CONSTRUCTION AND OPERATIONAL ACTIVITIES OF THE …eia.met.gov.na/screening/235_20190417F_EIA Scoping...

CONSTRUCTION AND OPERATIONAL ACTIVITIES OF THE

HANGANA SEAFOOD FISH PROCESSING FACILITY, WALVIS

BAY

UPDATED ENVIRONMENTAL ASSESSMENT SCOPING REPORT

Assessed by: Assessed for:

April 2019

EXECUTIVE SUMMARY Geo Pollution Technologies (Pty) Ltd was appointed by Hangana Seafood (Pty) Ltd to update their

existing Environmental Impact Assessment (EIA) for their fish processing facility in Walvis Bay. The

update aims at including the existing operations and proposed construction activities of Hangana

Seafood. Existing operations include the processing of fish in the existing wet fish factory and added

value factory, service hub operations (berthing, launching, storage, jetty, quay, etc.), extraction of

seawater and disposal of brine and process water into the harbour, pest control activities, and food retail

activities. The site currently also operates a microbiological laboratory, a clinic, and various stores and

technical workshops. Additional activities undertaken on site by joint ventures and third parties include

fishmeal operations, the recycling of waste oil to produce light fuel oil (LFO) for boiler operations,

waste storage and sorting, bulk fuel storage and dispensing.

Proposed construction activities include the demolition of some existing infrastructure and the

construction of a new wet fish processing plant and related support infrastructure. Support infrastructure

include an industrial cold storage facility, a refrigeration plant, a truck / container loading bay, storage

facilities for consumables, chemicals packaging and spare, a wash bay for tubs, bins, pallets and other

utensils, a microbiological laboratory, a clinic, ablutions, and administrative offices and conference

facilities.

Current and future operational activities are typical of fish processing facilities in Walvis Bay. This

include fish receipt, handling, processing, packaging and storage, as well as fish meal production.

This study is conducted to determine all environmental, safety, health and socio-economic impacts

associated with Hangana Seafood. Relevant environmental data has been compiled by making use of

secondary data and from a reconnaissance site visit. Potential environmental impacts and associated

social impacts will be identified and addressed in this report.

The facility is within an industrial area in the Fishing Harbour of Walvis Bay and is surrounded by

similar industry. Due to the nature and location of the development, impacts can however be expected

on the surrounding environment, see summary impacts table below. It is recommended that regular

environmental performance monitoring continue and be adapted as the project develops, to ensure

compliance and that corrective measures be taken if necessary.

The fishing industry is one of the major contributors to the Namibian economy and provides

employment to a large number of people. The existing operations and proposed new factory at Hangana

Seafood will contribute to the local economy by increasing productivity and value addition, through

increased and continued employment, and by providing opportunities for diversification of economic

activity. By appointing local contractors and employees and implementing educational programs, the

positive socio-economic impacts can be maximised while mitigating any negative impacts.

The major concerns related to the construction and operational activities at the Hangana Seafood

premises are that of health and safety, air quality, waste production and surface water impacts. All

relevant local regulations and internationally accepted best practices should be adhered to, as it pertains

to the management of health and safety risks to employees and contractors on site. Noise pollution

should at all times meet the minimum World Health Organization requirements to prevent hearing loss

and not to cause a nuisance to nearby receptors. Water contaminated by pollutants that can no longer

be disposed of in the normal effluent disposal streams, and any other waste products, must be prevented

from entering the ocean at all costs and should be disposed of appropriately. Any waste produced must

be removed from site and disposed of in an appropriate way or re-used or recycled where possible.

Hazardous waste must be disposed of by a registered service provider and at an approved hazardous

waste disposal site. An emergency response plan must be implemented in the event of major system

failures.

The Environmental Management Plan should be used as an on-site reference document during

operational activities at the fish factory. This document and its supporting impact assessment, should

be reviewed on a regular basis, in order to ensure that it is still relevant to the activities executed on site.

Parties responsible for transgression of the EMP should be held responsible for any rehabilitation that

may need to be undertaken. Hangana Seafood implements numerous in-house and international policies

and standards to ensure protection of health, safety environment and quality. These include various a

group environmental management system, various management standards, a Corporate Social

Responsibility (CSR) strategy, and BRC Global Standards for Food Safety, ISO 22000:2005 and

Hazard Analysis and Critical Control Points (HACCP) 10330. These should be used in conjunction

with the Environmental Management Plan. Operators and responsible personnel must be taught the

contents of these documents.

BE = Biological/Ecological EO = Economical/Operational PC = Physical/Chemical SC = Sociological/Cultural

Impact Category Impact Type Construction Operations

5 5-5 -5

EO Skills, Technology and Development 2 4

EO Revenue Generation and Employment 2 4

SC Demographic Profile and Community Health -1 -2

SC Traffic -2 -2

SC Health, Safety and Security -2 -2

PC Fire -2 -2

PC/SC Air Quality -1 -2

PC Noise -2 -2

PC Waste Production -2 -3

BE Ecosystem and Biodiversity Impact -1 -3

PC/BE Groundwater, Surface Water and Soil Contamination -2 -3

SC Visual Impact -1 2

PC/SC Impacts on Utilities, Infrastructure and Seabed Scouring -3 -2

PC Cumulative Impact -2 -3

Positive Rating Scale: Maximum Value

Negative Rating Scale: Maximum Value

TABLE OF CONTENTS

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

2 SCOPE .......................................................................................................................................................... 2

3 METHODOLOGY ....................................................................................................................................... 3

4 INFRASTRUCTURE AND RELATED ACTIVITIES ............................................................................ 3

CONSTRUCTION OF A NEW FISH FACTORY AND REFURBISHMENT OF THE OLD FACTORY ........................... 4 THE SERVICE HUB ...................................................................................................................................... 5 FRESH FISH FACTORY OPERATIONS ........................................................................................................... 5 ADDED VALUE FACTORY ........................................................................................................................... 9 FLAKE ICE PLANT ....................................................................................................................................... 9 SHOP, KITCHEN AND CANTEEN .................................................................................................................. 9 AUXILIARY OPERATIONS............................................................................................................................ 9 COMPRESSOR ROOM AND COOLING TOWERS ........................................................................................... 10 TRANSFORMERS AND CONSUMER FUEL INSTALLATION ........................................................................... 11

FISHMEAL PLANT ..................................................................................................................................... 12 OIL RECYCLING PLANT ............................................................................................................................ 14 BOILER ROOM .......................................................................................................................................... 15 WATER USAGE AND WASTE WATER DISPOSAL ....................................................................................... 16

Seawater Treatment Plant .............................................................................................................. 16 Desalination Plant .......................................................................................................................... 18 Wastewater Treatment at the Hangana Seafood Fish Factory ....................................................... 22 Wastewater Treatment at the Fishmeal Plant ................................................................................. 23

FISHMEAL PLANT AIR QUALITY MANAGEMENT ...................................................................................... 24 EMPLOYMENT .......................................................................................................................................... 24 WASTE HANDLING ................................................................................................................................... 24 GENERAL OPERATIONAL ACTIVITIES ....................................................................................................... 24

5 ADMINISTRATIVE, LEGAL AND POLICY REQUIREMENTS ...................................................... 25

6 ENVIRONMENTAL CHARACTERISTICS .......................................................................................... 29

LOCALITY AND SURROUNDING LAND USE ............................................................................................... 29 CLIMATE .................................................................................................................................................. 31 CORROSIVE ENVIRONMENT ...................................................................................................................... 32 TOPOGRAPHY AND DRAINAGE ................................................................................................................. 33 GEOLOGY AND HYDROGEOLOGY ............................................................................................................. 34 SURFACE WATER ..................................................................................................................................... 34 PUBLIC WATER SUPPLY ........................................................................................................................... 34 FAUNA AND FLORA .................................................................................................................................. 35 AQUATIC ENVIRONMENT - CURRENTS AND TIDES ................................................................................... 35

AQUATIC ENVIRONMENT - WATER AND SEDIMENT QUALITY .................................................................. 37 DEMOGRAPHIC AND ECONOMIC CHARACTERISTICS ................................................................................. 42 CULTURAL, HERITAGE AND ARCHAEOLOGICAL ASPECTS ........................................................................ 43

7 PUBLIC CONSULTATION ..................................................................................................................... 43

8 MAJOR IDENTIFIED IMPACTS ........................................................................................................... 43

HEALTH AND SAFETY IMPACTS ................................................................................................................ 43 FIRE AND EXPLOSION ............................................................................................................................... 44 WASTE PRODUCTION ............................................................................................................................... 44 NOISE IMPACTS ........................................................................................................................................ 44 AIR QUALITY IMPACT .............................................................................................................................. 44 TRAFFIC IMPACTS .................................................................................................................................... 44 SURFACE WATER CONTAMINATION ......................................................................................................... 44 IMPACT OF LIGHTING ON BIRDS ............................................................................................................... 45 SOCIO-ECONOMIC IMPACTS ..................................................................................................................... 45

9 ASSESSMENT AND MANAGEMENT OF IMPACTS ......................................................................... 45

RISK ASSESSMENT AND ENVIRONMENTAL MANAGEMENT PLAN ............................................................. 46

Planning .......................................................................................................................................... 47 Skills, Technology and Development .............................................................................................. 48 Revenue Generation and Employment ............................................................................................ 49 Demographic Profile and Community Health ................................................................................ 50 Traffic ............................................................................................................................................. 51 Health, Safety and Security ............................................................................................................. 52 Fire ................................................................................................................................................. 54 Air Quality ...................................................................................................................................... 56 Noise ............................................................................................................................................... 57 Waste Production ............................................................................................................................ 58 Ecosystem and Biodiversity Impact ................................................................................................ 59 Groundwater, Surface Water and Soil Contamination ................................................................... 60 Visual Impact .................................................................................................................................. 62 Impacts on Utilities, Infrastructure and Seabed Scouring .............................................................. 63 Cumulative Impact .......................................................................................................................... 65

DECOMMISSIONING AND REHABILITATION .............................................................................................. 66 ENVIRONMENTAL MANAGEMENT SYSTEM ............................................................................................... 66

10 ALTERNATIVES TO THE PROJECT................................................................................................... 66

11 CONCLUSION ........................................................................................................................................... 67

12 REFERENCES ........................................................................................................................................... 68

LIST OF APPENDICES

APPENDIX A: PROOF OF PUBLIC CONSULTATION ................................................................................. 69 APPENDIX B: PROPONENT PERMITS ...................................................................................................... 74 APPENDIX C: CONSULTANTS’ CURRICULUM VITAE ............................................................................. 85

LIST OF FIGURES FIGURE 1. PROJECT LOCATION ............................................................................................................. 2 FIGURE 2. PROJECT LAYOUT ................................................................................................................ 4 FIGURE 3. LAYOUT OF NEW FISH FACTORY ......................................................................................... 5 FIGURE 4. SEA-BASED WET FISH OPERATIONS .................................................................................... 7 FIGURE 5. PROCESS FLOW OF LAND-BASED WET FISH OPERATIONS .................................................. 8 FIGURE 6. FISHMEAL PLANT AND OIL RECYCLING PLANT LAYOUT ................................................. 13 FIGURE 7. FISHMEAL PROCESSING FLOWCHART ................................................................................ 14 FIGURE 8. OIL RECYCLING PLANT LAYOUT AND TANK LOCATION .................................................. 15 FIGURE 9. SEAWATER TREATMENT FLOW DIAGRAM ........................................................................ 17 FIGURE 10. SEAWATER TREATMENT PLANT LAYOUT ......................................................................... 18 FIGURE 11. DESALINATION FLOW DIAGRAM ...................................................................................... 20 FIGURE 12. DESALINATION PLANT LAYOUT ........................................................................................ 21 FIGURE 13. FACTORY INDUSTRIAL WATER TREATMENT FLOW DIAGRAM ......................................... 23 FIGURE 14. SURROUNDING PROPERTIES .............................................................................................. 29 FIGURE 15. LAND USE ......................................................................................................................... 30 FIGURE 16. MONTHLY AVERAGE RAINFALL ........................................................................................ 31 FIGURE 17. FREQUENCY WIND CHARTS DISPLAYING WIND DATA FOR MEERSIG AREA, WALVIS BAY

(SOURCE: WWW.WEATHERUNDERGROUND.COM) .............................................................. 32 FIGURE 18. COMPARISON OF EBB (TOP) AND FLOOD (BOTTOM) SCENARIOS FOR BEFORE AND AFTER

THE CONSTRUCTION OF THE NEW CONTAINER TERMINAL (SOURCE: HYDRODYNAMIC

MODELLING REPORT OF DMC-CSIR 2010) ...................................................................... 36 FIGURE 19. HISTORIC SEDIMENT ANALYSIS PART 1 (BOTHA 2011) .................................................... 39 FIGURE 20. HISTORIC SEDIMENT ANALYSIS PART 2 (BOTHA 2011) .................................................... 40 FIGURE 21. WATER SAMPLING SITES FOR THE WATER QUALITY MONITORING DONE FOR PREVIOUS

DREDGING ACTIVITIES IN 2010/2011 (BOTHA 2011). ........................................................ 41

FIGURE 22. SAMPLING SITES FOR BIOLOGICAL FLESH .......................................................................... 42

LIST OF PHOTOS PHOTO 1. FILLETING AND SKINNING SECTION ........................................................................................ 6 PHOTO 2. WEIGHING AND PACKING AREA ............................................................................................. 6 PHOTO 3. PLATE FREEZER ....................................................................................................................... 6 PHOTO 4. TUNNEL FREEZER .................................................................................................................... 6 PHOTO 5. METAL DETECTOR .................................................................................................................. 6 PHOTO 6. ON-SITE LABORATORY ............................................................................................................ 6 PHOTO 7. CONSUMER FUEL INSTALLATION .......................................................................................... 12 PHOTO 8. TRANSFORMER ON SITE ........................................................................................................ 12 PHOTO 9. FISHMEAL PLANT .................................................................................................................. 12 PHOTO 10. EVAPORATOR ...................................................................................................................... 12 PHOTO 11. OLD OIL TANKS .................................................................................................................. 16 PHOTO 12. OIL RECYCLING AND HEATING TANK ................................................................................. 16 PHOTO 13. LFO TANK ........................................................................................................................... 16 PHOTO 14. BOILER ROOM ..................................................................................................................... 16 PHOTO 15. DAF TANKS (SEAWATER TREATMENT) .............................................................................. 19 PHOTO 16. DESALINATION PLANT ........................................................................................................ 19 PHOTO 17. NORTHERN NEIGHBOUR, ABROMA FISHING INDUSTRIES ................................................... 30 PHOTO 18. SOUTHERN NEIGHBOUR, NOVANAM .................................................................................. 30

LIST OF TABLES TABLE 1. LIST OF PESTICIDES ........................................................................................................... 10 TABLE 2. LIST OF CHEMICALS USED IN COMPRESSOR ROOMS AND COOLING TOWER .................... 11 TABLE 3. CHEMICALS USED IN BOILERS ........................................................................................... 15 TABLE 4. LIST OF CHEMICALS USED AT THE WATER TREATMENT PLANTS .................................... 19 TABLE 5. NAMIBIAN LAW APPLICABLE TO THE FACTORY AND RELATED OPERATIONS. .................. 25 TABLE 6. MUNICIPAL BY-LAWS, GUIDELINES AND REGULATIONS .................................................. 27 TABLE 7. RELEVANT MULTILATERAL ENVIRONMENTAL AGREEMENTS FOR NAMIBIA AND THE

DEVELOPMENT .................................................................................................................. 27 TABLE 8. STANDARDS OR CODES OF PRACTISE ................................................................................ 28 TABLE 9. SUMMARY OF CLIMATE DATA FOR WALVIS BAY (ATLAS OF NAMIBIA) .......................... 31 TABLE 10. AVERAGE ANNUAL CORROSION RATE FOR VARIOUS METALS IN DIFFERENT LOCATIONS IN

SOUTHERN AFRICA (FROM NICKEL DEVELOPMENT INSTITUTE: STAINLESS STEELS IN

ARCHITECTURE, BUILDING AND CONSTRUCTION. HTTP://WWW.NICKELINSTITUTE.ORG) 32 TABLE 11. THE OCEANOGRAPHIC AND HYDRAULIC CONDITIONS OF THE BAY AND THE SEA (ADAPTED

FROM TRACTEBEL, 1998; COWI, 2003B; DMC-CSIR, 2010). .......................................... 37 TABLE 12. METALS IN SEAWATER MINIMUM AND MAXIMUM CONCENTRATIONS IN 15 SAMPLES

COLLECTED BETWEEN 01 DEC 2010 AND 06 APR 2011 AT W3 (BOTHA 2011). ............... 37 TABLE 13. DEMOGRAPHIC CHARACTERISTICS OF WALVIS BAY, THE ERONGO REGION AND

NATIONALLY (NAMIBIA STATISTICS AGENCY, 2011) ....................................................... 43 TABLE 14. ASSESSMENT CRITERIA ..................................................................................................... 45 TABLE 15. ENVIRONMENTAL CLASSIFICATION (PASTAKIA 1998) ...................................................... 46 TABLE 16. IMPACT SUMMARY CLASS VALUES .................................................................................. 67

LIST OF ABBREVIATIONS

% Percentage

°C Degrees Celsius

AIDS Acquired Immune Deficiency Syndrome

BCLME Benguela Current Large Marine Ecosystem

BE Biological/Ecological

BOD Biological Oxygen Demand

BRC British Retail Consortium

CaCO3 Calcium carbonate

CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora

COD Chemical Oxygen Demand

CSR Corporate Social Responsibility Strategy

DAF Dissolved Air Flotation

DEA Department of Environmental Affairs

DWA Department of Water Affairs

EA Environmental Assessment

EEZ Exclusive Economic Zone

EIA Environmental Impact Assessment

EMA Environmental Management Act No 7 of 2007

EMP Environmental Management Plan

EMS Environmental Management System

EO Economic/Operational

ES Environmental Classification

FMP Fish Meal Plant

GPT Geo Pollution Technologies

HACCP Hazard Analysis and Critical Control Points ()

HIV Human Immunodeficiency Virus

HSEQ Health, Safety, Environment and Quality

IAPs Interested and Affected Parties

IQF Individually Quick Frozen

ISO International Organization for Standardization

IUCN International Union for Conservation of Nature

kVA Kilovolt-ampere

LFO Light Fuel Oil

LNAPL Light Non-Aqueous Phase Liquids

m/s Meter per second

m2 Square meter

m3 Cubic meter

mbs Meters below surface

MET Ministry of Environment and Tourism

mm/a Millimetres per annum

MSDS Material Safety Data Sheet

N Nitrogen

NaCl Sodium chloride

NaOCl Sodium Hypochlorite

NH3 Ammonia

PC Physical/Chemical

PCB Polychlorinated Biphenyl

PPE Personal Protective Equipment

ppm Parts per million

SANS South African National Standards

SC Sociological/Cultural

SO2 Sulfur dioxide

STPP Sodium Tripoly Phosphate

WHO World Health Organization

GLOSSARY OF TERMS

Alternatives - A possible course of action, in place of another, that would meet the same purpose

and need but which would avoid or minimize negative impacts or enhance project benefits. These

can include alternative locations/sites, routes, layouts, processes, designs, schedules and/or inputs.

The “no-go” alternative constitutes the ‘without project’ option and provides a benchmark against

which to evaluate changes; development should result in net benefit to society and should avoid

undesirable negative impacts.

Assessment - The process of collecting, organising, analysing, interpreting and communicating

information relevant to decision making.

Competent Authority - means a body or person empowered under the local authorities act or

Environmental Management Act to enforce the rule of law.

Construction - means the building, erection or modification of a facility, structure or infrastructure

that is necessary for the undertaking of an activity, including the modification, alteration, upgrading

or decommissioning of such facility, structure or infrastructure.

Cumulative Impacts - in relation to an activity, means the impact of an activity that in itself may

not be significant but may become significant when added to the existing and potential impacts

eventuating from similar or diverse activities or undertakings in the area.

Environment - As defined in the Environmental Assessment Policy and Environmental Management

Act - “land, water and air; all organic and inorganic matter and living organisms as well as biological

diversity; the interacting natural systems that include components referred to in sub-paragraphs, the

human environment insofar as it represents archaeological, aesthetic, cultural, historic, economic,

palaeontological or social values”.

Environmental Impact Assessment (EIA) - process of assessment of the effects of a development

on the environment and can also be considered / defined as an environmental risk assessment.

Environmental Management Plan (EMP) - A working document on environmental and socio-

economic mitigation measures, inclusive of health & safety of employees, which must be

implemented by several responsible parties during all the phases of the proposed project.

Environmental Management System (EMS) - An Environment Management System, or EMS, is

a comprehensive approach to managing environmental issues, integrating environment-oriented

thinking into every aspect of business management. An EMS ensures environmental considerations

are a priority, along with other concerns such as costs, product quality, investments, PR productivity

and strategic planning. An EMS generally makes a positive impact on a company’s bottom line. It

increases efficiency and focuses on customer needs and marketplace conditions, improving both the

company’s financial and environmental performance. By using an EMS to convert environmental

problems into commercial opportunities, companies usually become more competitive.

Evaluation – means the process of ascertaining the relative importance or significance of

information, the light of people’s values, preference and judgements in order to make a decision.

Hazard - Anything that has the potential to cause damage to life, property and/or the environment.

The hazard of a particular material or installation is constant; that is, it would present the same hazard

wherever it was present. It can also be referred to as a risk.

Interested and Affected Party (IAP) - any person, group of persons or organisation interested in,

or affected by an activity; and any organ of state that may have jurisdiction over any aspect of the

activity.

Mitigate - The implementation of practical measures to reduce adverse impacts.

Proponent (Applicant) - Any person who has submitted or intends to submit an application for an

authorisation, as legislated by the Environmental Management Act no. 7 of 2007, to undertake an

activity or activities identified as a listed activity or listed activities; or in any other notice published

by the Minister or Ministry of Environment & Tourism.

Public - Citizens who have diverse cultural, educational, political and socio-economic

characteristics. The public is not a homogeneous and unified group of people with a set of agreed

common interests and aims. There is no single public. There are a number of publics, some of whom

may emerge at any time during the process depending on their particular concerns and the issues

involved.

Scoping Process - process of identifying: issues that will be relevant for consideration of the

application; the potential environmental impacts of the proposed activity; and alternatives to the

proposed activity that are feasible and reasonable.

Significant Effect/Impact - means an impact that by its magnitude, duration, intensity or probability

of occurrence may have a notable effect on one or more aspects of the environment.

Stakeholder Engagement - The process of engagement between stakeholders (the proponent,

authorities and IAPs) during the planning, assessment, implementation and/or management of

proposals or activities. The level of stakeholder engagement varies depending on the nature of the

proposal or activity as well as the level of commitment by stakeholders to the process. Stakeholder

engagement can therefore be described by a spectrum or continuum of increasing levels of

engagement in the decision-making process. The term is considered to be more appropriate than the

term “public participation”.

Stakeholders - A sub-group of the public whose interests may be positively or negatively affected

by a proposal or activity and/or who are concerned with a proposal or activity and its consequences.

The term therefore includes the proponent, authorities (both the lead authority and other authorities)

and all interested and affected parties (IAPs). The principle that environmental consultants and

stakeholder engagement practitioners should be independent and unbiased excludes these groups

from being considered stakeholders.

Sustainable Development - “Development that meets the needs of the current generation without

compromising the ability of future generations to meet their own needs and aspirations” – the

definition of the World Commission on Environment and Development (1987). “Improving the

quality of human life while living within the carrying capacity of supporting ecosystems” – the

definition given in a publication called “Caring for the Earth: A Strategy for Sustainable Living” by

the International Union for Conservation of Nature (IUCN), the United Nations Environment

Programme and the World Wide Fund for Nature (1991).

1 BACKGROUND AND INTRODUCTION Geo Pollution Technologies (Pty) Ltd was appointed by Hangana Seafood (Pty) Ltd to update their

existing Environmental Impact Assessment (EIA) for their fish processing facility in Walvis Bay. The

update aims at including the existing operations and proposed construction activities of a new factory

at Hangana Seafood. The facility is located on erven 4606, 3691, 13B, 3692 and 14B in Ben Amathila,

Street in the industrial area of Walvis Bay. The main activities covered in the EIA are the construction

and operations of the new factory and the operations of the service hub, current fish processing facilities,

fishmeal plant, consumer fuel installation, oil recycling facility, fish shop, seawater treatment and

desalination plants, microbiology laboratory, on-site clinic, pest controllers, and the operations of the

waste storage and sorting site. More detail on construction and operational processes are provided in

Section 4.

A risk assessment was undertaken to determine the potential impact of the construction and operational

phases of the project on the environment. The environment being defined in the Environmental

Assessment Policy and Environmental Management Act as “land, water and air; all organic and

inorganic matter and living organisms as well as biological diversity; the interacting natural systems

that include components referred to in sub-paragraphs, the human environment insofar as it represents

archaeological, aesthetic, cultural, historic, economic, paleontological or social values”.

The updated environmental assessment was conducted to apply for an environmental clearance

certificate in compliance with Namibia’s Environmental Management Act (Act No 7 of 2007). Project

related activities that requires an environmental clearance certificate incudes the operations of the

consumer fuel installation, extraction of seawater, effluent discharge into the harbour, and storage and

recycling of used oil. These activities, along with other activities that could have potential

environmental impacts will be assessed and reported on.

Project Justification – The factory operates within the Walvis Bay harbour, which is one of only two

harbours in Namibia and the main location for the offloading and processing of fish in Namibia. The

fishing industry contributes significantly to the development and economy of Namibia, and remains an

important natural resources. The facility, along with its fishing fleet also create more than 1,400 direct

employment opportunities.

Benefits of the factory include:

Contribution to the food security of Namibia and other SADC countries

Contribution to the economy and export trade of Namibia

Value addition through processing and packaging of fish blocks sourced from the Hangana Seafood

fish factory and / or other fish factories

Processing and value addition to fish offal through production of fishmeal

Employment creation and skills development

Page 1 of 88

Geo Pollution Technologies (Pty) LtdHangana Seafood - EIA - April 2019

Figure 1. Project Location

2 SCOPE Hangana Seafood currently operates a fishing fleet as well as existing land based factories and

associated infrastructure for the processing and distribution of fish. In addition Hangana Seafood will

commission a new, state-of-the-art, fish processing factory and plans to refurbish some of the existing

infrastructure in future. The scope of the environmental assessment is to determine the potential

environmental impacts emanating from the current and future construction and operational activities of

Hangana Seafood at their Walvis Bay facility. Once determined, possible enhancement measures will

be listed for positive impacts while mitigation / preventative measures will be provided for negative

impacts. Relevant environmental data has been compiled by making use of primary data, secondary

data and from a reconnaissance site visit. As per the findings of this scoping report, an environmental

management plan (EMP) was incorporated into this report to be submitted to the Ministry of

Environment and Tourism.

The aims and objectives of this report are to:

1. Determine the potential environmental impacts emanating from the construction of a new facility

and the execution of current and additional operations of Hangana Seafood,

2. Identify a range of controls which could avoid or mitigate the potential adverse impacts to

acceptable levels,

3. Provide additional surety to relevant stakeholders that environmental parameters are adequately

monitored and managed when applying for abstraction / discharge permits,

4. Comply with Namibia’s Environmental Management Act (2007),

5. Provide sufficient information to the Ministry of Environment and Tourism to make an informed

decision regarding all current and proposed activities of Hangana Seafood.

Should the Directorate of Environmental Affairs (DEA) find that the impacts and related mitigation

measures, which have been proposed in this report, are acceptable, the existing environmental clearance

certificate may be amended to include the activities as described in this report. The amended

Page 2 of 88


environmental clearance certificate issued, based on this document, will render it a legally binding

document which should be adhered to. Focus could be placed on Section 9, which includes an EMP for

this project. It should be noted that the assessment process’s aim is not to stop the activity, or any of its

components, but to rather determine its impact and guide sustainable and responsible development as

per the spirit of the EMA.

3 METHODOLOGY The following methods were used to investigate the potential impacts on the social and natural

environment due to the operations of the factory:

1. Baseline information about the site and its surroundings was obtained from existing secondary

information as well as from a reconnaissance site visit.

2. As part of the scoping process to determine potential environmental impacts, interested and affected

parties (IAPs) were consulted about their views, comments and opinions and these are put forward

in this report.

4 INFRASTRUCTURE AND RELATED ACTIVITIES The general layout and location of Hangana Seafood is presented in Figure 2. Hangana Seafood owns

and operates on five adjacent properties, which has been internally divided into three sections, referred

to as Kuiseb, Protea and Consortium. A fresh fish factory, added value factory, a factory shop, one

finger jetty and part quay, refrigeration plant room, cold storage facilities, container storage facilities,

microbiology laboratory, clinic, technical workshops, seawater treatment plant, desalination plant,

water reservoirs, chemical stores, and administrative offices are located on Kuiseb. A fishmeal plant

and associated oil recycling plant, two finger jetties, container storage facilities, administrative offices,

and technical workshops are located on Consortium. A proposed new wet fish processing factory will

be located on Protea, along with the current consumer fuel installation, waste handling facility, ice

making and ice bunkering facilities, and the existing pest control chemical store. Related and supporting

infrastructure for the new factory includes waste water treatment facilities, a new clinic, a new

microbiological laboratory, new cold storage facilities, a loading bay, dry stores (for packaging,

chemicals, consumables and spares), technical workshops, a refrigeration plant room, ablutions, and

administrative offices. Operational procedures of the proposed new factory will be similar to that of the

current factory, although with increased capacity. The following section provides a description of the

infrastructure and their operations as well as some construction activities to be performed.

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Figure 2. Project Layout

CONSTRUCTION OF A NEW FISH FACTORY AND REFURBISHMENT OF THE OLD

FACTORY A new fish factory with factory floor area of 8,000 m2 will be constructed. It will include a cold

store with a capacity for 2,500 pallets. It will furthermore include a loading bay, stores for

packaging, consumables and spares, a technical building, a clinic, human resources department

and ablution facilities. The technical building will host among others the transformers,

generators, electricity distribution room, refrigeration plant room, etc. See Figure 3 for the layout

of the new fish factory.

To make room for the new fish factory, some existing buildings will be demolished. All

demolitions where asbestos is present will be performed by suitably qualified contractors and all

asbestos waste will be handled and disposed of as per the requirements of Namibian regulations.

Once the new factory is operational, the existing factory will be refurbished. The extent of

refurbishment is not know at this stage, and a risk assessment must be conducted prior to any

work being carried out on site. Management principles which should be adhered to during the

refurbishment process, will be defined in the EMP of this assessment.

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Figure 3. Layout of New Fish Factory

THE SERVICE HUB The Service Hub includes three concrete finger jetties, a quay, onshore operational and container

storage areas, as well as a Service Hub office. The Service Hub provides for mooring and

loading/offloading services for fish trawlers (main jetty), renting of berthing space (two

additional jetties), launching services, and renting out storage space for dry and frozen containers.

At the jetties, some general ships maintenance, cleaning, loading and related activities are

performed. For fishing trawlers, this include offloading and disposal of waste, refuelling of

vessels, restocking with food and freshwater supply as well as loading with ice before heading

back to sea. General operations on the jetty also include the operations of cranes, forklifts and

small trucks or vehicles. Support infrastructure on the jetty includes power supply, water supply,

fuel supply and fish offloading infrastructure.

Launching services performed from the Service Hub serves to provide vessels anchored offshore

with supplies, spares and crew changes. Two vessels performing these duties are currently in

service and future plans also include the addition of small craft for tourist excursions.

As part of the general operations, some maintenance dredging of the area surrounding the jetties

may have to be performed. This is to ensure that the water depth remains sufficient to allow the

vessels safe entry and docking. Volumes to be dredged are minimal and dredging will proceed

only if and when required. Dredging is typically conducted with a grab dredger operated from

the jetties. The grab is emptied into tipper trucks parked on the jetty. The truck will remain on

the jetty to allow excess water to drain from the dredged material and back into the sea. Dredged

sediments are then disposed of at the municipal waste handling facility.

FRESH FISH FACTORY OPERATIONS Processing of fish currently takes place in the existing factory. It has the capacity to process

fourteen to fifteen thousand tons of fish per year. Once the new factory is operational all wet fish

processing will move there. The old factory will be refurbished and once complete both factories

will be used for fish processing activities.

Hangana Seafood operates seven wet fish trawlers in the Namibian Exclusive Economic Zone

(EEZ). The fishing vessels have on board processing facilities where the fish caught is headed

and gutted and then kept cold in bins with ice. Trawlers returning from sea with their catch, dock

at the main jetty where fish is offloaded in plastic bins using cranes or conveyors and transported

to a chiller room in the fish factory. From the chiller room, the fish is transported to the automated

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grading and sorting line. Here the fish is graded and sorted according to size and reloaded into

tubs with flake ice and sent to a second chiller room. From the second chiller room, the fish is

loaded onto conveyors and enters the processing line. There the fish is mechanically filleted,

skinned and quality checked. All offal from this process is sent to the fishmeal plant. Filleted fish

is weighed, sorted to size and packed into boxes, liners or plastic trays. The packaged fish either

passes through a plate freezer, spiral freezer or tunnel freezer operating at -35°C. The individual

boxes of frozen fish are then conveyed through a metal detector to ensure no foreign metal objects

accidentally ended up in the product. The packaged fish are then stored in cold rooms, ready for

shipment.

Photo 1. Filleting and Skinning Section

Photo 2. Weighing and Packing Area

Photo 3. Plate Freezer

Photo 4. Tunnel Freezer

Photo 5. Metal Detector

Photo 6. On-site Laboratory

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Figure 4. Sea-based Wet Fish Operations

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Figure 5. Process Flow of Land-based Wet Fish Operations

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ADDED VALUE FACTORY At the added value factory, frozen blocks of filleted fish are processed and re-packaged into

smaller portions. These are boxed and prepared for shipment to various customers. The fish

processed here either comes from the Hangana Seafood factory, or is bought in bulk from other

fish factories. The process involves various steps including cutting, weighing, packaging,

screening and freezing. It currently process about one thousand tons of fish per year, but has the

capacity for four thousand tons per year.

FLAKE ICE PLANT The flake ice plant produces 90 tons of ice per day. The ice is typically used on Hangana

Seafood’s own fishing vessels, but some are also sold to third parties.

SHOP, KITCHEN AND CANTEEN A fish shop selling fish products produced in the factories directly to the public is operational on

site. It has been in operation since 2017. A kitchen, canteen and kiosk, operated by a licensed

external service provider, provides meals and take-away food to the employees of Hangana

Seafood and external clients.

AUXILIARY OPERATIONS Hangana Seafood has an on-site laboratory as well as a clinic. The laboratory is mainly used for

microbial testing of fish, air, water and surface swab samples. Testing is done by means of growth

media in Petri dishes.

The clinic conducts eye tests, hearing tests, pre-placement and routine screenings and medical

checks on food handlers. It provides general medical services and provides onsite treatment for

employees injured while on duty. The clinic further offers a full range of services aimed at

providing education and support to employees with regards to personal and community wellness.

All biohazardous waste from the laboratory and clinic is clearly marked and disposed of

according to regulations and industry accepted standards.

Hangana Seafood also has an in-house pest control service. The Pest Controllers are all trained

and registered with the Ministry of Health and Social Services. Pest control chemicals (Table 1)

are stored on site in an access controlled and ventilated chemical store. Pesticides are diluted and

or mixed inside the Pest Control Chemical Store prior to use on board the vessels, inside the land-

based facilities or on site. All pest control waste is treated as biohazardous waste and is stored

and disposed of in accordance with regulation and industry accepted standards.

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Table 1. List of Pesticides

Product Brand Name Hazard Identification Type

Max force gel Harmful, Harmful to aquatic life Pesticide

Super crack down Harmful to aquatic life Pesticide

Nu Pro Aerosol Flammable, Toxic Pesticide

Fly Zone None Pesticide

Ultra Pro Traps None Pesticide

Goliath Gel Toxic Pesticide

Glue Boards Toxic Pesticide

Racumin Rats & Mouse Wax Blocks Harmful Pesticide

Max force Ants Bait Granules Harmful to aquatic life Pesticide

Quickbayt Spray Fly Bait Harmful to aquatic life Pesticide

Deltakill None Pesticide

Fendona Aquatic toxicity Pesticide

Tempo EW Aquatic toxicity Pesticide

Trapper MC Glue Trap None Pest trap

COMPRESSOR ROOM AND COOLING TOWERS For cooling and freezing purposes, Hangana Seafood has three compressor rooms on site (two

existing and one under construction). All compressors uses ammonia as coolant.

Compressor Room No. 1 is the main compressor room in the existing factory and has three screw

compressors with three cooling towers. It is a single stage vapour-compression refrigeration

system capable of reaching -34 C. Two surge drums are present for separating liquid ammonia

from the vapour phase and recirculating it to the compressor as well as for absorbing surges in

the system. It also has one liquid receiver that contains excess ammonia not in circulation. An

estimated 7 to 8 tons of ammonia is stored and circulated through this system. Compressor Room

No. 1 is used to cool the freezers and chiller rooms in the fish factory.

Compressor Room No. 2 in the added value factory and ice plant has three compressors and also

is a single stage vapour-compression refrigeration system capable of reaching -34 C. However,

only two of the compressors are typically used while the third is only used during the “high stage”

i.e. when operating at reduced capacity. It only has two cooling towers and has two surge drums

and a liquid receiver. Compressor Room No. 2 is mainly used to produce flake ice at a production

capacity of 100 ton/day and it is used to cool the ice room. An estimated 8 to 9 tons of ammonia

is stored and circulated through this system.

Compressor Room No. 3 is under construction as part of the new added value factory and ice

plant. It will have five compressors, with the option of adding a sixth in future, three surge drums,

and a general liquid receiver. It will operate in three different circuits namely:

High Stage -10 C: For general refrigeration of the factory including air conditioning, flow

ice production, unsorted and sorted fish chillers, offal and inorganic waste chillers and loading

bay cooling.

Low Stage -34 C: For the cold store and freezing equipment such as plate freezers.

Low Stage -42 C: For individual quick freezing (IQF) of fish products in spiral or crust

freezers.

An estimated 15 tons of ammonia is stored and circulated through the Compressor Room No. 3

system. The three circuit design improves energy efficiency of the system by allowing for the

allocation of the circuits based on temperature requirements at various stages of operations.

The cooling process generate a significant amount of heat which is cooled by cooling towers. For

Compressor Room No. 1 and 2 a total of five cooling towers, two at the ice room and three at the

factory, is used. Warm air is circulated through the cooling towers where water is used to cool

the air. Each cooling tower contains between 2 and 3 m3 of water. The cooling towers are cleaned

once every three months on a rotational basis. Cooling tower water is dosed with chemicals once

a month by an external consultant to prevent bacterial growth. See Table 1 for a list of chemicals

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used for cooling water dosing. While some of these chemicals are toxic to aquatic environments

in high concentrations, they are sufficiently diluted when added to the cooling towers, to not

present any significant risks.

Compressor Room No. 3 will have two cooling towers with the option to add a third if required.

It will also have heat exchanging technology that aid in the cooling of ammonia and thus reduces

the energy (electricity) needs of the cooling towers.

Table 2. List of Chemicals Used in Compressor Rooms and Cooling Tower

Product Brand Name Hazard Identification Type / Use

Sudbak Biocide & Fungicide

Sudkor 355 Irritant Corrosion & Scale Inhibitor

MOBIL SHC CIBUS 32 HT Flammable Lubricant

OKS 451 Flammable Lubricant

OKS 470 None Lubricant

OKS 471 Flammable Lubricant

OKS 472 Toxic Lubricant

Electrical cleaner 128 None Electrical cleaner

Limex Lime Solvent

Castrol ATF 11 Multivehicle Harmful to aquatic life Transmission Fluid

Tekprol 131 Degreaser Flammable, Toxic Degreaser

Casrol Alpha SP 150 None Lubricant

WD 40 Flammable, Harmful Lubricant

Mechanical vaccum pump oil AV-

30 Lubricant

Compressor Bearing Lub Lubricant

Sudsperse CW Bio-dispersant

Castrol Aircol 299 None Lubricant

Castrol Perfecto XEP 68 None Lubricant

Suniso SL68 Irritant Lubricant

SuperClean Corrosive Condenser cleaner

Depositrol BL6501 Irritant Antiscalant, Biocide

Spectrus NX1164 Corrosive, Harmful to

aquatic life Water-based microbial control agent.

Gargoyle Arctic Oil 300 Irritant Lubricant

R507 Refrigerant Gas Compressed gas Compressed Gas

R407C Refrigerant Gas Compressed gas Compressed Gas

Mycom 68 Refrigeration Oil None Lubricant

CCW 5 Closed Cooling Water

Treatment Harmful, Irritant Cooling water treatment

Ammonia Toxic, Flammable Compressed Gas

Refrigerant Gas R22 None Compressed Gas



TRANSFORMERS AND CONSUMER FUEL INSTALLATION Hangana Seafood currently has five transformers in operation. Two additional transformers will

be added for power supply at the new factory. The existing transformers provide a combined

supply of 4,500 kVA, which will be increased to 9500 kVA with the addition of the two new

transformers. Three of the existing transformers are installed at the current factory (2 x 1,000

kVA, 1 x 1,250 kVA), one at the fish meal plant on Consortium (750 kVA), and one at the fleet

(1 x 500 kVA). The new transformers of 2,500 kVA each, will be installed in dedicated

transformer rooms. The transformers use polychlorinated biphenyl (PCB) free transformer oil.

All the transformers will be sufficiently bunded and any old transformer oil are and will be

discarded as hazardous waste according to its material safety data sheet instructions.

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Hangana Seafood also operates a consumer fuel installation with two 80 m3 above ground storage

tanks. The infrastructure of the consumer fuel installation belongs to Puma Energy. It is used to

supply ships docking at the jetty with diesel. Fuel is reticulated to the jetties via an underground

pipeline. The installation is sufficiently bunded and complies with SANS regulations.

Photo 7. Consumer Fuel Installation

Photo 8. Transformer on Site

FISHMEAL PLANT An existing fishmeal plant is located on Consortium. Fish offal from Hangana Seafood, as well

as other fishing industries in Walvis Bay, is processed into fishmeal at the plant. The plant is

operated by Exigrade Feeds.

Fish offal is received in tubs and / or rocker bins at the receiving area, where the water is drained

from the fish. The drained fish is transported directly to a crusher and then a cooker in the

fishmeal plant (FMP), where the fish is cooked using steam at 95°C to 98°C for 30 minutes. The

steam is generated by a small boiler powered by light fuel oil (LFO). Cooking coagulates the

proteins, ruptures the fat deposits, and liberates oils and physico-chemically bound water. From

the steam cooker, the product is transported over a dewatering conveyor to a thin screw press.

These steps removes water and oil and ensure moisture is reduced to 50%. The water and oil are

in turn transported to a storage tank. From the tank it passes through a decanter to remove any

remaining fish products (fine meal), and then through an oil water separator to remove the fish-

oils. The fine meal and dry pressed product undergoes a drying process by first passing through

a steam dryer and then an air dryer powered by LFO. The fishmeal is then cooled to 30°C and a

quinoline-based antioxidant, ethoxyquin, is added to the dry fishmeal. The final steps in the

production process are grinding and bagging of the meal.

Photo 9. Fishmeal Plant

Photo 10. Evaporator

The water extracted in the oil water separation process, known as stickwater, does contain some

remaining fish material. The stickwater, along with the water drained from the fish at the

beginning of the process, are concentrated by a process of evaporation. The recovered concentrate

is added to the fishmeal production process, while the steam from the evaporator is stored in a

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water tank and re-used in the fishmeal production process. This process of re-using the water and

steam limits the amount of odours released into the environment. Furthermore, odours are kept

to a minimum by only using fresh fish products and ensuring that no contaminants are present.

Figure 6. Fishmeal Plant and Oil Recycling Plant Layout

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Figure 7. Fishmeal Processing Flowchart

OIL RECYCLING PLANT Waste oil from various small industries in Walvis Bay are refined onsite to produce a LFO. The

LFO produced is not for retail purposes, and is only used for boiler and furnace operations at the

fishmeal plant.

All loading and offloading of oil is done on surfaces with adequate spill control. The oil is stored

in bunded tanks before being refined. On site spill control procedures are according to South

African National Standards (SANS). For the recycling process, waste oil is reticulated to a

heating tank where it is slightly heated to decrease its viscosity. The oil then passes through a

micro filter, before being heated to 80°C. A second filtration step follows before the oil enters

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two separators where all remaining sludge and solids are removed. From the separators, the semi-

clean oil passes through two more filters to produce clean LFO, ready for use.

The residual sludge produced is stored in sludge tanks, before being disposed of according to the

regulations and guideline provided in the Certificate of Safe Disposal issued by the Municipality

of Walvis Bay (Appendix B).

Figure 8. Oil Recycling Plant Layout and Tank Location

BOILER ROOM Steam is used during various phases of the fishmeal plant and is produced in a boiler. The boiler

has a maximum steam output capacity of 2,990 kg/h. Municipal or desalinated water, along with

the condensate from the fishmeal plant, are used for boiler operations.

Boiler water is treated to prevent boiler corrosion, scale build-up and boiler carryover. Chemicals

used for water treatment is presented in Table 3. The chemicals are used for alkalinity control to

prevent corrosion, as carbonic acid neutralisers and as oxygen scavengers. Blowdown from the

boiler (the intentional removal of water from the boilers for quality control) is diverted to the

evaporation plant.

Table 3. Chemicals Used in Boilers Product Name Active Ingredient(s) Notes

Cortrol IS3000E Sodium Bisulphite (aqueous) The low concentration of sodium bisulphite in

the mixture of Cortrol has no listed hazard

classification, although the active ingredient is

classified as “harmful if swallowed”. The

reaction of sodium bisulphite in the boiler will

produce sodium bisulphate as waste product.

Sudsteam 80

Sodium Hydroxide (3-5%) Sodium hydroxide is corrosive and an irritant. At

the low concentration present in Sudsteam, these

hazards will be limited, but the product must still

be handled with protective clothing (PPE).

Solus AP-26 Sodium Hydroxide (10-20%) Much more corrosive than Sudsteam. May cause

severe burns and eye damage. Within boilers will

be significantly diluted.

Steamate NA6540 2-Diethylaminoethanol (20-25%)

Morpholine (10-20%)

Corrosive and dermal contact, inhalation or

ingestion should be avoided. Within boilers will

be significantly diluted.

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Photo 11. Old Oil Tanks

Photo 12. Oil Recycling and Heating Tank

Photo 13. LFO Tank

Photo 14. Boiler Room

WATER USAGE AND WASTE WATER DISPOSAL Hangana Seafood has a seawater treatment plant as well as a desalination plant on site, and

therefor uses minimal water from the Municipality of Walvis Bay. Water usage at the fish factory

is mainly for processing, cleaning, ice production, domestic use and garden maintenance. At the

fishmeal plant fresh water usage is mainly for boiler operations and cleaning while seawater is

used for cooling purposes. Hangana Seafood has an existing permit for the abstraction of seawater

(not exceeding 28,000 m3/day), issued by Ministry of Agriculture, Water and Forestry, which is

valid until June 2022. Permits for the abstraction of seawater and disposal of industrial water and

effluent is in the name of Exigrade who operates the fishmeal plant and waste oil recycler. All

permits can be seen in Appendix B. It is expected that current production capacity and water

supply will be able to meet the demands of the new factory, as multiple water saving initiatives

will from part of the design.

Seawater Treatment Plant

Water from the seawater treatment plant is mainly used for cleaning and cooling purposes.

The plant has the capacity to treat 1,500 m3 seawater per day, although current operations only

use around 600 m3 per day. Water extracted from the ocean first passes through a strainer and

then undergoes flocculation by using flocculants to clump fine particles together. From the

flocculation tank water passes to the dissolved air flotation (DAF) plant to remove solids. The

water then passes through a sand filter before being chlorinated with chlorine gas and stored

in tanks. From the storage tanks, the water is sterilised through ultraviolet (UV) treatment,

before being utilised in the factory. Scum resulting from flocculation and DAF treatment, as

well as backwash from the sand filter, flows back into the ocean and adheres to regulations

set forth in the effluent discharge permit (Appendix B).

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Figure 9. Seawater Treatment Flow Diagram

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Figure 10. Seawater Treatment Plant Layout

Desalination Plant

The current potable water demand of Hangana Seafood is estimated at 800 m3 per day. A

desalination plant with a treatment capacity of 400 m3 per day is used to augment the

municipal potable water supply. Seawater for desalination purposes also undergoes

flocculation and DAF treatment to remove larger solids prior to pre-filtration to remove finer

solids such as sand and clay particles. The water then undergoes bag filtration and chemical

dosing before being purified by means of reverse osmosis, a process where the water is forced

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through a semi-permeable membrane. This step removes the salt and other impurities from

the water. The by-product of reverse osmosis is brine with an approximate 60% salt content

which is pumped back into the ocean. The desalinated water is chlorinated and then passes

through a hardener column (CaCO3) to condition the water before being ready for use as

potable water. Water from the desalination plant is mainly used for cleaning, in the cold

storage evaporators (cooling towers), ice production, domestic use and garden maintenance.

Table 4. List of Chemicals used at the Water Treatment Plants

Product Brand Name Hazard Identification Type

Soduim hypochlorite Corrosive, Toxic Water Disinfectant

Hydrochloric Acid Corrosive, Irritant Acid

Ultrafloc Blend U3500 Irritant Flocculant

Hydrex 4102 Irritant Antiscalant

Sodium metabisulphite Irritant Chlorine Removal

Ferric chloride solution Harmful Coagulant

Ethylenediaminetetraacetic acid Irritant, Environmental Pollutant Foulant / Sulfate remover

Sodium Tri Poly Phosphate

(STPP) Irritant Foulant / Sulfate remover

Sodium Hydroxide solution Harmful Alkali

Acetone Harmful Organic Solvent

DPD Free Chlorine Reagent Irritant Laboratory reagent

Sodium Hypochlorite (NaOCl) Corrosive, Toxic, Irritant Disinfectant

Photo 15. DAF Tanks (Seawater

Treatment)

Photo 16. Desalination Plant

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Figure 11. Desalination Flow Diagram

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Figure 12. Desalination Plant Layout

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Wastewater Treatment at the Hangana Seafood Fish Factory

Hangana Seafood has an existing Wastewater Discharge Permit from the Department of Water

Affairs and Forestry, Ministry of Agriculture, Water and Forestry for disposal of effluent into

Municipal sewers as well as disposal of industrial water into the ocean.

All industrial water from the factory forms one discharge stream. The stream contains a

combination of backwash, brine and scum from seawater treatment and desalination, wash

water from the factory and wastewater produced during the transportation and fish sorting

process. Industrial water from the factory collects in sumps, from where it is pumped to a

divider tank fitted with a 1 mm solid screen. The divider separated solids from water. Solids

are collected in skips and transported to the fishmeal plant and the water is discharged into

the ocean. There are two inspection drains in the discharge stream pipeline for water

monitoring purposes.

Industrial water from the new factory will either form part of this stream, or form a new

discharge stream with adequate treatment facilities. Wastewater from the factory will aim at

being the same quality or better at the discharge point, as it was at the abstraction point and

will meet all current permit requirements. Should this not be possible, Hangana Seafood will

apply for a new discharge permit.

Industrial water discharged into the ocean from the factory is analysed monthly for the

following:

Chemical Oxygen Demand (COD)

Free and Saline Ammonia, as N

Total Kjeldahl Nitrogen, as N

Magnesium

Total Dissolved Solids (TDS)

Absorbed Oxygen

Typical Faecal Coliforms

Phosphates

Conductivity

pH

All other wastewater, such as water generated from the canteen, ablutions and cooling towers

are disposed of in the municipal sewer systems according to permit conditions, or collected

by contractors if hazardous substances are potentially present.

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Figure 13. Factory Industrial Water Treatment Flow Diagram

Wastewater Treatment at the Fishmeal Plant

Exigrade has an existing Wastewater Discharge Permit from the Department of Water Affairs

and Forestry, Ministry of Agriculture, Water and Forestry for disposal of industrial water into

the ocean.

All industrial water from the plant forms one discharge stream which passes through a solids

trap. The stream contains a combination of wash water and cooling water from the fishmeal

plant. All water discharged into the ocean meet the standards and regulations as per the permit.

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Industrial water discharged into the ocean from the factory is analysed bi-annually for the

following:

Chemical Oxygen Demand (COD)

Free and Saline Ammonia (N)

Total Kjeldahl Nitrogen

Magnesium

Total Dissolved Solids (TDS)

Absorbed Oxygen

Typical Faecal Coliforms

Phosphates

Conductivity

pH

FISHMEAL PLANT AIR QUALITY MANAGEMENT During various phases in the factory, such as cooking, pressing and drying, low volumes of gas,

with high concentrations of odours will be produced. Other phases such as conveying of fish,

milling, ventilation and cooling may produce high volumes of gas with low concentrations of

odour. The necessary steps are taken to ensure the odours escaping from the factory are kept to a

minimum. This is achieved by ensuring fish is processed as fresh as possible. To reduce odours

and emissions from the fishmeal plant, all vapours produced in the plant passes through the

evaporation plant. No visual vapours (white vapour) is released from the fishmeal plant.

EMPLOYMENT Hangana Seafood employs approximately 1,400 direct employees in various sectors of the

operations. This includes factory operations, fishing vessels and office staff. Additional to this,

services from a number of contractors are utilized, generating more indirect employment

opportunities. The fishmeal and oil recycling plant employs an additional 29 employees.

WASTE HANDLING Hangana Seafood has a waste handling area on site, where Rent-A-Drum sorts and collects waste.

Recyclable waste is sorted and collected for recycling purposes. Solid waste and liquids, as well

as potentially hazardous waste is also collected by Rent-A-Drum and disposed of. The waste

handling area has sufficient surface cover, and is fenced off with a lockable gate. Waste that

could be blown away by wind is stored in covered bins / skips. All biological waste, such as that

produced in the laboratory and clinic is collected and disposed of according to regulations and

industry accepted standards.

All waste generated by pest control procedures (chemical and biological) is strictly handled and

disposed of as hazardous waste.

Waste generated from the oil recycling plant is mainly sludge and old oil filters. The sludge is

disposed of according to the regulations and guideline provided in the Certificate of Safe Disposal

issued by the Municipality of Walvis Bay (Appendix B). Old oil filters are properly drained

before being discarded as hazardous waste.

GENERAL OPERATIONAL ACTIVITIES Daily operations are typical of those of fish processing facilities in Walvis Bay. These include

administrative tasks, on-site security services, cleaning and basic maintenance. When required,

the waste and hazardous waste generated by the factory will be collected by contractors and

disposed of. Sludge and waste generated from the fishmeal and oil recycling plant is also disposed

of at a regular basis. Sufficient firefighting equipment is available at all section of the operations

and regular firefighting drills and maintenance is performed. Strict access control is practiced at

the site.

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5 ADMINISTRATIVE, LEGAL AND POLICY REQUIREMENTS To protect the environment and achieve sustainable development, all projects, plans, programmes and

policies deemed to have adverse impacts on the environment require an environmental assessment, as

per the Namibian legislation. The legislation and standards provided in Table 5 to Table 8 govern the

environmental assessment process in Namibia and/or are relevant to the factory.

Table 5. Namibian Law Applicable to the factory and related operations. Law Key Aspects

The Namibian Constitution Promote the welfare of people

Incorporates a high level of environmental protection

Incorporates international agreements as part of Namibian law.

Environmental Management Act

Act No. 7 of 2007, Government Notice No. 232

of 2007

Defines the environment

Promote sustainable management of the environment and the use of natural resources

Provide a process of assessment and control of activities with possible significant effects on the environment.

Environmental Management Act

Regulations

Government Notice No. 28-30 of 2012

Commencement of the Environmental Management Act

List activities that requires an environmental clearance certificate

Provide Environmental Impact Assessment Regulations.

Lists the “polluter pays principle” as one of the principles of environmental management.

Petroleum Products and Energy Act


of 1990

Regulates petroleum industry

Makes provision for impact assessment

Petroleum Products Regulations (Government Notice No. 155 of 2000)

o Prescribes South African National Standards

(SANS) or equivalents for construction, operation

and decommissioning of petroleum facilities (refer

to Government Notice No. 21 of 2002)

Petroleum Products and Energy Act

Regulations

Government Notice No. 112 of 1991

Regulations relating to the purchase, sale, supply, acquisition, possession, disposal, storage, transportation, recovery and re-refinement of used mineral oil.

The Water Act

Act No. 54 of 1956

Remains in force until the new Water Resources Management Act comes into force

Defines the interests of the state in protecting water resources

Controls the disposal of effluent

Numerous amendments.

Marine Resources Act

Act No. 27 of 2000

Prevents the discharge of anything that may be injurious to marine resources or may disturb ecological balance in any area of the sea or which may detrimentally affect the marketability of marine resources, or which may hinder their harvesting.

The Namibian Ports Authority Act

Act No. 2 of 1994

Provide for the establishment of the Namibian Ports

Authority and its functions

Responsible to protect the environment within its areas of jurisdiction.

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Law Key Aspects

Public Health Act

Act No. 36 of 1919

Provides for the protection of health of all people.

Public and Environmental Health Act


of 2015

Provides a framework for a structured more uniform public and environmental health system, and for incidental matters

Deals with Integrated Waste Management including waste collection disposal and recycling; waste generation and storage; and sanitation.

Labour Act

Act No 11 of 2007, Government Notice No. 236

of 2007

Provides for Labour Law and the protection and safety of employees

Labour Act, 1992: Regulations relating to the health and safety of employees at work (Government Notice No. 156 of 1997).

Atmospheric Pollution Prevention

Ordinance

Ordinance No. 11 of 1976

Governs the control of noxious or offensive gases

Prohibits scheduled process without a registration certificate in a controlled area

Requires best practical means for preventing or reducing the escape into the atmosphere of noxious or offensive gases produced by the scheduled process.

Hazardous Substances Ordinance

Ordinance No. 14 of 1974

Applies to the manufacture, sale, use, disposal and dumping of hazardous substances as well as their import and export

Aims to prevent hazardous substances from causing injury, ill-health or the death of human beings.

Pollution Control and Waste Management

Bill (draft document) Not in force yet

Provides for prevention and control of pollution and waste

Provides for procedures to be followed for licence applications.

Prevention and Combating of Pollution of

the Sea by Oil Amendment Act (No. 24 of

1991)

Amends the Prevention and Combating of Pollution of the Sea by Oil Act of 1981 to be more relevant to Namibia after independence.

Aquaculture Act (2002) Provides for water quality monitoring to protect

aquaculture activities.

Draft Wetland Policy of 2003

Considering the Walvis Bay Lagoon, the Wetland

Policy of 2003 is of importance and includes:

o Protection and Conservation of wetlands and

ecosystems

o As well as, including fulfilling Namibia’s

International obligations to the Ramsar Convention

and the SADC Protocol on Shared Water Systems.

Road Traffic and Transport Act

Act No. 52 of 1999 Government Notice No 282

of 1999

Provides for the control of traffic on public roads and

the regulations pertaining to road transport.

Road Traffic and Transport Regulations

Government Notice No 53 of 2001

Prohibits the transport of goods which are not safely

contained within the body of the vehicle; or securely

fastened to that vehicle, and which are not properly

protected from being dislodged or spilled from that

vehicle.

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Table 6. Municipal By-laws, Guidelines and Regulations Municipal By-laws, Guidelines or

Regulations

Key Aspects

Integrated Urban Spatial Development

Framework for Walvis Bay Completed during 2014 and in the final stages of

acceptance

Overall vision to transform Walvis Bay to being the primary industrial city in Namibia

Aims to ensure that appropriate levels of environmental management is enforced for all developments in Walvis Bay.

Integrated Environmental Policy of

Walvis Bay (Agenda 21 Project) Indicates the directions that the Municipality of

Walvis Bay will move towards in the forthcoming years to fulfil its responsibilities to manage the environment of Walvis Bay together with the town’s residents and institutions

Strong focus on conservation and protection of environment.

Drainage and Plumbing By-Law of 1958

(updated in 1982)

Regulations regarding discharges into sewers

specific to Walvis Bay.

Table 7. Relevant Multilateral Environmental Agreements for Namibia and the

Development

Agreement Key Aspects

International Convention on Oil

Pollution Preparedness, Response and

Cooperation of 1990

International maritime convention establishing measures for dealing with marine oil pollution incidents nationally and in co-operation with other countries.

National Marine Pollution Contingency

Plan of 2017 Coordinated and integrated national system for

dealing with oil spills in Namibian waters.

Benguela Current Convention of 2013 The Convention is a formal treaty between the governments of Angola, Namibia and South Africa that sets out the countries' intention "to promote a coordinated regional approach to the long-term conservation, protection, rehabilitation, enhancement and sustainable use of the Benguela Current Large Marine Ecosystem, to provide economic, environmental and social benefits."

Abidjan Convention of 1981 The Convention for Cooperation in the Protection, Management and Development of the Marine and Coastal Environment of the Atlantic Coast of the West, Central and Southern Africa Region

Provides an overarching legal framework for all marine-related programmes in West, Central and Southern Africa.

Convention on Biological Diversity Primary goal is the conservation of biodiversity

Prescribes the precautionary principle

Parties to the convention are obliged to:

o Establish a network of protected areas

o Create buffer areas adjacent to these protected areas

using environmentally sound and sustainable

development practices, and

o Rehabilitate degraded habitats and populations of

species.

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The Convention on Wetlands of

International Importance especially as

Waterfowl Habitat (referred as the

Ramsar Convention)

It is a framework for international cooperation in the

conservation and wise use of wetlands and their

resources

Recognizes the Walvis Bay Nature Reserve – a tidal

lagoon consisting of Pelican Point, adjacent

intertidal areas, sandbars serving as roosting sites

and mudflats exposed during low tide (12,600 ha) as

a Wetland of International Importance.

UN Convention for the Prevention of

Marine Pollution from Land-based

Sources

Concerns itself with the protection of marine fauna

and flora by preventing marine pollution from land-

based sources

Contracted parties, are committed to take all possible

steps to prevent pollution of the sea as well as the

direct or indirect introduction of substances or

energy by humans into the marine environment

resulting in such adverse effects as harm to living

resources and to marine ecosystems, hazards to

human health, damage to services/ facilities or

interference with other legitimate uses of the area.

Stockholm Declaration on the Human

Environment, Stockholm 1972.

Recognizes the need for a common outlook and

common principles to inspire and guide the people of

the world in the preservation and enhancement of the

human environment.

Namport Specifications and Legislation

Enforced Standards and Codes which governs

construction and operations relating to the port.

Table 8. Standards or Codes of Practise Standard or Code Key Aspects

South African National Standards

(SANS) The Petroleum Products and Energy Act prescribes

SANS standards for the construction, operations and demolition of petroleum facilities.

SANS 10089-1:2008 is specifically aimed at Storage and distribution of petroleum products in above-ground bulk installations

o Provide requirements for spill control infrastructure.

The operations on the Hangana Seafood premises are listed as activities requiring an environmental

clearance certificate as per the following points from Section 9 of Government Notice No. 29 of 2012:

2.3 “The import, processing, use and recycling, temporary storage, transit or export of waste”.

7.5 “Pest Control.”

8.1 “The abstraction of ground or surface water for industrial or commercial purposes.”

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

Hazardous Substances Ordinance, 1974.”

9.2 “Any process or activity which requires a permit, licence or other form of authorisation, or the

modification of or changes to existing facilities for any process or activity which requires an

amendment of an existing permit, licence or authorisation or which requires a new permit, licence

or authorisation in terms of a law governing the generation or release of emissions, pollution, effluent

or waste.”

9.4 “The storage and handling of a dangerous goods, including petrol, diesel, liquid petroleum gas

or paraffin, in containers with a combined capacity of more than 30 cubic meters at any one

location.”

9.5 “Construction of filling stations or any other facility for the underground and aboveground

storage of dangerous goods, including petrol, diesel, liquid, petroleum, gas or paraffin.”

Page 28 of 88


6 ENVIRONMENTAL CHARACTERISTICS This section lists pertinent environmental characteristics of the study area and provides a statement on

the potential environmental impacts on each.

LOCALITY AND SURROUNDING LAND USE Hangana Seafood operates on erven 4606, 3691, 13B, 3692 and 14B within the fishing harbour

in Walvis Bay (22.9332°S; 14.5145°E). The onshore premises is zoned for industrial land use

and is surrounded by properties of similar nature. Hangana Seafood is neighboured to the south

by NovaNam Ltd. and to the north by Abroma Fishing Industries. A map indicating neighbouring

industries can be seen in Figure 14.

Hangana Seafood’s fish factory and related operations falls under the authority of the

Municipality of Walvis Bay, although their activities are regulated by various ministries

including the Ministry of Agriculture, Water, and Forestry (effluent disposal permit). There are

no heritage or cultural sites located within close proximity to the facility.

Figure 14. Surrounding Properties

Page 29 of 88


Photo 17. Northern Neighbour, Abroma

Fishing Industries

Photo 18. Southern Neighbour, NovaNam

Figure 15. Land Use

Implications and Impacts

The site is situated in an area zoned for industrial purposes. The operations on the Hangana

Seafood premises are in line with activities conducted in the fishing harbour. The cumulative

impact of wastewater discharge from the various fishing industries into the Atlantic Ocean may

pose a risk to the water quality in the harbour. Boiler and odorous emissions may reduce air

quality in the area.

Page 30 of 88


CLIMATE Walvis Bay is centrally located on the Namibian coastline in the arid Namib Desert. The arid

conditions are a result of dry descending air and upwelling of the cold Benguela Current.

Namibia is situated within an anti-cyclone belt of the Southern Hemisphere. Winds generated

from the high-pressure cell over the Atlantic Ocean blow from a southerly direction when they

reach the Namibian coastline. As the Namibian interior is warm (particularly in summer),

localised low-pressure systems are created which draws the cold southerly winds towards the

inland desert areas. These winds manifest themselves in the form of strong prevailing south-

westerly winds, which range from an average of 20 knots (37 km/h) during winter months to as

high as 60 knots (110 km/h) during the summer. During winter months, high velocity, low

frequency east to north easterly winds occur. The east winds generated over the hot Namib Desert

have a strong effect on temperature, resulting in temperatures in the upper 30 degrees Celsius and

tend to transport plenty of sand.

Thick fog or low stratus clouds are a regular occurrence in Walvis Bay. This is due to the

influence of the Benguela Current and forms the major source of water for the succulent and

lichen flora in the Namib Desert. Variation in annual rainfall is very high and most communities

within this environment are dependent on regular fog occurrences. Months with the highest

likelihood of rainfall is January to April. Wind is predominantly south-westerly to south south-

westerly except in winter months when regular, strong east to northeast winds occur.

Table 9. Summary of Climate Data for Walvis Bay (Atlas of Namibia) Average annual rainfall (mm/a) 0-50

Variation in annual rainfall (%) >100

Average annual evaporation (mm/a) 2,800-3,000

Water deficit (mm/a) 1,901-2,100

Average annual temperatures (°C) 18-19

Figure 16. Monthly Average Rainfall

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

0.2 0.3 0.5 0.8 1.1 0.4 6.3 5.4 13.1 4.2 1.1 0.9

Average Monthly Rainfall (mm)

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

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

Average Monthly Rainfall (mm)

Page 31 of 88


Figure 17. Frequency Wind Charts Displaying Wind Data for Meersig Area, Walvis Bay

(source: www.weatherunderground.com)


It is not expected that the normal climatic conditions of Walvis Bay may cause or enhance any

environmental impacts of activities on the premises.

CORROSIVE ENVIRONMENT The corrosive environment of Walvis Bay may be attributed to the frequent salt-laden fog,

periodic winds and abundance of aggressive salts (dominantly NaCl and sulphates) in the soil.

The periodic release of hydrogen sulphide (H2S) from the ocean is expected to contribute to

corrosion (see Table 6 for corrosion comparison data with other centres).

The combination of high moisture and salt content of the surface soil can lead to rapid

deterioration of subsurface metal (e.g. pipelines) and concrete structures. Chemical weathering

of concrete structures due to the abundant salts in the soil is a concern.

Table 10. Average annual corrosion rate for various metals in different locations in southern

Africa (from Nickel Development Institute: Stainless Steels in Architecture,

Building and Construction. http://www.nickelinstitute.org) Pretoria

CSIR

Durban Bay Cape Town

Docks

Durban Bluff Walvis Bay Sasolburg

Environment

Location

type

Rural, very

low

pollution

Marine,

moderate

pollution

Marine,

moderate

pollution

Severe

marine,

moderate or

low pollution

Severe

marine, low

pollution

Industrial

high

pollution

SO2 Range

µg/m3

6-20 10-55 19-39 10-47 NA NA

Fog

days/year

NA NA NA NA 113.2 NA

Avg.

rainfall

(mm/year)

146 1,018 508 1,018 8 677

Summer Autum

Data from Jan 2008 to Mar 2015

Winter Spring

0

15000

30000

45000N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

0 - 0.5 0.5 - 2.5 2.5 - 4.5 4.5 - 6.5 > 6.5 m/s

0

15000

30000

45000N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

0 - 0.5 0.5 - 2.5 2.5 - 4.5 4.5 - 6.5 > 6.5

0

15000

30000

45000N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

0 - 0.5 0.5 - 2.5 2.5 - 4.5 4.5 - 6.5 > 6.5

0

15000

30000

45000N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

WNW

NW

NNW

0 - 0.5 0.5 - 2.5 2.5 - 4.5 4.5 - 6.5 > 6.5

m/s

m/s m/s

Page 32 of 88


Pretoria

CSIR

Durban Bay Cape Town

Docks

Durban Bluff Walvis Bay Sasolburg

Environment

Location

type

Rural, very

low

pollution

Marine,

moderate

pollution

Marine,

moderate

pollution

Severe

marine,

moderate or

low pollution

Severe

marine, low

pollution

Industrial

high

pollution

Relative

humidity

range %

26-76 54-84 52-90 54-84 69-96 49-74

Temp.

Range °C

6-26 16-27 9-25 16-27 10-20 5-20

Unpainted

galvanized

steel life,

years

5-15 3-5 3-7 3-5 0.6-2 5.-15

Annual Corrosion Rate (mm/year)

Stainless Steel

Type 316 0.000025 0.000025 0.000025 0.000279 0.000102 NA

Type 304 0.000025 0.000076 0.000127 0.000406 0.000102 NA

Type 430 0.000025 0.000406 0.000381 0.001727 0.000559 0.000107

Aluminium Alloys

AA 93103 0.00028 0.00546 0.00424 0.01946 0.00457 0.00281

AA 95251 0.00033 0.00353 0.00371 0.01676 0.00417 NA

AA 96063 0.0028 0.00315 0.00366 0.020 0.00495 NA

AA 96082 0.00033 0.00366 0.0034 0.02761 0.00587 NA

AA 85151 NA NA NA 0.0246 0.00375 0.00317

Copper 0.00559 0.0094 0.00711 0.0246 0.0384 0.014

Zinc 0.0033 0.0231 0.029 0.111 NA 0.0152

Weathering

Steel

0.0229 0.212 0.0914 0.810 1.150 0.107

Mild Steel 0.0432 0.371 0.257 2.190 0.846 0.150


Corrosion levels may be high and must be kept in mind when planning the maintenance of the

facilities and related infrastructure as well as for general maintenance.

TOPOGRAPHY AND DRAINAGE Walvis Bay is located in the Central Western Plain of Namibia. The Kuiseb River forms the

southern boundary of this landscape group, with the Namib Dune Field being present south of

the Kuiseb River. A bay is formed by a peninsula commonly known as Pelican Point. On the

southern part of the bay is a lagoon which used to be the mouth of the Kuiseb River. Dune

migration however forced the flow of the Kuiseb River to the north. This flow was stopped

through the construction of a flood control wall to prevent flooding of the town of Walvis Bay,

thus forcing the flood waters to move through the dune area to the lagoon. The Kuiseb River now

rarely reaches the lagoon.

The topography is generally flat with a local downward slope in a westerly direction towards the

ocean. Drainage is poorly developed due to the lack of rainfall <50 mm/annum received in the

area. A dune field is present southeast of Walvis Bay and also further to the northeast. These

dunes generally migrate in a northerly direction. Further inland is the gravel plains of the central

areas of the Namib Naukluft Park. Surface water around Walvis Bay is limited to the marine salt

pans, lagoon and ocean as well as a man-made wetland formed as a result of the sewage treatment

works. The site and surrounding areas are generally flat draining slightly to the north.

Page 33 of 88



Any pollutants that are not contained may be transported via surface water flow to the ocean and

potentially pollute the surrounding environment.

GEOLOGY AND HYDROGEOLOGY Walvis Bay is located in the Central Western Plain of Namibia. The Kuiseb River forms the

southern boundary of this landscape group, with the Namib Dune Field being present south of

the Kuiseb River. Northerly dune migration is forcing the Kuiseb River in a northerly direction,

with Kuiseb River paleochannels being present as far south as Sandwich Harbour.

Following the breakup of West-Gondwana during the early Cretaceous (130 – 135 Ma ago),

continental uplift took place, enhancing erosional cutback and the formation of the Namibian

Escarpment. A narrow pediplain formed, mainly over Damara Age rocks. The South Atlantic

started filling in over the pediplain, with marine conditions established around 80 Ma ago.

Towards the end of the Cretaceous (70 – 65 Ma ago) a relative level surface was created, on

which later deposition of sediments took place. Marine deposition took place in the parts covered

by the newly formed South Atlantic Ocean, while terrestrial deposits took place on land. Further

continental uplift moved the shoreline to its present position.

Northwards migration of sand covered parts of the exposed marine deposits, with Kuiseb floods

also depositing material over the marine sediments. Depth to bedrock in Walvis Bay is expected

to be deeper than 40 m below surface. Based on previous work conducted in the area, it is

expected that the sediments under the project area would consist of medium to coarse grain sand

with thin lenses of more clayey material and layers of shell material.


Groundwater is not utilised in the area. Pollution of the groundwater is however still prohibited.

Shallow groundwater will lead to rapid lateral spreading of hydrocarbon products spilled or

leaked. This will further have potential impact on underground utilities and may cause impacts

on neighbouring properties.

SURFACE WATER No freshwater sources are found in close proximity to the factory. The property is however on

the shore of the Atlantic Ocean. Seawater is extracted from the Atlantic Ocean and used for

industrial purposes at both the fish factory and the fishmeal plant, and then returned to the ocean.

Industrial effluent (cleaning water etc.) and brine will also be released into the Atlantic Ocean.

Similar activities take place from surrounding industries of similar nature.


Any pollutants that enter the Atlantic Ocean, whether through the waste water stream or directly

from spills will deteriorate the quality of the aquatic environment. This will also reduce the

quality of seawater used as processing water by the fishing industry.

PUBLIC WATER SUPPLY Public water supply to Walvis Bay and the surrounding developments is provided by NamWater

from the NamWater Kuiseb Water Supply Scheme. The current factory is a bulk consumer of

potable water. Potable water usage at the factory is estimated at 800 m3/day of which 400 m3 is

produced by the desalination plant on site. The facility has a seawater treatment plant as well as

a desalination plant with a capacity of 400 m3/day. It is estimated that current supply of potable

water will be able to meet the demand of the new factory, as water saving initiatives will be put

in place.

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Although potable water usage is not expected to increase, the usage of potable water, along with

the influx of people to Walvis Bay, due to the growing industry may put strain on the potable

water supply. The growing industry therefore increases the need for desalination plants, to

provide a secure water supply. Periods of droughts may lead to water shortages.

FAUNA AND FLORA The site is located within an industrial area and is built up. The only fauna present of the site is a

garden established by Hangana Seafood, there is no other fauna or flora present at the site.

Of note nearby is the Walvis Bay Lagoon, the salt works and the southern part of the bay west of

the lagoon, which are the key components of the 12,600 ha Ramsar site (Wetland of International

Importance). It is important both as an over-wintering area for Palaearctic migrant wader species

as well as for African species such as Greater and Lesser Flamingos, Great White Pelican and

Chestnut-Banded Plovers. The sewerage ponds, situated about 3 km south of the study area, are

regarded as sensitive manmade wetlands. Although a manmade fresh water source, they are an

attraction for pelicans and flamingos. These wetlands also support 53% of the duck and geese

population in the area. The wetland is formed by the constant inflow of semi-purified water and

supports extensive stands of reeds. There is also flight paths for birds between the sewerage

ponds, the lagoon and the offshore bird breeding platform (Ghwano Island) 6 km north northeast

of the site. The Hangana Seafood premises is located close to the flight path between the Walvis

Bay Lagoon and Bird Island).

The marine mammals, occurring at various times in the Walvis Bay area, are the cetaceans which

are the Common Bottlenose Dolphins, the Namibian endemic Heaveside’s Dolphins, Dusky

Dolphins, Humpback Whales, Southern Right Whales and Pigmy Right Whales as well as the

Cape Fur Seals. The Common Bottlenose Dolphin, Heaveside’s dolphin and Cape Fur Seal are

seen most frequently (daily), the Pigmy Right Whale less frequently (monthly) and the rest

infrequently as they are seasonal or infrequent visitors. The Common Bottle Nose Dolphin with

a population of less than a 100 individuals is thought of as quite unique in being one of the

smallest mammal populations in Africa.

The Namibian coastal waters are home to five species of turtles and all five species are listed as

threatened under the IUCN which is controlled through CITES. The most common occurring

turtles near the proposed development are the Leatherback Turtle and Green Sea Turtle with the

Hawksbill Sea Turtle occurring occasionally.


Hangana Seafood operates within an already disturbed industrial area. Thus no immediate threat

to the flora or land based fauna in the area is expected, however bright lighting may negatively

affects birds flying at night and may cause disorientation and collisions.

Whales, dolphins and seals are often considered as flagship species to which people attach great

inherent value. This is evident from the million dollar tourism industry based on the presence of

these mammals. Their role in the ecosystem is also of significant importance. Pollutants entering

the marine environment may negatively impact on these animals as well as on the food chains

that sustain them. Larger species may also get trapped at the seawater intake points, which may

lead to injury or death of the animal.

AQUATIC ENVIRONMENT - CURRENTS AND TIDES The Benguela Current flows in a north-westerly direction along the Namibian coast. The average

speed of the current is between 0.25 and 0.35 m/s (DMC-CSIR, 2010). The most important

hydraulic conditions are shown in Table 11 (Tractebel, 1998; COWI, 2003a; DMC-CSIR, 2010).

Page 35 of 88


Water enters and exits the bay at the northern tip of Pelican Point (DMC-CSIR 2010). Water

entering flows below the exiting water. Current velocities are on average 0.12 m/s with sporadic

maximums up to 0.25 m/s.

A study in 1965 indicated a pre-dominant clockwise circulation of currents in the bay (Tractebel,

1998). This was later confirmed in the COWI (2003b) and DMC-CSIR (2010) studies.

Circulation occurs mostly in the upper layer and it depends on the wind direction. The current

pattern is clockwise in the morning, towards the south. At Pelican Point, the current moves mostly

northward for the whole day. A general northward current is found along the east side of the bay,

very close to the coast.

Water currents prior to the construction of the new container terminal as well as modelling of

currents once construction is completed are depicted in Figure 18. From this figure it can be seen

that, in the vicinity of the Hangana Seafood premises, the water current flows in a strong north-

easterly direction along the quay walls.

Figure 18. Comparison of Ebb (top) and Flood (bottom) Scenarios for Before and After the

Construction of the New Container Terminal (Source: Hydrodynamic Modelling

Report of DMC-CSIR 2010)

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Table 11. The Oceanographic and Hydraulic Conditions of the Bay and the Sea (adapted from

Tractebel, 1998; COWI, 2003b; DMC-CSIR, 2010).

Hydrological Conditions Description

Tides and sea level -Tide statistics

for Walvis Bay from SA Tide

Tables

Highest Astronomical Tide +1.97

Mean High Water of Spring Tide +1.69

Mean High Water of Neap Tide +1.29

Mean Level +0.98

Mean Sea Level +0.966

Mean Low Water of Neap Tide +0.67

Mean Low Water of Spring Tide +0.27

Lowest Astronomical Tide 0.00

Waves 60 % southerly

23 % south-south-westerly

7 % south-westerly

Ocean current The Benguela current runs north-westerly along the Namibian coastline at a

speed between 0.25 m/s to 0.35 m/s

Tidal current Negligible


Polluted effluent or poor quality effluent disposed of into the ocean may result in reduced water

quality at sensitive receptors down current, specifically seawater intakes of the fishing industry.

Discharge of effluent from various industries in the area may lead to a greater cumulative impact

on the water quality.

Hydrocarbon pollution from the oil recycling plant and consumer fuel installations will impact

on downstream users, and may render the water unusable until the spill is cleared.

AQUATIC ENVIRONMENT - WATER AND SEDIMENT QUALITY Historic analysis data of heavy metals in the sediments of Walvis Bay harbour are presented in

Figure 19 and Figure 20. These analysis were done as part of the Container Terminal project as

well as prior to the 2010/2011 dredging campaign. Metal concentrations are compared to the

BCLME guidelines and are presented in three categories: 1) lower than BCLME guideline values;

2) higher than BCLME guideline values; and 3) higher than BCLME probable effect

concentrations. Note that the locations with high concentrations of heavy metals seems to be

associated mostly with the beginning of the entrance channel where finer sediments were found

(Botha 2011).

Prior to and during the dredging of late 2010 and early 2011, water quality samples were collected

through the port area, see Figure 21 for locations. During this time the BCLME guideline values

were sometimes exceeded, mostly for short periods. Concentrations of copper, lead and zinc

exceeded the BCLME guideline values at a number of occasions, see Table 12 (Botha 2011). The

data span a short time frame and some influence might be present from the dredging that took

place in the commercial harbour.

Table 12. Metals in Seawater Minimum and Maximum Concentrations in 15 Samples

Collected Between 01 Dec 2010 and 06 Apr 2011 at W3 (Botha 2011).

Minimum Maximum BCLME Water

(Recommended

Guideline Value)

# Exceed

Detection

Limit

# Exceed

Guideline

Value

Arsenic 0.0036 0.0092 No Value 15/15 0

Antimony <0.005 <0.005 No Value 0/15 0

Barium 0.0048 0.015 No Value 15/15 0

Beryllium <0.001 <0.001 No Value 0/15 0

Cadmium <0.0004 <0.0004 0.0055 0/15 0

Page 37 of 88


Minimum Maximum BCLME Water

(Recommended

Guideline Value)

# Exceed

Detection

Limit

# Exceed

Guideline

Value

Chromium <0.002 0.003 No Value 1/15 0

Cobalt <0.001 <0.001 0.001 0/15 0

Copper <0.003 0.018 0.0013 3/15 3/15

Mercury <0.00004 0.00028 0.0004 14/15 0

Lead <0.003 0.01 0.0044 1/15 1/15

Molybdenum 0.0085 0.013 No Value 15/15 0

Nickel <0.002 0.0022 0.07 1/15 0

Selenium <0.005 0.0052 No Value 1/15 0

Tin <0.005 <0.005 No Value 0/15 0

Vanadium <0.002 0.0079 0.1 11/15 0

Zinc <0.005 3.7 0.015 8/15 2/15

Filter-feeding organisms such as mussels act as a conduit for the transfer of toxic trace metals

from primary trophic levels to higher levels such as birds and humans. Metals accumulated in the

filter-feeding organisms and mussels can therefore be used as an indicator for the presence and

bioavailability of metals in the environment.

Namport in accordance to the dredging Environmental Management Plans has carried out

analyses of heavy metals in samples from mussels. According to Racal (1999), the accepted

human health safe concentration limits for trace metals in e.g. mussels and oysters are for Copper,

Lead and Zinc respectively 250 µg/g, 20 µg/g and 1500 µg/g. Biological tissue samples were

collected at various points during the monitoring of the last dredging activities (Botha 2011) to

determine the impact on the marine environment. This included pre-dredging samples used to set

baseline concentrations.

Oyster samples were collected from two locations in the Mariculture Farm near Pelican Point.

Mussel samples were collected from Langstrand, Bird Island, the entrance to the Lagoon and

from the Mariculture Farm at Pelican Point. The sample sites are shown in Figure 22. The samples

collected were submitted to the Council for Scientific and Industrial Research (CSIR) Durban

Laboratory for Cadmium, Mercury, Copper, Chrome, Lead, Zinc and Tin analysis. The sampling

schedule and the results can be found in the report by Geo Pollution Technologies (Botha 2011).

The Foodstuffs, Cosmetics and Disinfectants Act No. 54 of 1972 of South Africa was used as a

base for the evaluation of mussel and oyster analysis.

The biological tissue analysis data indicates that the guideline values for lead were exceeded in

the samples collected on 11 and 26 January 2011 from the entrance of the lagoon (B1), as well

as in the sample collected on 10 February 2011 from the Bird Island area (B6) (Figure 22). No

other metals exceeded the guideline values. The cadmium content in oyster flesh from B4

exceeded the guideline values on 23 February and 23 March 2011.

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Figure 19. Historic Sediment Analysis Part 1 (Botha 2011)

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Figure 20. Historic Sediment Analysis Part 2 (Botha 2011)

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Figure 21. Water sampling sites for the water quality monitoring done for previous dredging

activities in 2010/2011 (Botha 2011).

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Figure 22. Sampling sites for biological flesh


Introduction of pollutants from any construction and operational activities at the site can cause

serious negative effects on the surrounding marine environment. Mitigating measures must be

in place to prevent the pollution and waste from entering the marine environment.

Maintenance dredging may mobilise pollutants contained within sediments in the water column.

DEMOGRAPHIC AND ECONOMIC CHARACTERISTICS At local level Walvis Bay has an urban population size of 62,096 (Namibia Statistics Agency,

2014) although the current estimate is around 90,000 to 100,000. Walvis Bay is the principal port

of Namibia, and is an import/export facility for processed fish, mining products and beef. The

area is linked to Namibia’s air, rail and road network, making its port well situated to service

Zambia, Zimbabwe, Botswana, Southern Angola and South Africa. The fishing industry is the

major employer of low skilled workers on a permanent and seasonal basis. The total employment

of this sector is estimated at 2% of the total Namibian workforce. Hangana Seafood currently

employs approximately 1,400 people, which will increase with the completion of the proposed

new factory. Economic activities relate mostly to businesses of similar nature within the area.

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Table 13. Demographic Characteristics of Walvis Bay, the Erongo Region and Nationally

(Namibia Statistics Agency, 2011)

Walvis Bay Erongo Region Namibia

Population (Males) 30,500* 79,823 1,021,912

Population (Females) 29,000* 70,986 1,091,165

Population (Total) 62,096 150,809 2,113,077

Unemployment (15+ years) N/A 22.6% 33.8%

Literacy (15+ years) N/A 96.7% 87.7%

Education at secondary level (15+ years) N/A 71.8% 51.2%

Households considered poor N/A 5.1% 19.5%


Hangana Seafood currently employs approximately 1,400 people, this number may increase once

the proposed new factory is constructed and in operation. Hangana Seafood’s operations in

Walvis Bay aids in the economic growth of Walvis Bay and Namibia. Economic growth of the

town, and appointing contractors during construction and operations may result in more job

opportunities being generated.

Some skills development and training will also benefit employees during construction as well as

operational phases.

CULTURAL, HERITAGE AND ARCHAEOLOGICAL ASPECTS There are no church, mosques or related buildings in close proximity to the site. No known

archaeological resources have been noted in the vicinity since the urbanisation of the area. No

other structures, sites or spheres of heritage of cultural significance was determined to be in close

proximity to the site.


The operations and construction on the Hangana Seafood premises will not impact on any cultural

or historically significant areas or buildings.

7 PUBLIC CONSULTATION Consultation with the public forms an integral component of an environmental assessment investigation

and enables Interested and Affected Parties (IAPs) e.g. neighbouring landowners, local authorities,

environmental groups, civic associations and communities, to comment on the potential environmental

impacts associated with the facility and to identify additional issues which they feel should be addressed

in the environmental assessment.

During the initial environmental impact assessment, key IAPs were identified during the public

participation process, the registered IAPs once again received notification letters regarding the update

of the EIA. Notification letters was delivered to neighbours. The Walvis Bay Municipality, Ministry of

Fisheries and Marine Resources and Namibia Port Authority were also notified. See Appendix A for

proof of the public participation processes. No written comments or feedback were received.

8 MAJOR IDENTIFIED IMPACTS During the scoping exercise a number of potential environmental impacts have been identified. The

following section provides a brief description of the most important of these impacts.

HEALTH AND SAFETY IMPACTS Some health and safety risks are present on site and include moving vehicles and forklifts,

exposure to steam or cold temperatures, slipping on wet surfaces, falling objects, injuries while

cutting fish on processing lines, etc. Exposure to chemicals can occur in the boiler house,

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compressor rooms (ammonia leaks) or during cleaning. Ammonia is corrosive and can cause

freeze burns. Inhalation of dangerous Legionella bacteria can occur where contaminated water

becomes airborne. Typical conditions favourable to Legionella growth include stagnant water

between 20 and 45 °C with media such as scale build-up present. These are often found in cooling

towers, water coolers, water reservoirs, etc.

FIRE AND EXPLOSION Diesel, old oil and LFO, although not very flammable at ambient temperatures, are stored on site

for use in boilers and ship refuelling. These present a risk of fire. Should an ammonia leak occur

in one of the compressor rooms, a mixture of 15% to 28% ammonia in air is explosive if an

ignition source exist.

WASTE PRODUCTION Waste is produced in the form of packaging material, waste water, typical office related and

domestic waste. Besides sludge and old oil filters produced from the oil recycling plant, limited

hazardous waste is produced e.g. used transformer oils, biological waste from laboratory etc. The

oil recycling plant also reduces waste from other industries by recycling and utilising their waste

oil. Organic waste in the form of fish offal are converted into fishmeal.

NOISE IMPACTS Noise impacts are mostly associated with the moving parts of the fish processing lines, low

frequency droning noise from the boiler, compressors of freezers and cold rooms, moving

vehicles, and audible warning signals of trucks and forklifts. During construction there may be

more noise producing activities.

AIR QUALITY IMPACT Exhaust gasses from the boiler contributes to air pollution and emission of greenhouse gasses

into the environment. Further impacts on air quality are related to odorous compounds emitted

during activities such as fishmeal production. These odours may contain compounds such as fatty

acids, hydrogen sulphide, methyl mercaptan and ethyl mercaptan. In the event of an ammonia

leak, temporary reduced air quality an occur either in the compressor rooms or immediately

outside thereof.

TRAFFIC IMPACTS During construction activities and operations some traffic impacts can be experienced when

trucks and delivery vehicles access the sites on Ben Amathila Street. As this is a street with

multiple industrial operations, traffic is constant. If delivery trucks are parked outside of the

facility, it may cause congestion in Ben Amathila Street.

SURFACE WATER CONTAMINATION Surface water contamination can occur when pollutants, including high organic loads, enter the

ocean. Insufficient removal of fish waste products from the effluent water will increase the

organic load of waste water disposed of into the ocean. This increases the chemical oxygen

demand (COD) and biological oxygen demand (BOD) of the waste water. While the contribution

of the Hangana Seafood fish factory and the fishmeal plant to the COD and BOD of the fishing

harbour water may be insignificant, the cumulative impact of effluent from all fishing industries

should be considered.

Leaking tanks and pipelines, as well as accidental spills or leaks during handling, transfer and

storage of hydrocarbons may contaminate the marine environment. Ammonia leaks that is

absorbed in water is toxic to the aquatic environment. This will negatively impact on marine

fauna as well as surrounding industries utilising seawater.

During dredging activities contaminants trapped within sediments may be suspended in the water

column.

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IMPACT OF LIGHTING ON BIRDS Birds flying at night, for example flamingos, are disorientated by lights and this can result in bird

collisions with manmade infrastructure. The urban environment of Walvis Bay has a strong

cumulative impact in this regard, as most of the industrial and commercial areas are either near

or in one or more of the flight paths. The Hangana Seafood premises is situated close to the flight

path between Bird Island and the Walvis Bay Lagoon. Lights used at night to illuminate the yard

may impact on birds.

SOCIO-ECONOMIC IMPACTS Operations from Hangana Seafood provides direct employment to an estimated 1,400 employees.

The proposed factory will increase this number. Hangana Seafood thereby significantly

contribute to employment and economic development in Walvis Bay and Namibia. Employees

also undergo training and skills development. True value addition and contribution to the

Namibian Economy is achieved by processing and packaging all fish harvested at the factory and

then transporting the products to markets.

9 ASSESSMENT AND MANAGEMENT OF IMPACTS The purpose of this section is to assess and identify the most pertinent environmental impacts that are

expected from the construction and operational activities on the Hangana Seafood premises. An

Environmental Management Plan based on these identified impacts are also incorporated into this

section.

For each impact an Environmental Classification was determined based on an adapted version of the

Rapid Impact Assessment Method (Pastakia, 1998). Impacts are assessed according to the following

categories: Importance of condition (A1); Magnitude of Change (A2); Permanence (B1); Reversibility

(B2); and Cumulative Nature (B3) (see Table 14)

Ranking formulas are then calculated as follow:

Environmental Classification = A1 x A2 x (B1 + B2 + B3)

The environmental classification of impacts is provided in Table 15.

The probability ranking refers to the probability that a specific impact will happen following a risk

event. These can be improbable (low likelihood); probable (distinct possibility); highly probable (most

likely); and definite (impact will occur regardless of prevention measures).

Table 14. Assessment Criteria Criteria Score

Importance of condition (A1) – assessed against the spatial boundaries of human interest it will

affect

Importance to national/international interest 4

Important to regional/national interest 3

Important to areas immediately outside the local condition 2

Important only to the local condition 1

No importance 0

Magnitude of change/effect (A2) – measure of scale in terms of benefit / disbenefit of an impact

or condition

Major positive benefit 3

Significant improvement in status quo 2

Improvement in status quo 1

No change in status quo 0

Negative change in status quo -1

Significant negative disbenefit or change -2

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Major disbenefit or change -3

Permanence (B1) – defines whether the condition is permanent or temporary

No change/Not applicable 1

Temporary 2

Permanent 3

Reversibility (B2) – defines whether the condition can be changed and is a measure of the control

over the condition

No change/Not applicable 1

Reversible 2

Irreversible 3

Cumulative (B3) – reflects whether the effect will be a single direct impact or will include

cumulative impacts over time, or synergistic effect with other conditions. It is a means of judging

the sustainability of the condition – not to be confused with the permanence criterion.

Light or No Cumulative Character/Not applicable 1

Moderate Cumulative Character 2

Strong Cumulative Character 3

Table 15. Environmental Classification (Pastakia 1998) Environmental Classification Class Value Description of Class

72 to 108 5 Extremely positive impact

36 to 71 4 Significantly positive impact

19 to 35 3 Moderately positive impact

10 to 18 2 Less positive impact

1 to 9 1 Reduced positive impact

0 -0 No alteration

-1 to -9 -1 Reduced negative impact

-10 to -18 -2 Less negative impact

-19 to -35 -3 Moderately negative impact

-36 to -71 -4 Significantly negative impact

-72 to -108 -5 Extremely Negative Impact

RISK ASSESSMENT AND ENVIRONMENTAL MANAGEMENT PLAN The EMP provides management options to ensure possible negative impacts emanating from the

activities are minimised. An EMP is a tool used to take pro-active action by addressing potential

problems before they occur or to manage an emergency situation once an impact does occur. This

should limit the corrective measures needed, although additional mitigation measures might be

included if necessary. The environmental management measures are provided in the tables and

descriptions below. These management measures should be adhered to during the various phases

of the operations and construction on the premises. This section of the report can act as a stand-

alone document. All personnel taking part in the construction operations on the premises should

be made aware of the contents in this section, so as to plan the operations accordingly and in an

environmentally sound manner.

The objectives of the EMP are:

to include all components of construction activities (upgrades, maintenance, etc.) and

operations of the facility;

to prescribe the best practicable control methods to lessen the environmental impacts

associated with the facility;

to monitor and audit the performance of operational personnel in applying such controls; and

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to ensure that appropriate environmental training is provided to responsible operational

personnel.

Various potential and definite impacts will emanate from the construction and operational phases.

The majority of these impacts can be mitigated or prevented. The impacts, risk rating of impacts

as well as prevention and mitigation measures are listed below.

As depicted in the tables below, impacts are expected to mostly be of medium to low significance

and can mostly be mitigated to have a low significance. The extent of impacts are mostly site

specific to local and are not of a permanent nature. Due to the nature of the surrounding areas,

cumulative impacts are possible and include surface water contamination and traffic impacts.

Planning

During the phases of planning, construction, future operations and possible decommissioning

of the factory, it is the responsibility of the proponent to ensure they are, and remain,

compliant with all legal requirements. The proponent must also ensure that all required

management measures are in place prior to and during all phases, to ensure potential impacts

and risks are minimised. The following actions are recommended for the planning phase and

should continue during various other phases of the project:

Ensure that all necessary permits from the various ministries, local authorities and any

other bodies that governs the construction activities and operations of the project is

obtained and valid.

Ensure all appointed contractors and employees enter into an agreement which includes

the EMP. Ensure that the contents of the EMP are understood by the contractors, sub-

contractors, employees and all personnel present or who will be present on site.

Make provisions to have a Health, Safety and Environmental Coordinator to implement

the EMP and oversee occupational health and safety as well as general environmental

related compliance at the site, by both the Hangana Seafood employees and the

contractors and their employees.

Appoint or designate a community liaison officer to deal with complaints.

Have the following emergency plans, equipment and personnel on site where reasonable

to deal with all potential emergencies:

o Risk management / mitigation / EMP/ Emergency Response Plan and HSE Manuals;

o Adequate protection and indemnity insurance cover for incidents;

o Comply with the provisions of all relevant safety standards;

o Procedures, equipment and materials required for emergencies.

If one has not already been established, establish and maintain a fund for future ecological

restoration of the project site should a spill occur or project activities cease and the site is

decommissioned and environmental restoration or pollution remediation is required.

Establish a reporting system to report on aspects of construction activities, operations and

decommissioning as outlined in the EMP.

Keep monitoring reports on file for submission with environmental clearance certificate

renewal applications where needed.

Update the EIA and EMP and apply for renewal of the environmental clearance certificate

prior to expiry.

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Skills, Technology and Development

During various phases of the facility, training is be provided to a portion of the workforce, in

order to maintain and operate various features on the Hangana Seafood premises at peak

capacity and according to the required standards. This is not limited to only training in the

formal sense, but also awareness practices which can assist in adherence to the safety and

environmental plans. Skills are transferred to an unskilled workforce for general tasks. The

technology required for the factory is often new to the local industry, aiding in operational

efficiency. Development of people and technology are key to economic development.

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Construction Technological development and

transfer of skills 2 1 2 3 1 12 2 Definite

Daily Operations Technological development and

transfer of skills 3 2 2 2 2 36 4 Definite

Indirect Impacts Enhancement in the efficiency of

facilities 3 2 2 2 2 36 4 Definite

Desired outcome: To see an increase in skills of local Namibians, as well as development and

technology advancements in the fishing industry.

Actions

Mitigation: If the skills exist locally, contractors must first be sourced from the town, then the region

and then nationally. Deviations from this practice must be justified.

Skills development and improvement programs to be made available as identified during

performance assessments.

Employees to be informed about parameters and requirements for references upon

employment.

The proponent must employ Namibians where possible. Deviations from this practise

should be justified appropriately.

Responsible Body:

Proponent

Contractors

Data Sources and Monitoring: Record should be kept of training provided.

Ensure that all training is certified or managerial reference provided (proof provided to

the employees) inclusive of training attendance, completion and implementation.

Bi-annual summary report based on records kept.

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Revenue Generation and Employment

An increase of skilled and professional labour takes place due to various operations on the

Hangana Seafood premises. Resources are sourced and processed locally and then exported,

contributing to the economy and trade balance of Namibia. Employment will be sourced

locally while skilled labour/contractors may be sourced from other regions.

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2 1 2 2 2 12 2 Definite

Daily Operations Employment, contribution to local

economy

3 2 2 3 2 42 4 Definite

Indirect Impacts Decrease in unemployment, increase

in revenue generated

3 2 2 3 2 42 4 Definite

Desired outcome: Contribution to national treasury and provision of employment to local

Namibians.

Actions

Mitigation: The proponent must employ local Namibians where possible.

If the skills exist locally, employees must first be sourced from the town, then the region

and then nationally.

Deviations from this practice must be justified.

Local businesses and industries should be supported

Responsible Body:

Proponent

Contractors

Data Sources and Monitoring: Bi-annual summary report based on employee records.

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Demographic Profile and Community Health

The project is reliant on a large labour force during the operational phase. Due to this being

an existing operation, a change in the demographic profile of the local community is not

expected. Community health may still be exposed to factors such as communicable disease

like HIV/AIDS and alcoholism/drug abuse, associated with trucking (transport of products to

SADC markets). An increase in foreign people in the area may potentially increase the risk of

criminal and socially/culturally deviant behaviour.

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Construction Social ills related to unemployment

and transport

2 -1 1 1 2 -8 -1 Probable

Daily Operations Social ills related to unemployment

and transport

2 -1 2 2 2 -12 -2 Probable

Indirect Impacts The spread of disease 2 -1 2 2 2 -12 -2 Probable

Desired Outcome: To prevent the in-migration and growth in informal settlements and to

prevent the spread of communicable diseases and prevent / discourage socially deviant

behaviour.

Actions:

Prevention: Employ only local people from the area, deviations from this practice should be justified

appropriately.

Adhere to all municipal by-laws relating to environmental health which includes but is

not limited to sand and grease traps for the various facilities and sanitation requirements.

Mitigation: Educational programmes for employees on HIV/AIDs and general upliftment of

employees’ social status.

Appointment of reputable contractors.

Responsible Body: Proponent

Data Sources and Monitoring: Factory inspection sheet for all areas which may present environmental health risks, kept

on file.

Bi-annual summary report based on educational programmes and training conducted.

Bi-annual report and review of employee demographics.

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Traffic

Operations and construction activities on the Hangana Seafood premises may increase the

traffic flow to the site due to trucks collecting and delivering various products. An increase in

traffic to and from the site may increase congestion and increase the risk of incidents and

accidents, especially Ben Amathila Street.

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supplies

2 -1 2 2 2 -12 -2 Probable

Daily Operations Increase traffic, road wear and tear

and accidents

2 -1 2 2 2 -12 -2 Probable

Desired Outcome: Minimum impact on traffic and no transport or traffic related incidents.

Actions

Prevention:

Erect clear signage regarding access and exit points at the facility.

Mitigation: Refrigerator trucks collecting finished products and construction vehicles should not be

allowed to obstruct any traffic or access to facilities in Ben Amathila Street.

If any traffic impacts are expected, traffic management should be performed to prevent

these.

The placement of signs to warn and direct traffic will mitigate traffic impacts.

Responsible Body:

Proponent

Contractors

Data Sources and Monitoring:

Any complaints received regarding traffic issues should be recorded together with action

taken to prevent impacts from repeating itself.

A report should be compiled every 6 months of all incidents reported, complaints

received, and action taken.

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Health, Safety and Security

Every activity associated with the construction and operational phase is reliant on human

labour and therefore exposes them to health and safety risks. Injuries can occur due to

incorrect lifting of heavy equipment and materials, falling from heights, stacked items tipping

over, getting caught in moving parts of machines, accidents involving forklifts and vehicles,

and exposure to hot and cold temperatures. Some chemicals handled and stored on site is

hazardous with inherent health risks to personnel on site when inhalation, accidental ingestion,

eye or skin contact occurs. This includes ammonia if leaks occur. Asbestos containing material

is present on site which pose risks during demolition. Legionella bacteria in water sources that

can become airborne may pose health risks including Legionnaires’ disease. Security risks are

related to unauthorized entry, theft and sabotage.

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Construction Physical injuries, exposure to

chemicals and criminal activities

1 -2 3 3 1 -14 -2 Probable

Daily Operations Physical injuries, exposure to

chemicals and criminal activities

1 -2 3 3 2 -16 -2 Probable

Desired Outcome: To prevent injury, health impacts and theft.

Actions

Prevention:

All Health and Safety standards specified in the Labour Act should be complied with.

Clearly label dangerous and restricted areas as well as dangerous equipment and products.

Equipment that will be locked away on site must be placed in a way that does not

encourage criminal activities (e.g. theft).

Provide all employees with required and adequate personal protective equipment (PPE)

to be worn at all times.

Ensure that all personnel receive adequate training on operation of equipment / handling

of hazardous substances.

Always follow safe stacking and storage methods.

Implementation of maintenance register for all equipment and fuel/hazardous substance

storage areas.

Guards should be in place at conveyor belt drive systems, lockout procedures should be

followed when belts are being serviced.

A Legionella risk assessment and management plan should be compiled which includes

bi-annual inspection and analysis of water sources potentially containing Legionella.

Ammonia has a strong smell and leaks are typically quickly detected by smell only.

However, leak detectors should be considered since personnel will not always be present

in the compressor rooms.

Mitigation: Selected personnel should be trained in first aid and a first aid kit must be available on

site. The contact details of all emergency services must be readily available.

Implement and maintain an integrated health and safety management system, to act as a

monitoring and mitigating tool, which includes: colour coding of pipes, operational, safe

work and medical procedures, permits to work, emergency response plans, housekeeping

rules, MSDS’s and signage requirements (PPE, flammable etc.).

The compressors rooms must have emergency response plans specific to ammonia if leaks

or accidental release of ammonia occur. This include emergency showers and eyewash

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stations, PPE and water hoses with water diffusing nozzles. Water absorbs ammonia

vapour if sprayed by a fine mist or droplets of water. Refer to MSDA and SANS 10147.

All asbestos removal must be performed by qualified and approved contractors and

disposed of at an approved facility.

Security procedures and proper security measures must be in place to protect workers and

clients.

Strict security that prevents unauthorised entry.

Responsible Body:

Proponent

Contractors

Data Sources and Monitoring: Any incidents must be recorded with action taken to prevent future occurrences.

A report should be compiled every 6 months of all incidents reported. The report should

contain dates when training were conducted and when safety equipment and structures

were inspected and maintained.

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Fire

Operational and construction activities may increase the risk of the occurrence of fires. LFO,

liquefied petroleum gas, oil and diesel stored in on the premises presents a fire risk. Various

equipment like extractor canopies in canteen and mobile equipment used for welding all

contribute to the risks of a fire. Ammonia if released from the refrigeration systems and

present in a 15% to 28% mixture with air, is explosive. Other flammable chemicals may also

be on site in small quantities.

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Construction Uncontrolled fire resulting in

property damage, burn wounds or

casualties

1 -2 3 3 1 -14 -2 Improbable

Daily Operations Uncontrolled fire resulting in

property damage, burn wounds or

casualties

1 -2 3 3 1 -14 -2 Improbable

Desired Outcome: To prevent property damage, possible injury and impacts caused by

uncontrolled fires.

Actions:

Prevention:

Ensure all fuel or chemicals are stored according to MSDS instructions.

Maintain regular site, mechanical and electrical inspections and maintenance.

Clean all spills / leaks.

Follow SANS standards for operation and maintenance of the consumer fuel installation,

oil recycling plant and oil / LFO tanks.

Follow MSDS and SANS standard for operation and maintenance of the refrigeration

systems containing ammonia.

Mitigation: A holistic fire protection and prevention plan is needed. This plan must include an

emergency response plan, firefighting plan and spill recovery plan and should be done in

conjunction with neighbouring fuel depots.

Special note must be taken of the regulations stipulated in sections 47 and 48 of the

Petroleum Products and Energy Act, 1990 (Act No. 13 of 1990).

The compressors rooms must have emergency response plans specific to ammonia related

fire risks if leaks or accidental release of ammonia occur. This include explosive proof

lighting, extractor fans, PPE and water hoses with water diffusing nozzles. Water absorbs

ammonia vapour if sprayed by a fine mist or droplets of water. Refer to MSDA and SANS

10147.




Maintain firefighting equipment, good housekeeping and personnel training (firefighting,

fire prevention and responsible housekeeping practices).

Responsible Body:

Proponent

Contractors

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Data Sources and Monitoring: A register of all incidents must be maintained on a daily basis. This should include

measures taken to ensure that such incidents do not repeat themselves.

A report should be compiled every 6 months of all incidents reported. The report should

contain dates when fire drills were conducted and when fire equipment was tested and

training given.

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Air Quality

The boiler is the principal emitters and of key concern are the “exhaust” gases: nitrous oxides,

sulphurous oxides, hydrocarbons, carbon monoxide, carbon dioxide, and particulate matter,

which are all considered to be sources of air pollution. Odorous compounds from the fishmeal

plant include ammonia, amines, fatty acids, hydrogen sulphide, methyl mercaptan and ethyl

mercaptan. These are foul smelling and can decrease the quality of life of residents of Walvis

Bay.

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Construction Excessive dust generated from

maintenance and upgrade activities

1 -1 2 2 2 -6 -1 Probable

Daily Operations Emission of gasses and odorous

compounds

2 -1 2 2 2 -12 -2 Definite

Desired Outcome: To prevent health impacts and minimise the dust generated.

Actions

Prevention:

Regular maintenance and cleaning of all equipment.

Process fish as fresh as possible.

Mitigation: All vapour generated in the fishmeal plant should pass through a deodoriser.

Measures should be taken to ensure no white vapour (visual vapours) is emitted from the

factory.

Develop an air quality management plan and make the necessary adjustments to the

boilers to reduce emissions if required.

Compressor rooms must have extractors in case of leaks or accidental ammonia releases.




Quality checks should be conducted on the LFO used in boiler operations. Good quality

LFO will reduce emissions.

Scrubbers or ceramic filters should be considered to minimise emissions from boilers.

Responsible Body:

Proponent

Contractors

Data Sources and Monitoring: A complaints register should be kept for any air quality related issues and mitigation steps

taken to address complaints where necessary.

All information and reporting to be included in a final report.

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Noise

The site is situated in an industrial area and no limitations on the operating hours exist. Noise

pollution will exist due to heavy vehicles accessing the site for delivery and collection of

products, the use of forklifts (audible warning signs), processing machinery, and compressors

of freezers and cold rooms. Construction may generate excessive noise.

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Construction Excessive noise generated from

construction activities – nuisance

and hearing loss

1 -2 2 2 2 -12 -2 Probable

Daily Operations Noise generated from the operational

activities – nuisance

1 -2 2 2 2 -12 -2 Definite

Desired Outcome: To prevent any nuisance and hearing loss due to noise generated.

Actions

Prevention:

Follow World Health Organization (WHO) guidelines on maximum noise levels

(Guidelines for Community Noise, 1999) to prevent hearing impairment.

All machinery must be regularly serviced to ensure minimal noise production.

The use of low frequency white noise or flashing lights should be considered instead of

audible high frequency warning signals for moving forklifts or trucks.

Mitigation: Hearing protectors as standard PPE for workers in situations with elevated noise levels.

Responsible Body:

Proponent

Contractors

Data Sources and Monitoring: WHO Guidelines.

Maintain a complaints register.

Bi-annual report on complaints and actions taken to address complaints and prevent future

occurrences.

Page 57 of 88


Waste Production

Various waste streams are produced during the operational phase. Waste may include

hazardous waste associated with the operations of the factory, fishmeal plant and oil recycling

plant, such as used transformer oils, organic/biological waste and sludge. Domestic waste is

generated by the factory and related operations. Containers contaminated with chemicals can

pose health risks if discarded at regular disposal sites where it may be collected for re-use by

people. Construction waste may include building rubble and discarded equipment

contaminated by hydrocarbon products. Hydrocarbon contaminated soil and water is

considered as hazardous waste. Old oil filters used for refining of oil should be treated as

hazardous waste, or cleaned in a way that no more oil or sludge is present prior to disposal.

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Construction Excessive waste production, littering,

illegal dumping, contaminated

materials

1 -2 2 2 1 -10 -2 Definite

Daily Operations Excessive waste production, littering,

contaminated materials

2 -2 2 2 1 -20 -3 Definite

Desired Outcome: To reduce the amount of waste produced, and prevent pollution and

littering.

Actions

Prevention:

Waste reduction measures should be implemented and all waste that can be re-used /

recycled must be kept separate.

Ensure adequate disposal storage facilities are available.

Ensure waste cannot be blown away by wind.

Prevent scavenging (human and non-human) of waste storage.

Mitigation: Waste should be disposed of regularly and at appropriately classified disposal facilities,

this includes hazardous material (empty chemical containers, medical waste,

contaminated rugs, paper water and soil).

See the material safety data sheets available from suppliers for disposal of contaminated

products and empty containers.

Medical or biological waste presenting a biohazard, if any, must be incinerated.

Liaise with the municipality regarding waste and handling of hazardous waste.

Waste water, waste generated from the oil recycling plant and sewage must be disposed

of according to their relevant permit requirements.

Responsible Body:

Proponent

Contractors


Regular site inspections and remedial action where required.

A register of hazardous waste disposal should be kept. This should include type of waste,

volume as well as disposal method/facility.

Waste water quality testing results on file.

Any complaints received regarding waste should be recorded with notes on action taken.

All information and reporting to be included in a bi-annual report.

Page 58 of 88


Ecosystem and Biodiversity Impact

Dredging and jetty maintenance may lead to habitat loss. However the project location is

within an already disturbed fishing harbour and the nature of the operational activities is such

that the probability of creating a habitat for flora and fauna to establish is low. This being a

existing site, no impact on flora is expected. Impacts on fauna is mostly related to birds and

marine animals. Excessive lighting used at night and especially those that are directed

upwards blinds birds like flamingos that fly at night. This may result in disorientation of birds

and collisions with structures. Further impacts will mostly be related to pollution of the

environment and during dredging, contaminants trapped in sediments can also be suspended

in the water column. Marine mammal entanglement with, or ingestion of, human generated

debris.

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Construction Impact on fauna and flora. Loss of

biodiversity

1 -1 3 2 2 -7 -1 Improbable

Daily Operations Impact on fauna and flora. Loss of

biodiversity

2 -2 3 2 2 -28 -3 Improbable

Desired Outcome: To avoid pollution of, and impacts on, the ecological environment.

Actions.

Mitigation: Report any extraordinary sightings of animals not normally encountered in the area or

injured animals (land or sea) to the Ministry of Environment and Tourism.

Mitigation measures related to waste handling and the prevention of groundwater, surface

water and soil contamination should limit ecosystem and biodiversity impacts (refer to

section 9.1.10 and 9.1.12).

All hazardous substances, including hydrocarbons, should be stored in bunded areas with

proper spill control infrastructure and emergency response plans in place.

Ensure waste cannot be blown away by wind.

The establishment of habitats and nesting sites at the factory should be prevented where

possible.

Seawater intake points should have screens or screening boxes to prevent the intake and

entrainment of larger marine organisms.

Lights used at site should as far as is practically possible be directed downwards to the

working surfaces to prevent blinding and disorientation of birds flying at night.

The compressor rooms must have structures (bunds) to contain any ammonia rich water

which may be created if an ammonia leak is present and water is sprayed to absorb

ammonia vapours. These should prevent contaminated water from entering the

environment and importantly the ocean.



in the compressor rooms. Emergency response plans should be in place if leaks are

detected.

Responsible Body:

Proponent


All information and reporting to be included in a bi-annual report.

Page 59 of 88


Groundwater, Surface Water and Soil Contamination

Operations entail the storage and handling of hydrocarbons which present a contamination

risk. Surface water contamination can also occur when pollutants including high organic loads

enter the ocean. Insufficient removal of fish waste products from the effluent water sump and

solid traps will increase the organic load of effluent disposed of into the ocean. This increases

the chemical oxygen demand (COD) and biological oxygen demand (BOD) of the waste

water. Contaminated water or oxygen poor water may negatively impact on aquatic

ecosystems.

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Construction Contamination from hazardous

material spillages and hydrocarbon

leakages

2 -1 2 2 1 -10 -2 Probable

Daily Operations Contamination from hazardous

material spillages and hydrocarbon

leakages

2 -2 2 2 2 -24 -3 Probable

Desired Outcome: To prevent the contamination of water and soil.

Actions

Prevention:

Spill control structures and procedures related to consumer fuel installation must be in

place according to SANS standards or better.

Regular inspection and maintenance of the effluent sump and screens / solid traps.

Contaminated water must be prevented from entering the effluent streams, and treated as

hazardous waste that must be disposed of at an appropriately classified facility.

Mitigation: Any fuel spillage of more than 200 litre must be reported to the Ministry of Mines and

Energy, Directorate of Petroleum Affairs.

Emergency Response Plans and Spill Contingency Plans must be in place and include all

chemicals being handled.

Any spill must be cleaned up immediately.

All chemicals must be handled according to their respective material safety data sheet

instructions.

All hazardous substances, including hydrocarbons, should be stored in bunded areas with

proper spill control infrastructure in place.

For chemicals that will form part of effluent to be discharged into the ocean,

environmental effects must be considered and alternative chemicals investigated if

needed.

Effluent must meet standards as per the effluent discharge permits.

Use of reputable and well trained contractors are essential.

The compressor rooms must have structures (bunds) to contain any ammonia rich water

which may be created if an ammonia leak is present and water is sprayed to absorb

ammonia vapours. These should prevent contaminated water from entering the

environment and importantly the ocean.




Page 60 of 88


Responsible Body:

Proponent

Contractors

Data Sources and Monitoring: Regular inspections and remedial action taken if required.

Regular effluent streams monitoring as per effluent disposal permit conditions, to ensure

that any abnormal increases in organic matter or other chemicals are detected swiftly and

remediation measures can be implemented. Refer to Department of Water Affairs &

Forestry Code of Practice: Volume 6.

A report should be compiled bi-annually of all spills or leakages reported and monitoring

results. The report should contain the following information: date and duration of spill,

product spilled, volume of spill, remedial action taken, comparison of pre-exposure

baseline data (previous pollution conditions survey results) with post remediation data

(e.g. soil/groundwater hydrocarbon concentrations) and a copy of documentation in which

spill was reported to Ministry of Mines and Energy.

Page 61 of 88


Visual Impact

This is an impact that not only affects the aesthetic appearance, but also the integrity of the

facility and the visual landscape character. The facility is situated within the fishing harbour

of Walvis Bay, a built up area with multiple fish factories. The new factory is the same as the

existing urban character. If kept tidy and neat it may contribute positively to the visual

character of the harbour.

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Construction Aesthetic appearance and integrity of

the site

1 -1 2 2 2 -6 -1 Probable

Daily Operations Contribution to the landscape

character, enhanced aesthetic

appearance

2 1 2 2 2 12 2 Probable

Desired Outcome: To minimise aesthetic impacts associated with the facility.

Actions

Mitigation: Regular waste disposal, good housekeeping and routine maintenance on infrastructure

will ensure that the longevity of structures are maximised and a low visual impact is

maintained.

Responsible Body:

Proponent

Contractors


A report should be compiled every 6 months of all complaints received and actions taken.

Page 62 of 88


Impacts on Utilities, Infrastructure and Seabed Scouring

Any damage caused to existing infrastructure and services supply like sewers, water or

electricity where present. Additional demand for electricity and potable water and increased

effluent discharges into sewers may add strain on the available services supply of the area.

Scouring of the seabed caused by vessel propellers. This may lead to the upwelling of

sediments, which in return may impact the depth of certain areas as well as impact on the

structural integrity of jetties and quays.

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Construction Phase Disruption of services. Too shallow

vessel manoeuvring areas 2 3 2 2 1 -30 -3 Improbable

Daily Operations Too shallow vessel manoeuvring

areas.

Unwanted chemicals or hydrocarbons

entering any sewers

2 -1 2 2 2 -12 -2 Probable

Desired Outcome: No impact on utilities and infrastructure. No unwanted products entering

sewers. Water depth maintained at safe vessel manoeuvring depths.

Actions

Prevention: Appointing qualified and reputable contractors is essential.

The contractor must determine exactly where amenities and pipelines are situated before

construction commences (utility clearance e.g. ground penetrating radar surveys). Liaison

with the Municipality and suppliers of services is essential.

Liaise with suppliers of water, electricity and sewers in terms of supply and demand

statistics. Timely communication of significant increases in future usage of resources to

allow for planning and additional provision.

Scour protection should be installed where necessary to protect the seabed from scouring

and to prevent siltation of adjacent berthing areas. Dredging activities must comply with

the capital and maintenance dredging EIA and EMPs of Namport (Botha et al. 2013;

Botha et al. 2014a; Botha et al. 2014b).

Regular water depth determination.

All drains leading directly into sewers must be closed off, and locked where possible, to

prevent any unwanted products from entering sewers should an accidental spill, pipe

burst, valve malfunction, etc. occur. Where drains are present to drain wash water, these

should only be opened during times of washing and closed immediately thereafter.

Mitigation: Implement programmes to monitor consumption of water and electricity and programmes

to ensure water and energy efficient strategies.

Emergency procedures available on file.

Timely planning for temporary measures to supply electricity and water during shortages

in their supply.

Regular maintenance dredging to be performed when necessary.

Responsible Body:

Proponent

Contractors

Page 63 of 88



Utility drawings (municipal)

Supply and demand statistics for water and electricity.

A report should be compiled every 6 months of all incidents of water and electricity

disruptions reported or incidents of damage to utilities and infrastructure. This should

include measures taken to deal with the situation and ensure that such incidents do not

repeat themselves.

Page 64 of 88


Cumulative Impact

Although the surface water contamination impact from the operations on the premises can be

sufficiently mitigated, the cumulative impact due to multiple industries in area extracting

seawater and discharging effluent into the Atlantic Ocean, may increase the environmental

risk related to this impact.

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Construction Phase The build-up of minor impacts to

become more significant

2 -1 2 2 2 -12 -2 Probable

Daily Operations The build-up of minor impacts to

become more significant

2 -2 2 2 2 -24 -3 Probable

Desired Outcome: To minimise cumulative impacts associated with the facility and industry.

Actions

Mitigation: It is recommended that all industries in the area utilising seawater and discharging effluent

into the ocean implement a joint monitoring program to ensure the water quality of the

harbour does not decrease.

Reviewing biannual and annual reports for any new or re-occurring impacts or problems

would aid in identifying other cumulative impacts and help in planning if the existing

mitigations are insufficient.

Responsible Body:

Proponent

Fish processing industry


Annual summary report based on all other impacts must be created to give an overall

assessment of the impact of the operational phase.

A joint water quality monitoring program may be implemented by the industries in the

area.

Page 65 of 88


DECOMMISSIONING AND REHABILITATION Decommissioning is not foreseen during the three year validity period of the environmental

clearance certificate. Should decommissioning occur at any stage, rehabilitation of the area may

be required. Decommissioning will entail the complete removal of all infrastructure including

buildings and underground infrastructure. Any pollution present on the site must be remediated.

The impacts associated with this phase include noise and waste production as structures are

dismantled. Noise must be kept within WHO standards and waste should be contained and

disposed of at an appropriately classified and approved waste facility and not dumped in the

surrounding areas. Future land use after decommissioning should be assessed prior to

decommissioning and rehabilitation initiated if the land and infrastructure would not be used for

future purposes. The Environmental Management Plan for the facility will have to be reviewed

at the time of decommissioning to cater for changes made to the site and implement guidelines

and mitigation measures.

ENVIRONMENTAL MANAGEMENT SYSTEM The proponent Hangana Seafood implements numerous in-house and international policies and

standards to ensure protection of health, safety environment and quality. These include various

management standards, a Corporate Social Responsibility (CSR) strategy, and BRC Global

Standards for Food Safety, ISO 22000:2005 and Hazard Analysis and Critical Control Points

(HACCP) 10330. Hangana Seafood subscribes to a group environmental management system

that ensure ongoing incorporation of environmental constraints. At the heart of an EMS is the

concept of continual improvement of environmental performance with resulting increases in

operational efficiency, financial savings and reduction in environmental, health and safety risks.

An effective EMS need to include the following elements:

A stated environmental policy which sets the desired level of environmental performance;

An environmental legal register;

An institutional structure which sets out the responsibility, authority, lines of communication

and resources needed to implement the EMS;

Identification of environmental, safety and health training needs;

An environmental program(s) stipulating environmental objectives and targets to be met, and

work instructions and controls to be applied in order to achieve compliance with the

environmental policy; and

Periodic (internal and external) audits and reviews of environmental performance and the

effectiveness of the EMS.

The Environmental Management Plan

10 ALTERNATIVES TO THE PROJECT The new factory is being constructed on a property owned by Hangana Seafood, and is used for similar

operations, within the fishing harbour of Walvis Bay. Industries on the surrounding properties are of

similar nature. The Hangana Seafood premises being located on the shore within the harbour ensure

fish are offloaded as close to the factory and other operations as possible, thus preventing additional

environmental impacts such as increased traffic in Walvis Bay.

Hangana Seafood should consider incorporating a dissolved air floatation (DAF) plant, or similar, into

the design of the new factory, as a method of cleaning effluent from the fish factory before it is pumped

into the ocean. The DAF plant will reduce the BOD and COD of effluent and thus reduce any negative

impacts on the marine environment.

All chemicals used on site must be handled according to their MSDS requirements. For chemicals that

will form part of effluent to be discharged into the ocean, environmental effects must be considered and

alternative chemicals investigated if needed.

Page 66 of 88


11 CONCLUSION Operations on the Hangana Seafood premises has a positive impact on Walvis Bay and Namibia as a

whole. Operations on the premises has a significant impact on employment, payment of taxes and fees

and income opportunities created for the downstream businesses as a number of indirect jobs are also

created through the outsourcing of certain services to contractors. The construction of the new factory

will amplify these positive impacts.

During the update of the environmental assessment, potential environmental impacts resulting from the

additional activities on the Hangana Seafood premises were identified. Negative impacts can however

successfully be prevented or mitigated while positive impacts can be maximised. Noise pollution should

at all times meet the minimum World Health Organization requirements to prevent hearing loss and not

to cause a nuisance to nearby receptors. Health and safety regulations should be adhered to in

accordance with the regulations pertaining to relevant laws and internationally accepted standards of

operation. Contaminated water must be prevented from entering the ocean, especially old oil and sludge

from the recycling plant. Any waste produced must be removed from site and disposed of in an

appropriate way or re-used or recycled where possible. Hazardous waste must be disposed of at an

approved hazardous waste disposal site. Surface water contamination is a serious concern and should

be prevented by safe work practices and regular inspection and maintenance of the effluent sump.

Vapours and odours emitted during operations of the fishmeal plant should at all times be kept at a

minimum. All permits should remain up to date and strictly adhered to.

The Environmental Management Plan should be used as an on-site reference document for all the

operational activities. Parties responsible for transgression of the EMP should be held responsible for

any rehabilitation that may need to be undertaken. Hangana Seafood should use their group

environmental management system and related policies and standards in conjunction with the

Environmental Management Plan. It is imperative that all construction and operational personnel are

taught the contents of these documents to ensure better environmental practises all round.

Based on the information supplied in this EIA, and if all preventative, mitigation and monitoring

methods are strictly adhered to, activities and construction on the Hangana Seafood premises should be

able to continue without significant environmental impacts.

Table 16. Impact Summary Class Values

BE = Biological/Ecological EO = Economical/Operational PC = Physical/Chemical SC = Sociological/Cultural

Impact Category Impact Type Construction Operations

5 5-5 -5

EO Skills, Technology and Development 2 4

EO Revenue Generation and Employment 2 4

SC Demographic Profile and Community Health -1 -2

SC Traffic -2 -2

SC Health, Safety and Security -2 -2

PC Fire -2 -2

PC/SC Air Quality -1 -2

PC Noise -2 -2

PC Waste Production -2 -3

BE Ecosystem and Biodiversity Impact -1 -3

PC/BE Groundwater, Surface Water and Soil Contamination -2 -3

SC Visual Impact -1 2

PC/SC Impacts on Utilities, Infrastructure and Seabed Scouring -3 -2

PC Cumulative Impact -2 -3

Positive Rating Scale: Maximum Value

Negative Rating Scale: Maximum Value

Page 67 of 88


12 REFERENCES Botha, P. 2011. Final Environmental Monitoring Report for Walvis Bay Harbour Capital Dredging of

the Entrance Channel. Geo Pollution Technologies.

Botha, P., Hooks. P. & Faul, A. 2013. Update of the Environmental Impact Assessment for the Capital

and Maintenance Dredging of Walvis Bay Harbour.

Botha P., Hooks P. & Faul A., 2014a October; Environmental Management Plan #1 Update For The

Capital And Maintenance Dredging Of Walvis Bay Harbour.

Botha P., Hooks P. & Faul A., 2014b October; Environmental Management Plan #2 Update For The

Capital And Maintenance Dredging Of Walvis Bay Harbour.

COWI, 2003a. Walvis Bay Local Agenda 21 Project Namibia. Coastal Area Study. Marine Pollution.

Danida 2003.

COWI, 2003b. Walvis Bay Local Agenda 21 Project Namibia. Coastal Area Study. Hydrodynamic

Modelling. Danida 2003.

De Beer, GJ. 2017. Technical report, Application of Permit: Waste Water Discharge. Hangana Seafood

(Pty) Ltd.

Digital Atlas of Namibia Unpublished Report. Ministry of Environment & Tourism

Directorate of Environmental Affairs, 2008. Procedures and Guidelines for Environmental Impact

Assessment (EIA) and Environmental Management Plans (EMP), Directorate of Environmental

Affairs, Ministry of Environment and Tourism, Windhoek.

DMC-CSIR, (Delta Marine Consultants & Centre for Scientific and Industrial Research), 2010. EIA

Study for Strategic Expansion of the Walvis Bay Container Terminal. Final Environmental Impact

Report and Environmental Management Plan.

Faul A, Botha P, Brews L. 2016. Environmental Impact Scoping Assessment for the Jetty and Quay

Wall Construction of Hangana Seafood in the Fishing Harbour of Walvis Bay

Namibia Statistics Agency. Namibia household Income and Expenditure Survey 2009/2010.

Namibia Statistics Agency. Namibia 2011 Population and Housing Census Main Report.

National Planning Commission, 2012. Namibia 2011 Population and Housing Census – Preliminary

Results.

Pastakia, C.M.R.; 1998; The Rapid Impact Assessment Matrix (RIAM) – A new tool for Environmental

Impact Assessment.

Tractebel, 1998. Environmental Impact Assessment study for the dredging of the port of Walvis Bay -

Final Report. February 1998.

http:// www.weatherunderground.com accessed 14 January 2015

Page 68 of 88


Appendix A: Proof of Public Consultation

Page 69 of 88


Notified and Registered IAPs Contact Person Organisation

Kaatri Brumfitt NACOMA

Kleopas Kantika NACOMA

Iina Ruben NACOMA

Anja Kreiner Ministry of Fisheries and Marine Resources

Victor Libuku Ministry of Fisheries and Marine Resources

Elina SP Vakuwile Environmental Practitioner

Juan Magdelena NovaNam Ltd.

Jose Ramon Canosa NovaNam Ltd.

Patricia S. Kaulinge NovaNam Ltd.

Luisa Negonga NovaNam Ltd.

Toivo Neliwa Abroma Fishing

Petrus Shoopala Abroma Fishing

Wilma Nasima Abroma Fishing

Elzevir Gelderbloem Namport

Tim Eiman NamPort

Howard Rieth Express Bearing Centre

Cardinale de Klerk Walvis Trawl

Linde Punzul Raylin Engineering

Regan Diergaart Erongo Red

Lorraine Beukes Deep Ocean (Novanam)

Lelani Coetzee Municipality of Walvis Bay (Office of the Secretary of the CEO)

Permanent Secretary Ministry of Fisheries and Marine Resources

Page 70 of 88


Notification Letter

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Notification Letter: Ministry of Fisheries and Marine Resources

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Notification Letter Delivery Sheet

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Appendix B: Proponent Permits

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Appendix C: Consultants’ Curriculum Vitae

Page 85 of 88


Hydrogeologist Pierre Botha

Pierre Botha is the Managing Director of Geo Pollution Technologies, Namibia. Mr. Botha has excellent

experience and knowledge in Environmental Impact Assessments, groundwater pollution assessment,

groundwater exploration, resource evaluation, urban and rural water supply, groundwater management,

monitoring and hydrochemistry. He gained most of his experience in Namibia and is involved in the

Namibian groundwater industry since 1992.

Mr Botha's experience in the environmental / groundwater field has been gained from various projects

ranging from groundwater exploration, groundwater management and modelling, environmental impact

assessments, pollution mapping and rehabilitation to health risk evaluations.

CURRICULUM VITAE PIERRE BOTHA Name of Firm : Geo Pollution Technologies (Pty) Ltd. Name of Staff : PIERRE BOTHA

Profession : Hydrogeologist / Hydrologist

Environmental Assessment Practitioner

Years’ Experience : 25

Nationality : Namibian

Position : Managing Director

Specialisation : Hydrogeology

Languages : Afrikaans – speaking, reading, writing – excellent

English – speaking, reading, writing – excellent

EDUCATION AND PROFESSIONAL STATUS: B.Sc. Geology & Geography : University of OFS, 1992

B.Sc. (Hons.)(cum laude) Geohydrology/Hydrology : University of OFS, 1994

First Aid Class A EMTSS, 2017

Basic Fire Fighting EMTSS, 2017

PROFESSIONAL SOCIETY AFFILIATION: Environmental Assessment Professionals of Namibia (EAPAN) – President 2014 - Vice President 2012, 2013

Hydrogeological Association of Namibia (HAN)

Geological Association of Namibia

AREAS OF EXPERTISE: Knowledge and expertise in:

risk based corrective action analyses

bioremediation

monitoring, mapping and evaluation of groundwater pollution

hydrochemistry studies

environmental impact assessments

project management

soil vapour surveys

groundwater modelling

groundwater monitoring

hydrocensus

hydrogeological data evaluation and interpretation

groundwater exploration and resource evaluation

geophysical interpretations (Ground Penetrating Radar, Electrical Resistivity, Electromagnetic & Magnetic)

urban and rural water supply

groundwater management

borehole siting, drilling and test pumping supervision, aquifer testing

EMPLOYMENT: 1998-Date : Geo Pollution Technologies (Pty) Ltd

1995 : Parkman Namibia (Groundwater Consulting Services) - Hydrogeologist

1994 : Institute for Groundwater Studies, University of the Orange Free State - Hydrogeologist

1992-1993 : Groundwater Consulting Services - Field Geologist

1988 : Tsumeb Corporation Ltd - Student geologist

PUBLICATIONS: Contract reports : +400

Publications : 1

Page 86 of 88


ENVIRONMENTAL SCIENTIST André Faul

André entered the environmental assessment profession at the beginning of 2013 and since then has

worked on more than 70 Environmental Impact Assessments including assessments of the petroleum

industry, harbour expansions, irrigation schemes, township establishment and power generation and

transmission. André’s post graduate studies focussed on zoological and ecological sciences and he holds

a M.Sc. in Conservation Ecology and a Ph.D. in Medical Bioscience. His expertise is in ecotoxicological

related studies focussing specifically on endocrine disrupting chemicals. His Ph.D. thesis title was The

Assessment of Namibian Water Resources for Endocrine Disruptors. Before joining the environmental

assessment profession he worked for 12 years in the Environmental Section of the Department of

Biological Sciences at the University of Namibia, first as laboratory technician and then as lecturer in

biological and ecological sciences.

CURRICULUM VITAE ANDRÉ FAUL Name of Firm : Geo Pollution Technologies (Pty) Ltd. Name of Staff : ANDRÉ FAUL

Profession : Environmental Scientist

Years’ Experience : 17

Nationality : Namibian

Position : Environmental Scientist

Specialisation : Environmental Toxicology

Languages : Afrikaans – speaking, reading, writing – excellent

English – speaking, reading, writing – excellent

EDUCATION AND PROFESSIONAL STATUS: B.Sc. Zoology : University of Stellenbosch, 1999

B.Sc. (Hons.) Zoology : University of Stellenbosch, 2000

M.Sc. (Conservation Ecology) : University of Stellenbosch, 2005

Ph.D. (Medical Bioscience) : University of the Western Cape, 2018



PROFESSIONAL SOCIETY AFFILIATION: Environmental Assessment Professionals of Namibia (Learner Practitioner)


Water Sampling, Extractions and Analysis

Biomonitoring and Bioassays

Biodiversity Assessment

Toxicology

Restoration Ecology

EMPLOYMENT: 2013-Date : Geo Pollution Technologies – Environmental Scientist

2005-2012 : Lecturer, University of Namibia

2001-2004 : Laboratory Technician, University of Namibia

PUBLICATIONS: Publications: 5 + 1 in preparation

Contract Reports +70

Research Reports & Manuals: 5

Conference Presentations: 1

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ENVIRONMENTAL GEOLOGIST Wikus Coetzer

Wikus has 4 years’ experience in environmental science related fields with 1 year experience in

conducting environmental impact assessments and preparation of environmental management plans.

He holds an honours degree in Environmental Sciences – Environmental Geology from the Northwest-

University Potchefstroom (NWU) South Africa. He first completed a B.Sc. degree in Geology and

Botany in the required time also from the Northwest University Potchefstroom, South Africa. His

honours project focused on the rehabilitation and phytoremediation of various tailings types and soils.

He has working experience as an environmental monitor / assisting environmental officer at Petra

Diamonds, Cullinan Diamond Mine (CDM) where he gained a proper understanding of environmental

monitoring responsibilities as well as legislations, regulations and the implementation of

EMS/ISO14001. He started working at Geo Pollution Technologies in 2017, and regularly

conducts/assists and report on environmental impact assessments, environmental management plans

and pollution surveys.

CURRICULUM VITAE WIKUS COETZER

Name of Firm : Geo Pollution Technologies (Pty) Ltd. Name of Staff : WIKUS COETZER

Profession : Environmental Geologist

Nationality : South African

Position : Environmental Geologist

Specialisation : Environmental Geology/ Geochemistry

Languages : Afrikaans – speaking, reading, writing

English – speaking, reading, writing

EDUCATION AND PROFESSIONAL STATUS: B.Sc. Environmental and Biological Sciences – Geology & Botany : NWU Potchefstroom 2013

B.Sc. (Hons.) Environmental Sciences – Environmental Geology : NWU Potchefstroom 2014




Phytoremediation

Environmental Geology / Geochemistry

Environmental Monitoring

Environmental Compliance

EMPLOYMENT: 2017 - : Geo Pollution Technologies

2015 - 2016 : Petra Diamonds CDM – Environmental monitor / Assisting environmental officer

2015 : Petra Diamonds CDM – Graduate program: Environmental Officer

2014 : NWU Potchefstroom department of Geo and Spatial Sciences – Research assistant

PUBLICATIONS: Contract Reports: +15

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