Amended Environmental Management Plan for the Tsumeb Smeltereia.met.gov.na/screening/121_20160319_EMP Amendment... · high arsenic content. Currently, it receives copper concentrate

Tsumeb Smelter

Amended Environmental Management Plan for the Tsumeb

Smelter

SLR Project No.: 734.04040.00007

February 2016

Dundee Precious Metals Tsumeb

Tsumeb Smelter

Amended Environmental Management Plan for the Tsumeb

Smelter

SLR Project No.: 734.04040.00007

February 2016

Dundee Precious Metals Tsumeb

DOCUMENT INFORMATION

Title Amended Environmental Management Plan for the Tsumeb Smelter

Project Manager Simon Charter

Project Manager e-mail [email protected]

Author Simon Charter

Reviewer Werner Petrick

Client Dundee Precious Metals Tsumeb

Date last printed 2016/09/23 09:34:00 AM

Date last saved 2016/09/23 09:34:00 AM

Comments

Keywords Dundee, amendment, Tsumeb, EMP

Project Number 734.04040.00007

Report Number 734.04040.00007

Revision Number 1

Status Final

Issue Date February 2016

This report has been prepared by an SLR Group company with all reasonable skill, care and diligence,

taking into account the manpower and resources devoted to it by agreement with the client. Information

reported herein is based on the interpretation of data collected, which has been accepted in good faith as

being accurate and valid.

No warranties or guarantees are expressed or should be inferred by any third parties.

This report may not be relied upon by other parties without written consent from SLR.

SLR disclaims any responsibility to the Client and others in respect of any matters outside the agreed

scope of the work.

SLR Consulting Africa

SLR Ref. 734.04040.00007

Amended Environmental Management Plan for the Tsumeb Smelter

February 2016

Page i

AMENDED ENVIRONMENTAL MANAGEMENT PLAN FOR THE TSUMEB SMELTER

CONTENTS

1 INTRODUCTION ................................................................................................................................ 1-1

1.1 BACKGROUND AND PURPOSE ......................................................................................................... 1-1

2 DESCRIPTION OF OPERATIONS .................................................................................................... 2-3

2.1 RECEIVING BAY ............................................................................................................................. 2-3

2.2 COPPER REVERBERATORY FURNACE .............................................................................................. 2-3

2.3 AUSMELT FURNACE........................................................................................................................ 2-3 2.3.1 PIERCE SMITH CONVERTER FURNACE ........................................................................................................ 2-3 2.3.2 ARSENIC PLANT AND BAG HOUSE ................................................................................................................ 2-4 2.3.3 SLAG MILL ............................................................................................................................................... 2-4 2.3.4 POWER PLANT ......................................................................................................................................... 2-5 2.3.5 OXYGEN PLANT ........................................................................................................................................ 2-5 2.3.6 OTHER INFRASTRUCTURE .......................................................................................................................... 2-5 2.3.7 WASTE SITES ........................................................................................................................................... 2-5

3 ENVIRONMENTAL MANAGEMENT PLAN ...................................................................................... 3-1

3.1 AIMS ............................................................................................................................................. 3-1

3.2 OBJECTIVES .................................................................................................................................. 3-1

3.3 MANAGEMENT ACTIONS ................................................................................................................. 3-1

3.4 ROLES AND RESPONSIBILITIES ........................................................................................................ 3-1

3.5 SCHEDULE ..................................................................................................................................... 3-2

3.6 REQUIREMENTS FOR IMPLEMENTATION ........................................................................................... 3-2

3.7 PROTOCOLS ................................................................................................................................... 3-2

3.8 ENVIRONMENTAL MANAGEMENT PLAN ............................................................................................ 3-3

LIST OF TABLES

TABLE 5-1: ROLES AND RESPONSIBILITIES FOR IMPLEMENTATION OF THE EMP ......................................... 3-1


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ACRONYMS AND ABBREVIATIONS

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

Acronyms / Abbreviations

Definition

ACW Asbestos Containing Waste

DPMT Dundee Precious Metals Tsumeb

EA Environmental Assessment

EEC Estimated Environmental Concentration

EMP Environmental Management Plan

ETP Effluent Treatment Plant

Ha Hectare

HDPE High Density Polyethylene

OMPL Ongopolo Mining and Processing Limited

MET Ministry of Environment and Tourism

Minimum Requirements Minimum Requirements for the Handling, Classification and Disposal of Hazardous Waste.

PPE Personal Protective Equipment

PM10 Particular matter less than 10 micrometre

SA-DWAF South African Department of Water Affairs and Forestry

SLR SLR Namibia (Pty)

TSC Tsumeb Smelter Complex


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AMENDED ENVIRONMENTAL MANAGEMENT PLAN FOR THE TSUMEB SMELTER

1 INTRODUCTION

1.1 BACKGROUND AND PURPOSE

The Tsumeb Smelter, currently owned and operated by Dundee Precious Metals Tsumeb (DPMT), a

subsidiary of Dundee Precious Metals Incorporated (Dundee), is located on the outskirts of Tsumeb in

the Oshikoto Region of Namibia, approximately 2 km North East of the town centre. Various metals have

been mined at the Dundee Precious Metals Tsumeb (DPMT) site for over a hundred years. Between

1961 and 1963 the original smelter was replaced with a new copper and lead smelter while an arsenic

plant and a cadmium plant were also established for the processing of by-products originating from the

smelting process. At the time, the combination of the copper and lead smelter with an arsenic and

cadmium plant allowed for the interchange of intermediate products between the smelter lines and

provided a suitable bleed for the arsenic and cadmium.

In mid-1998 Goldfields Namibia, the holding company of TCL went into liquidation and the Tsumeb

Smelter was shutdown. In 2000, the former TCL assets were taken over by Ongopolo Mining and

Processing Limited (OMPL) and the copper and arsenic plants were re-commissioned. The cadmium

plant was decommissioned and no lead processing has taken place since re-commissioning. In July 2006

the assets of OMPL were sold to Weatherly Mining International who owned and operated the plant for

four years before selling it to Dundee Precious Metals Inc. (DPM) in March 2010. The company now

operates as Dundee Precious Metals Tsumeb Ltd, a wholly owned subsidiary of DPM that is primarily

listed on Canada’s Toronto Stock Exchange.

The smelter was constructed in the early 1960s to process concentrate from the Tsumeb copper mine

and is one of only five commercial-scale smelters in Africa capable of processing concentrates with a

high arsenic content. Currently, it receives copper concentrate from El Brocal, Peru, Chelopech, Bulgaria,

Kapan, Armenia and Opuwo, Namibia for processing in the smelter.

The Tsumeb Smelter comprises of one primary smelting furnace, the refurbished Ausmelt furnace. The

old reverberatory furnace has been permanently shut down. Both blister copper and arsenic trioxide

(As2O3) are produced from the copper concentrate. The blister copper is delivered to refineries for final

processing and the As2O3 sold to third parties.

Dundee Precious Metals Tsumeb requires ECC renewal from the Ministry of Environment and Tourism

(MET): Department of Environmental Affairs (DEA) as per the requirements of the Environmental

Management Act, 7 of 2007 to continue with its current operations at the Tsumeb Smelter.

MET has informally indicated that the process for ECC renewals is to re-submit the Environmental

Management Plan (EMP) with project description changes where required and where they don’t trigger

any listed activities. This basically involves updating the project description to make it more relevant.


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This Environmental Management Plan (EMP) provides an update to the environmental actions described

in the initial approved EMP (Synergistics, 2011) prepared by Synergistics Environmental Services, and

documents management actions which are designed to meet legal requirements, avoid, minimise or

manage the impacts associated with the construction, operation, decommissioning and closure of the

Tsumeb Smelter.


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2 DESCRIPTION OF OPERATIONS

This section provides an updated description of the existing approved operations.

2.1 RECEIVING BAY

The majority of materials and concentrates are received by rail and are off loaded at the receiving bay.

Materials received include coal, silica, concentrates and ore. These are stockpiled in different sections

for use.

During the preparation of charge for the reverb. or Ausmelt furnaces the necessary fuel, concentrates

and additional materials are (crushed and) blended for introduction into the furnaces. The charge for the

Ausmelt is pelletised in a small pelletising plant.

2.2 COPPER REVERBERATORY FURNACE

The copper reverberatory furnace has been decommissioned.

2.3 AUSMELT FURNACE

The Ausmelt furnace has been refurbished by DPMT to smelt copper concentrates and was re-

commissioned in 2008. The Ausmelt is a Top Submerged Lance (TSL) furnace that is charged with

pelletised copper concentrates and fuelled with heavy furnace oil. Matte from the TSL goes directly to

the converters.

Off-gases from the Ausmelt are filtered through the baghouse before being released to the atmosphere

via the second stack. Dust recovered at the baghouses is taken to the arsenic plant for processing.

2.3.1 PIERCE SMITH CONVERTER FURNACE

Molten matte material tapped off the Ausmelt furnace is transferred to the converter furnace for the final

production of blister copper. Air is added to the matte material and the oxygen reacts with sulphur, iron,

lead, zinc. The sulphur from the metal sulphides provides the energy (exothermic reaction) to complete

the conversion of matte to blister copper. The blister copper (98.5 % Cu) is cast into 1.62 tonne bars for

shipment to refineries.

Slag formed in the converter is either returned to the reverb furnace for further smelting or is granulated

for treatment at the slag mill.

Hot off-gases from the convertor furnace are passed through a balloon flue before being cooled in a

series of U-tubes. A new gas cooling tower was installed in February 2010 to provide additional cooling




Page 2-4 Page 2-4

of the gases before they pass through the convertor section of the copper baghouse before being

released through the copper stack at the southern section of the smelter. The ducting required to carry

the off-gases was replaced in October 2010. The baghouse was also extended to increase its capacity

in February 2011.

2.3.2 ARSENIC PLANT AND BAG HOUSE

Concentrates and other secondary material processed at the smelter are traditionally high in arsenic.

The majority of the arsenic passes through the smelter and is captured from the off-gases in the bag

houses. Bag house dusts with high arsenic levels are used as feedstock into the arsenic plant. Bag

house dusts that cannot be processed in the arsenic plant are disposed of in the hazardous waste

disposal site.

The arsenic plant is used to produce arsenic trioxide from dusts recovered during the smelting process.

Four roasters are used to convert the material into arsenic trioxide, which is sold for the manufacture of

pesticides and wood treatment.

The plant operates a two stage process, firstly converting the arsenic dusts into black arsenic and then

producing 99% arsenic trioxide from the black arsenic. In the initial conversion the bag house dusts are

mixed with coal fines and pyrite (or other sulphur-bearing material) and introduced to the roaster. In the

second conversion the resulting black arsenic is mixed with coal and slag material and introduced to the

roaster. During the roasting process arsenic sublimes and is then condensed as arsenic trioxide.

Roaster calcines are formed as a by-product from the arsenic plant and are either dumped as waste or, if

copper is present, returned to the smelting cycle.

Off-gases from the arsenic plant pass through a bag house before being released to the atmosphere

through the same stack as the Ausmelt off-gases.

Both the bag house and arsenic plant have been improved in recent years as per the currently approved

EMP requirements. The original bag house was removed and replaced with a newer facility in order to

improve efficiency. The arsenic plant has been improved in order to reduce dust emissions. This has

primarily been achieved through the replacements of the original manual handling system to an

automated enclosed pneumatic system.

2.3.3 SLAG MILL

Slag material skimmed from the various furnaces is either smelted directly or is granulated and passed to

the slag mill for milling and concentration of copper by conventional flotation. The concentrates

produced are re incorporated into the smelting process. The tailings produced during the flotation

process are deposited on the old mined section of the old tailings dam located to the east of the smelter.




Page 2-5 Page 2-5

2.3.4 POWER PLANT

Electrical power for the majority of the smelters operations was historically supplied by an on-site power

plant. The power plant has been decommissioned in recent years and electrical power is drawn from the

national grid as required. However, the cooling component of the power plant is still in use.

2.3.5 OXYGEN PLANT

An oxygen plant was commissioned by in February 2010 in order to increase production at the Ausmelt.

The oxygen plant extracts oxygen from air and produces oxygen (96% O2). The oxygen is injected into

the Ausmelt furnace where it will react predominantly with iron and sulphur through exothermic reactions.

As a result of the additional heat in the Ausmelt it is possible to smelt greater quantities of copper

concentrate and thus increase production. Burning of the sulphur in the concentrate also reduces the

consumption of fuels such as coal and heavy furnace oils. The additional heat from the sulphur and

oxygen provides for a higher smelting rate.

A new oxygen plant and associated infrastructure was commissioned in January 2014.

2.3.6 OTHER INFRASTRUCTURE

Other infrastructure present on site includes:

Admin and support buildings

New offices (container offices)

New general warehouse

Canteen

Reservoirs

Roads (gravel and tar)

Rail loop

There are also a number of additional operation components that have been approved by the MET in

separate EIA applications and are managed through separate EMPs. These include:

New sulphuric acid plant and associated infrastructure

New sewerage plant

2.3.7 WASTE SITES

2.3.7.1 Blast Furnace Slag Dump

Slag originating from the blast furnace in the lead section of the smelter was historically disposed on site

and resulted in the formation of an extensive blast furnace slag dump which is still present on site. The

slag however contains high concentrations of some sought after metals including germanium. The blast




Page 2-6 Page 2-6

furnace has not been in operation since the operations ceased and thus blast furnace slag is no longer

produced.

2.3.7.2 Tar Pits

The tar present on the site originated as a waste product produced from a “gas producer” that was in

operation in the past. The gas producer was utilised to generate gas used to fire the lead furnaces the

sinter plant as we as the arsenic roasters at the arsenic plant. A combination of coal and wooden blocks

were used as a fuel for the gas produced. The wooden blocks were supplied by local farmers in the

area. The process resulted in the production of tar and ash and this material was frequently cleaned

from the cyclones and gas pipes at the gas producer plant. The plant has not been operated for many

years.

The tar was disposed of in drums or directly onto surface at various sites at the smelter. Two existing tar

disposal sites are currently known. Requirement’s for the cleaning up of these tar pits has bene included

in the EMP.

2.3.7.3 Old Slag Mill Tailings Dump

Historically the tailings originating from the slag mill were deposited north of the slag mill adjacent to the

access road to the smelter. The dump contains high levels of metals including copper. The newer

tailings dam to the east of the smelter was used for the disposal of slag mill tailings under the previous

Smelter owner’s operations. DPMT currently disposes of the slag mill tailings in the reworked section of

the old tailings dam located west of the smelter.

2.3.7.4 Mine Tailings Dumps

Tailings originating from the Tsumeb Concentrator were deposited on a tailings dam located within the

Tsumeb Smelter Complex for the purposes of this EMP this has been referred to as the “old tailings

dam”. TCL decided to rework a section of this tailings dam, necessitating the need for a new tailings

dam which was established as a valley fill to the east of the smelter complex.

The new tailings dam was used by OMPL both for slag mill and mine tailings originating from the Tsumeb

Mill (when it was in operation). The eastern tailings dam is no longer in use and requires rehabilitation.

DPMT have made use of the reworked section of the old tailings dam for the disposal of slag mill tailings.

Linked to the old tailings dam is a return water dam, evaporation ponds and associated pump houses.

Also linked is an old building and transformer (seeping) at the floor of the old tailings dam.

2.3.7.5 Arsenic Calcines Dumps

Calcines are produced in the arsenic roasters as a waste product. When the lead smelter was in

operation the calcines were used as a feed into the blast furnace. However, from 1988 the quantity of

calcines produced was in excess of what could be used as a feed into the lead smelter. The excess




Page 2-7 Page 2-7

material was dumped on a section of the blast furnace slag dump, west of the arsenic plant. Some

calcines were also produced by OMPL and dumped adjacent to the TCL material.

2.3.7.6 Hazardous Waste Disposal Site

The HWS is located within an old rock quarry located south of the Smelter Complex on a ridge

separating the Smelter from the town of Tsumeb. The site is within the DPMT property boundaries,

approximately 650 m north east of the old Tsumeb Mine (19° 14’ 10”S & 17° 43’ 20”E). The quarry (and

hence the approved landfill footprint) covers an area of approximately 5 ha.

Quarrying activities at the proposed site have resulted in the formation of two terraces, with the northern

section having been excavated to a depth of approximately 8 m lower than the southern section. The

waste site has been developed in the lower section along the northern section of the site.

The HWS was constructed in 2012 and has been designed with both a synthetic (HDPE) and clay liner,

an under drainage system for the collection of leachate originating within the waste and a leachate

detection system which provides for the monitoring of the competency of the liners. The facility has a

permitted capacity to contain approximately 280 000 m3 of hazardous waste. Some optimisation of the

site within the approved/permitted boundaries has been undertaken in 2014/2105. As per the existing

approved EIA, a further small construction within the existing (old) quarry footprint is allowed and as is

planned for 2016/17. No further expansion of the facility is planned or has been applied for at this time.

2.3.7.7 General Waste Disposal Site

General waste including domestic waste and office waste is disposed of within the smelter property.

Workshop waste is disposed together with this waste at a site located to the east of the old tailings dam

and immediately south of the smelter buildings.

Recyclable general waste (cans, papers, plastics, glass) is collected at 3 recycling stations on site and

removed by an independent waste contractor for recycling and processing off-site.

2.3.7.8 RCC Quarry Operations

The Namibian Roads Contractor Company (RCC) operates a quarrying activity in the property of the

smelter. The quarry was established to produce construction material used for the Northern Extension

Railway development from Tsumeb to Ondangwa.

The quarry does not operate on a full time basis and when it does it is responsible for its own dust

suppression and general environmental management (it has recently purchased and installed its own

sprinkler). DPMT provides general oversight of the operations of the quarry insofar as they have the

potential to contribute to DPMT’s overall environmental impact. Regular liaison meetings between

DPMT’s environmental management department and quarry management are held.




Page 3-1

3 ENVIRONMENTAL MANAGEMENT PLAN

3.1 AIMS

The aim of the environmental management plan (EMP) is to detail the actions required to effectively

implement the mitigation measures identified in the environmental impact assessment (EIA). These

actions are required to minimise negative impacts and enhance positive impacts associated with the

operations at the Tsumeb Smelter.

The EMP gives the commitments, which form the environmental contract between Dundee Precious

Metals Tsumeb (DPMT) and the Government of the Republic of Namibia. Represented by the Ministry of

Environment and Tourism.

It is important to note that an EMP is a living document in that it will be updated and amended as new

information (e.g. environmental data), policies, authority guidelines and technologies develop.

3.2 OBJECTIVES

Specific objectives are given for each of the actions described in the EMP. These objectives relate

directly to addressing the impacts identified in the EIA.

3.3 MANAGEMENT ACTIONS

The various actions that need to be implemented in order to ensure that environmental objectives are met

are described in the EMP. Each action is given a reference number. The actions are measurable and

are therefore are easy to monitor. Compliance with the EMP can thus also be audited.

3.4 ROLES AND RESPONSIBILITIES

The Environmental Contract is between DPMT and the government. DPMT is thus responsible for

adherence to the EMP. The successful implementation of the EMP is however dependent on clearly

defined roles and responsibilities for each of the management actions given in the EMP. Table 3-1 sets

out the roles and responsibilities prescribed to relevant parties for the implementation of the EMP.

TABLE 3-1: ROLES AND RESPONSIBILITIES FOR IMPLEMENTATION OF THE EMP

DPMT Management: Those responsible for the overall management of DPMT operations

under the managing director.

HWS and tailings

superintendent:

DPMT representative overall responsible for the management of the

Hazardous Waste Site and tailings facility.




Page 3-2

Site Manager: A representative of DPMT responsible for overseeing the day-to-day

implementation of the project and the overall management of the site

team.

Environmental Control

Officer:

A member of DPMT management responsible for ensuring

compliance of the project team with the EMP.

Site Engineer:

A representative of the consulting engineers present on site during

construction.

Environmental Consultant: Independent consultants appointed to audit the implementation and

compliance with the EMP.

Service Provider: A company awarded a contract by DPMT to undertake a component

of the waste site project.

Environmental Department: Environmental Department of DPMT, responsible for environmental

monitoring.

3.5 SCHEDULE

The schedule serves to give the time-frame in which the environmental management measures are to be

implemented. The successful implementation of the action within the specified timeframes is to be

monitored.

3.6 REQUIREMENTS FOR IMPLEMENTATION

This component of the EMP details what is required for the action to be implemented successfully. This

includes equipment, supplementary documentation, protocols and additional actions that will need to be

put in place.

3.7 PROTOCOLS

Protocols are developed to supplement the actions given in the EMP and provide a detailed description of

how the action is to be implemented.


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3.8 ENVIRONMENTAL MANAGEMENT PLAN

Ref. Objective Responsibility Schedule Requirements for Implementation

1 Environmental Awareness and Training

Objective: To ensure that all persons working at the smelter are aware of the objectives of the EMP as well as the consequences of their individual actions

1.1 Environmental induction training is to be undertaken by all persons

undertaking work at the smelter (to be incorporated into normal induction

training) including permanent workers, contractors and consultants.

Environmental Manager Ongoing Environmental induction training material

1.2 On the job environmental training to be undertaken by each person

working at the smelter.

Superintendent/

Supervisors

Ongoing General Environmental Training/Training of supervisors

1.3 An environmental awareness programme to be implemented for smelter

work force addressing pertinent topics as required.

Environmental Manager Immediate

Ongoing

Programme for implementation of awareness topics.

Environment to be an agenda item in SHE meetings.

Poster campaigns

2 Public Relations

Objective: To promote transparency and facilitate communication of the affected public

2.1 Environmental Forum to be established which includes elected

representatives of the Tsumeb community.

Public Relations Officer Within 6 months of

approval

Ongoing

Establish Environmental Forum

2.2 Monitoring information to be made available to the affected community. Environmental Manager Immediate

Ongoing

Community website

Information Centre

Public reports (quarterly reports)

Public meetings (as required but at least every six months)

2.3 Public feedback meetings to be held to communicate information on

smelter operations and to provide opportunity for members of the public to

Public Relations Officer Immediate Public reports (quarterly reports)

Public meetings (as required but at least every six months)


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ask questions and raise concerns.

3. Projects and Expansions

Objective: To ensure that due consideration is to be given to environmental risks associated with projects at the smelter.

3.1 Environmental risks of all projects and expansions to be assessed. Project

Manager/Environmental

Manager

Prior to project

implementation

Environmental risk assessment

3.2 Environmental risks of increased production to be formally assessed prior

to implementation and measures to minimise these risks demonstrated to

be included in project planning.

General Manager Prior to project

implementation

3.3 Environmental legal review is required for all new projects, expansions

and increased production and actions implemented to ensure legal

compliance.

Environmental Manager Prior to project

implementation

Legal review

3.4 Should additional environmental impacts and management actions be

required for projects, expansions and increased production, the EIA and

EMP are to be amended by suitable experts as appropriate to provide for

such actions.

Environmental Manager Prior to project

implementation.

EIA and EMP amendment

4. Air Quality

Objective: To reduce SO2 emissions from the smelter to ensure compliance with international ambient air quality standards

4.1 Daily monitoring of SO2 emissions from stack Environmental Manager Daily Monitoring protocol and schedule approved by an independent

air quality specialist.

4.2 Activities that lead to an increase in current SO2 or arsenic emissions

beyond acceptable/legislated limits are not to be allowed. All production

and process changes are to be assessed prior to implementation to

ensure that no such increases take place.

General Manager Immediate Review of production and process changes prior to

implementation in terms of potential contribution to increased

emissions.


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4.3 Continuous ambient monitoring of SO2 to provide a warning system when

SO2 levels are above the RSA SANS limits (see below).

Environmental Manager Ongoing SO2 continuous monitors.

Automated notification system

4.4 Implement corrective management actions should SO2 levels exceed

guideline levels as per the RSA SANS limits (SANS:1929,2004), and in

line with the number of exceedences of RSA standards as per Table 18,

Appendix M of the Air Impact Assessment report in the Sulphuric Acid

Plant ESIA.

General

Manager/Environmental

Manager

Ongoing Management procedure

Objective: To reduce arsenic emissions from the smelter to ensure compliance with international ambient air quality standards

4.5 Converter furnace hood to be used to reduce fugitive emissions. Operations Manager Ongoing Training of relevant staff.

4.6 Long-term furnace fugitive sampling to be undertaken. Operations Manager Ongoing Monitoring Protocol approved by air quality specialist

4.7 Annual isokinetic sampling of particulates Environmental Manager Ongoing Monitoring Protocol approved by air quality specialist

Objective: To reduce dust at Tsumeb Smelter from new tailings dam.

4.8 Rehabilitation of new tailings dam surface to reduce dust. Environmental Manager Within 1 year of

approval

Tailing rehabilitation protocol.

5. Soils

Objective: To minimise contamination of smelter footprint

5.1 Concrete or similar impervious surfaces are to be provided in all areas

where concentrates and hazardous smelter wastes (e.g. baghouse dusts)

are handled or stored.

Operations Manager Within 6 months of

approval

5.2 The integrity of concrete surfaces is to be checked and maintained on a

continuous basis to ensure that contaminants do not enter into underlying

soils.

Operations Manager Immediate and

ongoing

5.3 The handling and storage of hazardous workshop wastes is to take place

on concrete and bunded surfaces.

Engineering Manager Ongoing


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5.4 Existing stockpiles of arsenic calcines and baghouse dusts are to be

disposed within a hazardous waste disposal facility or another registered

hazardous waste disposal facility.

Environmental Manager June 2012 Identify suitable hazardous waste disposal facility

5.5 Baghouse dusts and calcines that cannot be processed are to be disposed

of at the hazardous waste site.

General Manager Ongoing

5.6 Existing onsite contamination should be managed as part of the broader

site contamination management

Site Manager Ongoing

6.7 Appropriate protective clothing should be worn when in close contact with

the soil material to limit dermal and respiratory contact

H&S Manager Ongoing

5.8 Ensure that the source control measures specified in the plant design are

implemented

Plant Manager Ongoing

5.9 Provide for some specific aspects of the source control measures

specified in the plant design

Plant Manager Ongoing

6. Groundwater and surface water protection

Objective: To minimise contamination risk to groundwater

6.1 Implement commitment 5.1-5.5

6.2 East tailings dam is to be rehabilitated to prevent groundwater pollution as

required.

Environmental Manager Within 1 year of

approval

Four seasons of monitoring to confirm contamination risks and

rehabilitation requirements.

6.3 Groundwater monitoring to be undertaken on a quarterly basis. To be re-

assessed during next EMP renewal process.

Environmental Manager Immediate Monitoring protocol

6.4 Groundwater analyses to be undertaken by an independent laboratory. Environmental Manager Immediate Monitoring protocol

6.5 Regular maintenance and proper safety procedures to prevent leaks and

spills

Plant manager and

Transport manager

Ongoing Maintenance schedules and safety procedures

6.6 Current groundwater site wide monitoring system and sampling procedure SHE Manager / Plant Within 1 year of Improve and update monitoring system and sampling


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should be improved by obtaining accurate information regarding

monitoring borehole construction and equipping boreholes to allow

efficient and consistent collection of groundwater samples.

Manager approval procedure

6.7 Procedures to be put in place to respond to emergency product spills in

areas of DPMT responsibility. This may extend beyond the immediate

boundary of the DPMT site.

SHE Manager / Plant

Manager

Ongoing Emergency spill procedure

6.8 Continued monitoring of groundwater quality and levels for the minimum

period as specified by Namibian environmental regulations where

applicable (e.g. e.g. S 31 EMA and the Water Act).

SHE Manager / Plant

Manager

Ongoing

6.9 Install one upgradient and two down gradient monitoring boreholes that

can be monitored and sampled to determine the potential quality of

unsaturated groundwater flow in the immediate vicinity of the acid plant.

SHE Manager Immediate

6.10 Regular monitoring of the existing groundwater monitoring system shall

occur at least quarterly and reported annually to authorities who regulate

the management of the Tsumeb aquifers (Northern OML aquifer

resource).

SHE Manager Ongoing Monitoring procedure

6.11 Any complaints with respect to the management of groundwater quality

will be directed to the site management. Complaints and any actions

arising from a complaint will be recorded in a complaints register to be

maintained by site management;

SHE Manager Ongoing Complaints register

6.12 Decommissioning and closure procedures will be developed to avoid

contamination of the groundwater resources as a result of actives such as

the demolition, decontamination and storage of potentially contaminated

plant infrastructure and waste.

SHE Manager Within 1 year of

approval

Closure plan

Objective: To minimise contamination risk to groundwater


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6.13 The use of standard erosion control measures, such as interception

drains, contour planting, silt fences, establishment of groundcover species,

optimal drainage construction, and silt ponds are applied where

appropriate. Where possible earthwork activities should be undertaken

during dry periods.

Site manager Within 1 year of

approval

6.14 Construction of a revised stormwater management plan to separate clean

and dirty water areas. Oil and fuel storage areas should be bunded.

Systematic use of bunded areas for acid storage, gas cleaning and acid

handling equipment as well as acid loading area.

Environmental Manager Ongoing Stormwater management plan

6.15 Specific procedures to avoid and to remediate acid/chemical spillages

should be included in operation manual. Storage of hazardous materials

with total volume equal or greater than 1000 litres in areas with impervious

surfaces that are sloped or bermed should be designed to contain a

minimum of 110 % of the largest tank or 25 % of the total storage volume.


approval

Spill management procedures

6.16 Develop mitigation and management strategies for the site when toxic

material is identified, implementation of the management strategy should

occur during the operations.


approval

Mitigation and management streategy

6.17 Regular maintenance and proper safety procedures to prevent leaks and

spills

Plant manager and

Transport manager

Ongoing Maintenance schedules and safety procedures

6.18 Dispose of contaminated material in a landfill designed to take the type of

contaminated material or wastes uncovered.

Environmental Manager Ongoing

7 Noise

Objective: To minimise noise disturbance to surrounding communities

7.1 Monitor public complaints related to noise production from the smelter. Environmental Manager Immediate Complaints procedure

Database of complaints.


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7.2 If a complaint regarding noise emissions relating to the continuous

audibility of the operations, the oxygen plant is to be reduced by installing

a noise shield.

Environmental Manager If required

8 Ecology

Objective: To prevent damage or risks to natural ecology

8.1 Implement measures 4.1-4.5 to reduce risk of damage to vegetative

material as a result of SO2 emissions.

8.2 Implement measures 4.6-4.11 to reduce release of particulates which

results in contamination of soils and browse material.

Objective: To control encroachment by invasive species

8.3 Problem alien invasive species on DPMT property are to be identified and

measures implemented to prevent the invasion of such species.

Environmental Manager Ongoing Procedure for the control of invasives.

8.4 Alien invasive species on DPMT property are to be identified and removed

unless they are providing a stability function (in that case they are to be

replaced prior to removal).

Environmental Manager Ongoing Procedure for the control of invasives.

9 Land Use

Objective: To minimise the risk to agricultural crops and livestock

9.1 Implement measures 4.1-4.5 to reduce risk of damage to vegetative

material as a result of SO2 emissions.

9.2 Implement measures 4.6-4.11 to reduce release of particulates which

results in contamination of soils and browse material.

9.3 Monitor complaints regarding acute damage to vegetative parts of crops

and vegetables and establish a policy related to action and compensation.

Environmental manager Immediate Action and compensation policy

9.4 Buffer zone to be established in consultation with municipal authorities Environmental Manager Within 6 months of Liaise with Municipality in establishing of buffer zone.


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which excludes agricultural development, collection of plant material (such

as marula fruit) and certain commercial activities that place people at risk

within areas that may result in bioaccumulation as a result of historical and

future fallout of dust from the smelter.

approval

Objective: To minimise risk of exposure of residents to contaminants that may pose a health risk

9.5 Buffer zone to be established that excludes residence within areas that

may result in the exposure of persons to air quality emissions on soils

containing high levels of heavy metals.

Environmental Manager Within 6 months of

approval

Buffer zone to be defined based on health risk assessment

Liaise with Municipality in establishing of buffer zone.

10. Community Health

Objective: To monitor the impact of smelter operations on community health

10.1 Buffer zone to be established as per commitment 9.5 based on outcomes

of health risk assessment.

Environmental Manager Within 6 months of

approval

Buffer zone to be defined based on health risk assessment

Liaise with Municipality in establishing of buffer zone.

10.2 Implement measures 4.1-4.11.

10.3 Quarterly (or as identified in health risk assessment) monitoring to be

undertaken of voluntary community members for arsenic in urine and lead

in blood.

Environmental Manager Ongoing Community health monitoring campaign

10.4 Actions are to be identified to address issues of exposure identified by

community health monitoring and to implement measures to reduce such

exposure.

Environmental Manager As required

11 Socio-Economic Investment

Objective: To increase contribution to local economy

11.1 Priority to be given to employment of local persons Human Resources

Manager

Immediate Employment procedure

11.2 Procurement to be given to local providers within the district as far as

practical

Procurement Manager Immediate Procurement hierarchy and decision-making criteria.


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11.3 Tsumeb has a Small and Medium Enterprise (SME) base which could be

utilised. A list of companies is available with the Local Economic

Development Officer at the municipality. It is advised that DPMT

procurement procedures address capacity building within the community

skill sector to meet potential job opportunities available at the plant or any

future DPMT operations.

Procurement Manager Immediate Procurement hierarchy and decision-making criteria.

11.4 With the correct policies and procedures in place and in collaboration with

the local municipalities and NGOs, the community trust can be an effective

tool to enhance the town of Tsumeb.

DPMT Management Ongoing Policies and procedure development

12 Waste management

Objective: To minimise the impacts associated with waste generation on site

12.1 Ensure all waste-storage facilities are properly designed and constructed,

as well as properly lined so as to prevent seepage into subsoil and the

surrounding environment. These precautions will also restrict unwanted

contact with humans and possible incompatible materials.

DPMT Management Ongoing Waste storage procedures

12.2 General requirements for storage of waste:

the containers in which any waste is stored, are intact and not

corroded or in any other way rendered unlit for the safe storage

of waste;

adequate measures are taken to prevent accidental spillage or

making;

the waste cannot be blown away;

nuisances such as odour, visual impacts and breeding of vectors

do not arise; and

pollution of the environment and harm to health are prevented.


Officer

Ongoing


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12.3 Clearly marked and positioned signage should be erected on and around

storage areas, and storage procedures should be compiled and adhered

to.


Officer

Ongoing

12.4 A well-designed drainage system around waste-generating and –storage

sites will be required so as to intercept any spillage and contaminated run-

off that might result from loading and transporting of waste on the

Smelter’s site. Waste water collected at a central drainage sump can be

returned to the plant as process water or be tied-in with the feed to the

Effluent Treatment Facility.

DPMT Management Ongoing

12.5 Emergency and safety protocols need to be in place in case of an incident

which could lead to endangering the environment and human health.

DPMT Management Ongoing

12.6 Proper construction of waste-transporting pipelines, made of compatible

and durable material, and their inclusion in periodical maintenance and

inspection schedules will minimise the risk of leaks, spills and pollution, as

well as human injury.

Transport management Ongoing Contractual requirements (transport)

Training and awareness

Emergency and safety protocols

12.7 The Road Traffic and Transport Regulations of 2001 specify duties of the

operator, driver, consignor and consignee (Section 308), require the driver

to undergo training (Section 311) and specify the documents to be held by

driver (Section 312). Compliance with these regulations will ensure proper

handling of dangerous goods during transport.

Operator, driver, consignor

and consignee

Ongoing

12.8 Emergency and safety protocols need to be in place in case of an incident

which could lead to endangering the environment and human health.

DPMT Management Immediate

12.9 In accordance with Road Traffic and Transport Regulations of 2001, is

training of truck drivers will ensure the dangerous goods reach the

DPMT Management Immediate Driver training


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intended hazardous waste site for disposal. Proper handling of waste at

the disposal site will also be ensured as to prevent waste being spilled

unnecessarily or mistakenly off-loaded at wrong areas on-site.

13 EMP Implementation and Monitoring

Objective: To ensure effective implementation of the EMP

13.1 Monthly internal audits of EMP compliance Environmental Manager Monthly

13.2 Annual external audit of EMP compliance Independent Consultant Annually

13.3 Submission of external annual report to environmental authorities Environmental Manager With ECC renewal

applications


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RECORD OF REPORT DISTRIBUTION

SLR Reference: 734.04040.00007

Title: Amended Environmental Management Plan for the Tsumeb Smelter

Site name: Tsumeb Smelter

Report Number: 734.04040.00007

Client: Dundee Precious Metals Tsumeb

Name Entity No. of copes

Date issued Issuer

COPYRIGHT

Copyright for this report vests with SLR Consulting unless otherwise agreed to in writing. The

report may not be copied or transmitted in any form whatsoever to any person without the

written permission of the Copyright Holder. This does not preclude the authorities’ use of the

report for consultation purposes or the applicant’s use of the report for project-related

purposes.

Documents

Amended Environmental Management Plan for the Tsumeb Smeltereia.met.gov.na/screening/121_20160319_EMP Amendment... · high arsenic content. Currently, it receives copper concentrate