846 Annual Environmental Report 2018

2018 ANNUAL REPORT ON
ENVIRONMENTAL MANAGEMENT
AT ORANO MINING NAMIBIA
HSE ENV RE 40
2018 Annual Environmental Management Report i
TABLE OF CONTENTS
No. Description Page No

1 INTRODUCTION 1
1.1 Orano Mining Namibia 1
1.2 Update on Activities 1
1.3 Objectives of the Annual Report 3
2 ENVIRONMENTAL POLICY 3
3 ENVIRONMENTAL ASPECTS AND IMPACTS 4
3.1 Aspects and Impacts of Orano Mining Namibia 4
4 LEGAL AND OTHER COMPLIANCE 6
4.1 National Legislation 6
4.2 Environmental Legislation Review 6
4.3 Licences and Permits 6
4.4 Government Inspections 6
4.5 Interaction with Government Institutions 7
5 OBJECTIVES AND TARGETS 7
6 ENVIRONMENTAL MANAGEMENT PROGRAMME 8
6.1 Overview 8
6.2 Policies and Procedures 8
7 STRUCTURE AND RESPONSIBILITIES 9
8 TRAINING, AWARENESS AND COMPETENCE 10
9 MONITORING AND FEEDBACK 10
9.1 Environmental Incidents 11
9.2 Environmental Monitoring Network 11
9.3 Climate and Air Quality Monitoring 11
9.4 Environmental Radiation Monitoring 18
9.5 Land Surface 21
9.6 Biodiversity 21
9.7 Water Quality Monitoring 24
9.8 Erongo Desalination Plant Monitoring 31
10 NATURAL RESOURCE CONSUMPTION 31
10.1 Electricity Consumption 31
10.2 Fuel Consumption 31
10.3 Water Consumption 32
11 EMISSIONS AND WASTE MANAGEMENT 33
11.1 Greenhouse Gas Emissions 33
11.2 Waste Management 34
12 RESEARCH AND DEVELOPMENT 34
12.1 Restoration Testing and Monitoring 34
13 AUDITING 34
14 REFERENCES 35
ATTACHMENTS
1 ENVIRONMENTAL STRATEGY AND ACTION PLAN PROGRESS REPORT 2017 37
2018 Annual Environmental Management Report ii

LIST OF FIGURES

1.1 Locality Map 1
1.2 Examples of C&M Activities in 2018 2
2.1 Orano Mining Namibia Environmental Policy 3
7.1 QHSE Department Structure in 2018 10
9.1 Used Resin Stored in Shipping Container 11
9.2 Weather Stations: Campbell at Midi and Davis at Maxi 13
9.3 Monthly Rainfall at Trekkopje Weather Stations 14
9.4 Annual A-pan Evaporation Data 2009-2018n 14
9.5 Average and Maximum Wind Speed at the Midi Station in 2018 15
9.6 Dust Fallout Bucket and PM10 Monitor 15
9.7 Monthly Dust Fallout Results in 2018 16
9.8 Average Annual PM10 Dust at Arandis 17
9.9 Average Annual PM10 Dust at the Midi Offices 18
9.10 Thermoluminescent Dosimeter Results 2010-2018 19
9.11 Annual Exposure Doses from Inhalation of Dust at Monitoring Sites 20
9.12 Average Annual Radon Exposure Doses at PSVOL Monitoring Sites 21
9.13 Average Plant Condition over Time 22
9.14 Survival Rates of Transplanted Namib Corkwood 23
9.15 Number of Animal Fatalities in 2013-2018 24
9.16 Water Quality Monitoring Boreholes 25
9.17 Main Water Quality Parameters at Borehole M1 in 2007-2018 25
9.18 Main Water Quality Parameters at Borehole M2 in 2007-2018 26
9.19 Sewage Effluent Quality in 2018 30
9.20 Water Level Trends 30
10.1 Trekkopje Mine Monthly Electricity Consumption 31
10.2 Trekkopje Mine Monthly Diesel Consumption 32
10.3 Trekkopje Mine Monthly Water Consumption 32
11.1 Direct and Indirect Greenhouse Gas Emissions 33
LIST OF TABLES

3.1 Summary of Environmental Impacts and Significance Ratings for Trekkopje Mine 4
3.2 Summary of Environmental Impacts and Significance Ratings for the Erongo Desali- 5
nation Plant
6.1 List of Policies, Strategies and Procedures 8
8.1 Training of QHSE Section Staff 10
9.1 Summary of Weather Data 2018 13
9.2 Rainfall Data at Annaberg and Midi Stations 14
9.3 Dust Fallout Monitoring Sites and Average Dust Concentration in 2018 16
9.4 PM10 Dust Monitoring Results 17
9.5 Thermoluminescent Dosimeter Coordinates and 2018 Results 19
9.6 PSVOL2 Dosimeter Coordinates and 2018 LLRD Results 19
9.7 Inferred Radon Exposure Doses from PSVOL Monitors 20
9.8 Vegetation Monitoring Transects 22
9.9 Groundwater Quality Analysis Results 2018 27
9.10 Microbiological Analysis of Potable Water 28
9.11 Sewage Analysis Results 2018 29
2018 Annual Environmental Management Report iii

Glossary
˚C Degrees Celsius
APN Orano Mining Namibia Processing Namibia
ARN Orano Mining Namibia Resources Namibia
DEA Directorate of Environmental Assessment (MET)
DWAF Department of Water Affairs and Forestry (MAWF)
EIA Environmental impact assessment
EMP Environmental Management Plan or Programme
EPZ Export processing zone
ESIA Environmental and social impact assessment
GDP Gross domestic product
GIS Geographical information system
HSE Health, safety and environment
HSE ENV PO Health, Safety and Environment – Environmental Section - Policy
HSE ENV PR Health, Safety and Environment – Environmental Section - Procedure
HSE ENV ST Health, Safety and Environment – Environmental Section - Strategy
km kilometre
km/h kilometre per hour
m metre
m2 square metre
m3 cubic metre
mg/L milligrams per litre
mm millimetre
Mm3/a million cubic metres per annum
mS/m millisiemens per metre
MAWF Ministry of Agriculture, Water and Forestry
MET Ministry of Environment and Tourism
MME Ministry of Mines and Energy
NACOMA Namibian Coastal Management Project
NBSAP National Biodiversity Strategy and Action Plan
NERMU Namib Ecological and Rehabilitation Monitoring Unit
NIMT Namibian Institute of Mining and Technology
NHC National Heritage Council
NRPA National Radiation Protection Authority
PM10 Inhalable dust fraction smaller than 10 microns
PPE Personal Protection Equipment
RMP Radiation Management Plan
SEA Strategic environmental assessment
SEMP Strategic environmental management plan
t tonne
TDS Total dissolved solids
2018 Annual Environmental Management Report iv

2018 ANNUAL REPORT ON ENVIRONMENTAL
MANAGEMENT AT ORANO MINING NAMIBIA
1 INTRODUCTION
1.1 Orano Mining Namibia
The French nuclear energy concern that owns the Trekkopje uranium project has changed its name
from AREVA to Orano in January 2018 and the local subsidiary became Orano Mining Namibia in
April. Orano’s Trekkopje mine is situated within the Erongo region of Namibia, 70 kilometres (km)
north-east of Swakopmund (Figure 1.1). Orano also owns the Erongo Desalination Plant at Wlotzkas-
baken, 30 km north of Swakopmund, which was built to supply the mine, but at present mainly pro-
duces water for the Namibia Water Corporation (NamWater).
Figure 1.1: Locality Map
1.2 Update on Activities
The Trekkopje project was put under care and maintenance (C&M) in July 2013. Since then, Orano
has been monitoring the uranium market to re-assess the feasibility of the mine and be prepared to
start up as soon as it becomes feasible. However, uranium spot market prices around US$25 in 2018
did not suggest an imminent upswing.
The company had 17 employed in 2018, including administration and services. The Engineering de-
partment protected and maintained all equipment and structures on site to keep them in working
condition. C&M includes activities such as testing and servicing of equipment and treatment against
2018 Annual Environmental Management Report Page 1

corrosion. A computerised maintenance schedule has been compiled according to the manufactur-
ers’ specifications and job cards are issued on a daily basis. The photos in Figure 1.2 show some ex-
amples of work done in 2018.
Installed stairs and handrails Maintained power supply system
Repainted prefab buildings and sealed roofs Rotated conveyor pulleys and idlers
Sealed corroded roofs of workshop containers (photos before – after)
Figure 1.2: Examples of C&M Activities in 2018
The Quality, Health, Safety & Environment (QHSE) section is in charge of all compliance-related issues
which include reporting on environmental management. Environmental monitoring continues during
C&M at a reduced scale, including air quality, radiation, groundwater and effluent quality, as well as
annual monitoring of vegetation transects and rehabilitation trial areas. EMP compliance audits are
carried out and reports are prepared as per statutory requirements. Orano Mining Namibia remains
an active member of the mining community and continues to support sustainable development pro-
jects in the community.

1.3 Objectives of the Annual Environmental Report
The main objective of this annual report is to give Orano management in France and regulators in the
Namibian government a comprehensive overview of all environmental management aspects related
to Orano Mining Namibia’s activities. Though the main area of interest is Trekkopje mine, monitoring
extends to Arandis and the Erongo Desalination Plant. The report describes the major environmental
impacts (section 6) and results of monitoring and investigation programmes (section 9). Additional
data tables can be found in the attachments. In addition to providing a useful summary and inter-
pretation of data collected over the past year, the report documents the history of environmental
management at Trekkopje and serves as a reference for comparison with future monitoring results.
2 ENVIRONMENTAL POLICY
Figure 2.1 shows Orano Mining Namibia’s environmental policy that is in line with the environmental
policy of the Orano Mining business unit. The company’s approach to environmental management is
also guided by Namibian legislation, especially the Environmental Management Act of 2007, as well
as the sustainable development principles of the International Council for Mining and Metals.
ENVIRONMENTAL
POLICY
Orano Mining Namibia acknowledges its Safety of Operations

responsibility as custodian of land in the sensitive
central Namib Desert. • Strictly apply operating procedures for routine and
non-routine situations, including transport.
The objectives of this policy are:
• Pay attention to contractors’ environmental
• Sustainable assurance of a high level of safety of our performance at the purchasing stage and while
facilities, products and services. working on site.
• Strengthened operational discipline, a daily concern of • Share experience as part of standard practice and
management and all parties involved. implement identified improvement plans.
• Inclusion of risk prevention and environmental • Produce pertinent environmental assessments and
protection in all processes at our operations. reports aligned with regulatory requirements.
PRIORITY ACTIONS FOR 2017-202 Environmental Performance
Facility Safety • Reduce the environmental footprint of our activities to

minimise the impact on biodiversity.
• Ensure the environmental safety of mine facilities
through proper design, construction and renovation. • Monitor and control air, soil, groundwater and surface
water quality.
• Guarantee that risk management systems comply with
standards and legislation. • Reduce water and energy consumption, emissions of
greenhouse gases, effluent and waste.
• Avoid, prevent or minimise environmental impacts,
including impacts on biodiversity, by implementing the
environmental management plan and in particular by
appropriate waste management.
• Conduct site rehabilitation programmes that comply >> Within the Orano group, the
with defined objectives and ensure that future land use
is consistent with anticipated final site conditions. activities of the Mining business
unit are subject to a sustainable
development approach.
Continuous improvement and
the application of strict
environmental and social
Hilifa Mbako standards guide us in our day-
to-day actions, taking us
Managing Director towards the achievement of our
March 2018 long-term objectives.
Figure 2.1: Orano Mining Namibia Environmental Policy

3 ENVIRONMENTAL ASPECTS AND IMPACTS
3.1 Aspects and Impacts of Orano Mining Namibia
The aspects and impacts of the mine and desalination plant are listed in Tables 3.1 and 3.2 including
significance ratings with and without mitigation. The ratings originally identified in the ESIAs were
reviewed in previous annual reports based on research findings and experience gained since 2008.
The highest impact of the mine arises from the destruction of flora due to land surface disturbance.
The high significance is explained by the potential impact on a number of plant species that are en-
demic to the Namib Desert. Other impacts classified as high without mitigation can be reduced to
moderate or low if appropriate measures are implemented.
Table 3.1: Summary of Environmental Impacts and Significance Ratings for Trekkopje Mine
Significance Significance
Aspect Impact without mitig. with mitigation
Atmosphere Dust generation M L
Radiation Radionuclide contamination of surface water M L
Radiation Radionuclide contamination of groundwater M L
Radiation Dust-borne radionuclides M L
Radiation Radionuclide uptake by fauna L L
Radiation Radon emanation H-M M
Radiation Occupational exposure to radiation M L
Land surface Soil disturbance H H
Land surface Destruction or alteration of water courses M L
Soils Water quality degradation due to land surface impacts L L
Soils Erosion/compaction L L
Soils Pollution/salinization L L
Pollution risk Pollution from chemicals/reagents L L
Pollution risk Pollution from organic matter/sewage L L
Pollution risk Pollution from other waste streams L L
Land use Land-use change through land surface disturbance M L
Water Groundwater pollution by spent rinse water M L
Water Seepage from spent leach heaps M L
Water Water consumption H H+
Water Groundwater drawdown and flow disruption L L
Flora Destruction through land surface disturbance H H-M
Flora Destruction through dust generation or pollution L L
Fauna General impacts H M
Traffic Increased traffic volume L L
Traffic Habitat destruction due to road development M L
Traffic Increased access L L
Noise Noise generated by blasting L L
Visual Visual intrusion of infrastructure L L
Archaeology Cultural/archaeological site pollution and damage H L
Key: H = high, M = moderate, L = low, + = positive impact

Though the desalination plant is a separate entity operated by AVENG Water Treatment, the respon-
sibility to ensure compliance with the desalination plant EMP remains with Orano Mining Namibia.
The highest impact of the desalination plant is positive, i.e. assuring the water supply for socio-
economic development of the Erongo region. On the negative side a previously not identified impact
only appeared after the power line to the desalination plant was constructed: collisions of migrating
birds such as flamingos with the power cables (refer to section 9.6.3 for details). NamPower is plan-
ning to install mitigation measures in 2019. Local residents are most concerned about the impact of
brine salinity and chemicals on marine life, but monitoring has confirmed the original ESIA’s low sig-
nificance rating of this aspect (refer to section 9.8 for details).
Table 3.2: Summary of Environmental Impacts and Significance Ratings for the Desalination Plant
Significance Significance
Aspect Impact without mitig. with mitigation
Atmosphere Dust generation from site maintenance and traffic L VL
Atmosphere Fume emission from transport and commuting L VL
Atmosphere Air emissions from hazardous materials (e.g. chlorine) L VL
Soils Pollution by sewage, hazardous materials or waste M L
Water Water pollution from accidental spills L VL
Fauna Impacts from noise or pollution M VL
Fauna Bird collision with power lines (not in 2008 ESIA) H M
Flora Habitat destruction through plant construction H L
Visual Visual intrusion of plant infrastructure M-H L
Land use Preclusion of other land use L L
Noise Sound transmission to Wlotzkasbaken or tourists M VL
Marine life Water quality impacts caused by brine salinity L L
Marine life Entrainment of organisms at the intake structure M L
Flow distortion at discharge, effects of pipeline on
Marine life L L
natural sediment dynamics
Marine life Impact of chemicals discharged with brine M L
Social Change of lifestyle at Wlotzkasbaken H L
Social Alteration of tourists’ desert heritage experience H L
Social Increased traffic from commuting and deliveries M VL
Social Positive impact of plant on water availability +M +H
Key: H = high, M = moderate, L = low, VL = very low, + = positive impact
Based on the 2008 ESIA reports and environmental management programmes (EMPs) environmental
clearances were issued by the Ministry of Environment and Tourism (MET). The original EMPs were
updated in 2012 and 2016 to take into account operational changes and to revise the mitigation
measures that proved to be impractical or unnecessary (Ref. 3 and 4). Environmental clearance cer-
tificates valid for three years were issued in April 2013 and renewed in September 2016. A further
review of the desalination plant EIA and EMP started at the end of 2018 to obtain approval for the
construction of a small sewage treatment plant. This project is expected to begin towards the end of
2019 or in 2020.

4 LEGAL AND OTHER COMPLIANCE
4.1 National Legislation
Acts and policies that may be applicable to environmental management or to the business of Orano
Mining Namibia in general have been identified in previous annual reports. A review of the Govern-
ment Gazette did not reveal any new relevant legislation enacted in 2018.
4.2 Environmental Legislation Review
MET appointed consultants to amend the Environmental Management Act and EIA regulations and
to draft new SEA regulations. Several stakeholder consultation workshops were held during the year
to discuss the proposed changes. Orano Mining Namibia was represented at these workshops and
provided copious written feedback on the draft legislation.
4.3 Licences and Permits
MAWF/DWAF: The effluent discharge exemption permit number 688 for Trekkopje mine is valid until
31 May 2021. The objectives of the permit as stated by the Department of Water Affairs and Forest-
ry (DWAF) are to regulate the disposal of effluents produced by the mine and to prevent the spread
of groundwater pollution from effluent or waste disposal sites into the environment. The permit
stipulates that regular and adequate groundwater quality monitoring has to be carried out according
to a prescribed schedule and according to a list of parameters to be determined. Water manage-
ment reports have to be submitted to the DWAF biannually or on request.
Permit number 10529 to extract up to 120 000 m3/a of groundwater from three boreholes on the
mine is valid until 2 May 2021. The company is however only using one production borehole, apply-
ing the saline water for road maintenance.
The Erongo Desalination plant’s permit for seawater abstraction (number 10535) was extended for
three years until 31 August 2020. The quota was at the same time increased to 60 Mm3 per annum
so that the plant will be able to produce the contracted volume of 12 Mm3 for NamWater.
Domestic wastewater and effluent disposal exemption permit 687 for the desalination plant is valid
until 31 May 2021. An important condition of this permit is that “the quality of brine from the desal-
ination plant that will be disposed into the marine environment should not have an effect and impact
on the marine ecosystem and therefore the fishing industry.”
MET/DEA: Orano Mining Namibia’s environmental clearances were renewed in September 2016,
which means they are valid until 2019.
MHSS/NRPA: The National Radiation Protection Authority (NRPA) approved Orano Mining Namibia’s
Radiation Management Plan (RMP) for phase 2 of the care and maintenance phase in 2017. NRPA
licences that are needed for equipment that emits ionising radiation (XRF machines, sealed sources)
were kept current for 2018. An annual report on the implementation of the RMP and the results of
exposure dose monitoring was produced according to NRPA specifications.
4.4 Government Inspections
The Department of Water Affairs and Forestry did not inspect the mine or the desalination plant in
2018, but was kept informed by means of biannual monitoring reports. The National Radiation Pro-

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

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

The health, environment, radiation safety and security standards developed by the Namibian Urani-
um Association (Ref. 5) and the relevant objectives of the Strategic Environmental Management Plan
(SEMP) that was developed as part of the “Strategic Environmental Assessment of the central Namib
Uranium Rush” (Ref. 6) are fully incorporated in the company’s strategy documents, environmental
procedures and action plans.
6 ENVIRONMENTAL MANAGEMENT PROGRAMME
6.1 Overview
The 2016 version of the EMPs for Trekkopje mine and the desalination plant currently form the basis
of the company’s environmental management programme. Policies, strategies and procedures de-
veloped by Orano Mining Namibia (Table 6.1) specify how the actions recommended in the EMPs are
translated into practice and thus provide an important tool for environmental management. The
table in Attachment 1 provides a summary of progress with the achievement of objectives, targets
and mitigation measures. Details on specific management measures and monitoring results are de-
scribed in section 9 of this report. Compliance with the EMPs is audited annually; audit reports and
ECO reports on the status of the environment are submitted to Government. A system is in place to
report and investigate non-compliance incidents and follow up on remedial action.
6.2 Policies and Procedures
Policies, strategies and procedures are reviewed every three years and updated whenever conditions
change. Approved documents are filed on a central IT server according to the document control pro-
cedure. Orano Mining Namibia employees are informed about the procedures relevant to their
tasks, e.g. during inductions and training sessions. Before new contractors start working on the mine
they are given inductions and copies of all the procedures that are applicable to their jobs. All poli-
cies, strategies and procedures that were due for review in 2018 were updated and changed to the
new Orano format.
Table 6.1: List of Policies, Strategies and Procedures
Title Reference Application Latest

date revision
Environment policy HSE ENV PO 01 1 Jul 2009 1 Mar 2018
Social policy HSE ENV PO 03 1 Jul 2009 1 Mar 2018
Air quality strategy HSE ENV ST 01 1 Dec 2009 1 Feb 2017
Biodiversity strategy HSE ENV ST 02 1 Dec 2009 1 Feb 2017
Closure strategy HSE ENV ST 03 1 Jun 2010 1 Nov 2018
Construction camp strategy HSE ENV ST 04 1 Dec 2009 1 Nov 2018
Environmental strategy HSE ENV ST 05 1 Jun 2009 1 Feb 2017
Hazardous materials strategy HSE ENV ST 06 1 Dec 2009 1 Feb 2017
Noise and vibration strategy HSE ENV ST 07 1 Dec 2009 1 Feb 2017
Sustainable development strategy HSE ENV ST 08 1 Jul 2009 1 Feb 2017
Water strategy HSE ENV ST 09 1 Oct 2011 1 Feb 2017
Public health strategy HSE ENV ST 10 1 Oct 2011 1 Feb 2017
Waste management strategy HSE ENV ST 11 1 Oct 2011 1 Feb 2017
Radiation management strategy HSE ENV ST 12 1 Oct 2011 1 Feb 2017
Mineral waste management strategy HSE ENV ST 14 1 Oct 2011 1 Feb 2017
Visual impact management strategy HSE ENV ST 15 1 Mar 2013 1 Feb 2017

Table 6.1: List of Policies, Strategies and Procedures (continued)
Title Reference Application Latest

date revision
Procedures
Dust monitoring HSE ENV PR 01 1 Apr 2010 1 Apr 2018
Dust control HSE ENV PR 02 1 Dec 2009 1 Apr 2018
Environmental auditing HSE ENV PR 03 1 Dec 2009 1 Apr 2018
Environmental incidents HSE ENV PR 04 1 Dec 2009 1 Apr 2018
Flora protection and rescue HSE ENV PR 05 1 Dec 2009 1 Apr 2018
Ground disturbance HSE ENV PR 06 1 Dec 2009 1 Apr 2018
Historical sites HSE ENV PR 07 1 Dec 2009 1 Apr 2018
Management of EMP non-compliance HSE ENV PR 08 1 Mar 2009 cancelled
Off-road driving and track rehabilitation HSE ENV PR 09 1 Dec 2009 1 Apr 2018
Oil/diesel spill clean-up HSE ENV PR 10 1 Dec 2009 1 Apr 2018
Hazardous materials management HSE ENV PR 11 1 Jul 2009 1 Apr 2018
Wildlife interactions HSE ENV PR 12 1 Jul 2012 1 Apr 2018
Environmental aspects of road construction HSE ENV PR 13 1 Dec 2009 1 Apr 2018
Road material selection HSE ENV PR 14 1 Dec 2009 1 Apr 2018
Topsoil handling HSE ENV PR 15 1 Dec 2009 1 Apr 2018
Vegetation monitoring HSE ENV PR 16 1 Dec 2009 1 Apr 2018
Bird interactions HSE ENV PR 17 1 Oct 2011 1 Apr 2018
Waste dump guidelines HSE ENV PR 18 1 Dec 2009 cancelled
Waste management HSE ENV PR 19 1 Dec 2009 1 Apr 2018
Water quality management HSE ENV PR 20 1 Dec 2009 1 Apr 2018
Water quality monitoring HSE ENV PR 21 1 Dec 2009 1 Apr 2018
Water supply management HSE ENV PR 22 1 Dec 2009 1 Apr 2018
Weather monitoring HSE ENV PR 23 1 Jan 2010 1 Apr 2018
Groundwater supply monitoring HSE ENV PR 24 1 Dec 2009 1 Apr 2018
Environmental monitoring HSE ENV PR 25 1 Feb 2010 1 Apr 2018
Environmental code of practice HSE ENV PR 26 1 Mar 2010 1 Oct 2018
Bioremediation HSE ENV PR 27 1 Feb 2010 1 Oct 2018
Environmental indicators HSE ENV PR 29 1 Oct 2011 1 Oct 2018
Soil monitoring HSE ENV PR 30 1 Oct 2011 1 Oct 2018
Legal audit (environment) HSE ENV PR 31 1 Oct 2011 1 Oct 2018
Gas monitoring HSE ENV PR 32 1 Oct 2011 1 Oct 2018
Radiation monitoring HSE ENV PR 33 1 Oct 2011 1 Oct 2018
Rehabilitation area monitoring HSE ENV PR 34 1 Oct 2011 1 Oct 2018
Closure cost estimation HSE ENV PR 35 1 Oct 2011 1 Oct 2018
7 STRUCTURE AND RESPONSIBILITIES

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

Org chart QHSE 2018
QHSE
Mine Manager
Consultant
FR van Dyk
Sandra Müller
QHSE Specialist
Kaarina Nkandi
ILS Paramedic
Jan Olivier
Figure 7.1: QHSE Department Structure in 2018
8 TRAINING, AWARENESS AND COMPETENCE

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

Professional qualification MSc Geology MSc Biology ILS Param.
Paramedic refresher courses √
NOSA safety training √ √ √
First aid training, firefighting √ √
Radiation safety officer courses √ √ √
Environmental management √ √
Environmental auditing (ISO) √ √
Leadership training √ √
Post-graduate diploma applied radiation science √
9 MONITORING AND FEEDBACK

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

9.1 Environmental Incidents
Any action or event that may lead to environmental damage or does not comply with the mine’s EMP
must be reported according to procedure HSE ENV PR 04. The severity of environmental incidents is
rated according to the Orano Mining Namibia procedure as either non-significant (NS, very low im-
pact intensity) or significant with levels ranging from moderate (S0) to serious (S1), major (S2) or cat-
astrophic (S3). Numerical limits for these categories are provided in the procedure.
Due to the low level of activity on site there was only one environmental incident in 2018. Inappro-
priate storage of bags containing used resin in a shipping container was detected during an inspec-
tion of the Midi Plant on 30 July 2018. A small portion of the resin had spilled out of the container
onto unprotected ground. The spill was cleaned up and the resin was placed in sealed plastic drums.
Figure 9.1: Used Resin Stored in Shipping Container
9.2 Environmental Monitoring Network
The design of the environmental monitoring network at the mine was originally based on the source
terms during mining operations: open pits, ore stockpiles, crushers, heap leach pads, waste rock and
tailings, as well as process water and effluent ponds (Map 1 on the next page). The pathways that
have to be monitored were air, radiation, water and soil. Extent and frequency of monitoring were
reduced since 2013 because C&M does not result in emissions to the environment. Details of the
monitoring network and results obtained in 2018 are described in the following sections.
9.3 Climate and Air Quality Monitoring
9.3.1 Climate
Orano Mining Namibia currently operates two weather stations, a Campbell station at the Midi office
and a Davis station at the Maxi office (Figure 9.2). Both stations were serviced in 2018 and Campbell
station was also calibrated in April 2018. Another Davis station at the Arandis gate stopped working
in 2017 and was removed. It was not needed because Arandis weather data are recorded by the
PM10 dust E-sampler (see Section 9.3.2). Table 9.1 shows a summary of the most relevant weather
data for the year 2018.

Map 1: Trekkopje Mine Monitoring Sites (Status 2012)

Table 9.1: Summary of Weather Data 2018
Midi Temperature ˚C Rainfall Wind Speed (m/s) Dominant

Month Mean Maximum Minimum (mm) Average Maximum Direction
Jan-18 19.0 28.8 11.7 0.0 3.2 7.7
Feb-18 19.3 30.1 11.2 0.0 2.9 6.4
Mar-18 20.0 31.6 11.3 6.8 2.8 6.8
Apr-18 22.8 33.6 12.9 15.2 2.7 8.9
May-18 20.2 35.6 7.5 0.0 3.2 8.5
Jun-18 20.8 34.5 7.7 0.0 4.2 13.0
Jul-18 14.6 35.3 3.1 0.0 3.3 13.1
Aug-18 14.6 35.3 3.1 0.0 3.3 13.1
Sep-18 16.6 34.5 6.4 0.0 2.8 12.9
Oct-18 19.6 37.0 7.2 5.0 3.6 12.8
Nov-18 19.9 36.1 8.6 0.0 3.2 12.0
Dec-18 18.9 30.9 9.1 0.0 3.1 7.7
2018 18.9 37.0 3.1 27.0 3.2 13.1
Maxi Temperature ˚C Rainfall Wind Speed (m/s) Dominant

Month Mean Maximum Minimum (mm) Average Maximum Direction
Jan-18 18.8 28.4 12.3 0.0 2.4 13 W
Feb-18 19.2 29.8 11.2 0.0 - - W
Mar-18 19.2 29.0 11.7 6.0 - - W
April-18 22.8 33.9 13.6 0.0 - - SSW
May-18 - - - - - -
Jul-18 - - - - - -
Aug-18 13.4 31.9 4.1 0.0 - - N
Sep-18 16.2 34.9 4.9 0.0 2.2 17.0 SW
Oct-18 20.2 37.8 8.3 5.4 3.2 20.1 SSW
Nov-18 20.0 36.0 11.1 2.8 12.8
Jan-18 18.8 28.4 12.3 0.0 2.4 13.0 W
Dec-18 - - - - - -
2018 18.7 37.8 4.1 11.4 2.6 20.1 W
Figure 9.2: Weather Stations: Campbell at Midi (left) and Davis at Maxi (right)

Rainfall
The annual precipitation in millimetres per year at the Annaberg and Midi stations for the last eleven
years is shown in Table 9.2. The weather station recorded 27 mm of rain in 2018 (Table 9.1), but ac-
cording to the rain gauge it was only 15 mm. The area upstream of the mine received more rainfall
on 22 October 2018, so that the river in the vicinity of the Annaberg mine had some runoff.
Table 9.2: Rainfall Data for the Annaberg (2007-2013) and Midi Stations (2014-2018)
Year 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Rain (mm) 4.6 58.1 139.6 32.2 133.9 24.6 29.0 53.7 18.3 17.8 15.0 15.0
A wet cycle with unusually high rainfall in 2009-2012 was followed by an ongoing period of drought
with very low rainfall in 2013 and 2015-2018 (Figure 9.3). The total rainfall of only 15 mm in 2017
and 2018 was well below the average rainfall of 50 mm.
120
Annaberg Midi
100
80
mm/month
60
40
20
0
Jan-07 Jan-08 Jan-09 Jan-10 Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16 Jan-17 Jan-18
Figure 9.3: Monthly Rainfall at Trekkopje Weather Stations
Evaporation
The average evaporation rate measured at the Midi offices in 2018 was 9.3 mm/day, which brings
the average since monitoring started at the Midi plant in 2011 to 8.6 mm/day. The figure for 2016
was excluded in the average calculation because a non-standard pan was used during that year. A
standard A-pan was commissioned in June 2017. The increased evaporation rate since 2013 was
possibly related to the reduction in rainfall (compare Figure 9.3).
11
Evaporation rate (mm/day)
9.9
10
9.3
9.0
9 8.4 8.5
8.1 8.1
8 7.6
7.0
7
5
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Figure 9.4: Annual A-pan Evaporation Data 2009-2018

Wind
Monthly average wind speeds at the Midi offices ranged from 2.7 to 4.2 metres per second (m/s)
with an average of 3.2 m/s (Figure 9.5). A maximum speed of 13.1 m/s was recorded during east
wind events in July and August 2018. The average wind speed at the Maxi station of 2.6 m/s is not
statistically valid because the station was out of order from February to July. The 2018 once again
confirmed that the typical pattern of predominant wind directions tends to be south-westerly in
summer and north-easterly to easterly in winter with higher wind speeds during berg wind events.
14
12
10
Wind speed (m/s)
0
Jan-18 Feb-18 Mar-18 Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18
Average wind speed Maximum wind speed
Figure 9.5: Average and Maximum Wind Speed at the Midi Station in 2018
9.3.2 Dust Monitoring
Information on environmental impacts arising from dust emissions and dust monitoring methods can
be found in the 2014 environmental report (Ref. 17). Dust fallout buckets and PM10 monitors (Fig-
ure 9.6) were used throughout the year 2017. The two-monthly sampling frequency introduced in
2017 was maintained for the 13 buckets located at Trekkopje Mine, Arandis and the Erongo desalina-
tion plant (Table 9.3). The low dust levels experienced during the care and maintenance period do
not warrant the effort and expense of monthly monitoring.
Figure 9.6: Dust Fallout Bucket and PM10 Monitor

The monthly dust fallout at each site is shown in Figure 9.7. Low dust levels of 8.7-33.9 mg/m2/day
were recorded with a maximum of 74.8 mg/m2/day at DM16 near the Midi offices in July-August
2018. Dust levels of 8.6-45.4 mg/m2/day were recorded at Arandis (DM33 and DM34). Dust in the
town was mainly caused by traffic on unpaved roads and construction activities.
Table 9.3: Dust Fallout Monitoring Sites and Average Dust Concentrations in 2018
2
ID Locality Description UTM33 WGS84 X UTM33 WGS84 Y Dust fallout mg/m /day
DM07 French camp 487701 7548811 7.7
DM08 Granite quarry near TW07 482206 7545215 27.3
DM10 1000 m NE of Midi plant 485808 7545443 15.6
DM14 1000 m SW of Midi plant 483696 7543326 14.3
DM16 Midi offices next to AD02 504379 7547543 26.5
DM20 Maxi pad, on road to TW12 482186 7549715 16.6
DM27 Maxi pad, east of first cell 483550 7549356 20.3
DM29 NamWater pipeline, at TLD05 486400 7543500 11.4
DM30 Western security gate 471315 7544446 24.5
DM33 NE of Arandis 498358 7522405 15.0
DM34 SW of Arandis 497189 7519806 22.0
DS02 Desalination plant substation 442412 7525830 15.8
DS03 Desalination plant security gate 441666 7525849 12.3
400
Dec/Jan 18 Feb/Mar 18 Apr/Jun 18 Jul/Aug 18 Sep/Oct 18 Nov/Dec 18
300
Dust fallout (mg/m2/day)
200
100
0
DM07 DM08 DM10 DM14 DM16 DM20 DM27 DM29 DM30 DM33 DM34 DS02 DS03
Figure 9.7: Dust Fallout Results in 2018
In the absence of a Namibian standard the results were evaluated against the South African National
Dust Control Regulations (NDCR). The NDCR define “low” dust levels as 0-250 mg/m2/day. The aver-
age values measured in 2018 were very low and none of the peak values exceeded the upper limit of
250 mg/m2/day. The results confirm that surfaces previously disturbed by mining and construction
are stable and not prone to wind erosion. Currently, dust is mostly mobilised by vehicle traffic on
gravel roads.
The inhalable dust fraction (PM10) is more important than fallout dust since particles smaller than 10
micrometres have a greater impact on health. The concentration of PM10 dust is measured with
monitors that pump air at a steady rate through a measuring chamber that records real-time dust
levels. The dust can also pass through a fine filter that is periodically replaced and sent to a laborato-
ry for analysis. The dust concentration in micrograms per cubic metre (μg/m³) is downloaded from

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

3
Locality Average Daily PM10 Dust Concentration (μg/m )
Year 2011 2012 2013 2014 2015 2016 2017 2018
Arandis 11.0 6.8 10.4 9.1 9.8 9.0 9.8 10.3
Arandis
31.7 22.0 30.7 26.1 27.4 26.4 29.3 29.9
corrected
Midi offices 7.0 8.0 no data - - 7.5 5.8 11.2
Midi cor-
14.7 16.8 no data - - 15.8 11.7 23.8
rected
The monitor at Arandis recorded an average PM10 dust concentration of 29.9 μg/m³ (Figure 9.8),
while the PM10 sampler at the Midi offices recorded a slightly lower average concentration of 23.8
μg/m³ in 2018 (Figure 9.9). The Midi instrument was installed in 2016 and worked until May 2017,
when it started showing alarms. It was replaced with a newly calibrated E-sampler in early 2018.
40
PM10 dust concentration
30
(ug/m3)
20
10
0
2011 2012 2013 2014 2015 2016 2017 2018
Corrected annual average WHO IT-3 limit
Figure 9.8: Annual Average PM10 Dust Concentration at Arandis
Standards for inhalable dust were developed by the World Health Organisation (WHO). The Strategic
Environmental Assessment of uranium mining in the Erongo region proposed the adoption of the
WHO interim target 3 (IT-3) of 75 μg/m³ for the average daily PM10 concentration and 30 μg/m³ for
the average annual concentration as local standard. Now that the calibration factors have been ap-
plied it has become apparent that the average annual limit of 30 μg/m³ was exceeded at Arandis in
2011 and 2013, while the average for 2018 was just below the guideline. The annual average values
at the Midi offices were all below the limit.
The average daily PM10 concentrations, which are not shown in the graphs, exceeded the IT-3 of 75
μg/m³ on several days when there were strong east or south-west winds.

PM10 dust concentration 40
30
(ug/m3)
20
10
0
2011 2012 2016 2017 2018
Corrected annual average WHO IT-3 limit
Figure 9.9: Annual Average PM10 Dust Concentration at the Midi Offices
9.4 Environmental Radiation Monitoring
9.4.1 Introduction
When Trekkopje mine is in operation members of the public residing in surrounding areas could po-
tentially be exposed to radiation via the following pathways:
1. Direct exposure to gamma radiation

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

Table 9.5: Thermoluminescent Dosimeter Coordinates and 2018 Results
ID Location Description X Y 2018 mSv/a

ARN TLD03 East French camp 488075 7549055 3.3
ARN TLD04 North NamPower line 481629 7552117 3.1
ARN TLD05 South Former NamWater pipeline 486400 7543500 3.4
ARN TLD07 Offices Midi offices 500846 7552454 4.2
ARN TLD09 Arandis Arandis 496886 7520722 3.4
ARN TLD10 Maxi area Former explosives magazine 480684 7547947 4.2
ARN TLD11 U plant Mini plant 484960 7545543 4.2
ARN TLD15 West Western security gate 471315 7544446 3.4
6.0
2010 2011 2012 2013 2014 2015 2016 2017 2018
5.0
Exposure dose (mSv/a)
4.0
3.0
2.0
1.0
0.0
East North South Office Arandis Maxi area U plant West gate
Figure 9.11: Thermoluminescent Dosimeter Results 2010-2018
9.4.3 Inhalation of Radioactive Dust
Environmental dust monitoring by means of passive dust fallout buckets and active inhalable dust
samplers provides an estimate of the volume of dust emitted, but the dust itself must be analysed to
determine its radioactivity. Orano Mining Namibia uses the Algade PSVOL2 mobile sampling system
to measure the specific alpha activity of long-lived radionuclides in dust (LLRD). In 2018, four instru-
ments were in place at the locations shown on the map in Attachment 3 and listed in Table 9.6 to-
gether with the 2018 results. The average annual dose from inhalation of LLRD was 0.02 mSv/a. A
table of all results since 2008 is included in Attachment 1.
Table 9.6: PSVOL2 Dosimeter Coordinates and 2017 LLRD Results
ID Location Description X Y 2018 mSv/a

ARN AD02 Office Midi offices 484443 7544317 0.022
ARN AD05 Arandis Arandis, Maletz workshop 496960 7521005 0.022
ARN AD06 Maxi area BME explosives store 480684 7547947 0.015
ARN AD08 South Former NamWater pipeline 486400 7543500 0.015
The measured LLRD activities were used to calculate exposure doses for members of the public, i.e.
individuals who actually (in case of Arandis) or theoretically (all other locations) live at the monitor-

ing sites. Figure 9.12 presents annual public exposure doses as a result of the inhalation of LLRD.
The results for most sites showed no major deviations from previous values, except for Arandis
where a slight rising trend has been observed since 2012, possibly related to the increasing height of
the Rössing Uranium tailings facility. The high doses at the office and uranium plant in 2010 were a
result of uranium ore crushing that took place in the Midi area. The exposure doses were lower in
2011 and following years because crushing had stopped.
0.20
2010 2011 2012 2013 2014 2015 2016 2017 2018

0.15
0.10
0.05
0.00
Arandis Background Office Annaberg U plant Maxi area South
Figure 9.12: Comparison of Annual Exposure Doses from Inhalation of Dust at Monitoring Sites
The monitoring records over the last nine years confirm the findings of studies carried out in the re-
gion, i.e. that dust inhalation is generally one of the lowest contributors to a person’s total exposure
dose.
9.4.4 Inhalation of Radon and Progeny
Environmental radon exhalations were monitored using the Algade PSVOL2 integrated monitoring
system. In 2018, average atmospheric radon concentrations were monitored at four locations as
shown in Table 9.7. The calculated public exposure doses due to radon and progeny varied between
0.78 and 1.02 mSv/a with an average of 0. 91 mSv/a (Table 9.7). The calculation of public exposure
doses uses an equilibrium factor of 0.4 for indoor and outdoor occupation, and assumes that a per-
son spends 8760 hours per year at the monitoring site. As mentioned above, the occupational radia-
tion exposure is calculated on the basis that a person spends only 2000 hours per year at work. Pub-
lic doses are however used here for better comparison between the results of Arandis and the mine.
Table 9.7: Inferred Radon Exposure Doses from PSVOL2 Monitors (mSv/a)
Location 2011 2012 2013 2014 2015 2016 2017 2018

Offices 0.97 0.47 1.14 0.96 1.13 1.03 1.35 1.00
Arandis 0.34 0.48 0.65 0.51 0.72 0.59 0.91 0.78
Maxi area 0.67 0.69 0.61 0.71 0.79 0.76 0.78 1.02
South 0.87 0.74 0.63 0.61 0.65 0.77 0.64 0.83
During the last nine years, the readings at Arandis varied from 0.3 to 0.9 mSv/a with an average of
0.6 mSv/a (Figure 9.13). This is just above the population-weighted average of 0.5 mSv/a for the
Erongo region that was published in the Strategic Environmental Assessment (SEA, Ref. 6). The radon
dose of 1.0 mSv at the Midi office is similar to previous results. The office is located close to the Midi
pad which is the source of higher than background radon levels. The ore on the heap leach pad was

wet during most of 2012, which may explain the lower radon emanation, unless it was caused by
measurement errors. Radon levels around 0.6-1.0 mSv/a at the Maxi area and along the former
pipeline to Arandis are slightly above the regional average, which can be expected for sites close to a
uranium ore body.
2.0
2010 2011 2012 2013 2014 2015 2016 2017 2018
1.5
1.0
0.5
0.0
Arandis Background Office Annaberg U plant Maxi area South
Figure 9.13: Average Annual Radon Exposure Doses at PSVOL Monitoring Sites
9.4.5 Ingestion of Contaminated Food and Water
Saline groundwater at Trekkopje mine is unfit for human consumption and will be avoided by most
animals. The risk of ingesting radionuclides by way of drinking contaminated borehole water is
therefore considered very low. Since there are no edible plants on the mine consumption of meat is
the only other potential pathway to humans. It can however be disregarded because there are hard-
ly any springbok present on the mine during the current drought.
9.5 Land Surface
9.5.1 Soil Monitoring
The results of baseline surveys of radionuclide activities in soil carried out in 2008, 2010 and 2012
were presented in previous annual reports. Since there will be no dust emission during the care and
maintenance phase the soil monitoring programme has been suspended until the mine starts up.
9.6 Biodiversity
9.6.1 Vegetation Monitoring
To assess whether or not dust deposition arising from mine operation will have an impact on the vi-
tality of the plants fixed vegetation transects were established in 2008. Transects are located around
the main dust sources and at some distance from the centre of the mine (Table 9.8). Transect 3 was
destroyed during the construction of the Maxi pad. The new Transect 7 was laid out to the west of
the northern turning circle in the same habitat. Two additional transects were added in 2012 to cov-
er more diverse habitats, specifically small river beds. Transect 6 is located near the western mine
boundary and Transect 8 along the former Arandis pipeline south of the Midi plant. The condition of
the specimens is observed annually by taking photos of each plant and noting the presence of leaves,
flowers, seeds and young shoots. The average height and diameter of the plants are measured every
five years as the growth rate is very slow.

Table 9.8: Vegetation Monitoring Transects
Locality X Y
1 Palaeodunes near French camp 487627 7548748
2 Riverbed south of Mini pad 485330 7545451
3 Riverbed north of Maxi pad 484087 7552671
4 Riverbed west of MCC 481306 7547428
5 Lichen field in the west 475588 7544221
6 Near western mine boundary 472508 7544996
7 Maxi pad northern turning circle 483450 7552378
8 Along former NamWater pipeline 486690 7543015
To evaluate the descriptive data in numerical terms and observe trends in plant condition, it was as-
sumed that the presence of leaves, buds, flowers and seeds equals 100% vitality (Ref. 18). Each of
these components is assigned 25%. This is a simplistic method, as some species do not have leaves
or buds and some carry seeds only on female plants. The method just serves to compare the relative
condition over the years in graphical form as shown in Figure 9.14. The survey in December 2018
found the perennial and multi-annual plant species in below average condition with an average of
33%. As shown in Figure 9.14 for the years 2008-2018, the average plant condition usually varies
around 40%. The peak condition was reached in 2013 after unusually high rainfall in 2011 and 2012.
Subsequent drought years caused a generally declining trend with a slight improvement in 2017.
70
60
Transect 1
50 Transect 2
Percent
Transect 4
40
Transect 6
30 Transect 7
Transect 8
20 Average
10
2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Figure 9.14: Average Plant Condition over Time
Many Salsola swakopmundii shrubs (an endemic species of salt bush) carried seeds in 2018, but there
were no flowers. The condition of Namib corkwood (Commiphora dinteri) was similar to previous
years with few specimens carrying leaves, flowers or seeds. Under drought conditions the dollar
bush (Zygophyllum stapffii) sheds its leaves in summer, which often results in low survey ratings,
while the plants tend to look much better after the rainy season. The dollar bushes appeared to be
in poor condition in 2018 with very few remaining leaves.
9.6.2 Plant Relocation
When the Maxi leach pad was built in 2008, 82 Namib corkwood (Commiphora dinteri) shrubs were
rescued from the construction site and transplanted to an area north of the Annaberg tin mine.
Since then the shrubs have been monitored every year to assess their condition. It has become clear

after 10 years that the relocation exercise was not very successful. The survival rate dropped again
from 22% in January 2018 to 17% in January 2019, which means that only 14 plants are still alive.
The graph in Figure 9.15 gives an impression of the survival rate over time.
80
70
60
Number of trees
50
40 Alive
30 Dead
20
10
0
2011 2012 2013 2014 2015 2016 2017 2018 2019
Figure 9.15: Survival Rates of Transplanted Namib Corkwood
The problem of the low survival rate was discussed in the 2015 annual report and is repeated here
for reference. The question was whether or not one should attempt to relocate endemic species and
how the chances of success could be improved. Orano Mining Namibia’s ESIA recommended that
Commiphora dinteri should be rescued because the species is endemic to the central-western Namib.
The 106 shrubs found around the Maxi leach pad were regarded as a meaningful number for this par-
ticular species, making them worthy of rescue and relocation attempts, even though the species did
not enjoy formal protection status and there was no legal obligation to undertake this work (Ref. 19).
The attempt to rescue the Namib corkwood was useful in terms of improving the translocation
method if there is a need to rescue more plants in future. The biodiversity impact of the lost Commi-
phora dinteri population was limited because there are still numerous plants left in the undisturbed
area around the Maxi leach pad.
9.6.3 Fauna Monitoring
Orano Mining Namibia has been involved in the NamPower/Namibia Nature Foundation (NNF) part-
nership project that investigates the effect of power lines on bird kills and options for the mitigation
of such incidents since 2010. The NamPower/NNF Partnership was initiated to mitigate the negative
effects of power lines on both birds and the electricity industry. Orano Mining Namibia’s contribu-
tion consisted of occasionally inspecting the power lines, sometimes together with the researchers
employed by NNF, and reporting any bird kills. Since there have been many incidents on the Trek-
kopje power lines over the years, NamPower has identified the need for mitigation measures. The
installation of markers on the 10.4 km Trekkopje bypass on the Khan-Trekkopje line and the 4 km
section running eastwards of the Wlotzkasbaken desalination plant was postponed to 2019.
Animal fatalities reported by employees on the mine are logged in a database and treated as envi-
ronmental incidents. There was one animal kill on the mine roads in 2018 (Cape hare), while four
bird collisions with power lines (“Birds PL” in the graph) were reported. The animal fatality numbers
for 2018 are shown in Figure 9.16 in comparison with the previous five years.

20
15
Number
10
0
Cape hare Jackal Birds Birds PL Springbok Aardvark Snake
2013 2014 2015 2016 2017 2018
Figure 9.16: Number of Animal Fatalities in 2013-2018
9.7 Water Quality Monitoring
The mine’s domestic and industrial effluent disposal exemption permit no. 688 requires annual re-
porting on the results of the prescribed groundwater and sewage effluent quality monitoring, as well
as other matters relating to water management. An annual report on water management at Trek-
kopje Mine was submitted to the Directorate Resource Management of the Ministry of Agriculture,
Water & Forestry (Ref. 21). This report can be consulted for additional details on water quality moni-
toring and permit compliance.
Groundwater quality monitoring took place in April 2018 and included comprehensive analyses of
major and minor determinants at eleven monitoring sites (Figure 9.17). Samples for potable water
microbiology and sewage effluent analyses were taken in April and October 2018. Water levels were
measured during sampling in April and again close to the end of the year. The water quality monitor-
ing results for 2018 are presented in the following text and tables.
9.7.1 Major Ions in Groundwater
Groundwater at Trekkopje is brackish to saline with total dissolved solids concentrations of 10 000-
26 000 milligrams per litre (mg/L). All groundwater samples are of a similar water type, i.e. sodium
chloride (NaCl) waters with a range of salinity (TDS) levels and minor sulphate and calcium concen-
trations. The April 2018 analysis results are shown in Table 9.9. The samples were analysed by Ana-
lytical Laboratory Services in Windhoek and DD Science in Randfontein. A duplicate sample of bore-
hole M6 was included for quality control (indicated as M6A in Table 9.9).
An evaluation of the data showed no major changes compared to previous years. The graph of bore-
hole M1 in Figure 9.18 demonstrates that typically only very slight water quality changes occur at
Trekkopje. The only borehole that shows more obvious trends is M2, situated southwest of the Maxi
plant (Figure 9.19). The salinity at this site increased until 2016, then started declining in 2017. The
increase was probably due to soil salts flushed down to the shallow water table (8-9 m below sur-
face) during heavy rains in 2009-2012. For comparison, borehole M1 where the water level is at 36
m below surface only showed rising sodium and chloride concentrations since 2016 because it takes
longer for recharge to reach the deeper aquifer.

Figure 9.17: Water Quality Monitoring Boreholes (Map by SLR)
20000
18000
16000
14000
Concentration (mg/L)
12000
10000
8000
6000
4000
2000
0
Sep 07 Feb 08 Mar 09 Mar 10 Mar 11 Sep 11 Mar 12 Mar 13 Mar 14 Mar 15 Mar-16 Mar 17 Apr-18
Total Dissolved Solids Chloride as Cl- Sodium as Na Sulphate as SO42- Total Hardness as CaCO3
Figure 9.18: Main Water Quality Parameters at Borehole M1 in 2007-2018

30000
25000
20000
15000
10000
5000
0
Sep-07 Feb-08 Mar-09 Mar-10 Mar 11 Mar 12 Mar 13 Mar 14 Mar 15 Mar 15 Mar-16 Mar-17 Apr-18
Total Dissolved Solids Chloride as Cl- Sodium as Na Total Hardness as CaCO3 Sulphate as SO42-
Figure 9.19: Main Water Quality Parameters at Borehole M2 in 2007-2018
9.7.2 Metals and Trace Elements in Groundwater
The geochemical environment at Trekkopje Mine is characterised by a predominance of strontium,

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

Table 9.9: Groundwater Analysis Results 2018
Sampling point TW01 TW05 TW07 TW10 TW12 OO-18 M1 M2 M6 M6A M14
Date of sampling Unit 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17 2018/04/17
pH 7.1 7.2 7.5 7.4 7.4 7.1 7.3 7.0 7.6 7.7 7.4
Electrical conductivity mS/m 2620 1563 2072 2330 1518 1630 2590 3400 1474 1473 3340
Turbidity NTU 178 0.65 18 0.25 197 39 4.7 37 50 46 13
Total dissolved solids (det.) mg/L 18304 10692 14892 16138 10177 11355 18099 23805 10016 10092 23459
P-Alkalinity as CaCO3 mg/L 0 0 0 0 0 0 0 0 0 0 0
Total alkalinity as CaCO3 mg/L 240 210 150 98 142 225 125 175 90 90 82
Total hardness as CaCO3 mg/L 3761 2163 2678 2796 2198 1955 3141 4189 1457 1476 3715
Ca-hardness as CaCO3 mg/L 1805 1718 1895 1865 1745 1531 2247 3201 1086 1101 2117
Mg-hardness as CaCO3 mg/L 1956 445 782 931 453 424 894 988 371 375 1598
Chloride as Cl- mg/L 9908 4954 6682 7834 4954 5185 9447 11291 4609 4493 11752
Fluoride as F- mg/L 1.8 2.4 2.9 2.6 2.1 2.3 2.4 2.1 2.7 2.8 3.2
Sulphate as SO42- mg/L 2773 2000 3496 2995 2045 2264 3433 3527 2405 2343 4310
Nitrate as N mg/L 5.4 29 57 43 25 25 49 38 25 24 87
Nitrite as N mg/L 0.01 <0.01 0.02 <0.01 0.29 <0.01 <0.01 0.01 0.01 0.01 0.01
Silica as SiO2 mg/L 11 15 17 12 9 14 15 18 14 14 9
o-Phosphate as PO4 mg/L <0.03 <0.03 <0.03 <0.03 <0.03 0.03 <0.03 0.03 0.06 0.06 0.12
Sodium as Na mg/L 5702 3240 4694 5277 3122 3508 5866 6969 3331 3284 7848
Potassium as K mg/L 136 76 137 137 72 83 161 166 107 107 227
Magnesium as Mg mg/L 475 108 190 226 110 103 217 240 90 91 388
Calcium as Ca mg/L 723 688 759 747 699 613 900 1282 435 441 848
Al aluminium µg/l 752 6.1 24 12 11 302 85 447 811 791 193
As arsenic µg/l 0.1 1.4 15 8.5 0.2 1.1 4.2 1.1 2.8 2.5 2.3
B boron µg/l 3930 7280 5890 8510 3510 4530 7040 6790 5060 5220 6980
Ba barium µg/l 44 20 15 15 19 15 19 23 26 27 17
Be beryllium µg/l 0.7 0.2 0.2 0.1 0.1 0.2 0.1 0.2 0.2 0.2 0.09
Cd cadmium µg/l 0.1 0.1 0.2 0.2 0.1 0.1 0.1 0.1 0.2 0.1 0.3
Cr chromium µg/l 1.6 0.3 6.7 3.7 0.1 1.4 0.7 0.6 1.8 2.6 11
Cu copper µg/l 7.4 1.0 2.9 1.1 0.7 7.8 5.7 9.5 12 12 6.4
Fe iron µg/l 2263 13 2677 18 8681 174 82 264 417 365 225
Hg mercury µg/l 0.1 0.7 0.4 0.5 <0.001 0.4 0.5 0.4 0.4 0.5 0.3
Li lithium µg/l 853 239 445 544 228 250 523 593 221 232 775
Mn manganese µg/l 934 0.4 5.8 0.6 81 4.4 3.9 10 53 51 20
Mo molybdenum µg/l 17 25 59 56 17 26 40 25 33 34 73
Ni nickel µg/l 5.9 0.4 1.7 0.2 0.7 0.5 0.7 1.5 1.9 1.8 1.6
Pb lead µg/l 5.4 0.5 1.0 0.5 1.0 1.6 5.7 2.8 25 26 9.6
Sb antimony µg/l 0.08 0.03 0.1 0.06 0.05 0.05 0.08 0.1 0.05 0.07 0.1
Se selenium µg/l 5.2 12 17 17 8.2 14 27 32 17 8.6 27
Sn Tin µg/l 0.07 0.07 0.08 0.04 0.1 0.05 0.1 0.06 0.08 0.1
Sr strontium µg/l 19312 10421 15024 15971 11322 9415 18477 25594 6483 6834 18139
Ti titanium µg/l 4.2 0.4 14 0.6 1.1 11 4.0 14 12 11 7.0
Th thorium µg/l 4.3 0.03 0.03 0.02 0.02 0.2 0.09 0.4 0.1 0.2 0.2
U uranium µg/l 290 189 347 155 83 188 186 402 115 121 102
V vanadium µg/l 24 33 178 40 2.5 35 54 32 26 27 18
Zn zinc µg/l 6.3 2.0 4.9 4.3 3.4 13 11 27 25 25 7.9

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

Site cfu/mL MPN/100mL MPN/100mL
Reservoir Feb-18 52 <1 <1
Reservoir Jul-18 12 18 <1
Reservoir Sep-18 55 26 <1
Reservoir Nov-18 15 >100 <1
Midi canteen tap Feb-18 505 <1 <1
Midi canteen tap Apr-18 2600 <1 <1
Midi canteen tap Jul-18 <1 <1 <1
Midi canteen tap Sep-18 1 <1 <1
Midi canteen tap Nov-18 <1 <1 <1
Maxi office Feb-18 11 <1 <1
Maxi office Jul-18 48 <1 <1
Maxi office Sep-18 163 <1 <1
Maxi office Nov-18 254 <1 <1
cfu/mL = Colony forming units per millilitre (mL),< = less than MPN/100mL = Most probable number per 100 mL
The sample taken at the canteen in April 2018 showed an exceptionally high heterotrophic plate
count. The potable water supply system at the Midi plant was therefore cleaned in May. A review of
the domestic water consumption showed that the problem of bacteria growth was caused by the
long period that water is stored in three 10 000 litre tanks. It was decided that two storage tanks
next to the first aid station will be bypassed because they are not required anymore. Samples were
taken on 3 July 2018 to confirm that the water quality had improved.
9.7.4 Sewage Effluent Quality
The Namibian water quality standard prescribes that the TDS in effluent may not increase by more
than 500 mg/L based on the incoming water quality, while the upper limit for sodium is 90 mg/L in-
crease. This means a maximum TDS of 1100 mg and 290 mg/L of sodium based on the average desal-
inated water TDS and sodium concentrations in early 2018. Chemical oxygen demand (COD) should

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

Date Effluent Standard Apr-18 Apr-18
pH 6.5-9.5 6.6 6.1
Conductivity mS/m <75 mS/m increase (180) 163 365
Redox potential mV 496 590
Dissolved oxygen as O2 mg/L >75% 6.2 5.8
Total dissolved solids (meas.) mg/L <500 mg/L increase (1100) 944 2063
Total suspended solids mg/L 100 10 7
Chemical Oxygen Demand as O2 mg/L 100 62 41
Kjeldahl Nitrogen as N mg/L 33 8.0 121
Oxygen absorbed as O2 mg/L 10 15.1 6.1
Nitrate as N mg/L 20 45 5.3
Nitrite as N mg/L 3 0.08 <0.01
Free and saline ammonia as N mg/L 10 3.6 42
Sodium as Na mg/L <90 mg/L increase (290) 252 473
E. coli MPN/100ml absent in 100 mL 74 not detected
Sampling site Proposed General Midi Maxi

Date Effluent Standard Oct-18 Oct-18
pH 6.5-9.5 6.3 6.8
Conductivity mS/m <75 mS/m increase (180) 166 307
Redox potential mV 505 748
Dissolved oxygen as O2 mg/L >75% 5.4 7.4
Total dissolved solids (meas.) mg/L <500 mg/L increase (1100) 1078 1809
Total suspended solids mg/L 100 6 4
Chemical Oxygen Demand as O2 mg/L 100 64 *
Kjeldahl Nitrogen as N mg/L 33 6.0 *
Oxygen absorbed as O2 mg/L 10 10.6 *
Nitrate as N mg/L 20 35 *
Nitrite as N mg/L 3 1.30 *
Free and saline ammonia as N mg/L 10 6.0 <0.02
Sodium as Na mg/L <90 mg/L increase (290) 264 529
E. coli MPN/100ml absent in 100 mL not detected not detected
Key: * could not be measured due to interference by chlorine
mS/m millisiemens per metre mV millivolt
mg/L milligrams per litre MPN most probable number

Midi Maxi
10000 10000
2063 1809
944 1078
1000 1000 473 529
252 264
100 62 64 100
41 42
10
10 5.9 6.0 10 6.7
3.6 4.3
1 1
Apr-18 Oct-18 Apr-18 Oct-18
TDS Sodium COD Suspended solids Ammonia as N TDS Sodium COD Suspended solids Ammonia as N
Figure 9.20: Sewage Effluent Quality in 2018
9.7.5 Groundwater Levels
Most boreholes showed little water level variation since monitoring started in 2007, for instance M1
and TW01 in Figure 9.21. Borehole TW01 in the eastern part of the mine received recharge from ma-
jor rainfall events in 2011 and 2012. The very slow rise of the water table indicates a generally low
permeability of the palaeochannel sediments which results in small flow rates and volumes.
M1 TW01
-32 -10
-34 -12
m below top of casing
-36 -14
-38 -16
-40 -18
-42 -20
Jan-07 Jan-08 Jan-09 Jan-10 Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16 Jan-17 Jan-18 Jan-19 Jan-07 Jan-08 Jan-09 Jan-10 Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16 Jan-17 Jan-18 Jan-19
TW05a TW12a
-16 -23
-18
-25
Water Level (m below collar)
Water level (m below top of casing)
-20
-27
-22
-29
-24
-31
-26
Sep-06 Sep-07 Sep-08 Sep-09 Sep-10 Sep-11 Sep-12 Sep-13 Sep-14 Sep-15 Sep-16 Sep-17 Sep-18 Sep-19 -33
Nov-06 Nov-07 Nov-08 Nov-09 Nov-10 Nov-11 Nov-12 Nov-13 Nov-14 Nov-15 Nov-16 Nov-17 Nov-18
TW21 M2
-28 -5
-30 -7
-9
-32
-11
-34
-13
-36
-15
-38 Jan-07 Jan-08 Jan-09 Jan-10 Jan-11 Jan-12 Jan-13 Jan-14 Jan-15 Jan-16 Jan-17 Jan-18 Jan-19
Oct-06 Feb-08 Jul-09 Nov-10 Apr-12 Aug-13 Dec-14 May-16 Sep-17 Feb-19
Figure 9.21: Water Level Trends

Production boreholes TW05 and TW12 that intercept the marble aquifers are still recovering from
groundwater extraction in 2008-2010, with water levels that are about two metres lower than before
the start of pumping. Boreholes TW21 and M2 in the vicinity of the western mine gate are situated
on the same marble bands, which is why their water levels were affected by pumping from the for-
mer production boreholes. The recovery of the water table at these sites is very slow owing to the
persistent drought conditions since 2013.
9.8 Erongo Desalination Plant Monitoring
A description of water quality and environmental monitoring results obtained at the Erongo Desali-
nation Plant in 2018 can be found in Ref. 26.
10 NATURAL RESOURCE CONSUMPTION

Orano Mining Namibia monitors its environmental footprint by keeping track of environmental indi-
cators, such as water, electricity and fuel consumption, as well as greenhouse gas emissions and pro-
duction of waste.
10.1 Electricity Consumption
Orano Mining Namibia’s total electricity consumption of 1175 megawatt hours (MWh) was below the
limit of 1560 MWh set for 2018 (Figure 10.1). The saving was achieved by running the diesel-
powered standby generators whenever the crushers and compressors have to be started to test their
functionality. This serves as testing of the generators at the same time.
250
Actual Planned
200
MWh
150
100
50
0
Figure 10.1: Trekkopje Mine Monthly Electricity Consumption
10.2 Fuel Consumption
The diesel consumption of 35 047 litres (0.36 GWh) was much lower than the expected consumption
of 48 000 litres (Figure 10.2); mostly because of a further reduction in the frequency of road mainte-
nance.

10000
Actual Planned
8000
6000
Litres
4000
2000
0
Figure 10.2: Trekkopje Mine Monthly Diesel Consumption
10.3 Water Consumption
The mine’s water consumption of 24 323 m3 was well below the annual target of 66 000 m3 (Figure
10.3). The reason was the same as for the reduced diesel consumption, i.e. a reduction in road
maintenance and dust suppression. The total supply consisted of 15 388 m3 of desalinated seawater
and 8935 m3 of groundwater extracted on site. The reservoirs on the mine were only filled up once
(to 70%) in September 2018, and remained 50% full at the end of the year.
20000
Actual Planned
15000
Cubic metres
10000
5000
0
Figure 10.3: Trekkopje Mine Monthly Water Consumption

11 EMISSIONS AND WASTE MANAGEMENT
11.1 Greenhouse Gas Emissions
The annual direct and indirect greenhouse gas (GHG) emissions related to Orano Mining Namibia’s
activities in tonnes of carbon dioxide equivalent (CO2eq) are shown in Figure 11.1. Direct GHG emis-
sions are calculated from the fuel consumption. In line with the reduced diesel consumption the
greenhouse gas emissions were also lower than expected, i.e. 95 t CO2e compared to the limit of 130
t CO2e. The calculation converts the impact on the atmosphere of greenhouse gases such as methane
(CH4) and nitrous oxide (N2O) to the impact of an equivalent tonnage of carbon dioxide (CO2). Fuel
use for vehicles on the mine site and for employee transport is included in the figures. There were
no direct greenhouse gas emissions from transport of materials to and from the mine.
Indirect greenhouse gas emissions from the purchase of NamPower electricity are much higher than
direct emissions (Figure 11.1). Namibia imports about 60% of its electricity from South Africa and
other neighbouring countries, while the remainder is supplied by a local hydropower scheme. The
40% share of hydropower has zero emissions. The GHG figures for the remaining 60% are calculated
from the emission factor of the South African power utility Eskom that mainly operates coal-fired
power stations. Application of the Eskom factor of 0.96 kg CO2 per kilowatt hour results in direct
GHG emissions of 888 483 t CO2eq for 2018 (note that the figures in the graph below are in kilotonnes
and the vertical scale is logarithmic).
The electricity consumed for seawater desalination by the Erongo desalination plant is defined as
‘other indirect’ emissions in accordance with the definitions of the Global Reporting Initiative. The
desalination plant has been running since 2010, supplying only Trekkopje mine from 2010 to August
2013. Since then, water is mostly sold to NamWater to meet the demand of other consumers whose
rising demand explains the high indirect GHG emissions.
100000
10000
Kilotonnes of CO2 eq.
1000
100
28933
21587
16511
10597
10510
3392
2190
1191
1013
973
888
677
10
1
2.4
0.7
0.6
0.2
0.2
0.1
0
2013 2014 2015 2016 2017 2018
Direct Indirect Other indirect
Figure 11.1: Direct and Indirect Greenhouse Gas Emissions
The indirect GHG emissions in 2018 were 21 587 000 t CO2eq. Orano Mining Namibia consumed only
a minute fraction of the desalinated water that was produced with this energy, and one could argue
that the GHG emissions should be split pro rata. On the other hand, water production can be re-
garded as a company activity because Orano Mining Namibia benefitted from the sale of water to the
national water supplier. This approach was taken here to assign the entire GHG load to Orano.

Ozone-depleting substances are released from coolants in air conditioning systems. Offices on the
mine are equipped with air conditioners that use R410-a coolant with a global warming potential of
2088 relative to carbon dioxide. The mine did not refill coolants in any air conditioners in 2018, so
the GHG emissions from this source are reported as zero.
11.2 Waste Management
In the past, domestic and non-hazardous industrial waste from Trekkopje mine used to be taken to
the municipal landfill at Swakopmund as return freight from weekly deliveries. Since these trips had
stopped waste was taken to the Arandis landfill until it was decided towards the end of 2018 to sepa-
rate recyclable items and burn the remaining waste on site. It was not possible to estimate the ton-
nage of waste. The QHSE section transported 1074 kg of used vehicle batteries, fluorescent tubes
and medical waste from the first aid station to the Walvis Bay hazardous waste facility in 2018.
Some types of mineral waste, such as drill cuttings and samples, sulphate overburden and tailings are
classified as low-level radioactive waste. A comprehensive inventory of radioactive waste types is
included in the Trekkopje Mine Radiation Management Plan (Ref. 22). The disposal of mineral waste
has been addressed in the mine closure plan. The volume of tailings stored on the leach pads is
1.587 million m3 and the volume of overburden is 1.409 million m3. The overburden consists of
weathered granite removed from the quarry and sulphate-bearing conglomerate that covered the
ore in the open pit. There is also low-level radioactive waste from the uranium production process,
e.g. protective clothing, spare parts from the processing plants, empty SDU drums, etc. Approxi-
mately 40 m3 of this waste were stored in locked shipping containers. This is an interim measure
during the care and maintenance phase until a more suitable disposal site can be provided.
12 RESEARCH AND DEVELOPMENT
12.1 Restoration Testing and Monitoring
The monitoring programme was suspended in 2018 because the test plots remained barren after low
rainfall.
13 AUDITING
Audits and inspections are carried out to ensure compliance with the environmental management
plans for Trekkopje mine and the Erongo desalination plant (Ref. 25). Orano Mining Namibia ap-
pointed an independent consultant to conduct the external EMP compliance audit in October 2018.
The updated EMPs dated January 2016 were used as the basis for the audit. The auditor only in-
spected the desalination plant, since the mine site had already been inspected by the Chamber of
Mines Safety Committee in June 2018. A few environmental deviations were found during this audit
were addressed immediately. The verification of relevant documents and environmental action
plans took place on 3 October at the town office.
The auditor found the mine 99% compliant. The only non-conformance related to waste manage-
ment as the EMP does not make provision for the use of the Arandis landfill or for waste burning on
site. The desalination plant achieved 96%. The auditor reported that the plant appeared generally
tidy and clear of waste or spillages. Very few activities were taking place that could cause potentially
negative environmental impacts. Waste management has improved since the previous audit and a

hazardous material (bunded) area has been constructed. All findings from the previous audit have
been addressed. The following issues were found in 2018:
 Waste management: skips were not labelled; recyclable waste and non-recyclable (and pos-
sibly some hazardous) waste were mixed, emptied and (apparently) disposed of by the con-
tractors on the general Swakopmund landfill site.
 Chemical spillage could occur when caustic soda is off-loaded, which happens regularly.
There were some spillages outside the lined area. Sodium hypochlorite spillage inside the
bunded area appears to be washed into the drains which discharge to the environment.
 Paint storage in container involves the risk of paint flowing out of the container into the
drainage line.
An action plan to address the findings has been prepared and is being implemented by AVENG Water
Treatment.
Report compiled by:
Sandra Müller
QHSE Consultant
Date: 9 April 2019

14 REFERENCES
1. Limpitlaw, D & M Hoadley (2008): Trekkopje Mine Environmental and Social Impact Assessment
Report. Report prepared by Turgis Mining Consultants for UraMin Namibia.
2. Stacey, J & P Roux (2008): Report of the Environmental and Social Impact Assessment - Trekkop-
je Desalination Project, Erongo Region, Namibia. Report by Turgis Mining Consultants.
3. Müller, S (2016): Environmental Management Plan – Trekkopje Mine. Document prepared by
AREVA Resources Namibia.
4. Müller, S (2016): Environmental Management Plan – Erongo Desalination Plant. Document pre-
pared by AREVA Resources Namibia.
5. Namibian Uranium Institute (2011): Health, Environment and Radiation Safety and Security
(HERSS) Standards (on website www.namibianuranium.org).
6. SAIEA (2010): Strategic Environmental Assessment for the central Namib Uranium Rush. Ministry
of Mines and Energy, Windhoek, Republic of Namibia.
7. Liebenberg-Enslin, H (2011): Air Quality Baseline Assessment for Trekkopje Mine in Namibia.
Report No. APP/11/ARN-01 by Airshed Planning Professionals, Johannesburg, South Africa.
8. Blerk, JJ van & N Potgieter (2011): Radiological Public Impact Assessment for the Trekkopje Ura-
nium Mine: Swakopmund (Namibia). Report No. ASC-1012B-1 prepared by AquiSim Consulting
(Pty) Ltd, Pretoria, South Africa.
9. Winker, F (2012): Non-reactive transport model of Trekkopje Mine, Erongo Region. Report No.
2012-G14-V1 compiled by SLR Consulting Namibia, Windhoek.
10. Müller, S (2012): 2011 Annual Report on Environmental Management at Trekkopje Mine. Orano
Mining Namibia Processing Namibia document no. HSE ENV RE 08.
11. Burke, A (2009): Biotope Assessment for AREVA Resources Namibia’s Trekkopje Mine in the Cen-
tral Namib Desert. Report by EnviroScience, Windhoek.
12. Burke, A (2012): Biotope re-assessment for AREVA Resources Namibia’s Trekkopje Mine in the
central Namib Desert. Report by EnviroScience, Windhoek.
13. Müller, S (2011): Rehabilitation Projects and Monitoring 2011. Orano Mining Namibia Pro-
cessing Namibia internal report.
14. Hooks, P (2014): An Assessment of the Intensity and Extent of Brine Discharges from the Erongo
Desalination Plant: Implications for Environmental Management. Mini-dissertation (MOB791)
submitted in the partial fulfilment of the requirements for the degree Magister in Environmental
Management, University of the Free State, Bloemfontein, South Africa.
15. Roux, P et al (2010): Environmental Impact Assessment Trekkopje Road. Report No. 30375 EIA
compiled on behalf of Turgis Mining Consultants, Johannesburg, South Africa.
16. Kinahan, J (2006): Archaeological Assessment of a proposed open-cast uranium mine at Trek-
kopje, Erongo Region, Namibia. QRS Job 73 prepared by Quaternary Research Services on be-
half of Uramin (Pty) Ltd, Windhoek, Namibia.
17. Müller, S (2015): 2014 Annual Report on Environmental Management at Trekkopje Mine. Orano
Mining Namibia Processing Namibia document no. HSE ENV RE 22.
18. Müller, S (2011): Results of Fixed Transect Vegetation Monitoring 2008-2010. Orano Mining
Namibia Processing Namibia internal report.
19. Mannheimer, C (2008): Rescue, relocation and monitoring of Commiphora dinteri from the Maxi
Leach Pad at Trekkopje Uranium Project. Unpublished report for Uramin.
20. NamPower/Namibia Nature Foundation Partnership (2016): Newsletter No. 17, October 2016.

21. Müller, S (2018): Biannual Report on Water Management at Trekkopje Mine, July-December
2017. Orano Mining Namibia document no. HSE ENV RE 32.
22. Oertzen, D von et al (2012): Trekkopje Mine Radiation Management Plan. Report by VO Consult-
ing and Orano Mining Namibia to the National Radiation Protection Authority.
23. Burke, A (2017): Restoration Monitoring at Trekkopje - Monitoring Report of 2017. Report by
EnviroScience, Windhoek.
24. Burke, A and S Müller (2012): Trekkopje Mine Closure Plan, Working document, version 2. Re-
port by EnviroScience, Windhoek.
25. Petrick, W (2018): 2018 Environmental (EMP) Compliance Audit of Orano's Trekkopje Mine and
Desalination Plant Project. No: NSP201801, Report No.: 01, Swakopmund.
26. Müller, S (2019): Erongo Desalination Plant 2018 Annual Report on Water Management. Orano
Mining Namibia document no. HSE ENV RE 42.

ATTACHMENT 1: ENVIRONMENTAL STRATEGY AND ACTION PLAN PROGRESS REPORT 2018
The objective of this attachment is to report on progress made with the environmental action plan by the end of the year 2018 and to set document the ac-
tion for 2019. The plan is based on Orano Mining Namibia’s environmental strategies each of which has separate colour-coded tables. Strategies, objectives
and actions that are not applicable during the time of care and maintenance are shown in grey font. They are kept in the plan for reference and to be reac-
tivated in future.
1. ENVIRONMENTAL STRATEGY AND ACTION PLAN
Themes Objectives Actions Status at end of 2018
Integrated  Local regulations and Orano directives  Maintain a legal register and keep in-  Full legal register to be implemented at
Management are enforced and potential modifica- formed about proposed legislation start-up, meanwhile subscribing to Gov.
System tions are anticipated changes in Namibia Gazette and checking for applicable acts
 The significant environmental aspects  Obtain directives and policy changes  Orano Head Office places updated doc-
and risks associated with each activity from Orano Head Office uments on intranet and e-mail
are identified, assessed and prioritized  Identify environmental aspects and risks,  Trekkopje aspects updated in 2016 EMP,
 A consolidated environmental action update EMPs desalination plant EIA & EMP updated in
plan is drawn up and each action is  Set up a QHSE action plan for each year 2018
monitored at least annually and monitor progress annually  Tracking progress in QHSE action plan
 Environmental criteria are taken into  Conduct internal environmental assess- and EMP audits
account when decisions with a signifi- ments for projects with significant impact  No significant projects were planned or
cant environmental impact are made and prioritize remedial actions implemented in 2018
Awareness  All new hires are alerted to significant  New employees and contractors attend  Re-induction for employees in early 2017,
Training environmental aspects and risks asso- environmental induction before starting induction given to all new contractors dur-
ciated with the company’s activities work ing the year
 The environment is discussed at meet-  Environmental issues are presented at  Refer to minutes of monthly HSE meet-
ings and toolbox talks monthly HSE meetings and discussed ings and records of weekly safety talks
 Managers at all levels carry out partici- shift at start talks  Managers conducted HSE inspections as
patory HSE inspections including envi-  Managers include environmental as- planned, environmental findings were
ronmental issues pects in their HSE inspections mainly waste-related

Internal  The environmental policy is updated  Update policy annually and display on  Policy updated in 2018 and displayed,
Communication and posted, objectives and indicators notice boards objectives and indicators tracked in
are set annually and tracked  Investigate and report significant envi- monthly reports
 All incidents are investigated; employ- ronmental incidents according to proce-  One environmental incidents was report-
ees are informed of the corrective or dure, inform employees of events and ed in the Orano database and monthly
preventive action taken action taken report
 Improvement ideas and good practices  Environmental improvement ideas are  No specific improvement ideas, but good
are recorded and exchanged between recorded in monthly reports and ex- practices were exchanged within Orano
business units changed within Orano Mining Namibia and with members of the Namibian Ura-
and with other mines nium Association, e.g. in the water and
radiation working groups
External  Publish an environmental and social  Compile a report at least every two  Published a report for 2017 in 2018 and
Communication report to stakeholders years, either publish on company web- distributed printed copies to stakeholders
 Interact with the public site or send printed copies to local  Community consultant held meetings, but
stakeholders stakeholders did not raise environmental
 Hold meetings with stakeholders concerns
Biodiversity  Draw up a biodiversity action plan  Refer to Biodiversity Strategy  Refer to Biodiversity Strategy
Chemical  A hazard study is carried out and a  Carry out chemical risk assessment,  No new chemicals introduced in 2018
Accident schedule is drawn up to implement the review MSDS and emergency procedure  Still in care and maintenance phase, no
Risks conclusions when new chemicals are introduced new risks identified
 HAZID and/or HAZOP risk analyses are  Assess the risk of each new project  Trained employees and contractors in
carried out prior to the launch of pro- phase, modify the design if required emergency response procedures, equip-
jects or major upgrades of facilities  Maintain effective emergency response ment and response team are in place
procedures and equipment

Chemical  The group directives concerning asbes-  Asbestos and asbestos-containing mate-  Implemented, refer to Environmental
Health Risks tos, legionnaire’s disease and CMR rials are not permitted on site Code of Practice
substances are enforced  A legionnaire’s disease risk assessment  Legionella risk has been assessed and
is carried out and a monitoring schedule found to be low, no monitoring needed
is implemented if required  Completed CMR hazard assessment
 CMR substances are identified and re- study in 2009. No CMRs are used during
placed with less hazardous alternatives care and maintenance
if these are available
Soil and  All pre-existing pollution is assessed  Establish baseline conditions before ex-  Baseline survey (2007) did not identify
Groundwater prior to acquisition ploration or production work begins any pre-existing polluted sites
 Compile a plan to prevent the risk of  Compile procedures for activities that  Procedures are in place and employees
pollution and reduce potential impacts may cause pollution, train employees in were trained in spill response, restocked
 Prevent groundwater pollution through spill response and provide clean-up ma- spill kits in all workshops
seepage or spills terial  Soil surveys have been suspended for
 Carry out regular soil surveys to assess the care and maintenance phase as no
the mine’s impact when in operation new soil pollution is being generated
 Monitor the groundwater quality annually  Implemented, refer to annual reports
Monitoring  The site has a plan for radiological,  Implement the:  Using TLDs and alpha dosimeters for ra-
chemical and biological monitoring of o Radiological monitoring programme diation monitoring (see reports)
the air, water and soil o Air quality monitoring programme  Monitoring dust emission and climate
o Water monitoring programme  Analysing potable water, groundwater
o Soil monitoring programme (radionu- and sewage effluent quality
clide deposition from dust fallout)  Soil survey has been suspended
Decommissioning  Compile a decommissioning plan for  Prepare an end of mine-life closure plan  Closure plan prepared in 2010, cost esti-
exploration and production sites and and a plan for premature closure, in- mates last updated in 2018, provision in-
provide the necessary budget clude closure cost in the budget cluded in annual budget
 Consult stakeholders about future land  Stakeholders will be consulted once the
use options and expectations mine is in operation
 Consider retrenchment plan and sus-  Preliminary consideration in closure plan,
tainable development issues to be refined in future

Water,  Consumption and releases are moni-  Monitor consumption and releases as  Monitoring and reporting as required
Energy, tored, measured and published required and report to Orano HQ  Figures are included in 2018 stakeholder
GHG  Annual targets are set to reduce water  Publish results in the annual environ- report (data table)
and fossil energy consumption, and mental and social report  Site-specific targets are set every year
GHG emissions  Set site-specific targets for GHG emis- and performance is tracked in monthly
sions, water, fuel and power consump- operations reports
tion
Waste  Waste materials generated by the mine  Keep a waste register specifying waste  Waste register kept for domestic, mineral
are identified and quantified types and volumes and hazardous waste (annual report)
 Targets are set for reducing waste at  Investigate options for waste recycling  No targets set in C&M as not much waste
source and optimising recycling and plan for waste reduction at source is generated; do recycle paper, wood,
metal, printer cartridges
Innovation  Reduce the consumption of non-  Identify options, e.g. solar energy and  5 MW solar power station was built by
renewable resources power-demand reduction measures independent contractor at Trekkopje, will
 Develop advanced technologies for the  Re-use heap leach effluent in a closed include a small PV plant for the mine’s
treatment of waste and effluent loop to minimize effluent discharge use as well
 Improve modelling in terms of long-term  Geochemical modelling to assess long-  Implemented in water balance, also plan-
contaminant behaviour and transport term behaviour of contaminants re- ning to re-use high-chloride wash water
leased from backfilled tailings  Modelling done in 2012, closure plan ad-
justed according to outcome, no further
work needed

2. AIR QUALITY STRATEGY AND ACTION PLAN
Objectives Activities Tasks Status end of 2018
1. Emission sources are  Identify all emission  Identify and record emission sources  Sources identified for operations phase
identified, documented and sources  Use dust buckets and PM10 samplers to (see air quality model)
monitored  Monitor and record con- determine dust emission  Dust buckets and PM10 samplers in place
centrations of gases and  Use gas samplers for SO2 and NO2  Suspended during care and maintenance
dust
 Monitor radon emission  Alpha dosimeters for radon in place
 Collect climate data
 Operate and maintain weather stations  One weather station operating
 Standardise equipment to
compare data with other  Make air quality data available to the SEMP  Provided data for 2017 SEMP report that
mines in the area office and the public was published in 2018
 Investigate feasibility of equipment stand-  Most mines use E-samplers, but not stand-
ardisation with other mines ardised for all
2. No impact on community  Carry out a community  Determine possible impacts based on air  Public health risk assessment carried out in
health health risk assessment quality models 2011
based on air quality im-  Monitor air quality at Arandis and other crit-  Monitoring at Arandis and on the mine,
pacts ical group locations (if any) though no critical groups are present on or
 Communicate with stakeholders about as- near the mine site
sessment results  Results included in SEMP reports which
are published on the MME/GSN website
3. Emissions during con-  Set limits and monitor  Compare measured emissions to set limits  Monitoring was done until construction
struction are reduced as compliance and SA standard ended in 2012, see annual reports
far as practical (this objec-  Determine effective miti-  Mobile crusher feed bins to be fitted with  Was done, no crushing during C&M
tive does not apply during gation measures water sprays
care and maintenance but  Procedure in place and implemented during
is kept in the plan for ref-  Allocate responsibilities  Implement dust control procedure construction
erence) for dust control  Reduce dust through water spraying  Water still sprayed on the main roads
 Model and predict air  Update air quality model and apply results  Model was updated in 2011 and results
quality impacts in project design were applied during construction

4. Emissions during opera-  Include dust control  All material transfer points to be fitted with  Dust suppression equipment was fitted at
tion comply with WHO tar- measures in material dust suppression or dust extraction equip- primary and secondary crushers
gets (this objective does transport and handling ment
not apply during care and systems design  Compile emission control procedures for Procedures to be compiled by operating
maintenance but is kept in  Implement operational each source and emergency plans for ex- departments when the mine starts up
the plan for reference) control measures and cessive emissions
emergency plans  Spray surfaces with water to speed up
 Stabilise or rehabilitate disturbed surfaces crust formation
 Regularly update the air to reduce wind erosion
quality model  Only applicable during mine operation
 Update the model if conditions change
 Monitor compliance  Refer to Objective 1
 Maintain air quality monitoring network
5. Nuisance dust from the  Dust fallout levels at resi-  Provide dust fallout data to the SEMP Of-  Monitoring results for 2017 were provided
uranium mines is within dences in towns should fice to be included in annual SEMP reports to the SEMP Office
acceptable thresholds not exceed the recom-  Measure air quality at Arandis  Dust monitoring at Arandis and on the mine
(SEMP) mended limit of 600 continued in 2018
2
mg/m /day  Measure dust close to mine boundaries
when the mine is in operation
6. Annual human expo-  Ambient PM10 concen-  Ambient PM10 monitoring at Arandis by  Readings at Arandis for 2018 did not ex-
3
sures to particulate con- trations at public loca- Orano Mining Namibia ceed the WHO IT-3 limit of 75 µg/m
centrations are acceptable tions and mines may not  Assist SEMP office with ambient PM10  Provided an E-sampler to MME for use at
(SEMP) exceed the limits to be monitoring at Swakopmund or other sites, if Henties Bay for the duration of the ad-
set for the Erongo Region requested vanced air quality study (2016-19)
 Limits to be based on  Data are evaluated and PM10 emissions  PM10 values were below the WHO limit (no
international guidelines reduced through dust control measures if need for dust control measures)
considering local envi- limits are exceeded
ronmental, social and  The SEA recommended using the WHO IT-

3
economic conditions Contribute to the discussion about suitable 3 guideline of 75 µg/m for the Erongo re-
limits for the region gion, current MME/SEMP study proposed
similar limits

3. BIODIVERSITY STRATEGY AND ACTION PLAN
1. Develop a Biodiversi-  Assess and evaluate  Undertake desk studies and review status of  Baseline studies and reviews done in 2006-7
ty Management Plan biodiversity in and protected areas and legal requirements as part of EIA (2008). EIA evaluated BD im-
around the operation  Evaluate biodiversity importance and deter- portance, determined impact of operations
 Enhance biodiversity mine impact of operations and mitigation measures
understanding  Conduct consultations with conservation  Strategic environmental assessment of ura-
 Identify risks and op- groups and communities, integrate differing nium mining in the Erongo region (2010) in-
portunities perspectives into the assessment of biodiver- cluded wide consultation and differing per-
sity spectives of all stakeholders
 Integrate biodiversity
into the EMS (refer to  Carry out field surveys and regular monitor-  Field surveys done 2009-11, annual monitor-
Objective 3) ing at specific sites ing of vegetation transects ongoing
 Identify opportunities to protect or enhance  Carried out biotope assessments and identi-
biodiversity fied important areas to be protected
 Define responsibilities and boundaries  Not yet documented
 Reconcile trade-offs or offsets  Method to be developed (see Obj. 2)
 Establish links to partners and local and re-  In progress, some links established (MET
gional environmental programmes NBSAP, NERMU, NACOMA, OmBMC)
2. Minimise Biodiversity  Mitigate impacts  Determine which impacts can be avoided by  Used system of ground disturbance permits in
Impacts  Rehabilitate affected proper planning 2008-12 to avoid unnecessary impacts
areas  Minimise unavoidable impacts, e.g. by reduc-  Applied these mitigation measures during the
 Document habitat dis- ing the affected area, relocating plants, stor- construction phase, no further disturbance in
turbance and rehabili- ing topsoil 2013-14
tation  Rehabilitate areas as soon as possible after  Did this at the end of construction in 2012,
 Implement conserva- disturbance ends monitoring success of rehab measures
tion and offset actions  Use Biotope Method to document changes in  Have data for 3 years, will continue with this
habitat disturbance once the mine is in operation
 Use appropriate rehabilitation methods de-  Established own rehab trial plots to test differ-
veloped and tested in the Namib ent methods, monitoring them annually
 Identify acceptable offsets in consultation with  Offset system to be established by Govern-
stakeholders, implement approved actions ment, workshops held in 2018 to develop poli-
cy

 Support regional conservation groups and  Will continue once the mine is in operation
efforts as well as biodiversity studies
3. Integrate Biodiversity  Identify impacts of  Take part in project planning meetings and  No new projects in 2017
into Operating Plans planned processes on workshops to find out about new projects  All contractors on care and maintenance pro-
(most of this objective biodiversity  Obtain plans, do risk assessments and eval- jects receive environmental induction
does not apply during  Create awareness uate impacts
care and maintenance  EMS to be established before the start of op-
among contractors  Arrange for EMP training modules and pre- eration
but is kept in the plan who implement new
for reference) sent to engineers and contractors  Closure plan (2013) includes rehabilitation
projects
 Include biodiversity aspects in the EMS, re- measures and cost
 Develop EMS and habilitation and offsets in the closure plan
closure plan

4. HAZARDOUS MATERIALS STRATEGY AND ACTION PLAN
Objectives Activities Tasks Status at end of 2018
1. Plans are in place before  Understand the environ-  Document the environmental hazards of  Carried out health risk assessment in 2017
hazardous materials are mental risks of hazardous materials brought to site, site products, in- including all hazardous materials
purchased and used materials termediates and by-products  Assessment done by Orano HQ in 2010,
 Identify and assess envi-  Consider impacts associated with transport, recommendations implemented, no new is-
ronmental aspects and storage and use, including failure of sec- sues in 2018
potential impacts ondary containment structures  Internal criteria only developed for radioac-
 Develop internal compli-  Internal criteria must be in line with interna- tive materials which are regulated by gov-
ance criteria for hazard- tionally accepted regulations, guidelines, ernment (refer to RMP), other materials to
ous materials and site definitions and methodologies if govern- be addressed before mine start-up
contamination ment regulations are absent or incomplete  Inventory of hazardous materials kept on
 Maintain an inventory of  Inventory of hazardous materials brought to the purchasing system, but this does not in-
hazardous materials site or produced on site documents their clude details of storage and final destination
 Keep a register of con- storage, usage and final destination  Baseline survey did not identify any pre-
taminated sites with geo-  Identify existing contamination and assess existing polluted sites, any new spills that
graphical references (if its environmental impact, record contami- could cause contamination were cleaned up
any) nated sites in a register  System to be put in place at mine start-up
 Reduce the inventory of  Control the use and inventory of hazardous  Carried out CMR assessment in 2009, did
hazardous materials materials to minimum necessary quantities not identify any chemicals that could be re-
 Replace CMR with envi-  Assess and promote the use of safer alter- placed with alternatives
ronmentally safer alterna- natives to currently used hazardous materi-  Procedure for safe use, storage and
tives als, especially those classified as CMR transport is in place (HSE ENV PR 11)
 Ensure the safe use,  Apply risk assessment and set up proce-
storage and transport of dures for safe use, storage and transport
hazardous materials

2. Hazardous materials  All employees and con-  Include handling and use of hazardous ma-  General induction includes basic infor-
management is integrated tractors are made aware terials in job-specific inductions; give job- mation about hazardous materials; supervi-
into mine operations of environmental hazards specific training in routine activities and sors give job-specific training to new em-
and risks and are appro- emergency response training in remedia- ployees and contractors; QHSE department
priately trained tion of contamination trains emergency response teams
 Control new hazardous  Implement a permit system to allow only  System in place and described in proce-
materials, including those those new hazardous materials on site that dure HSE ENV PR 11, but up to now not
used by contractors do not adversely impact the environment applied to contractors
 Store materials in ade-  Procedure to prescribe storage conditions  Procedure in place; user departments are
quate conditions and se- and containment, securely protected from responsible for secure containment and ac-
cure containment within contact with non-authorised personnel and cess control; currently mostly kept at
controlled areas wildlife Warehouse and not accessible to wildlife
 Operate effective con-  Above-ground tanks, drum storages and  Some secondary containments in pilot
tainment barriers for pre- pipelines that contain hazardous material plants were not designed with the neces-
venting spills of hazard- must have properly designed secondary sary capacity, but they are not in use any-
ous material from reach- barriers to contain 110% of the volume of more; fuel depot has sufficient containment
ing the environment the largest container  Storage tanks and pipelines at Trekkopje
 Hazardous material stor-  If storage tanks or pipelines cannot be mine are all above ground
age tanks and pipelines above ground the exception must be au-
must be above ground thorised by the Mine Manager  Inspections are currently only carried out at
 Storage tanks and pipe-  Inspect storage tanks and pipelines con- the fuel depot, but will be included in plant
lines must have leakage taining hazardous materials to detect leak- operating procedures one the mine starts
identification and re- ages and take appropriate remedial action up
sponse procedures according to procedure  Transport company for radioactive materi-
 Control third-party trans-  Implement selection criteria and control als selected according to RMP require-
porters, purchasers and procedures for third parties; implement fol- ments; hazardous waste transported by
other recipients of haz- low-up procedures for any hazardous mate- Orano Mining Namibia staff, disposal certif-
ardous materials rial sent off-site, e.g. for disposal icates issued by Walvis Bay hazardous
 Be prepared to respond  Maintain emergency response procedures, waste facility
to on-site and off-site equipment and response team  Response team in place and trained, pro-
hazardous material spills  Carry out regular drills when mine is in op- cedure updated
 Remediate existing con- eration
taminated sites that show  Develop and implement a remediation  No pre-existing polluted sites were identi-
unacceptable environ- strategy for existing contaminated sites, if fied at Trekkopje mine
mental impacts any are present

3. The hazardous materials  Implement routine inspec-  Inspect, test and monitor storage tanks and  Storage tanks are inspected as per care
management system is in- tion, testing and monitor- pipelines for leaks or deterioration at a fre- and maintenance schedule on PRAGMA,
spected and audited ing procedures for stor- quency and methodology commensurate leaks are repaired when detected, bunding
age tanks and pipelines with the environmental hazards is in place
 Install leakage detection  Leakage detection equipment to be in-  Leakage detection equipment or monitoring
equipment that is ade- stalled where needed and linked to the ap- boreholes will be installed if and when re-
quate for the risk posed propriate operational control and emergen- quired during operation or before start-up
by the hazardous material cy response unit
 Audit significant aspects  Implement a systematic auditing procedure  Internal and external audits of hazardous
of hazardous materials for hazardous materials management on material storage and handling are carried
management site to verify its adequacy and performance out (see 2018 EMP audit report by SLR)

5. NOISE AND VIBRATION STRATEGY AND ACTION PLAN
(to be implemented at mine start-up, no environmental noise and vibration generated during care and maintenance)
1. Emission sources are  Identify and record all  Review mine plan and identify emission  Noise and vibration monitoring will be im-
identified, documented and emission sources sources plemented at mine start-up, there are no
monitored  Monitor and record noise  Use sound level meters to determine significant emissions during care and
and vibration noise levels; monitor blasting vibration maintenance
 Collect climate data  Operate and maintain weather stations  Weather stations are in place and working
 Manage cumulative im-  Cooperate with other uranium mines and  See first comment above
pacts compare data
2. No impact on community  Carry out a community  Determine possible impacts based on data  Data will be collected and impacts will be
health or wellbeing noise risk assessment collected at Trekkopje assessed at mine start-up, also at Arandis
 Include noise nuisance  Monitor noise levels at Arandis once the new road has been built
from traffic to the mine  Communicate with stakeholders  Stakeholders will be informed
3. Noise and vibration  Implement operational  Noise and vibration control through opti-  Optimal blast loading will be determined in
emissions during mine op- noise and vibration con- mal blast loading cooperation with Mining department
eration are managed trol measures and emer-  Material transfer systems at Arandis siding  Noise suppression will be considered in
gency plans to be fitted with noise suppression equip- design
 Include control measures ment  Will be done once the mine has started up
in the design of material  Compile control measures for each signifi-
transport and handling cant source and emergency plans for ex-
systems cessive emissions
 Update the plan if conditions change

6. SUSTAINABLE DEVELOPMENT STRATEGY AND ACTION PLAN
Commitments Objectives Activities Status at end of 2018
1. Financial performance: Sig-  Realise financial benefits  Optimise the mining process to  Trekkopje mine was put under care and
nificant contribution to the through uranium production reduce production cost maintenance in 2013 because the project
economy is currently not economic
 Contribute to the Namibian  Pay taxes and royalties
economy
 Use local suppliers  99% local procurement in 2018
 Invest in community economic de-  Community projects in 2018 focussed on
velopment SME development, education and sport
2. Environment and biodiversi-  Optimise the consumption of  Set annual targets and track per-  Setting targets and tracking consumption
ty: Reduce and mitigate the fuel, electricity and water formance of fuel, electricity and water
unavoidable impact of the
mine  Reduce the mining footprint  Prepare a biodiversity action plan,  Biodiversity impact areas identified, BD
and biodiversity disturbance plan for land use after closure plan to be prepared at start-up
 Control pollution and waste  Set targets to reduce emissions  Tracking greenhouse gas emissions and
disposal and waste waste volumes
 Prevent or mitigate hazardous ma-  Gave training and provided spill kits to
terial releases clean up accidental spills (four spills rec-
orded in 2017)
3. Occupational health and  Workers on the mine remain  Medical surveillance of employees  All medicals done, no new cases of occu-
radiation protection: No expo- fit for work and contractors pational disease identified
sure to unacceptable harm
 Comply with the ALARA prin-  Monitor and manage employee  No worker was exposed to over 8 mSv
ciple exposure over 12 months in 2018
 Optimise handling and secu-  Maintain effective security and  Product stored according to procedure;
rity of product emergency systems security and emergency systems in place
4. Occupational safety: Zero  Eliminate accidents at work  Implement the safety roadmap  2018 safety roadmap 98% implemented
accidents  No fatality or lost-time injury in 2018
 Improve near-miss reporting
 All incident frequency rate = 0
 Near-miss reporting in place
5. Community involvement  Implement the social policy  Employ local staff  Compliant with Namibian AA legislation
and relations with stakehold- (HSE ENV PO 03) and com-  Use local suppliers  99% local procurement in 2018

Commitments Objectives Activities Status at end of 2018
ers: Sustainable improvement munity engagement strategy  Identify sustainable projects in  Financed an SME micro-credit scheme to
of community conditions consultation with stakeholders support sustainable economic develop-
 Partner with government to im- ment in the Erongo region
prove social services (health,  Supported education projects (refer to
schools, training) Stakeholder Report for details)
6. Commitment to employees:  Enhance employees’ careers  Retain the current workforce  Headcount stable in 2018
Skills and diversity and skills, meet diversity tar-  Develop skills by training employ-  Employee training continued, contractors
gets ees and contractors included in HSE and first aid in 2018
 26% women on management  50% women on management committee at
committee the end of 2018
 Employ more disabled persons  No recruitment permitted in C&M
7. Innovation: Optimise mining  Improve operational efficien-  Conduct metallurgical test work to  No research projects in 2018
processes cy to reduce production cost optimise the heap leaching process
8. High standard of corporate  Operate in an accountable  Maintain external communication  Procedure in place, but no complaints re-
governance is maintained and transparent manner ac- and complaints procedures ceived in 2018
cording to the Orano Mining  Issue annual reports to stakehold-  Report on 2017 issued in April 2018
Namibia Values Charter (or ers
Ethics Standard)  Introduced a fraud hotline in October 2014,
 Offer employees and contractors received no reports in 2018
an anonymous tip-off service

7. WATER STRATEGY AND ACTION PLAN
1. Optimised water use ef-  Maintain adequate water  Manage seawater desalination as speci-  Operator managed the plant as specified
ficiency supply fied in contract and supplied sufficient water to the mine
 Optimise water balances  Compile monthly water balances when in  Not applicable during the care and
 Plan and construct site infra- operation, identify opportunities for de- maintenance phase
structure mand reduction  New options will be investigated before
 Investigate and implement water recy- mine start-up based on the outcome of
cling and treatment options metallurgical test work to optimise the
 Plan correct placement of fresh and fire heap leaching and elution processes
water pipes, effluent and recycle systems,  Done in construction phase 2010-2012,
tanks and ponds documented in as-built plans
2. Minimal adverse impact  Set up monitoring systems  Monitor boreholes and extend the net-  Current monitoring borehole network is
on water quality and the and check water quality, wa- work as required sampled annually (April 2018)
environment ter levels and condition of  Compile groundwater flow and geochem-  Groundwater flow and geochemical
vegetation ical transport models to predict the impact transport models were updated in 2011
 Model and predict impact of of spent ore backfilling on the natural and 2012, with the results being used to
mine processes groundwater quality compile the mine closure plan
 Take action to prevent or  Monitor and evaluate water quality trends,  Trends evaluated in annual report on en-
remediate pollution implement control measures in case of vironmental management, no significant
 Comply with MAWF permit spills or leakages spills occurred in 2018
conditions  Compile biannual reports on permit com-  Two reports for Trekkopje and one for
pliance, water management and water EDP compiled for 2018 and submitted to
quality monitoring DWAF (permits renewed in Jun 2016)

3. Awareness of internal  Identify and address com-  Identify community expectations and per-  Had meetings with individual stakehold-
and external stakeholders’ munity concerns ceptions in relation to water ers and groups, e.g. Swakop farmers
issues associated with wa-  Create water conservation  Include water awareness training in in-  Water conservation is included in induc-
ter awareness ductions for employees and contractors tions that are given to all new workers
 Contribute to sustainable  Compile internal and external reports on  Annual environmental and stakeholder
water management initia- the operation’s water performance reports contain water use data
tives  Be active in industry and civil organisa-  Orano Mining Namibia is a member of the
 Comment on proposed legis- tions, e.g. Namibian Uranium Association NUA Sustainable Development Commit-
lation and regulations (NUA), basin management committees tee and (dormant) Omaruru Basin Man-
 Participate in discussions with regulators agement Committee
to ensure that the industry’s concerns are  No discussions held in 2018, workshops
considered about the Water Act and regulations are
planned when it commences (according
to MAWF)

8. PUBLIC HEALTH STRATEGY AND ACTION PLAN (SEMP OBJECTIVES)
Objectives Indicators Activities Status at end of 2018
1. Increments in the concentra-  Public dose assessments pro-  Monitor pathways by which radiation  Monitoring on site and at Arandis,
tions of uranium, thorium and duced by each new mine project emissions may reach the public results reported to SEMP Office
health-relevant nuclides of include the cumulative impact of  Carry out public dose assessment  Public dose assessment done in
their decay chains (e.g. Ra- other operating mines based on modelling 2011, update not necessary in C&M
226 and Ra-228) in air and  Modelled cumulative radiation
water that originate from ura-  Manage emissions if they exceed the  Not applicable in C&M
dose to critical groups of the dose constraint
nium mines, must be con- public does not exceed 1 mSv/a  Public is informed about results by
strained so that the cumulative above background  Inform the public about results means of annual SEMP reports
public radiation dose does not  Update the model when conditions  Model will be updated when condi-
exceed 1 mSv/a above back- change and at closure tions change and at closure
ground
2. The cumulative radiation  Measured change in absorbed  Measure radiation doses of occupa-  Measure radiation doses of occupa-
dose to members of the public radiation dose of uranium mine tionally exposed and non-exposed tionally exposed workers
and radiation workers does not workers (radiation workers) workers  Not applicable during C&M, no work
exceed the legal limit  Reduce exposure if warning limit is done with highly radioactive material
exceeded  Results are reported to all workers in
 Report results to affected workers HSE meetings
3. No measurable increase,  Measured change in the inci-  Identify and record incidences of in-  Industrial diseases are identified at
directly attributable to uranium dence rate of industrial diseases dustrial diseases amongst uranium annual medical examinations; to date
mining in the incidence rates of amongst uranium mine workers mine workers through medical surveil- none reported for Orano Mining Na-
industrial lung disease (includ-  Measured change in the inci- lance mibia employees or contractors
ing pneumoconiosis), lung and
other industrial-related can-
dence rate of industrial diseases  If possible, take part in studies to iden-  Rössing started a study to identify the
scientifically attributed to radia- tify and record diseases scientifically incidence of cancer among workers
cers, industrial-induced renal tion amongst members of the attributed to radiation amongst mem- and members of the public, other
damage, tuberculosis, dermati- public, uranium mine workers bers of the public mines cannot take part
tis and medical personnel
4. Exposures are reduced to  All types of radiation sources  Identify radiation sources and docu-  RMP updated in 2016 for the care
as low as reasonably achieva- that could contribute to the ex- ment in Radiation Management Plan and maintenance phase identifies all
ble (ALARA) posure limits being exceeded  Identify public exposure pathways sources and pathways
are adequately characterised and assess dose rates  Medical examinations and radiation
 Radiation doses to workers and  Maintain exposure and medical moni- monitoring carried out as scheduled
the public are monitored and toring programmes  Applicable when the mine is in oper-
minimised ation
 Implement mitigation measures

9. WASTE MANAGEMENT STRATEGY AND ACTION PLAN
1. Waste is character-  Compile a waste invento-  Survey waste types and volumes of all de-  Will be done when mine is in operation,
ised and risks are as- ry partments and document currently have mostly domestic waste
sessed  Assess and evaluate  Carry out environmental risk assessment  RA was included in ESIA (2008)
risks associated with all  Research suitable disposal methods  Research and identification completed,
waste types generated on waste management plan documented in
site  Identify hazardous waste types that need
special storage and disposal procedure HSE ENV PR 19
 Identify appropriate man-
agement system  Compile a waste management plan based
on the waste management hierarchy
2. Waste is avoided and  Identify opportunities for  Compile a list of substances that can cause  CMR assessment carried out in 2009, no
reduced at source waste risk reduction cancer or mutations or that are reprotoxic CMR substances are used in C&M
 Identify actions and set  Identify less hazardous alternatives and  No opportunities for replacement when
targets for waste volume substitute if feasible mine was in operation
reduction  Identify reuse opportunities  To be done at mine start-up
 Separate materials for recycling and arrange  Recyclables to be separated in future
for removal and transport  Records kept of estimated volumes, no
 Keep records of waste volumes to assess if weighbridge available
reduction targets are met  Data are included in annual environmen-
 Report data as required tal reports
3. Waste disposal fol-  Store waste types sepa-  Provide colour-coded and/or labelled bins or  Colour-coded bins for domestic, hazard-
lows good practice rately in clearly marked skips at waste sources ous and contaminated waste are in place
dedicated areas  Train employees in correct waste separation  Trained employees in 2018
 Discard waste only at and handling  Took some waste to Arandis landfill in
approved landfills  Use Swakopmund or Walvis Bay landfills 2018
 Audit waste removal con-  Inspect and audit waste separation and  Deviations found during inspections and
tractors to ensure compli- storage audit are addressed
ance
 Report cases of non-compliance and follow  Swakopmund landfill inspected in 2016
up on corrective action  Filing system in place for Walvis Bay
 Keep records of waste disposal hazardous waste certificates

10. ENVIRONMENTAL RADIATION MANAGEMENT STRATEGY AND ACTION PLAN
2. An effective radiation man-  A clearly defined chain of re-  Define and document duties and  Duties and responsibilities are de-
agement system is established sponsibility is established responsibilities fined in the 2016 RMP
at the mine  Radiation areas and exposure  Survey radiation areas, identify  Mine-wide surveys suspended, but
levels are mapped sources and measure exposure dosimeters measure exposure
 Impacts on the environment are  Demarcate areas >5 mSv/a and  Completed and documented in
determined, managed and miti- restrict access RMP
gated  Assess and monitor impacts on air,  Monitoring of air and water contin-
 Response to emergencies, e.g. water, waste, food chain ued in 2018 (see annual report)
spills in public areas is immedi-  Optimise water management, air  Procedures are in place and up-
ate and effective emission control, waste disposal dated
procedures  Emergency procedures included in
 Establish emergency procedures RMP, but not relevant during C&M
3. Increments in the concentra-  Public dose assessments pro-  Monitor pathways by which radiation  Monitoring on site and at Arandis,
tions of uranium, thorium and duced by each new mine pro- emissions may reach the public results reported to SEMP Office
health-relevant nuclides of their ject include the cumulative im-  Carry out public dose assessment  Public dose assessment done in
decay chains (e.g. Ra-226 and pact of other operating mines based on modelling 2011, update not necessary in
Ra-228) in air and water that  Modelled cumulative radiation C&M
originate from uranium mines,  Manage emissions if they exceed
dose to critical groups of the the dose constraint  Not applicable in C&M
are constrained so that the cu- public does not exceed 1 mSv/a
mulative public radiation dose above background  Inform the public about results  Public is informed about results by
does not exceed 1 mSv/a above means of annual SEMP reports
background (SEMP)
4. The cumulative radiation  Measured change in absorbed  Measure radiation doses of occupa-  Measure radiation doses of occu-
dose to members of the public radiation dose of uranium mine tionally exposed and non-exposed pationally exposed workers
and designated radiation work- workers and medical profes- workers  Not applicable during C&M
ers does not exceed the legal sionals (designated radiation  Reduce exposure if limit is exceeded
limit (SEMP) workers)  Results are reported to all workers
 Report results to affected workers in HSE meetings

11. MINERAL WASTE MANAGEMENT STRATEGY AND ACTION PLAN (not applicable to C&M)
1. Waste is character-  Compile a waste in-  Identify all mineral waste types  Mineral waste types have been identified
ised and risks are as- ventory  Commission geochemical studies and mod-  Geochemical studies done 2008/9, model-
sessed  Characterize geo- elling to determine releases ling completed 2012
chemical behaviour  Carry out environmental impact assess-  Risks assessed in 2011/12 public health risk
 Assess risks associat- ments of long-term risks assessment and groundwater model
ed with mineral waste  Monitor radon emanation, dust emission and  Monitored radon emanation, no increased
 Monitor releases from leachates from waste dumps dust emission or leachates from dumps
mineral waste  Identify suitable disposal and rehabilitation  Closure plan updated in 2013 to include
 Plan closure measures methods best solutions for mineral waste disposal
2. The management of  Mines comply with  Ensure that DWAF permit contains condi-  DWAF indicated that the permit for the pro-
mines’ mineral waste DWAF industrial efflu- tions related to mineral waste management duction phase of the mine will contain rele-
sites (tailings and waste ent exemption permit  Update the RMP when NRPA issues regula- vant conditions
rock facilities) meets conditions tions for mineral waste management  NRPA had not yet issued regulations
national standards  Comply with NRPA
(SEMP)  Audit compliance of mineral waste manage-  Mineral waste facilities not audited in 2016
regulations ment measures with EMP (updated 2016)  Closure plan has not yet been submitted for
 Comply with approved  Rehabilitate backfilled areas as described in government approval. No backfilling done to
EMP the closure plan date, but rehabilitation measures being test-
 Comply with approved ed on disturbed areas
closure plan
3. Status of facilities is  Keep records of waste  Metallurgy department to monitor and report  Not applicable during care and maintenance
monitored and reported volume and monitor chemical analysis results
waste characteristics  Survey to measure mineral waste volumes
 Report to regulators  QHSE to compile statistics on mineral waste
and interested parties disposal, carry out inspections and arrange
 Inspect and audit to external audits, report to Orano Mining Na-
ensure compliance mibia and National Radiation Protection Au-
thority

12. VISUAL IMPACT MANAGEMENT STRATEGY AND ACTION PLAN
1. Visual im-  Visual impact and sense of place are in-  Carry out environmental impact assess-  Was included in 2008 environmental im-
pact is man- clude in all environmental impact as- ments including visual aspect identification pact assessment
aged sessments and sense of place  Stakeholder input was not included at the
 Mitigation measures are implemented as  Discuss visual impact with stakeholders at design stage because the mine is not visi-
per EMP the design stage to ensure that the final ble from towns and roads
 External monitoring of compliance with design includes mitigation measures  Visual impact was audited in 2015, auditor
visual impact mitigation measures takes  Monitor the visual impact as part of the found no impact on the public because the
place Environmental Control Officer’s annual ex- mine is far from towns and roads
ternal audit
2. Visual im-  Paint colours blend into the environment  Place structures close to each other and  All structures were placed as close to
pact of infra-  The height of plant structures is restricted away from areas that are visually exposed each other as possible
structure is  Set structures as low as possible, keeping  No structures on the mine are higher than
minimised  Mineral waste dumps are kept as low as
possible below 35 m above mean ground level 35 m above ground level
 Dump slopes are designed to resemble  Paint colours should be muted earth tones  Paint colours are mostly muted, except for
natural hills or medium grey for large surfaces (roofs the white precipitation building at the Maxi
and storage tanks) plant
 Bright colours should only be used for  No bright colours were used where they
safety markings as required by industry would be highly visible
 Height of dumps and pit backfill should not  Height restriction and slope angles for
exceed 7.5 metres. The slopes should be mineral waste dumps and backfilled tail-
flattened to less than 18 degrees ings included in closure plan and mineral
waste strategy
3. Light pol-  Light pollution is minimised, especially in  Where area lighting is needed use low-  Requirements mostly implemented, no
lution is re- areas that are visible from the B2 main level lighting which is shielded to reduce lights installed on high masts, only on
duced road, to reduce the impact on adjacent light spillage and direct lights to work are- plant structures
recreational land use as by using shutters to focus the beams
 Lighting is kept to a minimum within the  Install lamps close to working surfaces  Requirements mostly implemented, but a
requirements of the law, safety and effi- and mount reflectors above the lamp to light halo from the Midi plant can be seen
ciency improve ground level illumination and re- on the horizon from the vicinity of Arandis.
 Security lighting is designed to meet the duce light scatter to avoid the generation The impact should end when the Midi is
objective with the least amount of light of a light halo on the horizon decommissioned
pollution

 The impact of lighting on the environment  All area lighting must shine downwards,  Lights were installed so that they shine
(fauna) is reduced i.e. no high mast lighting, external up- downwards
lighting of structures or lamps that shine  Security lighting is the same as area light-
directly up into the sky ing which is controlled by ambient light
 Security and perimeter lighting must be sensors and stays on all night
shielded so that no light falls outside the  Manual switches were installed in low-use
area needing to be lit. Perimeter lights areas
and lights in low-use areas should be con-
trolled by motion sensors, ambient light  Lights are only installed in areas where
sensors or light switches they are needed, e.g. for security purpos-
es (CCTV)
 Lights should be directed into the work
area, i.e. shine inwards from the perimeter  Lights are mostly directed into work areas,
and not vice versa. More frequent light there are only a few elevated high-wattage
sources are preferable to single elevated lights, e.g. at the Maxi logistics yard
high-wattage lights
 Lighting structures used in the mining area  No lighting structures are used in the min-
should be mobile and placed below the ing area while the mine is under care and
level of the desert surface area if possible maintenance
 Use yellow light to limit attraction of night-  Yellow lights are used everywhere
flying insects

Orano Mining Namibia
PO Box 585
Swakopmund

846 Annual Environmental Report 2018

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2018 ANNUAL REPORT ON

No. Description Page No

1 ENVIRONMENTAL STRATEGY AND ACTION PLAN PROGRESS REPORT 2017 37

2018 Annual Environmental Management Report ii

No. Description Page No

No. Description Page No

2018 Annual Environmental Management Report iii

2018 Annual Environmental Management Report iv

1.1 Orano Mining Namibia

Figure 1.1: Locality Map

1.2 Update on Activities

2018 Annual Environmental Management Report Page 1

Installed stairs and handrails Maintained power supply system

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

Figure 1.2: Examples of C&M Activities in 2018

2018 Annual Environmental Management Report Page 2

Orano Mining Namibia acknowledges its Safety of Operations

PRIORITY ACTIONS FOR 2017-202 Environmental Performance

Facility Safety • Reduce the environmental footprint of our activities to

Figure 2.1: Orano Mining Namibia Environmental Policy

2018 Annual Environmental Management Report Page 3

3.1 Aspects and Impacts of Orano Mining Namibia

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

2018 Annual Environmental Management Report Page 4

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

2018 Annual Environmental Management Report Page 5

4.1 National Legislation

4.2 Environmental Legislation Review

4.3 Licences and Permits

4.4 Government Inspections

2018 Annual Environmental Management Report Page 6

4.5 Interaction with Government Institutions

4.5.1 Ministry of Mines and Energy – Geological Survey

4.5.2 Ministry of Agriculture, Water & Forestry – Water Basin Management

5 ENVIRONMENTAL OBJECTIVES AND TARGETS

2018 Annual Environmental Management Report Page 7

6 ENVIRONMENTAL MANAGEMENT PROGRAMME

6.2 Policies and Procedures

Table 6.1: List of Policies, Strategies and Procedures

Title Reference Application Latest

2018 Annual Environmental Management Report Page 8

Title Reference Application Latest

7 STRUCTURE AND RESPONSIBILITIES

2018 Annual Environmental Management Report Page 9

Figure 7.1: QHSE Department Structure in 2018

8 TRAINING, AWARENESS AND COMPETENCE

Table 8.1: Training of QHSE Section Staff

Courses/Training S Müller K Nkandi J Olivier

9 MONITORING AND FEEDBACK

2018 Annual Environmental Management Report Page 10

Figure 9.1: Used Resin Stored in Shipping Container

9.2 Environmental Monitoring Network

9.3 Climate and Air Quality Monitoring

2018 Annual Environmental Management Report Page 11

2018 Annual Environmental Management Report Page 12

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

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

2018 Annual Environmental Management Report Page 13

Figure 9.3: Monthly Rainfall at Trekkopje Weather Stations

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

2018 Annual Environmental Management Report Page 14

9.3.2 Dust Monitoring

Figure 9.6: Dust Fallout Bucket and PM10 Monitor