.
Temperatures: The temperatures are highest in January and February
with an average of 26.8°C. The lowest average
temperatures of 13.4°C occur in July during the year.
During the year, the average temperatures vary by
13.4°C.

Wind direction: Wind direction in the area is predominantly northerly,

and southerly.

3.4 Hydrogeology of the Study Area

Surface geology in the area consists of a sandy soil cover (clayey with depth in some
areas), having an unknown thickness. The above is underlain by dolerite sills and dykes
[Jd] of Jurassic to Cretaceous age, intruded into tillite, boulder shale, shale, sandstone and
limestone of the Dwyka Formation [Cd] (Karoo Sequence) and, shale and mudstone [Pp]
(Karoo Sequence) of the Ecca Group to the east and west of the site respectively.
Groundwater flow would be mostly along fractures, faults (secondary porosity) and
other geological structures present within the formations however no major faults are
observed near the site on the 1:1000 000 geological map.

Water to Keetmanshoop town is supplied by Namwater and is sourced from the Naute
Dam, situated approximately 50km southwest of Keetmanshoop. According to the
Department of Water Affairs (DWA) database, no boreholes exist within a 5km radius
from the site; however the presence of 5 boreholes was recorded during a hydrocensus
conducted of the area a few years ago.

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All of these boreholes belong to the municipality and are used for dust suppression on
the gravel roads. Depth to water table is expected to be less than 12mbs in the area. The
area does not fall within a water control area; however groundwater remains the
property of the Government of Namibia. This means that government controls the
exploration and usage of this resource.

3.4.1 Surface-and Groundwater use & users

Surface and groundwater are essentially one resource, physically connected by the
hydrologic cycle. Streams interact with groundwater in three basic ways, i.e. streams gain
water from inflow of groundwater through the streambed, streams lose water by outflow
through the streambed, or they do both depending upon the location along the stream. It is
the groundwater contribution that keeps streams flowing between precipitation events.
As a result, surface and groundwater pollution monitoring must form an integral part of
the Environmental Management Plan (EMP). Surface water pollution at the site is
currently mitigated by surface water run-off drainage systems with a built-in oil-water
separator present at the facility. Visual inspection of surface water pollution should be
adopted, with support of water sampling at specific locations as guided by visual
inspections.

Engen Namibia (Pty) Ltd is in the process of installing three (3) monitoring boreholes at
the fuel storage facility. The purpose of these boreholes is to quantify levels of any
pollution in the subsurface and to monitor the migration of possible pollution off site (if
any).

Baseline water samples will be collected from the boreholes immediately after drilling is
completed, in order to represent baseline conditions at the site. As such, these conditions
will be important in forecasting potential environmental impacts during the operations
of the facility, and can become measurements against which future changes are
compared. The boreholes will be monitored on a regular basis.

3.5 Storage Details and Installations

The site is equipped with fifteen (15) aboveground storage tanks (ASTs), which is;
 5 x Tank – 84 m3 unleaded petrol (ULP),
 8 x Tank – 84 m3 diesel (50ppm),
 2 x Tank – 84 m3 fire fighting water.

All of the tanks are located in a concrete containment bund wall. In addition to the above,
the following associated infrastructure exists;

 Office buildings, storerooms and security office,

 Road Gantry,
 Rail siding,

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  Product pump station,
 Fire water pump house,
 An oily water separator
 2.4m High fence (High density mesh panels).

The facility is constructed and operated according to relevant SANS standards (or
better). See Figure 2 for existing site layout plan.

Figure 2. Existing site layout plan

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4. ENVIRONMENTAL MANAGEMENT STRUCTURES
Roles, responsibilities and authority shall be defined, documented and communicated in
order to facilitate effective environmental management through implementation of the
EMP. The responsibility matrix table below shall be assigned for the storage facility.

Table 1. Responsibility Matrix

Function Name / Mobile Number Responsibility
Environmental Engen Namibia (Pty) Ltd /  Overall management of project and
Manager (EM) Depot Manager EMP implementation.
 Oversees site works, liaison with
Contractor, ESO and ECO.
Environmental Control To be appointed  Implementation of EMP and liaison
Officer (ECO) between Engen Namibia (Pty) Ltd,
Keetmanshoop Engen Fuel Storage
Depot, Department of Environmental
Affairs (MET), local authority,
Contractor and
Landowners/stakeholders.
Environmental Site SHE Officer  Interaction with ECO, landowners and
Officer (ESO) (Keetmanshoop Engen Fuel labourers. ESO must understand the
Storage Depot) content of the EMP.
Contractors/Suppliers To be appointed  Implementation and compliance with
recommendations and conditions of
the EMP, Appoints dedicated person
(ESO) to work with ECO

Management shall provide resources essential to the implementation and control of the
EMP including: human resources, technology, and financial resources. The general roles and
responsibilities of various parties during the operational phase of the project are outlined
below.

4.1 Roles of the Environmental Manager (EM)

The EM (proponent's representative) will act as the employer's on-site
implementing agent and has the responsibility to ensure that the Client's
responsibilities are executed in compliance with the relevant legislations. Any on-
site decisions regarding environmental management are ultimately the
responsibility of the EM. The on-site EM shall assist the ECO where necessary and
will have the following responsibilities in terms of the implementation of this EMP:

 Be fully knowledgeable with the contents of the Construction EMP;

 Review and authorise updates to the EMP.
 Ensure resource allocation for implementation of the EMP requirements.
 Ensure that environmental requirements are integrated into project plans, work
method statements, tender and contract documents.
 Ensure necessary support to the ESO for implementation of the EMP.

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  Undertake environmental system reviews, site inspections, audits and other
verification activities to assure that the EMP implementation is at an optimal
level.
 Participate in environmental performance verification activities to verify the
level of compliance with the EMP in delivering the legal and environmental
obligations.
 Assess the efficacy of the EMP and identify possible areas of improvement or
amendment required within the EMP.
 Participate in incident investigations (as required).
 Initiate external audits (as required).

4.2 Roles of the Environmental Control officer (ECO)

The ECO for the site is an independent environmental consultant appointed by
Engen Namibia (Pty) Ltd to monitor and review the on-site environmental
management and implementation of this EMP on the construction site.
The duties of the ECO:

 Ensure that all operational activities on site are undertaken in accordance with
the EMP;
 Undertake compliance audits against the EMP and conditions of the
Environmental Authorisation (where required).
 Provide support and advice to the project team, contractors and all suppliers in
the implementation of environmental management procedures and corrective
actions.
 Ensure that monitoring programs, which assess the performance of the EMP, are
implemented.
 Assist in the investigation of incidents and non-conformances and confirm in
conjunction with the ESO that corrective and preventive action is taken and is
effective.
 Assess the efficiency of the EMP and identify possible areas of improvement or
amendment required within the EMP.
 Facilitate the amendment of the EMP in conjunction with the Environmental
Manager (as required).
 Provide environmental training for key project personnel (in communication
with Environmental Manager).
 Reviewing and approving method statements in consultation with the
Environmental Manager.
 Prepare audit reports (and submit reports to the relevant authority as required).

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4.3 Roles of the Environmental Site Officer (ESO)
The ESO is expected to administer and control all environmental matters relating to
the operational activities of the fuel storage facility. This can be the SHE officer at the
fuel depot. The ESO will conduct the following:
 Ensure that the latest EMP documents are on site and readily accessible as
required.

 Monitor all appointed contractors activities for compliance with the various
environmental requirements contained in this EMP.
 Identify areas of non-compliance and recommend measures to rectify them in
consultation with the ECO and the EM as required.

 Ensure communication of EMP requirements to relevant projects, contractors

and sub-contractor as required for EMP implementation.

 Perform ongoing environmental awareness training of the depot and all

appointed contractor’s site personnel.
 Ensure that environmental problems are remedied timeously and to the
satisfaction of the ECO and the EM as required.

 Request the removal of people and/or equipment not complying with the
specifications of EMP.

 Facilitate environmental induction of all project staff and either deliver or

coordinate delivery of all such training that would be required for the effective
implementation of the EMP.
 Set up activity based method statements prior to the start of relevant
construction activities and submit these to the EM and the ECO as required.

 Maintain environmental incidents and stakeholder complaints register.

 Undertake environmental system reviews, site inspections, audits and other

verification activities to assure that the EMP implementation is at an optimal
level.

 Report significant incidents internally and externally as required by law and the
conditions of authorisation.

 Investigate incidents and recommend corrective and preventative actions.

4.4 Roles of Contractors (including suppliers, and service providers)

Contractors conducting work at the depot shall ensure that all their staff and
employees are familiar with, understand and adhere to the EMP. Failure by any
contractor to show adequate consideration to the environmental aspects of this

14
contract shall be considered sufficient cause for the ECO to instruct the EM to have
the employee removed from the site. The EM will also order the removal of
equipment from the site that is causing continual environmental damage (e.g.
leaking oils and grease, diesel and petrol fuels, and any other hazardous substance).
Such measures will not replace any legal proceedings the client may institute against
the Contractor.
The EM shall order the contractor to suspend part or all of the works if the
contractor and/or any sub-contractor, suppliers, etc., fail to comply with both the
EMP and procedures supplied by the ESO or EM. The suspension will be enforced
until such time as the offending procedure or equipment is corrected and/or if
required remedial measures are put in place.
By virtue of the environmental obligations delegated to contractors through the
Contract Document, all workers (including subcontractors, suppliers, and service
providers) appointed for the project would be responsible for:
 Ensuring adherence by providing adequate staff and provisions to meet the
requirements of the EMP;
 Ensuring that Method Statements are submitted to the EM for approval before
any work is undertaken, and monitor compliance with the EMP and approved
Environmental Method Statements;
 Ensuring that any instructions issued by the ESO and/or EM are adhered to;
 Ensuring the representation of a report at each site meeting, documenting all
incidents that have occurred during the period before the site meeting;
 Undertake daily, weekly and monthly inspections of the work area(s);
 Ensuring that a register of all the transgressions issued by the ESO is kept in the
site office;
 Ensuring that a register of all public complaints is maintained; and
 Ensure that all employees, including those of sub-contractors receive training
before the commencement of construction in order that they can constructively
contribute towards the success full implementation of the environmental
requirements of the Contract;
 Report and record any environmental incidents caused by the Contractor or due
to the Contractor’s activities;
 obtain required corrective action within specified time frames and close out of
environmental incidents;
 Provide weekly checklists to the EM and ESO.

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5. ENVIRONMENTAL MANAGEMENT PLAN
5.1 Training and Induction
Engen Namibia (Pty) Ltd is bound to be responsible for ensuring that environmental
awareness education of all employees and contractors is done satisfactorily. Engen
Namibia (Pty) Ltd should ensure that employees and contractors are made aware of the
environmental requirements of the project.

The EMP should form part of the Terms of Reference for all contractors, sub-contractors
and suppliers. All contractors, sub-contractors and suppliers will have to sign an
agreement to assure that they understood the EMP and that they will comply. All senior
staff should familiarise themselves with the full contents of the EMP and its implications.
Senior staffs (Depot Manager/Supervisor) are expected to train and assist the rest of the
employees on the contents of the EMP.

5.2 Environmental Incident Reporting

All environmental incidents occurring at the facility shall be recorded. The incident
report should include time, date, location, and nature of the incident, extent of the
incident, actions taken, and personnel involved.

All complaints received from the neighbouring properties/communities should be

directed to the manager of the Engen Depot and channelled to the ECO officer. Engen
Namibia (Pty) Ltd Management should be able to respond to the complainant within a
week (even if pending further investigation). It is important that the issues raised are
considered and that the complainant feels that their concerns have been addressed to
and wherever possible actions taken to address these. All complaints should be entered
in the environmental register and all responses and actions taken to address these
should be recorded.

5.3 Environmental Monitoring

Periodic environmental monitoring must be taken on a regular basis. Monitoring should
be done in order to ensure compliance with all aspects of the EMP. Findings should be
liaised with to all responsible officers as chain command.

5.4 EMP Administration

Copies of this EMP shall be kept at the site office and should be distributed to all senior
staff members, including those of the contractors.

5.5 EMP Amendments

The EMP amendments can only be made with the approval of the ECO officer and
ultimately the DEA. Amendments to the EMP should be liaised to all employees and
contractors.

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5.6 Non compliance of the EMP
Problems may occur in carrying out mitigation measures or monitoring procedures that
could result in non-compliance of the EMP. The responsible personnel should encourage
staff to comply with the EMP, and address acts of non-compliance and penalties.

Engen Namibia (Pty) Ltd is responsible for reporting non-conformance with the EMP, to
the ECO officer. The management of Engen Namibia (Pty) Ltd, in consultation with the
ECO officer must, thereafter, undertake the following activities:
 Investigate and identify the cause of non-conformance.
 Implement suitable corrective action as well as prevent recurrence of the
incident.
 Assign responsibility for corrective and preventative action.
 Any corrective action taken to eliminate the causes of non-conformance shall be
appropriate to the magnitude of the problems and commensurate with the
environmental impact encountered.

5.7 Environmental Register

An environmental register should be kept on site in which incidents related to actual
impacts are recorded. This will include information related to incidents as spillages, dust
generation and complaints from adjacent neighbours. It should also contain information
relating to actions taken. Any party on site may complete the register, however, it is
envisaged that the Depot Manager and the ECO will be the main contributors, and who
will also be the main parties involved in suggesting mitigation measures.

5.8 Site Management

Areas outside this designated working zone shall be considered “no go” areas. The
offloading zones must be clearly demarcated when offloading goods to enhance safety
around the proposed development.

5.8.1 Fire and safety management

Hydrocarbons are volatile under certain conditions and their vapours in specific
concentrations are flammable. If precautions are not taken to prevent their
ignition, fire and subsequent safety risks may arise.
No fire, whether for cooking or any other purpose, is to be made at the fuel
storage facility. All depot personnel and contractors shall take all reasonable
measures and active steps to avoid increasing the risk of fire through activities
on site and prevent the accidental occurrence or spread of fire; and shall ensure
that there is sufficient fire-fighting equipment on site at all times. This equipment
shall include fire extinguishers. All depot personnel and contractors should be
prepared for such events.
The Engen Namibia (Pty) Ltd management together with all depot personnel and
contractors shall take all reasonable measures to avoid increasing the risk of fire
and shall ensure that there is sufficient fire-fighting equipment on site at all
times.

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5.8.2 Staff management
Engen Namibia (Pty) Ltd and its contractors must ensure that all their employees
have suitable personal protective equipment and properly trained in fire fighting
and first aid.

5.8.3 Waste management

All waste shall be removed off-site to designated waste disposal site. Sufficient
bins or containers on-site to store any solid or liquid waste produced should be
provided by Engen Namibia (Pty) Ltd. The bins and containers should be
weatherproof and scavenger-proof.

5.8.4 Hydrocarbons management

If any spillage occurs, contaminated soil shall be collected in a holding tray or
drum and which will then disposed at a licensed hazardous waste site. Any
spillage of more than 200 litres must be reported to the Ministry of Mines and
Energy as per the Petroleum Products Act.
Engen Namibia (Pty) Ltd and its contractors shall take all reasonable measures to
prevent surface or groundwater pollution from the release of oils and fuels.
Sufficient space should be left in fuel storage tanks to allow for fuel expansion
and to prevent leakage of fuel from the fuel storage facility.

5.8.5 Flood management

Storm water management of the site should be a key aspect of flood management
on site. All stormwater systems, culverts and waterways should be kept clean to
allow storm water to flow freely.

5.8.6 Accidents on site

Engen Namibia (Pty) Ltd and its contractors shall comply with the Occupational
Health and Safety Act and any other national, regional or local regulations with
regard to safety on site. The Contractor shall ensure that contact details of the
local medical services are available to the relevant construction personnel prior
to commencing works

5.8.7 Emergency advisory procedures

Contractors shall ensure that there is an emergency advisory procedure on site
before commencing any operations that may cause damage to the environment.
The Contractor shall also ensure that site staffs are familiar with all emergency
procedures to be followed.

The Contractor shall ensure that lists of all emergency telephone

numbers/contact people are kept up to date, and that all numbers and names are
posted at the construction site at all times

18
6. MANAGEMENT OF ENVIRONMENTAL ASPECTS DURING OPERATIONAL
AND MAINTANANCE ACTIVITIES

This section will look at the potential environmental impacts, which may arise during the
operational phase of the Keetmanshoop Engen fuel storage facility. The impacts associated
with maintenance activities and possible site decommissioning is similar to construction
activities.

Groundwater

Maintenance/Decommissioning phase
Description Groundwater contamination can be caused by leakages and spills
of petroleum products (i.e. oil leakages, hydrocarbon fuel,
lubricants and grease) from machinery and equipment during
maintenance and possible decommissioning activities. Care must
be taken to avoid contamination of soil and groundwater.
Proposed Mitigation Prevent spillages of any chemicals and petroleum
Measures products (i.e. oils, lubricants, petrol and diesel). Use drip
trays, linings or concrete floors when evidence of leaks
are observed on vehicles or equipment.
No servicing and maintenance of vehicles and/or
equipment should be conducted at the site.
Existing ablution facilities at the site should be used. No
urinating outside these designated facilities shall be
allowed.
Proper environmental awareness and remedial response
training of operators must be conducted on a regular
basis.
Proposed Monitoring Regular visual inspection.

Responsible Party Engen Namibia (Pty) Ltd / Contractors.

19
 Operational phase

Description Groundwater quality could be impacted through leachate of oil

leakages, hydrocarbon fuel, lubricants and grease from road and
rail fuel tankers; and vehicles frequenting the facility. Spillages
may also occur during fuel delivery to the aboveground storage
tanks from road and rail fuel tankers. This may also take place
when dispensing fuel to road transport tankers. Care must be
taken to avoid contamination of soil and groundwater.
Proposed Mitigation All operational surfaces and fuel storage facilities must be
Measures installed with spill containment areas as per the relevant
SANS standards (or better). Special emphasis is placed on
SANS 10089:1999, SANS 100131:1977, SANS
100131:1979, SANS 100131:1982, SANS 100131:1999.
Proper monitoring of the product levels must take place
to eliminate overfilling.
Ensure that any petroleum products, such as grease,
waste oils and lubricants are contained in containment
structures (e.g. plastic liners, drip trays etc.).
Avoid discharge of pollutants (such as cement, concrete,
lime, chemicals, contaminated waste water or leachate)
into stormwater channels and water courses.
Equipment and materials to deal with spill cleanup must
be readily available on site and staff must be trained as to
how to use the equipment and briefed about reporting
procedures.
Develop and implement a groundwater monitoring
system and programme, with the aim of monitoring
possible contamination to the water resources.
Groundwater monitoring boreholes installed should be
sampled and analysed periodically.
Regular tank and pipeline tightness inspections are
advised to eliminate the risk of impact on the
environment due to leakage.
The condition of the fuel reticulation system will have to
be checked regularly and repaired to prevent leakages;
Proposed Monitoring Regular visual inspection.
Responsible Party Engen Namibia (Pty) Ltd

20
Surface Water

Maintenance/Decommissioning phase
Description Drainage in the area is well developed and run-off takes place to
the south. The relief of significant small dry river courses
(streams) running in the area remain relevant, and contribute
well to the drainage of surface run-off in the area.
Contaminants in the form of oil leakages, diesel, lubricants and
grease from the vehicles, machinery and equipment may occur
during maintenance and possible decommissioning activities. Oil
spills are known to form a film on water surfaces causing physical
damage to organisms. Oxygen transfer could be impaired.
Care must be taken to avoid contamination of soil and any surface
water bodies in the area.
Proposed Mitigation Any spillage of hazardous substances including fuel, oil,
Measures paint or cleaning solvent must be cleaned up and
disposed off at the designated disposal facility.
Use drip trays, linings or concrete floors when evidence of
leaks are observed on vehicles or equipment.
Prevent discharge of any pollutants, such as cements,
concrete, lime, chemicals, and hydrocarbons into nearby
water ways and courses.
Contain contaminated water from batching operations
and allow sediments to settle before being disposed of as
waste water.
Stabilise cleared areas as soon as possible to prevent and
control surface erosion.
Existing ablution facilities at the site should be used. No
urinating outside these designated facilities will be
allowed.
Proper environmental awareness and remedial response
training of operators must be conducted on a regular
basis.
An emergency plan should be in place on how to deal
with spillages and leakages during construction activities.
Proposed Monitoring Regular visual inspection. Surface water quality monitoring in
cases of evident pollution.
Responsible Party Engen Namibia (Pty) Ltd / Contractors.

21
 Operational phase

Description Spillages might occur during fuel delivery to the aboveground

storage tanks from road and rail transport tankers. This may also
occur during filling of road transport tanker trucks.
Spillages and/or leakages of various possible contaminants might
occur due to failure of reticulation pipelines or storage tanks.
Contaminated soil might pose a risk to surface water.
Proposed Mitigation Proper containment mechanisms installed should be able
Measures to contain any spillages that might occur during the
operation of the facility.
All spills should be cleaned up as soon as possible.
The presence of an emergency response plan and suitable
equipment is advised, so as to react to any spillage or
leakages properly and efficiently.
Ensure all stormwater drains or channels are clear of
litter or obstructing material.
Remove all excess sedimentation, rubble and any other
waste material present in the waterway and dispose of in
a suitable manner to ensure proper drainage runoff.
Proposed Monitoring Regular visual inspection. Surface water monitoring sampling for
hydrocarbon pollution.
Responsible Party Engen Namibia (Pty) Ltd

Air quality (including dust)

Air Quality (Dust Pollution)

Maintenance/Decommissioning phase
Description Dust may be produced during maintenance and
decommissioning activities; and might be worsened when
strong winds occur. These are expected to be site specific and
` could potentially pose a slight nuisance to the neighbouring
properties.
Possible air pollution in the form of emissions from
maintenance vehicles and machinery could also deteriorate air
quality in the area. This is especially true for construction
vehicles during decommissioning of the site.
Proposed Mitigation It must be ensured that all vehicles entering the site and
Measures machinery used in maintenance and possible
decommissioning activities are in good working order to
prevent unnecessary emissions.
Encourage reduction of engine idling at the project site.
Excavation, handling and transport of materials must be
avoided under high wind conditions.
Dust suppression measures (e.g. dampening with water)
may be required from time to time, should dust become
a nuisance.
Proposed Monitoring Regular visual inspection.
Responsible Party Engen Namibia (Pty) Ltd / Contractors.

22
 Operational phase

Description Air quality around the site could be impacted by exhaust fumes
from road and rail fuel tankers accessing the facility.
Hydrocarbon vapours will be released during delivery and
dispensing, as liquid displaces the gaseous mixture in the
tanks.
In terms of fuel storage tanks, the vapours will be released
through vent pipes on the tanks.
Proposed Mitigation Measures Vehicle idling time shall be minimised by putting up
educative signs.
All venting systems and procedures have to be
designed according to SANS standards (SANS
1929:2011) and placed in a sensible manner.
Vent pipes should be placed in such a manner as to
prevent impact on potential receptors. Use vapour
recovery equipment and techniques to avoid air
pollution and minimise fuel loss.
Proposed Monitoring It is recommended that regular air quality monitoring be
conducted at the facility. A complaints register regarding
emissions/smell should be kept and acted on if it becomes a
regular complaint.
Responsible Body Engen Namibia (Pty) Ltd

Health and Safety

Maintenance/Decommissioning phase
Description Safety issues could arise from the vehicles, equipment and
tools that will be used during maintenance and possible
decommissioning activities. This increases the possibility of
injuries and the contractor must ensure that all staff members
are made aware of the potential risks of injuries on site.
Proposed Mitigation Measures All vehicles, equipment and tools operators shall be
equipped with proper and adequate personal
protective equipment gear.
Maintenance operations should be strictly between
07H00 to 17H00. First aid and safety awareness
training for contractors.
Ensure the general safety and security at all times by
providing day and night security guards and adequate
lighting within and around the premises.
The facility must be properly fenced off to prevent
unauthorised persons from accessing the site, who
could get injured on site.
Proposed Monitoring Safety procedures evaluation. Health and safety incident
monitoring.

Responsible Party Engen Namibia (Pty) Ltd / Contractors.

23
 Operational phase

Description The operations of the fuel storage facility can cause health and
safety risks to workers on site. Occupational exposures are
normally related to inhalation of fuel vapours and physical
contact with fuels.
Proposed Mitigation Measures Ensure the general safety and security at all times by
providing day and night security guards and adequate
lighting within and around the premises.
All personnel and operators at the fuel depot must be
properly trained on safety and health issues of the
facility.
Well stocked first aid box which is readily available
and accessible should be provided within premises.
’NO SMOKING’ signs must be prominently displayed at
the premises.
Workers should be fully equipped with personal
protective equipment gear.
Proposed Monitoring Regular inspection and incident monitoring report evaluation.
Responsible Body Engen Namibia (Pty) Ltd

Noise Pollution

Maintenance/Decommissioning phase

Description Noise pollution exists due to vehicles frequenting the site.

Vehicles and equipment will be utilised during maintenance
and possible decommissioning activities and noise would be
generated. It is expected that the noise generated will not have
a significant impact on any third parties.
Proposed Mitigation Sensitize vehicle and machinery operators to switch
Measures off engines of vehicles or machinery not being used.
Ensure vehicles and equipment to be used at the
facility are fitted with mufflers.
Equipment and machinery operators should be
equipped with ear protection equipment.
Audio equipment (if any) should not be played at
levels considered intrusive by others.
Operations should be strictly between 07H00 to
17H00.
Proposed Monitoring Strict operational times. Regular inspection.

Responsible Party Engen Namibia (Pty) Ltd / Contractors.

24
 Operational phase

Description Noise pollution may be generated by vehicles, trucks and

people frequenting the site.
Proposed Mitigation Measures Delivery of fuel products by road and rail tankers
should be limited to normal working hours (07h00 to
17h00).
Loud music from any vehicles and/or trucks accessing
the site should be restricted.
Maintain the grievance mechanism to capture public
perceptions and complaints with regard to noise
impacts, track investigation actions and introduce
corrective measures for continuous improvement.
Proposed Monitoring Strict delivery and collection times. Observation of on-site
noise levels.
Responsible Body Engen Namibia (Pty) Ltd

Waste Generation
Maintenance/Decommissioning phase
Description This can be in a form of contaminated soil, building rubble,
pipe cuttings, electrical cuttings, oil spills or leakages of
petroleum products.
Proposed Mitigation Ensure that no excavated soil, refuse or building
Measures rubble generated on site are placed, dumped or
deposited on adjacent/surrounding properties or land.
Ensure that sufficient weather- proof bins / containers
are present at the facility for the disposal of waste.
The Contractor shall institute a waste control and
removal system for the site. All waste shall be disposed
off site at an approved landfill site.
No burning and/or burying of waste on site shall be
allowed.
Hazardous waste storage is to be clearly marked to
indicate the presence of hazardous substances, and the
protocols associated with handling of such hazardous
wastes shall be known by all relevant staff members.
Existing ablution facilities at the site shall be used by
all contractors. No urinating outside these designated
facilities.
Proposed Monitoring Regular inspection and housekeeping procedure monitoring.
Observation of site appearance.
Responsible Party Engen Namibia (Pty) Ltd / Contractors.

25
 Operational phase

Description Waste such as contaminated soil, litter, empty drums and cans
of petroleum product will be generated during the operational
phase.
Proposed Mitigation Measures Contaminated soil must be removed and disposed off
at a suitable waste disposal site.
Waste bins must be available at the fuel storage facility
at all times. Waste must be appropriately collected and
disposed off at an approved appropriate waste
disposal site.
Oil-water separator effluent originating from storm
water runoff, tank bottoms and washing activities
should be separated before disposal of the water.
Regular monitoring of the oil-water separator outflow
must be conducted. Water containing soaps and other
detergents must not enter the oil water separator as it
will place the hydrocarbons in suspension, rendering
the oil water separator ineffective.
Care should be taken when handling contaminated
material. The cradle to grave principal should be kept
in mind during waste disposal.
Any non-biodegradable hazardous material (i.e. oil
cans and containers etc.) generated should be properly
stored in containment structures, collected and
transported to the nearest approved hazardous waste
disposal facility.
Proposed Monitoring Regular visual inspection. Containment area inspections and
monitoring of the oil/water separators.
Responsible Body Engen Namibia (Pty) Ltd
Traffic

Operational phase
Description The site is situated in Swartmodder Street, in Keetmanshoop.
Slow traffic (trucks) frequenting the facility may become a
nuisance to motorists accessing neighbouring properties.
Proposed Mitigation Measures Delivery of fuel products by heavy-duty tankers should
be limited to normal working hours (07h00 to 17h00).
Proposed Monitoring Strict delivery times monitoring.
Responsible Body Engen Namibia (Pty) Ltd / Contractors.

26
Ecological impacts

Maintenance/Decommissioning phase
Description The site is within an urban setting and entirely build-up. No
known conservation worthy vegetation exists at the facility.
Proposed Mitigation Disturbance of areas outside the designated boundary
Measures of the fuel depot is not allowed.
No vegetation should be removed outside the
designated fuel depot area.
Proposed Monitoring Regular site inspection.
Responsible Party Engen Namibia (Pty) Ltd / Contractors.

Operational phase
Description The proposed facility operations will have minimal impacts
the fauna and flora.
Proposed Mitigation Measures The operational activities would not exceed the
demarcated area of the fuel storage facility.
Proposed Monitoring Regular site inspection.
Responsible Body Engen Namibia (Pty) Ltd

Overfilling of tanks, fuel tankers and vehicles

Operational phase
Description Overfilling of aboveground storage tanks; and/or road
transport tankers may take place.
Proposed Mitigation Measures This impact can be reduced by the installation of
proper spill containment systems around the tank
farm and gantry.
Proper training of the operators.
Proper monitoring of the product levels in the tanks
must take place to eliminate overfilling.
Proposed Monitoring Regular inspection of the level of fuel in tanks.
Responsible Body Engen Namibia (Pty) Ltd / Contractors.

27
Visual / Nuisance Impacts
Maintenance/Decommissioning phase
Description Aesthetics and inconvenience caused to person trying to
access/exit the site, and surrounding areas.
Proposed Mitigation Measures Contractor should maintain tidiness on site at all
times. Take cognition when parking vehicles and
placing equipment.
Workers should be attentive to the importance of not
littering. Littering is unsightly and has a negative
visual impact.
Sufficient waste bins must be provided onsite and
must be emptied regularly.
Proposed Monitoring Regular visual site inspection.
Responsible Party Engen Namibia (Pty) Ltd / Contractors.

Fire and explosion hazard

Operational phase
Description Hydrocarbons are volatile under certain conditions and their
vapours in specific concentrations and conditions are
flammable.
Proposed Mitigation Measures There should be sufficient water available for fire
fighting purposes.
Ensure that all fire-fighting devices are in good
working order and they are serviced.
All personnel have to be trained about responsible
fire protection measures and good housekeeping
such as the removal of flammable materials on site.
Proposed Monitoring Regular inspections should be carried out to inspect and test
fire fighting equipment.
Responsible Body Engen Namibia (Pty) Ltd

28
7. CONCLUSIONS
If the above-mentioned management recommendations are properly implemented, it is anticipated
that most of the adverse impacts on the environment can be mitigated. An appointed environmental
control officer will need to monitor or audit the site throughout operation and possible
decommissioning phase to ensure that the EMP is fully implemented and complied with. The EMP
caters for operational and maintenance phases (including possible decommissioning), but will need
to be reviewed during all phases of the project, especially when revisions are made to the
development and/or operations of the facility.
The Environmental Management Plan should be used as an on-site tool during all phases of the
development. Parties responsible for contravention of the EMP should be held responsible for any
rehabilitation that may need to be undertaken.
Clearance certificates issued on EMPs are only valid for 3 years and will need to be reviewed and
submitted to the Department of Environmental Affairs again for approval.

Matrix Consulting Services

M. Shippiki
Hydrogeologist / Environmental Practitioner
November 2019

This document is for the use of Shell Namibia Ltd only and may not be transmitted to any other party, in whole or in part, in any form without
written consent permission of Matrix Consulting Services