IMPACT ASSESSMENT CASE STUDIES FROM SOUTHERN AFRICA

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

SAIEA

Southern African Institute for Environmental Assessment

... working for a better Africa

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Aims of the Project
At the time of this project (2004), Namibia was importing more than half of its energy needs from South Africa, and rising demand in that country was likely to lead to a shortfall in supply from 2007. The Kudu Power Project was identified as one of the preferred options to address this shortfall, to increase base load capacity by 2011, and to meet the growth in power demand regionally (i.e. in SA and possibly other neighbouring countries). The power station would use natural gas reserves located offshore in the Kudu gas field, which were known to be sufficient to drive an 800 MW power plant for at least 20 years. The first phase of the Kudu Power Project would be development of an 800 MW combined cycle gas turbine (CCGT) power plant at Uubvlei near Oranjemund. Earlier planning had identified a Site D close to Oranjemund for the power station, but it was subsequently found that the routing of a gas pipeline to Site D was not favoured. NamPower and Namdeb, the diamond mining company with jurisdiction over the land that the power plant would occupy, identified Uubvlei as the most suitable alternative site. The EIA followed on from a Preliminary Environmental Assessment in 1998 and the EIA for Site D done in 2004; and information from those studies was applicable to the assessment of the Uubvlei site. This EIA covered all aspects related to the construction, operation and decommissioning of the CCGT plant as far it had been defined. The work was required to conform with relevant World Bank Guidelines for thermal power plants, as well as requirements of the International Finance Corporation.

Figure 1: Geographic context of the Kudu Gas Power Project.

SAIEA 2009

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Brief description of the development & alternatives considered
Natural gas would be the main fuel for the plant, with associated connections to the electricity and gas grids. Generation by combined cycle gas turbine is recognized as the most environmentally benign form of electricity generation by thermal methods, as it has a very high efficiency and proportionally lower air emissions and cooling water requirements than a conventional thermal plant. In particular, when firing on natural gas with low-NOx burners as planned, there are no significant emissions of NOx or SO2 and emissions of CO2 are over 50% lower than for a coal-burning plant. Where no constraints apply to gas availability, the CCGT technology is accepted world-wide as the most suitable technology for a power plant this size. Oranjemund is a small diamond mining town in the south-western corner of Namibia (Figure 1). Given the situation of the Kudu gas field, Oranjemund (rather than more distant towns such as Lderitz or Keetmanshoop) had been identified as the optimum location for a power plant; Uubvlei is located about 25 km north of the town. The site comprised mined-out land and lay within a high security diamond mining area. The area of the site, about 700 x 700 m, was adequate for construction staging and laydown as well as for possible later upgrading of the plant to 1600 MW capacity. All construction activities would be conducted on already disturbed land (Figure 2).

Figure 2: Map of the Uubvlei area showing the extent of land disturbed by diamond mining operations and proposed situation of the power station and associated activities.

SAIEA 2009

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Brief description of the development & alternatives considered
The construction workforce of about 1,300 workers would be accommodated near to the power station site. Either the existing mine hostel facilities at Uubvlei would be upgraded for this purpose, or new temporary facilities created on disturbed land. These temporary facilties would be in use for about two and a half years, after which it would have to be removed completely. In the event that the second phase of the power plant was implemented, these accommodation facilities would be required for another two and a half years years. Alternatives to a gas-fired power plant had been well covered in the 1998 and 2004 Kudu EIAs, and in a number of other NamPower projects including hydro, wind and biomass. It was clear that Namibia faced a serious power shortage in the near future and that the Kudu project was the best option under the circumstances. A number of within-project alternatives were considered, such as cooling options, minimization of social impacts, noise abatement and colour to reduce visual impacts. Issues around the availability of housing for senior staff still needed to be sorted out, but these were relatively minor and could be dealt with later in the process. The EIA process was hampered somewhat because of design uncertainties. The proponent was still considering various design options. This was not necessarily a weakness; on the contrary, it enabled the EIA process to influence design and operation one of the objectives of an EIA.

Environmental setting
Biophysical environment The topography between Oranjemund and the coast is low-lying and flat, and sand dunes rise up gently towards the interior to the north and east of town. Although located in a desert, cool, foggy conditions occur most mornings and strong southerly winds dominate the afternoons. Temperatures along the coastal strip are modified by the cold ocean. The area is arid with mostly winter rainfall. There is no agricultural potential at the site, it is used only for mining. The ecology of most of the southern Namib Desert is undisturbed because the Diamond Area has been closed to the public for about 100 years and mining activities were confined to the coastal strip and the Orange River valley (Figure 3). The proposed CCGT site was in a very disturbed mining area. Low hummock and shrub vegetation in most of the designated area was very sparse and in a disturbed state. Although some of the dominant and rarer plants were Namibian endemics or near-endemics, and some of them were protected species, they were relatively common along a considerable stretch of the coastal plains, and had already shown their propensity

SAIEA 2009

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Environmental setting
for re-establishing naturally once disturbance ceases. The zone that would be affected by the pipelines to and from the sea was similarly disturbed. Lichens are an important feature in the overall area, growing on plant hummocks, but it was not known if any species were endemic to a limited area here, or were of conservation significance for other reasons. As in much of the Namib, most of the ecological action by fauna in this area is carried out by small animals that can shelter from the harsh conditions of strong winds and meagre rainfall, and that can take advantage of fog water. While some conservation priority species were known to exist in the general area (e.g. the snake Bitis schneideri, and some wetland birds), the small footprint on disturbed land did not pose a significant threat to any. Socio-economic environment Oranjemund nearby lies within the Diamond Area and has strict controls on access. Though the land is owned by the State, infrastructure and assets are owned by Namdeb. The government intends Oranjemund to become a municipality, and a structure plan and site layout are being finalized in preparation for this. The town offers social services and facilities at a level usually only found in much bigger towns. Although it remains a closed town, it has developed a viable commercial service and industrial sector. Oranjemund has always rated itself as a very safe and secure town for its residents with an exceptionally low crime rate. This is partly due to the isolated nature of the town and its small size, but mostly because of the security measures which are implemented around the diamond industry.

Figure 3: Oranjemund and the proposed power station are situated in the Diamond Area or Sperrgebiet, where there has been strict control on access for over 100 years.

SAIEA 2009

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

EIA process followed
The EIA was undertaken in three stages: Scoping Specialist studies Integration and impact assessment. o Scoping The scoping undertaken during this EIA built on the preliminary work that had been undertaken before. Much of the background information for Uubvlei was identical to that for Site D; and issues relating to the functioning of the plant, emissions and other technical aspects were unchanged. However, in the interest of completeness, it was considered important to allow for thorough public participation once again. The process comprised the following: Compilation of a Background Information Document and invitation of stakeholders to a public meeting in Oranjemund. It was decided that Windhoek residents did not o o o o o Uubvlei hostel accommodation and options for supply of services to the workforce - water, electricity, recreation facilities, health services, catering, etc.; Visual and noise impacts; Security, access and transport; Aviation safety; Biophysical impacts; Project design and implementation, including options for water abstraction for cooling and purge water discharge; Options for waste management industrial waste during construction, household waste, sewerage, hazardous waste. Impacts of noise; Pollution, specifically impact of gas emissions on people housed in Oranjemund close by; The danger to people of non-standard operating situations; Power lines in proximity to Oranjemund and bird flight paths; Negative interactions between power plant workers and the Oranjemund residents. Regardless of the improved situation of the power plant, additional site specific issues warranted specific studies. These addressed the issues listed under scoping, and are discussed in the following section. require another public meeting, and would be able to respond to the Information Document by email. Issues were identified for further investigation, including: Specialist studies Establishing the plant at Uubvlei solved a number of the perceived drawbacks of Site D. These were: Visual distraction for Oranjemund residents;

SAIEA 2009

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Main environmental impacts & issues
Apart from the obvious economic benefit to Namibia of a secure energy supply, there was another positive impact that construction of the power station could provide employment opportunities for retrenched Namdeb workers. Social concerns and noise impacts The introduction of a large foreign workforce into the community of Oranjemund gave rise to a number of concerns of a socio-economic nature. Oranjemund residents live in a relatively small and closed community surrounded by tight security and the harsh southern Namib that is kept secure as the Forbidden Area. The town experiences little outside influence, and there was a concern t h a t t h e p o w er st at i o n w o u l d ch an g e t h i s. For instance, town might become unpleasantly crowded when large numbers of construction workers are present e.g. on Saturday mornings. However, since the workers would be housed 25 km away from the town, this concern could be mitigated by devising a transport schedule from Uubvlei to Oranjemund that smoothed out the surges in influx over the periods of concern. For recreation, it was proposed that two soccer fields be laid out next to the workers' accommodation to allow for informal football games to be played. These would probably satisfy much of the need for recreational facilities. Recreational facilities in Oranjemund would also be requested to open their doors to the temporary workers for the duration of the construction of the power plant. Whenever a large number of outside people join a community there is a concern that crime such as theft and assaults (at bars) will increase. However, since the workers would not be housed close to the town, the opportunities for such incidents could be regulated through the transport arrangements used to ferry the workers from the Uubvlei site. Construction vehicles would not be permitted in the residential and central business areas of the town. Since the workers would be housed 25 km away, use of their private vehicles would not add significantly to the traffic in town, except in the vicinity of the shopping centre for the short periods when they visited town to do their shopping. Since the power plant would be 25 km away from Oranjemund, noise from both its construction and operation would not have an impact on the town. Intermittent construction noises and more constant operational noises would impact people on site but these would come under relevant regulations under the Labour Act of 1992. Aviation safety The power plant at Uubvlei would not interfere with any aircraft flight paths. In this respect the Uubvlei site was again an improvement from the situation at site D. Air emissions An air quality study was undertaken to address the generation and subsequent dispersion of air pollution from the proposed power plant. Quantitative health risk assessments were done for SO 2 , NOx and particulate matter (PM); the main atmospheric emissions of concern were the oxides of nitrogen. The World Health Organisation (WHO) guidelines for NOx, the World Bank standard and the proposed new ambient air quality standards for South Africa were used for the assessment of impacts on human health. Risks were evaluated

SAIEA 2009

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Main environmental impacts & issues
for a child of 10 years and an adult of between 18-65 years of age at the site. Maximum average annual and 1-hour ambient concentrations for NOx from gas fired and No.2 fuel oil scenarios were modeled, and hazard quotients based on these results were mostly below the required safety margins for the acute and chronic NOx exposure scenarios. Emissions from the gas conditioning plant would be negligible. The health risk assessment for SO 2 exposure scenarios showed that it would be unlikely for any individual to develop adverse health effects due to SO2 exposure at the modeled concentrations. However, for 1-hour SO2 concentrations from the oil stack at double capacity, individuals at the site would be at risk. Concentrations modeled for total suspended particulate matter (TSP) from the oil stack after NO 2 mitigation were all well below international and proposed South African guidelines. Comprehensive air quality modeling and risk assessments showed that impacts from emissions from the proposed Kudu CCGT power station would be limited to the immediate area surrounding the plant. They would persist for the lifetime of the plant, but the intensity of the impact would be low, with and without mitigation. NOx was identified as important in terms of potential damage to vegetation in the study area. The modeling of NOx emissions indicated that levels would be well below those that had potential for impact. However, confidence levels for the assessment were low due to lack of data on effects that may occur in the specialized vegetation that is characteristic of the study area. However, the overall assessment of the impact of the proposed development on vegetation indicated that the significance of impacts was low based on pollutant loads and the distribution of the vegetation types on the Namibian coast. Assessment of the data did not indicate any fatal flaws. Visual impacts Consideration was given to whether the large power plant structure, with its associated cooling towers and the plume emanating from them, and the power transmission lines would have a significant visual impact on the ambience of the future Sperrgebiet National Park. The power plant, located at Uubvlei, would not be visually intrusive from more than about 7 km away. In addition, the power plant would be painted so that it blends into the surrounding landscape. In clear weather conditions, i.e. approximately 200 days per year, the plume would be visually intrusive, resembling a small cloud around the cooling towers. However, the feeling was that once people understood that it was water vapour being emitted, not smoke or chemical emissions, the significance of the plumes visual impact would decrease. Terrestrial ecology The proposed site of the power plant was in a previously mined area, where land was already disturbed. Construction here would have little further impact on the vegetation and flora. Any of the other structures associated with the power plant buildings, access roads, a materials laydown area, and possible temporary accommodation for the construction workforce, would be situated on disturbed land immediately south of and adjacent to the power station site. Due to the possible presence of amphibians and reptiles of conservation concern, and the trend of gradual reduction of their habitat, all activities

SAIEA 2009

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Main environmental impacts & issues
would need to be confined as much as possible to areas that were already disturbed. They should not be situated on undisturbed land. Impacts on particularly low hummock and coastal plain vegetation type would be expected during the construction and operational phases. In order to minimize disturbance, routes and turning points would need to be identified and demarcated before construction activities commenced, and the widening of tracks due to corrugations strictly prohibited. Impacts such as clearing for roads and other structures on any remaining pristine or less disturbed hummock vegetation in the direct surrounds of the CCGT site would need to be minimized. If sufficient control was exercised, later natural recolonisation of damaged areas (as had already occurred within the mining area) could facilitate restoration of the environment. Dust raised by construction activities would probably not increase dust levels significantly more than the area already experienced from mining activities. Plants, lichens and animals that inhabit this area are frequently exposed to strong sand-laden winds. Nevertheless, it was recommended that dust suppression should be practiced for the new construction. In regard to oil spill accidents, contractors must be familiar with steps to avoid such accidents, and what to do in the event it happens. It was suggested that the impact of operations on the affected area would need to be monitored by marking individual plants and lichens in the affected area and in a control area and monitoring them regularly. The mined-out foreshore zone and ponds habitat was an unnatural habitat, and had already been extensively

Figure 4: Coastal hummock vegetation typical of the Uubvlei site

SAIEA 2009

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Main environmental impacts & issues
compromised to such an extent that none of the proposed construction would compromise it any further. Beyond prevention of unnecessary collateral damage, no mitigation measures were suggested for this area. Overall, the ecological footprint of the power plant at Uubvlei Site was likely to be relatively small given the fact that the site was already ecologically sterile. The pockets of intact natural habitat were not to be disturbed. Purge water discharge For the purge water discharge, the two offshore discharge options both met World Bank water quality guidelines for effluent disposal. The shoreline discharge into the surf zone, however, required further investigation in terms of its impact on larval and juvenile fishes and larval invertebrates which may use the littoral drift as a transport/dispersal mechanism. This was of concern as a result of the proximity of the Orange River Estuary which serves as a nursery for a number of marine fish species. However, information from such an investigation might have allowed for even this option to be adopted. Cumulative Cumulative impacts were predicted to be minimal in this project, though associated impacts (visual impacts of the power line) would probably be more important. Because of the shift to Uubvlei, the visual and safety impacts of the power line were significantly less than was the case under the Site D scenario. Findings of the work on these issues were compiled in a Draft Environmental Impact Report which was made available for public comment. It was placed on the NamPower website, printed and CD copies of the document were distributed to government representatives on the Interministerial Review Group (IRG), and printed copies were made available in the Windhoek National Library, the Oranjemund Library and NamDeb in Oranjemund for comment.

Implementation of the EMP & compliance auditing

Follow-up of the recommendations was not necessary as the whole project was shelved shortly after planning for the Uubvlei site and powerlines had been completed, due to higher-level, strategic reasons. An EMP had deliberately not been included in the EIA report as NamPower and Namdeb were still considering a number of options regarding design. This lack of detail should not be considered a shortcoming of the EIA, but rather as a compliment to NamPower for including environmental considerations early.

SAIEA 2009

Compiled by John Pallett (SAIEA), for CSIR Client: NamPower

KUDU GAS POWER STATION NEAR ORANJEMUND, NAMIBIA

Main elements of excellence in this EIA
This EIA was one of a few that NamPower commissioned in their overall goal to generate electricity using southern Namibias offshore Kudu gas resource. Various sites for power stations and routes for powerlines were assessed as the power utility juggled with the complexities of siting a power station in a high-security diamond mining zone. Surprisingly no development of that resource has yet taken place. Strategic considerations, involving regional power utilities, led to this outcome. Nevertheless there were commendable elements of the EIA. The consultants produced an EIA report of high quality after running a process that was transparent and professional. Interested and affected parties were given ample opportunity to be part of the process, both during the compilation of the EIA and after the draft was published for comments. This EIA showed that Uubvlei was in many respects preferable to NamPowers original plans for the power station at Site D. In particular, diamond lock-up was likely to be less of a problem and social impacts were less. Given that the Uubvlei site was already highly disturbed because of past mining activities, the ecological impacts would be low and relatively easy to manage. Namdeb and Oranjemund residents were clearly more in favour of a northern site that would take the plant (and the visually intrusive power lines) further away from the town. In addition to being invited to participate in the EIA study, the I&APs were given ample opportunity to comment on the EIA report. It is somewhat surprising (and very disappointing) that no comments were received from the public on the draft EIA report. One can speculate on the reasons for this, but it is likely that no-comment in this case indicated satisfaction with the report. This assumption is based partly on verbal feedback from I&APs who are clearly relieved that the project was to be sited at Uubvlei rather than Site D. Moreover, there was probably an element of stakeholder fatigue, given that there had been so many studies, reports and meetings in the previous few years. The most substantial views were offered by Oranjemund residents and Namdeb. There is no doubt that their opinions influenced this project not only the siting of the power plant, but also other components of the project. The EIA provides a comprehensive record of the issues that were raised by the public, and the response of the consultants to these. The process was thorough and transparent. The consultants based their findings on various specialist reports, some of which were new whilst others were updates of previous reports. Overall, the EIA provided a thorough framework for decision making.

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