Ghana - Second Urban Environmental Sanitation Project : environmental and social assessment

E851 GOVERNMENT OF GHANA MINISTRY OF LOCAL GOVERNMENT AND RURAL DEVELOPMENT SECOND URBAN ENVIRONMENTAL SANITATION PROJECT (UESP II) ENVIRONMENTAL AND SOCIAL ASSESSMENT BUIRKINA FASU- 5114 , 4 C OT E D'I V OI RE tO ,,.G . ; 't B-43atan. i i T ;; | -* :1. V 1 ElNlJlROII ENIN>EERtIr'OT ( A DfAt n 8 4 NVAI>JAENVi EF'.T CC) N S LiT P>, rint.,'I,I - 0_ ~~~~~~~December 2003 uroj sr, i ~ ~ ~ ~ ~ S, 7"'I FLOOR, TRUST TOWERS, ACCRA, GHANA TEL.: 233-235403/4, FAX: 233-21-235403  TABLE OF CONTENTS 2 ABBREVIATIONS AND ACRONYMS 12 PART I. EXECUTIVE SUMMARY 14 PART II BACKGROUND 39 1.0 THE PROPOSED PROJECT 39 1.1 BACKGROUND ................................. . . 39 1.2 PURPOSE AND OBJECTIVES OF THE STUDY ................................ 41 1.3 SCOPE OF W ORK ................................. 41 2.0 DESCRIPTION OF THE PROJECT AREA OF INFLUENCE 43 2.1 PROJECT DESCRIPTION ............... 43 2.1.1 Component 1: Storm Drainage ............................... . 43 2.1.2 Component 2: Sanitation ................................ 44 2.1.3 Component 3: Solid Waste Management ............................... 46 2.1.4 Component 4: Community Infrastructure Upgrading .. ............................. 49 2.1.5 Component 5: Institutional Strengthening ............................... 50 2.2 PROJECTAREAOF INFLUENCE . . . .53 2.2.1 Storm Drainage ...................... 53 2.2.2 Sanitation ...................... 53 2.2.3 Solid Waste Management ...................... 53 2.2.4 Community Infrastructure Upgrading ..................... 55 2.2.5 Institutional Strengthening ....................... 56 3.0 DESCRIPTION OF POLICIES, LEGAL, AND INSTITUTIONAL FRAMEWORKS 57 3.1 POLICY ISSUES .... 57 3.1.1 Principles ..57 3.1.2 Policy Statement ..57 3.1.3 Waste Management ..57 3.2 GHANA LANDFILL GUIDELINES . . . .58 3.3 ENVIRONMENTAL SANITATION POLICY . . . .59 3.3.1 Solid Waste Management ..59 3.4 GUIDELINES FOR THE SAFE MANAGEMENT OF HEALTH CARE AND VETERINARY WASTE IN GHANA 59 3.5 LEGISLATION AND REGULATORY FRAMEWORK .60 3.5.1 Environmental Assessment Regulations ..61 3.6 INSTITUTIONAL FRAMEWORK ..64 3.6.1 Ministry of Environment and Science .64 3.6.1.1 Functtonn s.64 3.6.2 Ministry of Local Govemment and Rural Development .65 3.6.2.1 Local Government Act, 1993 (Act 462) ..65 3.6.2.2 Bye-LLas..65 3.7 INTERNATIONAL LEVEL ..66 3.8 COMMENTS AND RECOMMENDATIONS ..66 3.8.1 Collaboration and Coordination ............................. 66 3.8.2 District Environmental Management Committees ............................. 67 3.8.3 Legislative Gaps ............................. 67 3.8.5 Public Participation ............................. 67 3.8.7 Monitoring and Evaluation ............................. 68 3.8.8 Compliance and Enforcement ................................ 68 4.0 METHODS AND TECHNIQUES USED IN ASSESSING AND ANALYSING THE IMPACTS 70 4.1 BACKGROUND INFORMATION GATHERING AND LITERATURE REVIEW . .................................. ...... 70 4.2 ORIENTATION FOR EEMC ................................................... 70 4.3 FIELD WORK .................................................... . 70 4.3.1 Findings ................................................. 71 2  2.0 SANITATION IN AMA/GDA 71 4.4 CONSULTATIONS/ MEETINGS ......................... 76 4.4.1 Consultations .......................... 76 4.4.2 Meetings and Minutes ........................ ..77 4.5 GENERATION OF BASELINE DATA. 78 PART III: ENVIRONMENTAL& ANALYSIS AND ENVIRONMENTAL MANAGEMENT PLAN FOR THE PROJECT COMPONENTS AND SUB-COMPONENTS 79 5.0 STORM DRAINAGE 79 5.1 APPLICABLE SAFEGUARD POLICIES ............. ............................................. 81 5.2 THE IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS ................................... 82 5.2.1 The Environmental Impacts ......................................................... 82 5.2.1.1 Construction phase impacts ............................................................. 82 5.2.2 Social Impacts of the secondary drainage ......................................................... 83 5.3 ALTERNATIVES AND THEIR POTENTIAL ENVIRONMENTAL IMPACT ......................................................... 85 5.4 MITIGATION MEASURES .......................................................... 85 5.4.1 Impacts on peoples' livelihood .85 5.4.2 Slope, Erosion and Drainage .86 5.4.3 Spoil Disposal .86 5.4.4 Noise and Dust Pollution .86 5.4.5 Contractors' Camps .86 5.4.6 Construction Traffic .87 5.4.7 Maintenance of the drains .87 5.5 INTEGRATION OF EMP WITH THE PROJECT ............................................. 87 5.5.1 Objectives of Programme ............................................ . 87 5.5.2 Resources for Programme Implementation ............................................. 88 5.5.2.1. Pre-Construction Phase ............................................... 88 5.5.2.2 Construction Phase ............................................... 88 5.5.2.3 Operation and Maintenance Phase ............................................... 89 5.5.2.4 Specific Responsibilities of Some Concerned Agencies ............................................... 89 5.6 MONITORING ..89 5.6.1 The Construction Phase ..89 5.6.2 Operational and Maintenance Phase ..90 5.7 IMPLEMENTATION SCHEDULE AND COST ESTIMATES . .................................. 91 5.8 CONCLUSION AND RECOMMENDATION ..91 5.8.1 Conclusion .91 5.8.2 Recommendation .92 6.0 SANITATION 92 6.1 HOUSEHOLD, SCHOOLS AND PUBLIC LATRINES .............. .............................................. 92 6.2 TEMA SEWAGE SYSTEM IMPROVEMENT ........................................................... 93 6.2.1 Background ............................................................ 93 6.2.2 Rehabilitation Of Tema Sewerage System ........................................................... 93 6.2.3 Application of the Safeguard policies ........................................................... 94 6.3 IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL IMPACTS AND SOCIAL IMPACTS . ............................... 95 6.3.1 Environmental Impacts of the latrines construction and sewerage rehabilitation . . 96 6.3.1.1 Constructional and rehabilitation Phase Impacts .......................... ..................................... 96 6.3.2 Operational Phase impacts of the latrines as well as the Sewerage plant ........................................... 96 6.3.3 Social Aspect ............................................................ 97 6.4 ANALYSIS OF ALTERNATIVES AND POTENTIAL ENVIRONMENTAL IMPACTS . ....................................................... 98 6.4.1 The "Do-Nothing" or "Null"Altemative ........................................................... 98 6.4.2. Complete sewer systems ........................................................... 98 6.4.3 The Proposed Project ........................................................... 98 6.4.4 The Preferred Altemative ........................................................... 99 6.5 MITIGATION MEASURES OF THE ENVIRONMENTAL IMPACTS ............................................................ 99 6.5.1 Construction Rehabilitation Phase ........................................................... 99 6.5.2 Operational phase .................................................................................................................100 6.5.2.1 Noise nuisance control .....................o 00 3  6.5.2.2 Wastes ......................................... 00 6.5.2.3 Groundwater contamination .. ........................................ 0 6.5.2.4 Emergency response plans ..............................10........... 6.5.2.5 Public Sensitisation and Education .........................................100 6.6 INTEGRATION OF THE EMP WITH THE PROJECT ..................................... . 100 6.6.1 Major Environmental and Public Health Concems ..... 101 6.6.2 Air Quality and Odour Management . . . . . 101 6.6.3.1 Training and Awareness Programmes ........................................ 101 6.6.3.2 Accidental Spillage in Public Areas .. ...................................... 102 6.6.4 Programme to meet Requirements . . . . . 102 6.6. 5 Management Structure ..................................... . . 102 6.7 MONITORING . . . .103 6.7.1 The Construction Phase ..103 6.7.3 Operation and Maintenance . . . . . 104 6.8 IMPLEMENTATION SCHEDULE AND COST ESTIMATES . . . . 104 6.9 RECOMMENDATIONS AND CONCLUSIONS . . . . . . 105 PART IV: ENVIRONMENTAL ANALYSIS AND ENVIRONMENTAL MANAGEMENT PLAN FOR SOLID WASTE MANAGEMENT COMPONENT 107 7.0 NEW KWABENYA LANDFILL, ACCRA 107 7.1 BACKGROUND . . . . 107 7.1.1 Applicable World Bank Safeguard Policies . . . . . 107 7.2.1 Management System ........................... . . . .110 7.2.2 Justification for the Kwabenya Landfill . . . . .11................... I 7.2.3 Waste Types and Analysis . . . . . 112 7.2.4 Solid Waste Collection . ........................... . . 113 7.3 DESCRIPTION OF THE PROPOSED LANDFILL AT KWABENYA . . . . 117 7.3.1 Site Selection . . . . .117 7.3.2.1 Socio-Economic Issues ..119 7.3.3 Geological and Hydro Geological Aspects . . . . .123 7.3.4 Ground Water Resources . . . . .124 7.4 INFRASTRUCTURE . . . . 124 7.4.1 Buffer Zone ............ . . .. 124 7.4.2 Access Roads ............ . . . .124 7.4.3 Structures ............ . . . .124 7.4.4 Utilities ............. . . . 125 7.4.5 Entrance and fencing . . . . . 125 7.5 DESIGN AND CONSTRUCTION ..125 7.5.1 Phasing plan .....125 7.6 GENERAL DESIGN CRITERIA . . . .126 7.6.1 Leachate containment . . . . .126 7.6.2 Groundwater table . . . . .126 7.6.3 Bottom Liners .....127 7.6.3.1 Type 1 Liner . .127 7.6.3.2 Type 2 Liner .. 127 7.6.3.3 Type 3 Liner . .127 7.6.3.4 Discussion .. 127 7.6.4 Slopes and stability . . . . .128 7.6.5 Final Covers .....129 7.7 GROUND WATER MONITORING POINTS . . . . 129 7.8 SURFACE WATER MANAGEMENT . . . . 130 7.8.1 Stormwater Culvert . . . . .130 7.8.2 Catchwater drains . . . . .130 7.9 LEACHATE MANAGEMENT . . . . 130 7.10 LANDFILL GAS MANAGEMENT . . . . . 131 7.11 CONSTRUCTION AND QUALITY ASSURANCE . . . . . 132 7.12 OPERATION OF LANDFILL . . . . . 132 7.12.1 General Procedures . . . . .132 4  7.12.2 Waste Deposition .......................................... 133 7.12.3 Special Waste Cells ..........................................1 33 7.12.4 Self -haul .......................................... 134 7.12.5 Scavenging ......................................... 134 7.12.6 Equipment and staff ......................................... 135 7.13 CLOSURE . . .135 7.14 POST CLOSURE . . .136 7.14.1 Post Closure Use .136 7.14.2 Aftercare .136 7.15 ANALYSIS OF ALTERNATIVES AND THEIR POTENTIAL ENVIRONMENTAL IMPACTS . . .137 7.15.1 Start phasing with option B1 ......................................... 137 7.15.2 Altemative bottom liner ......................................... 137 7.15.3 Altemative site development ......................................... 137 7.15.4 Leachate treatment ......................................... 138 715.5 Altematives for failure of constructions caused by earthquake ......................................... 138 7.16 ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN . . ............................. 138 7.17 IMPLEMENTATION SCHEDULE AND COST ESTIMATES . . ................................ 149 8.0 TEMA NEW LANDFILL 150 8.1 BACKGROUND . . . 150 8.1.1 Applicable World Bank Safeguard Policies .151 8.2 SITE SELECTION .152 8.2.1 Description of the Proposed Landfill Site at Tema . . . 154 8.2.1.1 Location and Access ................... 154 8.2.1.2 Ownership.................... 154 8.2.1.3 Flora and Fauna ................... 154 8.2.1.4 Existing Land Use ................... 154 8.2.1.5 General Geology ................... 155 8.2.1.11 BufferZone ................... 156 8.2.1.12 Access Roads ................... 156 8.2.1.13 Drainage ................... 156 8.2.1.14 Ground Water Resources ................... 156 8.3 IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS . . .156 8.3.1 Environmental impacts-Construction Phase . . . 156 8.3.1.1 Noise and Vibration ................ 156 8.3.1.2 Dust ................ 156 8.3.1.3 Mud................ 157 8.3.1.4 Discharges to Water ................ 157 8.3.1.5 Road Traffic ................ 157 8.3.1.6 Public Safety ................ 157 8.3.1.7 Change of Land Use Issues ................ 157 8.3.2 Socio-Economic Impacts-Construction Phase . . .58 8.3.2.1 Relocation of non-resident gravel pit operators .158 8.3.2.2 Loss of Employment .158 8.3.3 Environmental Impacts- Operational Phase . . .158 8.3.3.1 Landfill Leachate ................ 158 8.3.3.2 Discharges to Water ................ 158 8.3.3.4 Landfill Gas ................ 158 8.3.3.5 Noise and Vibration ................ 158 8.3.3.6 Dust ............... ..159 8.3.3.7 Mud ............... ..159 8.3.3.8 Effects on Flora and Fauna ................ 159 8.3.3.9 Odour ................ 159 8.3.3.10 Litter ................ 159 8.3.3.11 Vermin ................ 159 8.3.3.12 Fire and Explosion ................ 159 8.3.3.13 Soc io-Economic Factors ................ 160 8.3.3.14 Visual Amenity ................ 160 8.3.3.15 Road Traffic ................ 160 5  8.3.3.16 Public Safety ......................................... 160 8.3.3.17 Seismicity ....................................... ..160 8.3.4 Environmental Impacts: Rehabilitation Phase . . . . . 160 8.3.4.1 Aesthetic Issues during restoration . . ..................................... 160 8.3.4.2 Landfill Leachate ......................................... 161 8.3.4.3 Landfill Gas ......................................... 161 8.3.4.4 Socio-Economic Issues ....................................... .. 161 8.4 MITIGATION MEASURES ................................... . . .161 8.4.1 Construction Phase .................................... . . 161 8.4.1.1 Noise and Vibration .................. 161 8.4.1.2 Dust .. ................ 161 8.4.1.3 Mud ................... 162 8.4.1.4 Water Quality ................ ..162 8.4.1.5 Socio-Economic Impacts .................. 162 8.4.1.6 Road Traffic ................. ..162 8.4.1.7 Public Safety .................. 163 8.42 Operational Phase . . . . .163 8.4.2.1 Leachate Management .................. 163 8.4.2.2 Landfill Gas Management ................ ..164 8.4.2.3 Noise and Vibration .................. 164 8.4.2.4 Dust ................ 164 8.4.2.5 Mud ................ 164 8.4.2.6 Effects on Flora and Fauna ................ ..164 5.3.2.4.2.7 Odourur... 165 8.4.2.8 Ltterer.165 8.4.2.9 Vermini n.165 8.4.10 Fire and Explosion ............ 165 8.4.3 Socio-economic and Public Health . . . . . 166 8.4.3.1 Employment .......... 166 8.4.3.2 Public Health .......... 166 8.4.3.3 Visual Amenity .......... 166 8.4.3.4 Road Traffic .. ........ 166 8.4.3.5 Public Safety .......... 167 8.4.3.7 Seismicity .......... 167 8.4.4 Closure and Post Closure Phase . . . . .167 8.5 ANALYSIS OF ALTERNATIVES OF MUNICIPAL WASTE MANAGEMENT . . . . . 167 8.5.1 Incineration . . . . . 167 8.5.2 Recycling/Reuse . . . . . 168 8.5.3 Composting .....168 8.5.4 Other forms of recycling and reuse . . . . . 168 8.6 MONITORING .....168 8.6.1 Construction Phase . . . . . 169 8.6.2 Operational and Maintenance Phase . . . . .169 8.6.2.1 Leachate Management .............. ..169 8.6.2.3 Surface Waters ................ 171 8.6.2.4 Landfill gas .. .............. 171 8.6.2.5 Flora and Fauna ................ 171 8.6.2.6 Decommissioning Phase ................. 171 8.7 TRAINING . ...... 171 PART V: IMPROVEMENT, CLOSURE, & REHABILITATION OF EXISTING WASTE DUMPS 183 9.0 REHABILITATION OF MALLAM-ACCRA 183 9.1.1 Applicable World Bank Safeguard policies .184 9.1.2 Description of Mallam Waste Dump .185 9.2 EVALUATION OF WASTE TYPES .185 9.3 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT .185 9.3.1 Cover ..185 9.3.2 Landfill gas 185 9.3.3 Leachate generation 185 6  9.3.4 O dour ........................................................ 185 9.3.5 Reduction in the value of the land and property around the dump sites . ........................... 186 9.3.6 Reduction in investment and Tourism ................................................... 186 9.4 DECOMMISSIONING PLAN INCLUDING ENVIRONMENTAL MITIGATION MEASURES . ............................................ 186 9.4.1 Mitigation measures ....................................................... 186 9.4.1.1 Mitigation of Social Impacts ............................................................. 189 9.4.2 Implementation of the Decommissioning Plan ....................................................... 189 9.5 BILL OF QUANTITIES AND PROJECT COST ....................................................... 189 9.6 CONCLUSIONS ........................................................ 189 10.0 OBLOGO WASTE DUMP 191 10.1 DESCRIPTION OF OBLOGO WSTE DUMP ........................................................ 191 10.1.1 Applicable Safeguard Policies . ....................................................... 191 10.2 EVALUATION OF WASTE TYPES ....................................................... 192 10.3.1 Leachate Problems . . . .194 10.3.2 Landfl gs. . . ... 195 10.3.3 Odourur.195 10.3.2 Dust and Mud . . . .196 10.3.3 Vermin...196 10.3.4 Adverse aesthetic conditions on the environment . . . .196 10.3.5 Scavenging . . . .196 10.3.6 Road Traffic . . . .196 10.3.6 Social Impa cts. . . .196 10.3.7 Health and Safety . . . .197 10.4 IMPROVEMENT AND DECOMMISSIONING PLAN INCLUDING MITIGATING MEASURES . .197 10.4.1 Provisions.198 10.4.1.1 Leachate Management .198 10.4.1.2 Storm water drainage.198 10.4.1.3 Landfill Gas Management .198 10.4.1.4 Monitoring Points.199 10.4.1.5 Access Road.199 10.4.1.6 Fencing and gate.199 10.4.1.7 Additional structures.199 10.4.1.8 Mitigation of Social Impacts.199 10.4.2 Landfill Operation ..................199 10.4.2.1 General Procedures .................................... 199 10.4.2.2 Waste d .....................................200 10.4.2.3 Scavenging .................................... 201 10.4.2.4 Equipment and staft.2 .................................... 1 10.4.3 Closure .................................203 10.4.3.1 Procedures 0.................................... 23 10.4.3.2 Final Cover .................................... 203 10.4.4 R ehabili tation and Affercare . ................................ . 204 10.4.4.1 ProposeduEs ..................................... End-.204 10.4.4.2 Aftercare .................................... 204 10.5 ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN FOR OBLOGO . .205 10.6 IMPLEMENTATION SCHEDULE AND COST ESTIMATES ..213 11 .0 KPONE LANDFILL 213 11.1.1 Applicable World Bank Safeguard Policies . . . .......................... 215 11.2 EVALUATION OF WASTE TYPES AND QUANTITIES .. ................................ 217 11.3.1 Smokeke.220 11.3.2 Landfill gas. . . . 220 11.3.3 Vermini n.220 11.3.4 Adverse aesthetic conditions on the environment . . . .220 11.3.5 Scavenging . . . .220 11.3.6 Health and Safety . . . .220 11.4 IMPROVEMENT AND DECOMMISSIONING PLAN INCLUDING MITIGATING MEASURES . .221 11.4.1 Mitigating measures and scope of work . . . .221 7  11.4.2 Provisions ....................... 222 11.4.2.1 Fire and Smoke .222 11.4.2.2 Storm water drainage .222 11.4.2.3 Landfill Gas Management .222 11.4.2.4 Monitoring Points .222 11.4.2.5 Access Road. 222 11.4.2.6 Additional structures .222 11.4.3 Landfill Operation ....................... 223 11.4.3.1 General Procedures ........................ 223 11.4.3.2 Waste deposition ........................ 224 11.4.3.3 Scavenging ........................ 225 11.4.3.4 Equipment and staff ........................ 225 11.4.4 Closure ....................... 226 11.4.4.1 Procedures ........................ 226 11.4.4.2 Final Cover ........................ 226 11.4.5 Rehabilitation and Aftercare .......................22 7 11.4.5.1 Proposed End-Use ........................ 227 11.4.5.2 Aftercare ........................ 227 11.5 ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN . . .228 11.6 IMPLEMENTATION SCHEDULE AND COST ESTIMATES . . .236 12.0 SEKONDI-TAKORADI 237 12.1 DESCRIPTION OF ESSIPON WASTE DUMP . . . .............................. 237 12.1.1 Applicable World Bank Safeguard Policies ..................................... 238 12.2 EVALUATION OF WASTE TYPES .................................... 239 12.3 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT . . ................................ 239 12.3.1 Leachate Problems ..239 12.3.2 Landfill gas ..240 12.3.3 Odour ..240 12.3.4 Bottom Lining ..240 12.3.5 Vermin ..240 12.3.6 Adverse aesthetic conditions on the environment ..240 12.3.7 Scavenging ..241 12.3.8 Health and Safety ..241 12.4 IMPROVEMENT AND DECOMMISSIONING PLAN INCLUDING MITIGATING MEASURES . .241 12.4.1 Mitigating measures and scope of work ..241 12.4.2 Provisions ..242 12.4.2.1 Leachate Management .242 12.4.2.2 Storm water drainage .242 12.4.2.3 Landfill Gas Management .242 12.4.2.4 Monitoring Points .243 12.4.2.5 Access Road .243 12.4.2.6 Fencing and gate .243 12.4.3 Landfill Operation ........................ 243 12.4.3.1 General Procedures ........................ 243 12.4.3.2 Waste deposition ........................ 244 12.4.3.3 Scavenging ........................ 245 12.4.3.4 Equipment and staff ........................ 245 12.4.4 Closure ........................ 246 12.4.4.1 Procedures ........................ 246 12.4.4.2 Final Cover ........................ 246 12.4.5 Rehabilitation and Aftercare ....................... 247 12.4.5.1 Proposed End-Use ........................ 247 12.4.5.2 Aftercare ........................ 248 12.5 ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN . . .248 12.6 IMPLEMENTATION SCHEDULE AND COST ESTIMATES. . . .. 256 13.0 OPERATION OF THE NEW SANITARY LANDFILLS KUMASI, TAKORADI AND TAMALE 257 13.1 IMPLEMENTATION OF OPERATING PROCEDURES . . .257 8  13.1.1 Introduction ...................... . . . 257 13.1.2 Receiving ...................... . . . 259 13.1.3 Landfilling ..................... . . . 260 13.1.4 Septage and Leachate Treatment ...................... 265 13.1.5 Leachate ..................... . . . 266 13.1.6 Sludge ..................... . . . 267 13.1.7 Landfill gas ..................... . . . 268 13.1.8 Transport ..................... . . . 269 13.1.9 Storage ..................... . . . 270 13.1.10 Site control ..................... . . 271 13.1.11 Infrastructure ..................... . . 272 13.1.12 Environmental Control ..................... . . 273 13.1.13 Maintenance .................... . . .274 13.1.14 Monitoring ..................... . . 275 13.1.15 Records and reports ....... 276 13.1.16 Equipment ..................... . . 277 13.1.17 Health & Safety ...................... . . 278 13.2 HEALTH AND SAFETY GUIDELINE FOR LANDFILL OPERATIONS . . .279 13.2.1 Roles and Responsibility .......................... . . . 279 13.2.2.1 Management Responsibility . . . . . .279 13.2.2.2 Employee Responsibility . . . . . . 279 13.2.3. Guidelines .......280 13.2.3.1 Record Keeping .... . . ............................. 280 13.2.3.2 Assessment of Risks ................................ . . . 280 13.2.3.4 Medical Surveillance .... . . ............................. 282 13.2.3.5. Worker Health and Safety Education and Training ...... ......................... 283 13.2.3.6. Incident and Injury Reporting ............................... 283 13.2.3.7 Emergency Response Plan ............................... 284 13.3 INTEGRATED WASTE MANAGEMENT PLAN FOR SEKONDI TAKORADI, KUMASI, TAMALE ......2 84 13.3.1 Problems of Waste Management in Sekondi- Takoradi, Kumasi and Tamale ..... 284 13.3.2 Socio Economic and Demographic Characteristics of the three cities ....... 285 13.3.2.1 Tamale ..... . . ......................................... 285 13.3.2.2 SEKONDI TAKORADI ...... 285 13.3.2.3 Kumasi ...... 286 13.3.3 Constitution of the Inter Sectoral Technical Team . . . . .286 13.3.4 Review of Waste Generation and Management . . . . .287 13.3.4.1 Status of infrastructure and services of Sekondi -Takoradi .. 287 13.3.4.2 Kumasi ...... 288 13.3.4.3 Tamale . .. . 288 13.3.5 Consultations with key stakeholders . . . . .289 13.3.6 Identification and evaluation of waste management options ..................................... 290 13.3.7 Projection and targets ................... ..................... 290 13.3.7.1 Objectives for the three cities . . . . . . 290 13.3.8 Prioritization of waste management options . . . . .291 13.3.10 Implementation of the plan . . . . .292 13.3.10.1 Immediate/short term . ............ . . . 292 13.3.10.2 Medium term ............. . . . . 292 13.3.10.3 Long term plans ............. . . . . 293 13.3.10.4 Monitoring and review of the plan . . . . . . .293 13.3.10.4.1 Supervision .. . 293 13.3.10.4.2 Monitong .. . 293 13.3.10.4.3 Monitoring indicators . 293 PART VI: COMMUNITY INFRASTRUCTURE UPGRADING 295 14.0 COMMUNITY INFRASTRUCTURE UPGRADING 295 14.1 PROJECT DESCRIPTION ....... . . ............................................ 295 14.2 APPLICABLE SAFEGUARD POLICIES ................................................ . . .295 14.3 IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS ...... 295 9  14.3.1 Environmental Impact Assessment .................................... 296 14.3.1 .1 Constructional Phase Impacts . 296 14.3.2 Social Impacts . . . .297 14.3.2.1 Disruption of Utility Services ......................................... 297 14.3.2.2 Displacement of families ........................................ 298 14.3.2.3 Reduction in the number of rented residential accommodation ........................................ 298 14.3.2.4 Dumping of solid waste and rubbish into the drains ........................................ 298 14.3.2 5 Accidents ........................................ 298 14.3.2.6 Inconvenience to be caused due to delays in payment ........................................ 298 14.3.2.1 Restricted Mobility ........................................ 298 14.4 ANALYSIS OF ALTERNATIVES ............................................ 299 14.4.1 The "Do-Nothing" or "Null" Altemative ............................................ 299 14.4.2 Ordinary Road Maintenance/Repair Works ........................................... 299 14.4.3 Rehabilitation/Reconstruction of the Road to Gravel Surfacing ........................................... 299 14.4.4 The Proposed Project . ........................................... . 299 14.4.5 The Preferred Altemative ........................................... 300 14.5 MITIGATION MEASURES . . .300 14.5.1 Construction Phase Impacts . . . . 300 14.5.1.1 Air Quality ............................................... 300 14.5.1.2 Noise and Vibration ............................................... 300 14.5.1.3 Constructional Waste Management ............................................... 301 14.5.1.4 Occupational Health and Safety ............................................... 301 14.5.1.5 Adherence to specification and Environmental Standards by Contractors ........................... .................. 301 14.5.1.6 Social Problems from Work Camps ............................................... 302 14.5.1.7 Housing and Sanitation for Non-Resident Workers ................................................ 302 14.5.1.8 Addressing Fear of Non-Compensation ................................................ 302 14.5.1.9 Resettlement ............................................... 302 14.5.2 Post Constructional Phase impacts .......................................... 303 14.6 INTEGRATION OF THE EMP . . .306 14.6.1 Environmental Management ................. 306 14.6.2 Objectives of Programme . . . .306 14.6.3 Resources for Programme Implementation . . . . 307 14.6.3.1 Pre-Construction Phase ............................... 307 14.6.3.2 Construction Phase ............................... 307 14.6.3.3 Operation and Maintenance Phase ............................... 307 14.6.3.4 Responsibilities of the ProjectResident Engineer ............................... 308 14.6.3.5 Responsibilities of the Contractor ............................... 308 14.7 MONITORING .. ...... 309 14.7.1 Construction Phase .309 14.7.2 Operation and Maintenance Phase .309 14.9 CONCLUSION AND RECOMMENDATION . . .31 1 14.9.1 Conclusion . . . .311 14.9.2 Recommendations . . . . 312 PART VIl: TRAINING PROGRAMME FOR STAFF OF METROPOLITAN/MUNICIPAL ASSEMBLIES 313 15.0 METROPOLITAN/MUNICIPAL ASSEMBLIESINGOS TRAINING PROGRAMME 313 15.1 BACKGROUND ..313 15.1.1 Rationale ............................. 313 15.1.2 Objectives ............................. 313 15.1.3 Methodology .............................. 314 15.1.4 Issues ............................. 314 15.1.5 Target Group ............................. 315 15.2 SAMPLE TRAINING PROGRAMME ............................. 315 15.2.1 Aims .............................. 315 15.2.2 Objectives .............................. 316 15.2.3 Scope ............................. 316 15.2.4 Procedure ............................. 317 15.3.2 COMMUNITIES AND LOCAL GOVERNMENT ............................... 322 10  15.3.2.1 Aim .................................. 322 15.3.2.2 Objectives ...................................... 322 15.3.2.3 Scope ....322.............................. 322 15.3.2.4 Procedure ...................................... 323 15.4 RECOMMENDATIONS .326 15.5 ESTIMATED BUDGET FOR TRAINING .330 15.6 HIV/AIDS CONTROL MEASURES .331 15.6.1 Training of Trainers (ToT) Workshop: ..... .............................. 332 15.6.2 Assessments of Institutions / Organizations: .................................. 332 16.0 LIST OF INDIVIDUALS/INSTITUTIONS CONTACTED 333 17.0 REFERENCES 334 18.0 APPENDIXES 335 Appendix 1-Terms of Reference (TOR) 335 Appendix 2: Consultations and Minutes of Meetings 349 Appendix 3: Conceptual Landfill Cost Calculations 377 Appendix 4: EPA Permit for Kwabenya Landfill 387  ABBREVIATIONS AND ACRONYMS AIDS Acquired Immuno Deficiency Syndrome AMA Accra Metropolitan Assembly BOD Biochemical Oxygen Demand CPPR Country Procurement Proficiency Review DA District Assembly DEMCs District Environmental Management Committees EA Environmental Assessment EEMC Environ Engineering and Management Consult EHD Environmental Health Department of the MA El Executive Instrument EIA Environmental Impact Assessment EIS Environmental Impact Statement EMP Environmental Management Plan EOP End of Project EPA Environmental Protection Agency GCL Geosynthetic Clay Liner GDA Ga District Assembly GPRS Ghana Poverty Reduction Strategy HIV/AIDS Human Immunodeficiency Virus/Acquired Immunodeficiency Syndrome KMA Kumasi Metropolitan Assembly IDA International Development Association ILGS Institute of Local Government Studies LGPSU Local Government Project Support Unit of MLGRD LI Legislative Instrument LSP Letter of Sector Policy MA Metropolitan or Municipal Assembly MDAs Ministry Department and Agencies MDG Millennium Development Goals MES Ministry of Environment and Science MLGRD Ministry of Local Government and Rural Development MOF Ministry of Finance MOU Memorandum of Understanding MSW Municipal Solid Waste MTR Mid-Term Review NDF Nordic Development Fund NEP National Environment Policy NEAP National Environmental Action Plan RAP Resettlement Action Plan RCC Regional Coordinating Council RPF Resettlement Policy Framework SAEMA Shama Ahanta East Metropolitan Assembly SOE Statement of Expenditures TAMA Tamale Metropolitan Assembly TEPZ Tema Export Processing Zone TDC Tema Development Corporation TMA Tema Municipal Assembly TOR Terms of Reference ToT Training of Trainers 12  WMD Waste Management Department of the MA UESP Urban Environmental Sanitation Project, Credit 2836-GH UESP 11 Second Urban Environmental Sanitation Project UNFCCC United Nations Framework Conventions on Climate Change WMD Waste Management Department 13  PART 1. EXECUTIVE SUMMARY 1. THE PROPOSED PROJECT 1. The Government of Ghana, through the Ministry of Local Government and Rural Development (MLGRD), intends to carry out a project to improve environmental sanitation in the five largest towns in Ghana, namely Accra, Kumasi, Takoradi, Tamale and Tema. The Government proposes to seek assistance for this purpose from the International Development Association (IDA) of the World Bank Group. 2. The proposed Second Urban Environmental Sanitation Project (UESP II) is a repeater of the ongoing Urban Environmental Sanitation Project (UESP, IDA Credit No. 2836), which is being implemented with assistance from the World Bank, NDF and AFD since September 1996. 3. Present environmental conditions in the project towns are characterized by a lack of sanitary and socially acceptable latrine service, accumulation of solid wastes, lack of all-year vehicular access to poor neighborhoods, flooding, and inadequate water supply. The proposed Project is intended to further improve sanitation, solid waste management, drainage, and vehicular access in a sustainable fashion, with special emphasis on the poor. The implementation of the additional works under UESP II would complement interventions successfully implemented under UESP. Preliminary designs already exist for most of the proposed subcomponents under UESP II. 4. The Ministry of Local Government and Rural Development (MLGRD), in complying with the EPA Act and the Environmental Assessment Regulations as well as the World Bank safeguard policies, have contracted Messrs Environ Engineering and Management Consult (EEMC) to conduct an Environmental and Social Assessment of UESP II. The study includes an Update and Completion of the Environmental Assessment of the Kwabenya Landfill in Accra, Preparation of an Environmental Management Plan for the Project and Development of Resettlement Policy Framework. Other subcomponents which this study covers are: new landfill in Tema; improved use, closure, and rehabilitation of existing landfills and dumps in Accra (Mallam, Djanman, Oblogo), Tema (Kpone) and Sekondi-Takoradi; lining of drains and erosion control; infrastructure upgrading in low-income communities; latrines; sewerage and sewage treatment; and malaria vector control. The study also includes institutional strengthening aspects of the MLGRD and other Central Agencies. This document therefore reports on the studies undertaken, the findings, conclusions and recommendations in accordance with the Terms of Reference in Annex 1. 2. DESCRIPTION OF PROJECT AREA OF INFLUENCE 5. The project area of influence comprises parts of the five project towns of Accra, Kumasi, Sekondi-Takoradi, Tamale and Tema. The growth of Accra and Tema has extended to neighboring Ga District, in which one of the two proposed sanitary landfills, Kwabenya, is also located. Within this overall expanse, the actual area of influence depends greatly on the nature of the project component, as explained in Section 2.2. The urban civil works will primarily be located in lower- lying areas, most of which are inhabited by low-income people and/or used by them for small-scale commercial activities. 14  6. The Project is composed of the same five components as UESP: * Storm Drainage; * Sanitation; * Solid Waste Management; * Community Infrastructure Upgrading; and * Institutional Strengthening. 3. DESCRIPTION OF POLICIES, LEGAL, AND INSTITUTIONAL FRAMEWORKS 7. Ghana's National Environment Policy (NEP) is contained in the broader framework of the National Environmental Action Plan (NEAP), Vol. 1, which was adopted in 1991. The principal objective of the NEP is to improve the surroundings, living conditions and quality of life of the entire citizenry of present and future generations. It seeks to ensure reconciliation between economic development and natural resource conservation, to make a high quality environment a key element in supporting the country's economic and social development and natural resource conservation and to make a high quality environment a key element in supporting the country's economic and social development. 8. The policy seeks to guide development in accordance with quality requirements to prevent, reduce and as far as possible eliminate pollution and nuisances. * Integrate environmental considerations in sectoral, structural and socio-economic planning at the national, regional, district and grassroots levels; * Seek common solutions to environmental problems in West Africa, Africa and the world at large. Ghana Landfill Guidelines 9. The Guidelines which are the result of close collaboration between the Ministries of Local Government and Rural Development, Environment and Science and Environmental Protection Agency cover landfill classification, site identification, design, upgrading of existing dump sites, operation and maintenance, closure, restoration and aftercare. Manual for the Preparation of District Waste Management Plans 10. The purpose of the Manual is to assist the District Assemblies and other relevant stakeholders in the planning and management of waste, through the preparation of integrated and systematic, Strategic Waste Management Plans. Environmental Sanitation Policy 11. In 1999 the Ministry of Local Government published an Environmental Sanitation Policy. This Policy was prepared long after the NEAP. Sanitation is construed to have a broader meaning than waste. The Policy objectives are developing a clean, safe and pleasant physical environment in all human settlements, to promote the social, economic and physical well-being of all sections of the population. It comprises various activities including the construction and maintenance of 15  sanitary infrastructure, the provision of services, public education, community and individual action, regulation and legislation. Environmental Assessment Regulations 12. L.l. 1562 follows in broad terms, the procedures for the preparation of an environmental assessment report. It provides a graduated system for determining what will be demanded from a proponent on the basis of the size and likely impacts of a particular project. On receipt of an application, including such information as may be required; the Agency will carry out an initial screening exercise taking into consideration factors such as: * Location, size, and likely output of the undertaking; * Technology intended to be used; * Concerns of the general public, if any, and in particular concerns of immediate residents if any; * Land use and other factors of relevance to the particular undertaking to which the application relates. Institutional Framework Ministry of Environment and Science 13. The Ministry of Environment and Science (MES) was established in 1994. Its creation was in response to a national development need to integrate environmental, scientific and technological considerations into the country's sectoral, structural and socio-economic planning processes at all levels. Local Government Act, 1993 (Act 462) 14. The Local Government Act (Act 462) seeks to give a fresh legal expression to government's commitment to the concept of decentralization. It is a practical demonstration of a bold attempt to bring the process of governance to the doorstep of the populace at the Regional and more importantly, the District level. The District Assemblies created under the law, constitute the highest political authority in each district, municipality and metropolis. 15. Among the functions of the District Assemblies are the following: * Formulate and execute plans, programmes and strategies for the effective mobilization of the resources necessary for the overall development of the district; * Initiate programmes for the development of basic infrastructure and provide municipal works and services in the district; and * Be responsible for the development, improvement and management of human settlements and the environment. 16  4. METHODS AND TECHNIQUES USED IN ASSESSING AND ANALYSING THE IMPACTS Background Information Gathering and Literature Review 16. Prior to the commencement of actual consultancy activities, EEMC obtained project documents on: Proposed landfills feasibility reports; * Technical designs of major projects and their sub-components; Landfills site selection and investigation reports and relevant preliminary permits (e.g. the Environmental Permit for the proposed Kwabenya Landfill) and licenses; Preliminary Environmental Impact Assessment reports on UESP; Impact study reports on UESP; * Operational Guidelines for New Sanitary Landfills in Kumasi, Takoradi and Tamale. Field Work 17. As part of the methodology and approach for the study the consultants have undertaken a series of consultative meetings with various groups of stakeholders and conducted field visits to major project sites. Summary of the Safeguard Work Done so far and Included in this Report, and Work to be Done Later Implement- Status of Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ Scoping Storm drainage All 5 Towns Construction Done Done To be done later N/A Liquid waste Tema Rehabilitation Done Done N/A N/A management Latrines All 5 Towns Construction or Done Done N/A N/A rehabilitation Sanitary landfill Kwabenya, Construction Done Done To be done later N/A Accra (updated) Sanitary landfill Tema Construction To be done Done To be done later Done later _ _ _ _ _ _ _ _ Closed dump Mallam, Accra Rehabilitation To be done Done To be done later Done later__ _ _ _ _ _ _ Active dump Oblogo, Accra Improve use, To be done Done To be done later Done closure, and later rehabilitation Active dump Kpone, Tema Improve use, To be done Done To be done later Done closure, and later rehabilitation Active dump Essipon, Improve use, To be done Done To be done later Done Sekondi closure, and later rehabilitation Community All 5 towns Construction Done Done To be done later N/A infrastructure upgrading Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). N/A: Not Applicable 17  18. There is bound to be a need to resettle families whose settlements will have to give way for the project. Through a well-structured process of consultation and consensus building, one or other of available resettlement options could be adopted. Land could be acquired at locations mutually agreed with those who would be resettled, and houses built for them that would contain the same number of rooms as those that would be abandoned. Another option could be to pay cash compensation adequate to enable people to be resettled find lands on their own and construct their own houses (with all the attendant risks of the money being misapplied). A third option could combine features of the two where land will be acquired and developed up to some point and some cash compensation paid for the people to complete them. All activities triggering OP 4.12 (as noted in the table above) will require a Resettlement Action Plan (RAP), the preparation of which will be guided by the provisions of the Resettlement Policy Framework (RPF), which as been prepared for this project in parallel with the present report. 5. STORM DRAINAGE 19. The provision of storm drainage was part of the Urban Environmental Sanitation Project being carried in five main cities of Ghana and will be part of UESP II. Secondary and some tertiary drains will be lined with concrete or stone pitching, which may involve deepening, widening, narrowing, and realigning, as the case may be. Applicable Safeguard Policies 20. The World Bank Safeguard Policies that are triggered are OP 4.01 and BP 4.01- Environmental Assessment, OP 4.01 Annexes A, B, and C on Environmental Assessment, OP 4.12 and BP 4.12-Involuntary Resettlement, and OP 4.12 and BP 4.12-Involuntary Resettlement Instruments. Identification of Potentially Adverse Environmental and Social Impacts Probable flooding downstream 21. There is a risk that the lining of more secondary drains may cause flooding downstream. Disruption of Utility Services 22. The excavation for the lining of storm drains will cause temporary disruption of utility services such as electricity and water. Such disruptions will be a nuisance to the affected communities in the area. Mitigation Measures Impacts on Peoples' Livelihood 23. The drainage improvement project will impact on peoples' livelihood due to the widening of the drains, and the provision of maintenance access reserve along the secondary and tertiary drains as barbers, kiosks operators and vegetable growers may lose some land. 18  Resources for Programme Implementation 24. The resources required for implementing the environmental management programme are basically personnel and finance. The key stakeholders in the environmental management activities are the Project Engineer, the Contractor, AMA and GDA, Ministry of Local Government, EPA and to some extent, the Public. Monitoring 25. The aim of the monitoring is to ascertain to what extent the predicted impact of the project is materialized, to detect any unforeseen impacts, and to allow for an adjustment of the mitigation measures at an early stage. Appropriate monitoring criteria are established, and the monitoring will keep relevant records to ensure compliance with sound environmental procedures. The monitoring plan will ensure that mitigating measures and impacts of the project during construction and operational phases are implemented. Safeguard Work Done so far and Included in this Report, and Work to be Done Later Implement- Status of Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ Scoping Storm drainage All 5 Towns Construction Done Done To be done later N/A Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). N/A: Not Applicable 6. SANITATION Household, Schools and Public Latrines 26. Most urban residents in Ghana, especially the poor, lack adequate sanitary facilities. About half of the population pays to use public latrines that are unclean, inadequate, inconvenient, and lack privacy. Bucket latrines have been banned and being phased out because of the health hazards to both users and conservancy workers. As a result of these factors at both the domestic and community levels, the situation has led some people, especially children, to defecate indiscriminately in bushes, open spaces and drains. Tema Sewage System Improvement Present Status of the Tema Sewage System 27. Investigations and field visits conducted revealed that in spite of the previous interventions the Tema Sewerage System is still not functioning. The three pumping stations and the sewerage treatment plant at community 3 are all not being run as result of a combination of several problems. The pumping stations have either some of the pumps not working or the relays in the control panels have been stolen. Another problem is the issue of non-payment of accrued electricity bills to the Electricity Company of Ghana for which reason power supply to the sewerage treatment plant has been disconnected. There are other issues such as the lack of a proper management system 19  and facilities management plans, insufficient funding from the Tema Municipal Authority and the paymentcollection of sewer fees by residents in the Tema Municipality. 28. Again most of the communities whose reticulation systems were not rehabilitated under the UESP have had their manholes overflowing as a result of either collapsed or blocked sewer lines. An ejector station at Tema Manhean has also broken down completely and may need to be replaced. Application of Safeguard Policies 29. The World Bank Safeguard Policies that are triggered are OP 4.01 and BP 4.01- Environmental Assessment, OP 4.01 Annexes A, B, and C on Environmental Assessment, OP 4.12 and BP 4.12-Involuntary Resettlement, and OP 4.12 and BP 4.12-Involuntary Resettlement Instruments. Identification of Potentially Adverse Environmental Impacts and Social Impacts 30. The potential negative impacts of the construction of household latrines, school latrines, public latrines and the rehabilitation of the sewage system improvements, mainly in Tema will have both negative and positive impacts on the environment. The negative impacts will occur during the construction/rehabilitation and operation of the latrines and the sewerage system improvements. Mitigation Measures of Environmental Impacts 31. The mitigating measures proposed below provide an efficient environmental management of the construction and sustainability of the latrines as well as the sewerage improvement plant. The mitigation measures have been proposed for the impacts identified under both the constructional and operational phase of the project. The aim is to identify the mitigation measures to be taken for noise, vibration, water quality, dust, air quality and public safety using visual assessment by the management and feedback from the other stakeholders. Monitorinq 32. This monitoring covers rehabilitation and construction of household, public and school latrines, as well as improvement of sewage systems. The issues to be monitored include noise, vibration, water quality, dust, air quality and public safety. The nature and extent of pollution observed will be determined by laboratory analyses of samples taken from the site. Appropriate measures should then be taken to rectify the problem. Safeguard Work Done and Included in this Report, and Work to be Done Later Implement- Status of Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ Scoping Liquid waste Tema Rehabilitation Done Done N/A N/A management Latrines All five Towns Construction or Done Done N/A N/A I _____________ rehabilitation Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). N/A: Not Applicable 20  7. KWABENYA LANDFILL, ACCRA 33. At present, all the collected refuse of Accra and parts of Ga District is dumped at Oblogo (see section 10, Oblogo Dump, below). The Accra Metropolitan Assembly (AMA) and other key stakeholders in the region identified the urgent need for a new landfills. Subsequent to site selection studies carried out by AMA and local consultants several years ago, the Advisory Committee of the Accra Metropolitan Assembly Waste Management Department advocated a site at Kwabenya for the proposed landfill. 34. An Environmental Impact Study (Government of Ghana and Accra Metropolitan Assembly: Kwabenya Landfill) on the proposed site was prepared in 1999 (here referred to as 1999 EIS) with funding from an external assistance agency. Some aspects of this report have been reviewed and updated in the present report. A slightly revised version if the report was issued in November 2002. 35. The 1999 EIS proposes a design designated as Option Al for initial development. Option Al comprises a void space for waste disposal of approximately 23 million m3. This is a substantial volume that would meet the landfill needs of Accra for about 30 years. A decision to expand to Option B1 (a further 10 million m3) could be taken at a later date. At the present time it is proposed that landfill is situated in Valley A only. Further investigation of Valley B is required before development in this area could be considered. 36. Phase 1 of the planned construction of the landfill was carried out in 2001 with funding from an external donor agency. This included a tarred access road and a 250 meter long culvert on the bottom of the valley for storm water evacuation. A partial compensation was paid to land owners and users. No further construction took place due to persistent opposition from nearby residents and the inability of the local authorities to settle the land claims and other compensation in a satisfactory manner. The donor's agreed lending program changed, and the assistance was withdrawn. Applicable World Bank Safeguard Policies 37. The construction of the new sanitary landfill in Kwabenya-Accra could have irreversible environmental impacts unless mitigating measures recommended are carried out during the construction and operation stages. Some of the potential adverse impacts that may occur relating to the physical environment are: * Groundwater pollution; * Surface water (especially the Gao lagoon) pollution; * Loss of top soil; * Loss of useful subsoil (Quarry stones); * Changes in drainage of soils; * Changes in runoff characteristics; * Change in smoke and particulate levels. 38. Arising from the potential adverse environmental impacts enumerated above, the significance of the impacts, the extent of encroachment both in the buffer zone and the actual site for the proposed landfill there would be the need to resettle families whose settlements will have to 21  give way for the project. These scenarios pertaining to the proposed Kwabenya Landfill means that the Environmental Assessment (OP 4.01, BP 4.01, GP 4.01) and Involuntary Resettlement policies (OP/BP 4.12) will be triggered. Socio-Economic Impacts 39. The loss of 194 hectares of land may look insignificant, put in the context of the larger Accra Metropolitan Area. Nevertheless any loss of land in an area whose population density is already over 5,000 persons per sq km, can only increase the density and hence the pressure on the land. Given the general Ghanaian cultural traditions, which are characterized by a strong attachment of lineage groups to their ancestral lands, the project may not only be traumatic, but could be a source of conflict within the lineage group that owns the land. This may happen unless a proper mechanism is worked out to ensure that: * The true owners who have a stake in the land are identified, * The amount of compensation due to them is assessed in accordance with the Resettlement Policy Framework, and * There is transparency about the amount of compensation payment and equity in its distribution among all legitimate stakeholders. Resettlement 40. There is bound to be a need to resettle families whose properties will have to give way for the project. Through a well-structured process of consultation and consensus building, one or other of available resettlement options could be adopted. Land could be acquired at locations mutually agreed with those who would be resettled, and houses built for them that would contain the same number of rooms as those that would be abandoned. Another option could be to pay cash compensation adequate to enable people to be resettled find lands on their own and construct their own houses (with all the attendant risks of the money being misapplied). A third option could combine features of the two where land will be acquired and developed up to some point and some cash compensation paid for the people to complete them. Design and Construction Phasing 41. The selected phasing plan comprises starting at the southern end of the valley with phase 1 and developing the next phases in a series of east-west cells across the full width of the valley. The advantages of this phasing are: * The collection point for leachate is in the lowest southern part, and will be constructed directly from the start of the development of the site. Meaning no leachate hindrance in constructing the next phases; * Access to the deposition site is easy from the higher northern grounds. 22  42. The consequence of this phasing is that provisions are necessary to collect clean storm water and runoff water from the flanks and to lead it around or underneath the site following the existing path of the water stream in the base of the valley. Stability and Setting of the Subsoil 43. Stability and settling of the subsoil has not been addressed in the 1999 EIS and the specifications. General Design Criteria Leachate Containment 44. The most important landfill design issue was considered to be leachate. Containment of leachate has been a key feature of the three designs that were developed in the 1999 EIS. 45. Three design philosophies are presented in the 1999 EIS (section 1.4 and 4.3.2). In view of the potential risk to ground water resources Design Philosophy 3 was selected as the proposed design. This design gives the best opportunity to contain leachate within the landfill site and incorporates a low permeability (10-9 m/sec) landfill liner comprised of either clay or on-site soils mixed with bentonite. A properly engineered low permeability liner would provide the most secure containment for leachate. The success of a clay lining scheme would be dependent on the availability of sufficient quantities of suitable materials within a reasonable distance of the proposed landfill site, the availability of funding to support lining throughout the life of the landfill, and adequate technical support and quality assurance. Groundwater Table 46. The groundwater measurements carried out for the 1999 EIS could not give detailed contours of the groundwater table. In lowered parts of the base of the valley standing water can reach the surface. The design proposed in the 1999 EIS includes perforated drains that will be installed under the liner to lower the groundwater table in the base of the valley below the liner. 47. With continuous lining the infiltration of water will decrease, and it is very unlikely that the standing water under the liner will reach the bottom of the liner. According to the Ghana Landfill Guidelines the bottom of the fill should be at least 2 m above the seasonally highest groundwater table. Taking into account that a groundwater table is found at approximately 2 m below ground level, and higher tables occur after rainfall events, in time the effect of rainfall will be reduced, and the average ground level is acceptable for the bottom of the waste. To lower the groundwater table of standing water in the first years of operation, drains will be installed at a depth of 2 m below ground level. Bottom Liners 48. Three types of liners are proposed in the 1999 EIS, depending of the location in the site. 23  Discussion 49. Using only a GCL for Type 1 Liner as recommended in the 2000 EIS would not perform better than a single clay liner. For that reason it would be recommended that a combination of GCL and clay. Liner is used in order to achieve a high impermeability through the swelling properties of the bentonite. In contact with high concentrations of salt or ions with a higher positive value than Sodium, the properties of the bentonite will decrease, with a consequent increase of the permeability. Generally, leachate contains high concentrations of chlorides amongst other anions and cations such as potassium, calcium and iron. In the leachate of the Mallam Landfill, which can be a reference for the quality, these concentrations are not extremely high, but high enough to get ion exchange in the bentonite. 50. The Ghana Landfill Guidelines specify the use of a geo-membrane to improve quality of bottom liner, if the availability of clay is limited. The principle of combination liners of geo- membrane and mineral liner is standard in the Guidelines of the EU countries and USEPA. For Kwabenya Landfill this suggests the use of a liner of 600 mm clay (standard Ghana Landfill Guidelines) and 2 mm HDPE geo-membrane. 51. Type 2 Liner in the Specification is an improvement of the 1999 EIS. It is more expensive than the standard 600 mm clay mentioned in the Ghana Landfill Guidelines. Under normal circumstances there is no specific reason to choose a design with a higher performance than specified in the Ghana Landfill Guidelines. 52. Type 3 Liner in the Specifications is 500 mm clay with k < 1 * 10-9 m/s. The reduced thickness as comprised in the 1999 EIS should be regarded to the Ghana Landfill Guidelines, meaning a thickness of 300-400 mm. For a reliable construction, 400 mm is recommended. 53. Another alternative for the GCL or the clay in type 1 and for the clay in type 2 and 3 is a mixture of polymer modified bentonite and sand with high impermeability and chemical resistance in a layer of 50 -70 mm. Slopes and Stability 54. The outside slopes from the restoration contours have a maximum of 1 horizontal to 3.5 vertical. This should give no stability problems for the outside slopes if some conditions are taken in account. 55. Saturated waste or sludge must not be deposited near the edge of the fill. This could create horizontal saturated layers of fine material that can be pressed away under heavy load. A safe distance from the edge is 50 m. Final Cover 56. The final cover can be placed once most of the expected settling of the waste has taken place, caused by loading and decomposition of the organic material. This can take several years after reaching the final height. This process will be monitored through periodic measurements. Until 24  that moment an intermediate cover of soil, rocks or other inert material, with a thickness of at least 0.2 m, should be applied to reduce litter, contact with the waste, and odour emission. Ground Water Monitoring Points 57. The 1999 EIS specifies that groundwater monitoring points shall be installed downstream and around the perimeter of the site in the order of 25 m deep (13.2.2). The Specification gives further details of the location and the method of construction. There is a potential risk of groundwater contamination to the south of the landfill if leachate leaks through the liner system (2.2.3 of this document and 5.4.2.2 and 10.5.1.2 of 1999 EIS). The monitoring points should therefore be more densely placed on this side, while on the other side the monitoring points could be less frequent than shown in the specifications. Surface Water Management 58. The Landfill is to be built by progressively filling in a northward direction. This has the effect of forming a dam in the valley. Runoff generated from intense rainfall must be prevented from entering the landfill because of the potential to generate additional leachate. It is therefore proposed to control runoff from the valley by passing it through a main culvert for the evacuation of storm water under the landfill. A 250 meter long section of such a culvert has already been constructed as part of the Phase 1 construction that was done in 2001 with financing from an external assistance agency. Leachate Management 59. The 1999 EIS calculation of the maximum leachate generation is based on realistic starting points. It results in 113.000 m3/year and a worst-case estimation in the wet season of 6 I/s. The prediction of time to maximum generation did not consider the effect of preferential pathways and a reduced infiltration in the wet season after final covering. This means that the maximum production of leachate will be reached at the end of the operational period. 60. For leachate treatment the 1999 EIS proposed recirculation over the landfill (4.3.2 and 10.5.2.2). This method could be feasible in the local climate. Some components in the leachate will be absorbed or decomposed in the waste depending on the chemical conditions and biochemical processes, but several components will accumulate in the leachate. The discharge of leachate into to surface water downstream should be avoided even if it is only slightly polluted. It is unacceptable if the leachate contains accumulated pollution. 61. Proposed criteria for downstream discharge are shown in Table 14 of the 1999 EIS (10.5.2.2). For a discharge to small surface water bodies, which is the situation here, the recommended magnitude of several of these components are in our opinion too high, and not according to standards. Landfill Gas Management 62. In the 1999 EIS the generation of landfill gas is described as significant (10.4.4) without an estimation or calculation of quantities. With this capacity and high percentage of organics (average of 50 %), passive venting as proposed in the 1999 EIS (4.3.2) will result in a high emission of 25  methane and carbon dioxide. Options mentioned are flaring or even conversion to other forms of energy. At least active withdrawal should be provided for. Construction And Quality Assurance 63. In order to achieve a reliable design and construction of the landfill at various stages, process certain quality requirements should be specified and monitored. After completion of the construction works the contractor should submit a copy of the quality log with all certificates, test results, etc., to the owner. As-built drawings and specifications should also be included in the documentation. Analysis of Alternatives And Their Potential Environmental Impacts Start Phasing with Option B1 64. Option BI makes it possible to divert the storm water from the higher northern part around the boundary. Starting with B1 makes the culvert under the bottom-lining unnecessary. The disadvantage of this option is that the works to be constructed in the southern direction during subsequent phases are lower than those of the existing phase. Bunds that hold leachate in each phase should be excavated after extension with the next phase, and leachate can be a hindrance to the construction works. This alternative is therefore rejected. Alternative Bottom Liner 65. Using a polymer modified bentonite sand mixture or a geomembrane instead of GCL, or a polymer-modified bentonite sand mixture instead of clay, gives a layer with a better impermeability performance. Using it instead of clay requires less natural materials. The feasibility is dependent on the results of further seismic studies, which were not available for reference in the preparation of the present report. Alternative Site Development 66. Substantial houses are at various stages of construction in the buffer zone, most of which are not authorised. In Section 7.4.1 a smaller buffer zone is proposed. Alternatives are: * Shifting the eastern boundary to the west and partly compensating for fhe decreased capacity with a higher landfill; * Incorporating valley B in the development, and starting the waste boundary at the west side of the stream in the valley. There would be less diversion of storm water required, and the culvert under the bottom liner would not be necessary. This culvert has been constructed recently and can remain and is used for the diversion of storm water. 67. These alternatives will need new permits from the EPA. In the meantime construction and operation could start according to the existing permit within the boundary of the alternative development. 26  Alternative Leachate Treatment 68. Recirculation is proposed in the 2000 EIS for leachate handling. The risks of operating this treatment are described in 7.9. In the beginning no problems for recirculation are expected. Alternatives during the operation phase are: * On-site treatment in an anaerobic or aerobic pond and discharge to surface water. The design and efficiency of these systems depend on the type and range of contaminants. * Discharge to a sewer. The closest sewer is in Accra at a distance of 10 km. For incidental situations leachate could be transported to the sewer by truck. Otherwise a pipe could be laid to transport the leachate to the sewer. Alternatives for failure of constructions caused by earthquake 69. The risks and alternative measures related to earthquakes of severe magnitude - and low probability of occurrence - are analysed in a conceptual scheme. Environmental Management and Monitoring Plan 70. The Environmental Management and Monitoring Plan contains the environmental impacts and risks, the mitigating provisions and management actions, the Environmental Monitoring Plan, enhancement or corrective actions and training and institutional measures. To protect the environment control provisions and management are integrated in the design, the operation and the Rehabilitation. In the 1999 EIS they can be found in the chapters 4.3 "Landfill Design", 10 "Adverse Environmental Impacts and Mitigation" and Chapter 12 "Environmental Management and Training". The monitoring has been described in chapter 13 "Monitoring" of the 1999 EIS. 71. The Environmental Management Plan presented in Section 7.16 in the text gives an updated view of relevant impacts and risks for the above-mentioned points. This plan should be seen as a dynamic report and will be updated and further elaborated based on the ongoing process of preparation, construction and operation. Safeguard Work Done and Included in this Report, and Work to be Done Later Implement- Status of Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ 1- ~~~~~~~~~Scoping Sanitary landfill Kwabenya, Construction Done Done To be done later N/A Accra (updated) Note: The preparation of the ReseKtlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). N/A: Not Applicable 8. TEMA NEW LANDFILL 72. The presently used disposal site is partly located in the newly-created Tema Export Processing Zone (TEPZ). Furthermore, the operation of the site has not been satisfactory. It should therefore be closed as early as possible, after a new disposal site has been constructed. Investigations indicate that if the wastes are sufficiently compacted to allow the further use of the existing site for some time, albeit with improved management, until that time that new sanitary 27  landfill has been completed. At that time the existing dump would be closed and rehabilitated (see Section 11, Kpone Dump, below). 73. The continuous use of the present dump could impact negatively on the physical environment, human health, quality of life, and economic activities. In addition, a sanitary landfill is also needed to accept industrial non-hazardous solid waste from the TEPZ and from the existing industries in the Tema Municipality. Applicable World Bank Safeguard Policies 74. The construction of the new sanitary landfill in Tema could have irreversible environmental impacts unless mitigating measures are taken during the design and operation. Some of the potential adverse impacts on the physical environment that may occur are: * Groundwater pollution; * Surface water pollution (especially the Gao lagoon); * Loss of top soil; * Loss of useful subsoil (quarry stones); * Change in the drainage of soils; * Change in the runoff characteristics; * Gas emission; and * Change in smoke and particulate levels. 75. Other receiving environments that may be affected are the ecological environment, land use, human health and economic issues. 76. The Environmental Assessment (OP 4.01, BP 4.01, GP 4.01) and Involuntary Resettlement policies (OP/BP 4.12) will be triggered due to the potential adverse environmental impacts enumerated above, the significance of these impacts, and the fact that the landfill would require about 44 acres of land. The development of the landfill at the proposed site would not result in involuntary settlement, but a compensation for loss of livelihood from minor activities such as quarrying would have to be made. An agreement in principle has been reached between the Tema Development Corporation (TDC) and the Tema Municipal Assembly (TMA) for TDC to release the site for the construction of the landfill. Site Selection 77. Three possible sites were considered by a team of officials from EPA, TMA and TDC. Preliminary surveys of these sites were conducted to determine the most suitable site to be used for the development of the landfill. The team visited Shai Hills, Afienya and Kpone and selected the Kpone site, which is located less than 1 km from the existing dump and about 500 m from the water tower of the EPZ. The site is part of an area of several square km that has been seriously degraded by the mining of laterite and stones, to the extent that it is can be used neither for building construction nor agriculture. 78. There is the need for further studies and analysis of alternatives to cover the following: 28  * Detailed site investigation covering the geological, geo-technical and hydro-geological aspects of the site; * Environmental Impact Assessment; and * Seismic (liquefaction) regime/impact. Safeguard Work Done and Included in this Report, and Work to be Done Later Implement- Status o Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ Scoping Sanitary landfill Tema Construction To be done Done To be done later Done _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ la te r _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). 9. REHABILITATION OF MALLAM, ACCRA 79. The solid waste management disposal site of the Accra Metropolitan Assembly at Mallam was used from 1995 to 2001. It was filled in a somewhat systematic fashion, with layers of about 6 meters high and terracing to reduce the chance of landslides. In 2001 the local residents, who had in the meantime encroached all around and right up to the site, protested vigorously against its further use. Yielding to this pressure, the site was closed and now requires rehabilitation in accordance with the EPA guidelines. 80. Following the closure of the Mallam Landfill Site, the disposal activities were transferred to Djanman for a few months and then to Oblogo (see below). Applicable World Bank Safeguard policies Environmental Assessment (OP 4.01 and BP 4.01) Yes Involuntary Resettlement (OP/BP 4.12) Yes Leachate generation 81. At Mallam there is an uncontrolled flow of leachate from the site, and particularly after it rains. There are houses built at the foot of the waste dump and at times the leachate floods the residents' compounds. The leachate is likely to contain pathogens and toxic materials. There is both groundwater and surface water contamination. Odour 82. Odours from decomposing waste are offensive and pose a health risk. At Mallam houses have been built at the foot of the mountain of waste, and odour nuisance is prevalent. Mitigation measures 83. It is noted that the closure, rehabilitation and subsequent aftercare of the dump are essential to protecting the environment. This will also allow for it to be used for other purposes, as well as fit into the immediate environs. 29  84. For the rehabilitation, the proposed scopes of work includes: * Defense wall, * Drainage, * Management of leachate, * Venting of gases, * Capping, and * Landscaping and other constructional works. Safeguard Work Done and Included in this Report, and Work to be Done Later Implement- Status of Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ I I I ~~~~~Scoping Closed dump Mallam, Accra Rehabilitation To be done Done To be done later Done later Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). 10. OBLOGO DUMP 85. The principal operational site for the disposal of solid waste from the Accra metropolitan area is currently at Oblogo, which is situated in the western part of Accra and was formerly a hard- rock quarry. The Oblogo site can be appropriately described as a controlled waste dump. The site has no engineered containment of leachate, but has a provisional bottom liner of clay. The wastes are partially compacted through the use of bulldozers. A compactor is on site, but is out of order most of the time. For hospital wastes a hole is usually dug in the waste fill, into which the hospital wastes are placed. The hole is then covered with refuse. This is a dangerous and unsatisfactory practice, especially since scavengers are allowed to operate on the site. 86. The dumping of waste at Oblogo began in January 2002. Since then Oblogo has been receiving an average daily waste load of about 1200 tons. The tip at Oblogo has an estimated capacity that could permit its use with the current operational practice only until July 2004. There is an urgent need for the development of a new site, which could accept solid waste in such a manner as to protect public health and minimize the damage to the environment. Applicable Safeguard Policies Environmental Assessment (OP 4.01 and BP 4.01) Yes Involuntary Resettlement (OP/BP 4.12) Yes 30  Environmental and Social Impact Assessment 87. The open waste dump at Oblogo has environmental and social impacts or implications since it is not a properly engineered and operated. The impacts identified and analyzed are: * Leachate problems; * Landfill gas; * Odour; * Dust; * Vermin; * Unaesthetic impacts; * Scavenging; * Road traffic; * Social impacts; * Health and safety hazards. 88. The mitigating measures and improvements are included in section 10.4 "Improvement and Decommissioning Plan". Leachate Problems 89. The site has leachate problems, which become more severe after a rainfall. The leachate appears to be confined to one outflow to the site, where it flows into a natural storm drain, through residential areas, and ultimately into the coastal wetlands of the Dansu River. This poses a risk for receptors (drinking water wells, streams). It is likely to also contaminate groundwater and to contain pathogens and toxins. 90. Storm water is not captured and diverted. It flows from higher grounds into the accumulated waste, increasing the leachate volume. Further detailed information on the hydrogeology of the site, the existing and maximal calculated leachate generation was not available, and should be studied to determine the impacts. Improvement, Closure, and Rehabilitation Plan, Including Mitigating Measures 91. The Oblogo Waste Dump is the only waste dump currently being used by AMA and parts of Ga District. After it is full, the dump has to be closed and rehabilitated. However because there is no immediate alternative site available, it will be necessary to improve the management practices at the site to prolong its life beyond the currently estimated time of July 2004. The improvement plan should include mitigating measures to reduce the environmental impacts. 92. The proposed scope of work and mitigating measures for improvement and eventual decommissioning consist of: * Identify and carry out improvements to the existing dump; * Improve the operation of the dump; * Closure; * Rehabilitation and aftercare. 31  Leachate Management 93. Leachate production at the Oblogo site will continue for many years after closure. The mitigating measures to be taken are: * Reducing leachate generation by preventing access to storm water, intermediate cover and final cover with low permeability; * Collecting leachate at the toe of the landfill and controlled drainage at the perimeter to one point (i.e. the eastern end of the landfill); * Treatment of the leachate by recirculation, discharge to a sewer, or treatment ponds near the site. 94. Further studies should be carried out for leachate generation treatment and the design of the collection. As a provisional measure a sump or retention lagoon could be created at the point where the leachate is seeping out now and recirculation back to the landfill could start. Storm water drainage 95. A perimeter drain should be constructed to capture and divert storm water from the site. The proposed drainage system would address the current situation of run-off water contamination by leachate. Landfill Gas Management 96. Investigations will be necessary to determine the waste generation (theoretical amount, pressure and composition) and the way of treatment. Landfill gas generation has not been calculated, but can be of a sufficient quantity to be hazardous to developments in the area. The gas management system needs to capture such gases so as to minimize the related environmental impacts and hazards and if possible also to derive some economic benefits from the recoverable gases. 97. The process will involve the installation of vertical gas gabions and perforated lateral HDPE pipes in the waste material directly under the final cover to collect the gases. These gases will have a controlled emission through vent pipes that would be located at various intervals. When it becomes necessary, the venting can be changed in an active extraction with flaring or even utilization. For the moment vertical gas gabions (1 per 2500 m2) should be installed. Also a vertical drainage screen against the face of the quarry could be necessary. This needs urgent study. Safeguard Work Done and Included in this Report, and Work to be Done Later Implement- Status o Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ Scoping Active dump Oblogo, Accra Improve use, To be done Done To be done later Done closure, and later rehabilitation I Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). 32  11. KPONE DUMP, TEMA 98. The Tema landfill was established in 1989 as an open dumpsite at a distance of approximately 10-km from the city center, on the road leading to Kpone. In 1998 the landfill measuring about 10 hectares was physically upgraded under the Urban II project, i.e. the site was fenced and interim roads dividing the site into appropriate cells for disposal were established. A receiving area with a gate house etc. was also established. However, due to lack of funds, operations at the landfill are still carried out in a similar manner to those at the other open dumpsites currently in operation in Ghana. Applicable World Bank Safeguard Policies Environmental Assessment (OP 4.01 and BP 4.01) Yes Involuntary Resettlement (OP/BP 4.12) Yes Waste Amounts 99. A weighbridge was installed but is not functioning, since it is missing some vital components. Based on the registration of number of trucks entering the landfill, approximately 1,300 loads/month, the total amount of waste received at the site can be estimated at 54,000 tons/year. Environmental And Social Impact Assessment 100. The open waste dump at Kpone has environmental and social impacts or implications since it is not a properly engineered and operated landfill. The impacts identified and analyzed are: * Landfill gas; * Smoke; * Odour; * Dust; * Vermin; * Unaesthetic impacts; * Scavenging; * Road Traffic; * Social impacts; * Health and safety hazards. 101. The mitigating measures and improvements are included in section 11.4 "Improvement and Decommissioning Plan". Improvement, Closure and Rehabilitation Plan, Including Mitigating Measures 102. The Kpone dump is the only waste dump currently being used by the TMA and parts of Ga District. The capacity of the dump has been estimated to last for about two and half years if it is operated in an efficient manner. Since there is no immediate alternative site for use if Kpone becomes full, it is necessary that the management practices at the site are improved prior to 33  closure and rehabilitation after the use of the new sanitary landfill can start. The mitigating measures to reduce the environmental impacts are part of this report. 103. The proposed scope of work and mitigating measures for improvement, followed by decommissioning are as follows: * Identify and carry out improvements to the existing dump; * Improve the operation of the dump; * Closure; * Rehabilitation and aftercare. Safeguard Work Done and Included in this Report, and Work to be Done Later Implement- Status of Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ Scoping Active dump Kpone, Tema Improve use, To be done Done To be done later Done closure, and later rehabilitation I I Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). 12. ESSIPON DUMP, SEKONDI-TAKORADI 104. UESP included the construction of a sanitary landfill for Sekondi-Takoradi. However the contractor failed to complete the construction by the time the project closed on December 31, 2003. It is proposed that the construction be completed under UESP II. It has therefore become necessary that the Essipon waste dump be improved under UESP II, so that it can continue to be used until the new site has been completed. Description of Essipon Dump 105. The Essipon dump in Sekondi is being used for the disposal of all waste in the Shama Ahanta East Metropolitan Assembly (SAEMA). The site has been in use for about ten years. On the average, about 85,000 metric tones of Municipal Solid Waste is dump per annum. The Essipon waste dump has no engineered facility. Waste disposal practices are crude. There is no provision for leachate management leading to soil and ground water pollution. The compactor which was supplied for the new sanitary landfill is on site, but is only occasionally used. It appears that it cannot be effectively deployed due to the unconsolidated nature of a deep layer of refuse, the low- lying location of the site, frequent rains, and a huge uncovered surface area of refuse. The dumped waste is not covered, leading to serious odour and air pollution problems. Applicable World Bank Safeguard Policies Environmental Assessment (OP 4.01 and BP 4.01) Yes Involuntary Resettlement (OP/BP 4.12) Yes 34  Environmental and Social Impact Assessment 106. The open waste dump at Essipon has environmental and social impacts or implications since it is not a properly engineered and operated landfill. The impacts identified and analyzed are: * Leachate problems; * Landfill gas; * Odour; * Vermin; * Unaesthetic impacts; * Scavenging; * Road traffic; * Social impacts. * Health and safety hazards. 107. The mitigating measures and improvements are included in section 10.4 "Improvement and Decommissioning Plan". Leachate Problems 108. The site has a serious leachate problem, which is worse after a heavy rain. It affects a large area and flows into the storm drains. The leachate is likely to contain pathogens and toxic substances. It contaminates ground and surface water. This is a potential risk for receptors (drinking water wells, streams). 109. Housing developments are springing up in the neighborhood and could be exposed to flooding with leachate since the area is poorly drained after a storm. Further information on the hydrogeology of the site, the existing and maximum calculated leachate generation was not available, and should be collected and analyzed to determine the impacts. Improvement, Closure and Rehabilitation Plan, Including Mitigating Measures 110. The Essipon Waste Dump is the only waste dump currently being used by SAEMA. The capacity of the dump is almost exhausted due to the lack of adequate waste compaction and improper management practices. Mitigating measures to improve the use of the site so that its life can be extended until the new sanitary landfill has been completed, as well as to reduce the detrimental environmental impacts, are presented in the report. 111. It is noted that the closure, rehabilitation and subsequent aftercare of any landfill site are part of the operation of a sanitary landfill. This is to ensure that the site is properly restored to enable it to be used for other purposes as well as fit into the immediate environs. 112. The proposed scope of work and mitigating measures for improvement/de-commissioning are as follows: * Identify and carry out improvements to the existing dump; * Improve the operation of the dump; * Closure; * Rehabilitation and aftercare. 35  Safeguard Work Done and Included in this Report, and Work to be Done Later Implement- Status of Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ .__________________ __ __ __ _ __ __ _ __ __ _ _ __ _S coping Active dump Essipon, Improve use, To be done Done To be done later Done Sekondi closure, and later I rehabilitation I_ I_I Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). 13. OPERATION OF NEW SANITARY LANDFILLS IN KUMASI, SEKONDI-TAKORADI AND TAMALE 113. An operating plan was prepared for the new sanitary landfills in Kumasi, Sekondi-Takoradi, and Tamale as part of the consulting assignment for the design and construction supervision of the landfills. The report includes a detailed monitoring plan and an environmental mitigation plan. The Waste Management Departments of the three Assemblies were introduced to these reports in 2002 through the capacity building component of UESP. This was followed in October 2003 by a series of seminars with the staff of the three MAs, given by the firm that produced the reports. 114. The implementation of these provisions will be continued in UESP II. There is a risk that the landfills will not be operated as prescribed in the report, mainly due to financial constraints and equipment breakdowns. This risk will be mitigated through a subsidy for operating the sanitary landfills, provided by the project, and through coaching and performance monitoring as part of the Institutional Strengthening component of the project. 14. COMMUNITY INFRASTRUCTURE UPGRADING 115. Under this component the infrastructure in some low-income communities in the project towns will be improved. Many of the roads in these neighbourhoods do not provide adequate vehicular access due to gullies caused by erosion. Existing roads will be leveled and a surface dressing applied, as well as lined with drains. In the process of upgrading the roads and constructing side drains, water pipes that run haphazardly through the neighbourhood will be replaced with supply lines along the drains, with service connections to all existing users. Street lights will be provided where it is a community priority. 116. The proposed project consists of the following: * Improving and surfacing of access roads to low-income communities, * Road drains, * Accompanied where necessary with street lighting, * Rationalization of water supply lines, footpaths, etc. Applicable Safeguard Policies Environmental Assessment (OP 4.01 and BP 4.01) Yes Involuntary Resettlement (OP/BP 4.12) Yes 36  Identification of Potentially Adverse Environmental and Social Impacts 117. The proposed infrastructure improvements will have both adverse and beneficial impact on the environment. An assessment of the negative impacts can be classified into construction phase and post construction phase impacts. During construction there may be a disruption of utility services due to their accidental disconnection or planned disconnection and reconnection, often involving subcontractors nominated by the utility company. Dust will invariably be created and should be controlled, and the passage of pedestrians and vehicles will be temporarily impaired. Some rooms, kiosks, steps, or other structures which were built into the roadway will have to be demolished, which will be done after an adequate process of consultation, compensation and/or reconstruction, in accordance with the provisions of the Resettlement Policy Framework. After the construction is completed, some residents may find their customary paths altered and causing inconvenience, such as the creation of retaining walls where footpaths or crude steps formerly existed. There could also be flooding of houses where thee was none before. More vehicular traffic will increase the chance of accidents. Analysis of Alternatives 118. Four (4) project alternatives were considered. These are: * "Do-nothing" or "Null" alternative (i.e. without project or no project at all); * Ordinary road maintenance (repair) works; * Rehabilitation/reconstruction of the road to gravel surfacing; and * The proposed project (rehabilitation/reconstruction of the existing road to bituminous treated surfacing). Mitigation Measures 119. Various mitigating measures are proposed in order to ensure an efficient environmental management of the construction and sustainability of the access roads. The mitigation measures are proposed for the impacts identified under both the construction and post construction phases. Integration of the EMP 120. Impact mitigation, road and environmental protection can be achieved through management and monitoring programmes. This section outlines a programme that accomplishes environmental protection and monitoring, as well as contributing to governmental strengthening of institutions. Monitoring 121. The aim will be to assess the mitigation measures for noise, vibration, water quality, dust, air quality and public safety using visual assessment by the management and feedback from the other stakeholder. 37  Safeguard Work Done and Included in this Report, and Work to be Done Later Implement- Status of Safeguard Work | Sub-component Location ation EA RPF RAP Analysis/ Scoping Community All 5 towns Upgrading of Done Done To be done later N/A infrastructure existing roads upgrading Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). N/A: Not Applicable 15. METROPOLITAN/MUNICIPAL ASSEMBLIES / NGOS TRAINING PROGRAMME 122. Local Government Act 462 of 1993 has made District, Municipal and Metropolitan Assemblies responsible for economic, physical and social development issues at the local level. Implicitly, national policies for development will be translated into action at the District level. One of the ways Government's policies could be translated into action at the district level is through community driven development type of activities. 123. One of such development activities in the communities is USEP II. Consequently, District Assemblies need to develop their capabilities to implement and monitor environmental and social plans within the context of the USEP II. This training programme is to address this need. 124. A detailed training programme for the identified target groups has been presented. Recommendations on the use of the programme have also been presented. An indicative budget has also been suggested for consideration. 38  PART 11 BACKGROUND 1.0 THE PROPOSED PROJECT 1.1 BACKGROUND It is the objective of the Government of Ghana under the Ghana Poverty Reduction Strategy (GPRS) to improve environmental sanitation, particularly in the areas of municipal solid waste management, management of human excreta and wastewater and drainage of stormwater. It is estimated that about 90 percent of the population of Ghana uses unsafe methods of solid waste disposal (dumping). In most of the Metropolitan/Municipal Assemblies only about 60% of the Municipal solid wastes are collected. Many people are affected by floods every year. The impactconsequences of inadequate environmental sanitation is the pollution of natural freshwater supply systems, morbidity and mortality. The main objectives of the Government of Ghana under the Urban Environmental Sanitation Project is to create and maintain conditions whereby people lead healthy and productive lives and ensure that the natural environment is protected and enhanced. Consequently, interventions are being put in place to reduce peoples' exposure to disease by providing a clean environment. This includes disposal of or hygienic management of excreta, solid waste, wastewater and stormwater, the control of disease vectors, and the provision of washing facilities for personal and domestic hygiene. The Government of Ghana, through the Ministry of Local Government and Rural Development (MLGRD), intends to carry out a project to improve environmental sanitation in the five largest towns in Ghana, namely: Accra, Kumasi, Takoradi, Tamale and Tema. The Government intends to seek assistance for this purpose from the International Development Association (IDA) of the World Bank Group. The proposed project is a repeater of the ongoing Urban Environmental Sanitation Project (UESP, IDA Cr. 2836), which is being implemented with assistance from the World Bank, NDF and AFD since September 1996. The proposed Second Urban Environmental Sanitation Project (UESP II) is intended to further improve sanitation, solid waste management, drainage, and vehicular access in a sustainable fashion, with special emphasis on the poor. The implementation of the additional works under UESP II would complement interventions successfully implemented under UESP. Preliminary designs already exist for most of the proposed subcomponents under UESP II. The urban civil works will primarily be located in deprived areas, most of which are inhabited by low-income people and/or used by them for small-scale commercial activities. Present environmental conditions in the project towns are characterized by a lack of sanitary and socially acceptable latrine service, accumulation of solid wastes, perennial lack of vehicular access to poor neighborhoods, flooding, and inadequate water supply. 39  An impact study that was recently carried out on UESP showed that several of the project components have had a positive impact on the poverty reduction efforts of the Government. The objective of the repeater project (UESP II) is therefore to deepen the successes achieved under the original project and further enhance the improvement in the urban environment within the selected project cities. This second Urban Environmental Sanitation Project is made up of the same five components. For a detailed description see Section 2.1): * Storm Drainage; * Sanitation; * Solid Waste Management; * Access Roads Upgrading in Low-income communities; * Institutional Strengthening: This would include Malaria Vector Control and HIV/AIDS Prevention programs (i) to eliminate the various types of breeding grounds for mosquitoes and (ii) a campaign to raise awareness about the need for a comprehensive approach to combating malaria. An effective EIA system was established in Ghana when the Environmental Protection Agency Act, 1994 (act 490) was passed in December 1994. In the Act, section 2 (i) states one of the functions of the Agency to be: To ensure compliance with any laid down environmental impact assessment procedures in the planning and execution of development projects, including, compliance in respect of existing projects. In 1999 the Environmental Assessment Regulations, Li 1652 was promulgated to give a complete legal status to the Ghana Environmental Impact Assessment (EIA) Procedures. The regulations require all significant impact scale developments to be subjected to Environmental and Social Assessment. The overall objective of the legislative instrument is to ensure that development activities are carried out or implemented in a sound and sustainable manner, with the view to promoting sustainable investments and development in Ghana. According to the World Bank's safeguard policies, the UESP II and its sub-component projects falls under the project categories that require an environmental and social impact assessment for project financing. The Ministry of Local Government and Rural Development (MLGRD), in complying with the EPA Act and the Environmental Assessment Regulations 1999 (Li 1652) as well as the World Bank safeguard policies have contracted Messrs Environ Engineering and Management Consult (EEMC) to conduct an Environmental and Social Assessment of the Second Urban Environmental Sanitation Project (UESP II). The study includes an Update and Completion of the Environmental Assessment of the Kwabenya Landfill in Accra, Preparation of an Environmental Management Plan for the Project and Development of Resettlement Policy Framework. Other subcomponents which this study covers are: New Landfill in Tema, Decommissioning of existing landfills and Dumps in Accra (Mallam, Djanman, Oblogo), Tema (Kpone) and Sekondi-Takoradi, Lining of drains and erosion control, Upgrading of urban access roads, Latrines, sewerage and sewage treatment and 40  Malaria vector control. The study also includes institutional strengthening aspects of the MLGRD and other Central Agencies. This document (Volume 1) therefore reports on the studies undertaken, the findings, conclusions and recommendations in accordance with the Terms of Reference in annex 1. As part of the preparation of the UESP II, a Resettlement Policy Framework (RPF) has been prepared (Volume 2). The RPF identifies and addresses the needs of the people who maybe affected by the project. The RFP has been prepared to the standards of the Government's own policy on Resettlement and the policy of the World Bank in its OP 4.12 on Involuntary Resettlement. 1.2 PURPOSE AND OBJECTIVES OF THE STUDY The objectives of the study are to carry out an Environmental and Social Assessment of the entire project, including the following: * Identify and assess any potential environmental and social impacts that are likely to emanate from the proposed investments; * Analyze alternative interventions and processes that may pose less environmental and social damage than the one(s) proposed under the project; . Recommend practical and cost-effective actions and processes to mitigate potential adverse environmental and social impacts that could emanate during project implementation; * Identify capacity building needs and recommend actions to strengthen MLGRD and the capacity of the 5 M/MA for ensuring sustained environmental and social compliance monitoring; and * Prepare guidelines for the mitigation of the potential negative social and environmental impact of the proposed project during implementation as well as operation. 1.3 SCOPE OF WORK * Assessment of the country's national environmental frameworks for environmental and social assessment, management, and reporting. * Review of proposed subprojects and assessment of their potential negative environmental and social impacts and formulate practical, time-bound and cost-effective recommendations to mitigate the adverse environmental and social impacts that could arise during implementation and operation; * Recommend what should be done for more detailed environmental and social analyses for specific subcomponents, as necessary; * Assessment of the potential occurrence of adverse social effects, such as loss of assets and access, reduced incomes, migration, social conflict, family separations, etc., of the 41  subcomponents during implementation or operation and formulation of recommendations on how to possibly avoid implementing activities that could generate social repercussions and to intervene with actions that minimize/mitigate social impacts; * Identification of alternatives that were examined in the course of developing the proposed project and identification of other alternatives, which would achieve the same objectives. * Formulation of a training program for the staff of Metropolitan/Municipal Assemblies on environment and social aspects linked to community driven development type activities. For partner NGOs, propose approaches to be undertaken for successful community mobilization programs on environment and social issues; * Formulation of a sample training program for communities, and local governments on how to implement and monitor environmental and social plans; * Propose concrete coordination modalities that will capitalize on environmental and social action plans; * Assist MLGRD with stakeholder consultation and disclosure, including presentations at workshops and incorporation of stakeholder comments into the Report; * Preparation a section for the project's Operating Manual on specific environmental assessments and corresponding mitigation measures to be financed by the project (preferably in a checklist format); * Assess which of the World Bank's safeguards policies will be triggered by the different subcomponents; for these the consultant should prepare specific management plans for mitigating each of the triggered safeguards. 42  2.0 DESCRIPTION OF THE PROJECT AREA OF INFLUENCE 2.1 PROJECT DESCRIPTION The five project towns of Accra, Kumasi, Sekondi-Takoradi, Tamale and Tema have a combined 2004 population of 4.3 million, constituting 23 % of Ghana's total population. The population of the project towns is expected to increase to 5.4 million by 2010 (Table 4.1). Nearly half the population of the project towns lives in Accra. The built-up urban area of Greater Accra extends into Ga District and houses about 200,000 people, who are not included in the table below. Neither is the itinerant population of about 600,000 who live in rural areas and stay in Greater Accra during the day or the workweek, mainly for petty trading or casual employment. Table 4.1 Population in the Project Towns Town Population, Percent, Growth Population, Population, 2000 2000 2000-2010 2004 2010 Accra 1,658,940 45% 3.5% 1,903,672 2,340,099 Kumasi 1,170,270 31% 3.5% 1,342,912 1,650,781 Sekondi-Takoradi 315,593 8% 2.5% 348,356 403,986 Tamale 202,320 5% 3.0% 227,713 271,901 Tema 380,770 10% 3.5% 436,942 537,114 5 cities combined 3,727,893 100% 3.4% 4,259,594 5,203,881 'Notes: - Based on the 2000 population census - Sekondi-Takoradi includes Shama, together forming SAEMA - Tema includes Newtown, Ashaiman and Lashibi 2.1.1 Component 1: Storm Drainage The lining of major and secondary storm drains constructed under UESP has significantly reduced the frequency, severity, and duration of flooding in these areas, according to residents and government officials. It is expected that additional drain lining will result in further reductions in flooding. The project will include (i) the realignment, dredging, and lining of a total of about 21 km of secondary drains, (ii) a small amount of tertiary drains, and (iii) erosion control measures. No involuntary resettlement is anticipated, but some moving or destruction of compound walls, rooms, toilets, bathhouses, or other structures that have encroached on the drains is anticipated. The drainage construction work will complement an ongoing Stormwater Drainage project in Tamale' and the Korle Lagoon Ecological Restoration project in Accra. The Greater Accra Metropolitan Area is drained by 10 major drainage basins in which severe flooding occurs annually. They fall under the administrative jurisdiction of three local governments: Accra Metropolitan, Tema Municipal and Ga District. 43  In 1996 a comprehensive plan for the reconstruction of storm drains in Greater Accra was prepared under UESP, which focused mainly on the four most populated basins: Chemu West, Odaw, Osu Klottey and Kpeshie. The high priority drains were identified and have been completed or are under construction, including the Odaw channel, which is a primary drain. The remaining secondary drains and bridges were prioritized according to the projected economic benefits and other considerations. The drains to be lined under the project will be selected from this list. The drains to be lined in Kumasi, Sekondi-Takoradi, Tamale and Tema will be determined later in the course of project preparation and implementation. 2.1.2 Component 2: Sanitation Under UESP all MAs except for Accra prepared Strategic Sanitation Plans (SSPs) that set out their strategy for providing comprehensive sanitation services by the year 2005. The SSPs include a priority listing of the mix of household, public and school facilities needed to serve the city's low- income household and a description of the management and financing arrangements needed to implement each component. The key objectives include: a. The elimination of pan latrines and a move from public facilities to household sanitation facilities, b. Improved public facilities in the communities and commercial centers, c. Improved school facilities and d. Provision of new septage treatment facilities. The SSPs contain recommendations about technology options, depending on housing densities and household income. Subsidies are targeted to low-income households, while in low-density, high-income housing areas the households finance the entire cost of flush toilets with septic tanks. Another option is to provide community systems consisting of simplified sewers and small treatment ponds, where the communities manage and finance the O&M. The project will assist AMA to prepare SSP through the Institutional Strengthening component. The following number of facilities will be constructed: Number of facilities planned Town Public Schools Household latrines Latrines latrines (Number of drop holes) (10-seaters) (12-seaters) Accra 1,700 12 20 Kumasi 2,500 20 30 Sekondi- Takoradi 2,200 10 16 Tamale 2,000 12 20 Tema 1,800 12 12 TOTAL 10,200 66 98 44  2.1.2.1 Household latrines The aim under UESP Il is to construct 10,200 household latrines, which would serve about 100,000 people. Compared with a 2010 population of 5.6 million in the project area (the 5 largest towns) this would make an impact of only 2%. Additional latrines will be built without the project, but they are not likely to exceed the population growth. It would be a totally different picture if the bylaws on latrine provision were enforced, as they have been in Burkina Faso with considerable success. The project will therefore assist the MAs in revising and enforcing the applicable bylaws, supplemented by an awareness campaign and hygiene education. Following the good response to the household latrine program under UESP, where the target was exceeded by 42%, the program will concentrate mainly on the low-income communities where infrastructure upgrading will be carried out. This allows a more comprehensive approach to the control of faecal contamination in low-income neighborhoods through combining improvements in solid waste collection, drainage, paved access roads, and water supply, where needed, with an intensive household latrine construction program and hygiene education. It will be supported by the enforcement of bylaws in the provision of latrines and the participation of local traditional councils and churches. Some MAs will contract one or more local firms termed "management intermediaries" to manage the household latrine program, who in turn will prequalify and train small local contractors in marketing and construction of the latrines, as was done under UESP. Their responsibilities will include vetting household grant applications received through the contractors, reviewing the design at the site, awarding individual contracts, making payments to contractors (25% down and 25% upon acceptance of the works), and monitoring the implementation. Other MAs will choose the cheaper option of managing the program through WMD and EHD, with prequalified artisans doing the construction. Marketing support will be provided mainly through direct targeting of the intended beneficiaries, possibly with the assistance of a marketing firm. Moreover, the consultants managing the community infrastructure upgrading will be required to provide marketing and logistical support to the "management intermediaries." The choice of technologies will be widened to include the Pour Flush and Mozambique types. 2.1.2.2 Public latrines The project will include the rehabilitation or construction of sixty-six (66) 10-seater units of public latrines. New construction will take place only in public areas such as markets, lorry parks and light industrial areas where operation on a full cost recovery basis is possible. Operation and maintenance will be contracted to private contractors through competition, as was the case with UESP. Some public latrines in low-income residential areas will also be rehabilitated or converted to more suitable types. Normally latrine block will consist of 20 seats, half for men and half for women, but an occasional 10-seater may also be constructed. 2.1.2.3 School latrines School latrines consisting of ninety-eight (98) 12-seater blocks will be renovated or constructed in primary and junior secondary schools, hygiene education given in the classroom, and water supply connections made to those schools that don't have them. Schools will be able to obtain a new or improved sanitation facility if (i) a Facilities Management Plan is prepared, and (ii) sufficient funds are collected to pay for O&M for at least one year. A local "management intermediary" will then 45  manage the implementation, including promotion, assistance to individual PTAs to prepare a Facilities Management Plan, selection of a contractor, construction supervision, training of selected teachers in hygiene education, and monitoring. The enrolment in schools averages about 400, divided into morning and afternoon sessions. In some instances two or three schools are clustered at the same site. Each will typically be served by a 12-seater block, consisting of a unit of 5 seats for girls and 1 for women teachers, and an identical unit for boys and men teachers. The technology will be a KVIP2 latrine with alternating pits or a WC or Pour Flush with a septic tank and a drain field. Schools would be grouped in batches of five to ten to facilitate implementation. The existing hygiene education materials, including those that were developed under UESP, will be reviewed and disseminated to participating schools. Operation and maintenance arrangements will be determined by school officials, in consultation with the PTA, and would be described in individual Facilities and Management Plans. PTAs will be encouraged to contract a qualified private company to maintain their facility, with support from school custodial workers. Private sludge haulers will periodically be hired to empty the latrine pits or septic tanks. 2.1.2.4 Liquid waste management in Tema Two septage treatment facilities were constructed under UESP, one in Kumasi and in Tema. The one in Tema was not completed and will be finished under UESP II, with an access road for Tema. Several projects for improving sewage treatment in Tema were carried out over the last decade, including some under UESP. However as of the end of 2003, none of the sewered wastewater was being treated - except for some factories that provide pre-treatment - mainly due to (i) objections from residents who live next to the treatment ponds to noxious odors, and (ii) the inability of the Tema municipality to pay the high electricity cost for sewage treatment with aerators and for pumping. The management of pumping station No. 3 by a private operator through a franchise will be supported through UESP II, serving the industrial and commercial zone in the east. Studies will be carried out in the project about alternative treatment or pumping for the remainder of the sewage network, and minor works rehabilitated and constructed. Some sewers will be rehabilitated and community-driven restoration of lagoons undertaken. 2.1.3 Component 3: Solid Waste Management The aim of this component is to increase the service level for solid waste and septage collection and achieving an environmentally sustainable final disposal. A similar component was part of UESP with the same objective. The planned outputs were by and large achieved, consisting of the construction of three sanitary landfills (one remaining incomplete), provision of equipment for their operation, introduction of private waste collection contracts, construction of septage treatment facilities in Accra, Kumasi and Tema (of which only one completed), and remedial works on the Tema sewerage system. When assessing the impact of these measures in regard to the objective of increased waste collection, one has to recognize that the base line figure was an approximation at best, coming from interviews with solid waste managers. The same sources estimate that the solid waste collection in the 5 towns has increased by 10 - 20 % during the life of the project. What can be determined with certainty however is that (a) the creation of engineered disposal sites for solid wastes and sludge is big improvement for the environment over dumping at uncontrolled 2 Kumasi Improved Pit Latrine 46  sites, and (b) the increased participation of the private sector in solid waste collection has greatly increased the chances of attaining a sustainable collection system in the long-run. UESP II will comprise similar activities to UESP, providing a geographic expansion as well as an intensification of the approach where pointed out from the experience of UESP. They will consist of (i) the construction of sanitary landfills in Accra and Tema, and supply of equipment for their operation, and the completion of the sanitary landfill in Sekondi-Takoradi, (ii) effective operation and monitoring of the three landfills in Kumasi, Tamale, and Sekondi-Takoradi that have been constructed under UESP, (iii) improved use, closure, and/or rehabilitation of dumps, and (iv) additional private solid waste collection. 2.1.3.1 Sanitary Landfills Two sanitary landfills will be constructed, one at Kwabenya (Ga District) for Accra and one for Tema. They will include weighbridges, a site office, water supply and a surrounding buffer zone. Access roads already exist, on which traffic flow and safety improvements will be made. The advisability of adding sludge disposal facility and an incinerator for hospital and other hazardous wastes suitable for incineration will be considered in the designs of both landfills. The WMDs will receive technical assistance on the operation and monitoring of the sanitary landfills, once completed, through the institutional strengthening component of the project. Accra sanitary landfill at Kwabenya. The construction of a new landfill near the village of Kwabenya in Ga District, 18 km north of the city center of Accra, will be completed. This landfill will serve Accra as well as the urban areas of Ga District adjacent to the city of Accra. Refuse is currently dumped in an old quarry at Oblogo in the McCarthy Hills and at various unplanned locations on the perimeter of the city. The construction was started in 2000 with financial assistance by DFID. Following the preparation of detailed designs and an environmental impact assessment and resettlement plan, Phase I of the Kwabenya landfill was constructed, consisting of an access road and a covered conduit for storm water drainage. In spite of prior consultations with various stakeholders, claims of land rights resurfaced during construction, and some nearby residents put up stiff resistance, delaying the start of Phase II of the construction, and DFID ultimately withdrew its support. The local government authorities have recently reached a tentative agreement with the Chiefs for the acquisition of land. The three design options that were identified by the original designers will be reviewed in light of the risk of seismic activity at this site. Tema sanitary landfill. In 1997 the existing landfill in Tema was reengineered with World Bank assistance under the Urban II project for a life of 5 years. All the cells are now full, and a buildup of 1-2 meters aboveground has been created, turning the site into an uncontrolled dump. While a new sanitary landfill for Tema and nearby townships is being designed and built, the existing dump can possibly be used for another 2-3 years if efficiently engineered and managed. Another imperative for the early closure of the present dump is that it projects partly into the Tema Export Processing Zone, which was created under the Trade and Investment Gateway Project, Credit 3114-GH. There is a risk that smoke from the perpetual burning at the landfill could create a nuisance for the industries that will eventually be located in this part of the processing zone. A site for a sanitary landfill has been identified about 1/2 km from the existing dump, which seems. well suited for a sanitary landfill. It lies in a former laterite and stone mining area with no settlement and no major economic activity on the site and is easily accessible by road. The geology is also 47  favorable. The preparation of designs and an environmental and social assessment are underway, financed through the Gateway project. Construction will begin only once a satisfactory Environmental Assessment (EA, providing more detailed information and mitigation plans than those provided in the present Environmental and Social Assessment) and Resettlement Action Plan (RAP, based on the RPF) have been prepared, and evidence of land rights obtained. Details of the EA and RAP work for the subprojects that is contained in this report is shown in the table in the Executive Summary entitled Summary of the Safeguard Work Done and Included in this Report, and Work to be Done Later. Sekondi-Takoradi sanitary landfill. Since the contractor failed to complete the construction on time under UESP, the landfill will be completed under UESP II. 2.1.3.2 Equipment for Sanitary Landfills Equipment for the eventual operation of the two sanitary landfills in Accra and Tema, which will be constructed under the project, will be procured through financing from NDF. It will consist of a front loader, a compactor, a tipper truck, a water tanker, motorcycles, and communications equipment. 2.1.3.3 Improved Use, Closure, and Rehabilitation of Waste Dumps While sanitary landfills are being constructed in Accra, Tema and Sekondi-Takoradi, optimal use will be made of the existing dumps to ailow their continued use in the interim, and to take remedial measures for safeguarding the environment. Once the new landfills are ready for use, the existing as well as those in the project towns that have already been closed will be rehabilitated as to minimize their negative environmental and social impact. They include 2 dumps in Accra (Mallam and Oblogo), 5 in Kumasi, 1 in Sekondi, several small ones in Tamale, and 1 in Tema (see Annex 10). Technical, environmental and social studies will be carried out to determine the specific requirements for each landfill. Closure and rehabilitation is likely to include relocation of scavengers, leachate captivation and treatment, methane ventilation, contour stabilization, soil cover, and fencing. 2.1.3.4 Operation of Sanitary Landfills The landfills that were recently completed in Kumasi and Tamale under UESP and the one at Sekondi-Takoradi, which will be completed under UESP II, were designed for efficient use and to environmentally sound standards. Their operation requires good management, including the utilization of the equipment that has been supplied through the project, at a cost that is difficult for the Assembly to afford under the current revenue generating arrangements. There is a risk that the landfill will revert to a dump and will fill up much faster in a short period if the operating principles of sectional filling, compaction and covering are not followed. As waste collection improves, cost recovery can be increased, and with economic growth the financial situation in the project towns is expected to improve to the extent that they can finance the operation and monitoring of the landfills eventually on their own. In the meantime, IDA will finance the operation of the sanitary landfills at the rate of 40% for the first two years, 30% for the next two years, and 20% for the remainder of the project as well as technical assistance. 48  2.1.3.5 Private Solid Waste Collection Contracting out solid waste collection by following a competitive process was introduced through UESP on a pilot basis, involving a subsidy from IDA to the contractor on a declining basis. Model contract were prepared and - after a long delay -one contract each awarded in Kumasi, Sekondi, and Tamale, and 3 in Tema. No program was carried out in Accra because one public company was given a monopoly by the previous government (see Annex 1). The experience has shown that high-income users are willing to pay for the service in full and middle-income users for part of it. Collecting from low-income users has been difficult partly because waste collection is not door-to- door. Franchising, whereby the contractor recovers at least part of the costs directly from the customer, appears to be more sustainable as it reduces the payment commitment of the Assembly to the contractor. The pilot has also shown that all the key aspects of the mutual obligations should be specified in the contract. The program will be continued under UESP II to apply the experiences learned and to extend this kind of service to other middle and low-income areas. Two such contracts are planned in each of the 5 MAs and one in Ga District. IDA will finance the contracts at the rate of 40% for the first two years, 30% for the next two years, and 20% for the remainder of the project. 2.1.3.6 Household Bins, Skips and Skip Pads Experience under UESP has shown that the supply of imported plastic refuse bins to households, by the waste collection contractor, designed for mechanical lifting by specific types of trucks, constitutes a large initial outlay that few contractors can afford. An alternative arrangement is for the Assembly to supply cheaper general-purpose refuse bins to the contractor up front under terms specified in the contract. The project will provide more skips and skip pads in areas where door-to door collection is not feasible. The monitoring of landfills and the reconditioning of waste management equipment will be carried out as part of the Institutional Strengthening component. 2.1.4 Component 4: Community Infrastructure Upgrading Community infrastructure upgrading has been part of nearly every Bank-assisted urban project in Ghana. It was carried out in 7 communities under UESP: 3 in Accra, 2 in Sekondi/Takoradi, and 2 in Kumasi. All or some of the following infrastructure were provided: upgrading of local roads, drains, water supply, public latrines, and street lighting, with roads taking up more than half the budget. The work was started in 1998 and was substantially completed in 1999. The interventions have had a significant impact in these communities, making it one of the most successful components of UESP. Under UESP II, it is proposed for twenty (20) communities in the five project towns to be upgraded, which would benefit an estimated 110,000 residents. It is anticipated that the same list of infrastructure improvements as in UESP will again feature prominently in the communities' list of priorities. The communities in Accra and Tema were chosen from a long list of 32 low-income communities in Greater Accra (which includes the urban part of Ga District adjacent to Accra) with severe infrastructure deficiencies, following the results of a study and community consultations that were completed in August 2002. A menu of road upgrading, drains, water supply, toilets, refuse collection, and street lighting was offered to the communities, and their priority choices were used to prepare preliminary plans. 49  The preparation for the infrastructure improvements will proceed as follows: a. The MAs will finalize the choice of communities in consultation with MLGRD; b. Consultative meetings will be held with the communities at a place inside the community and a community-based organization identified or formed for collaboration where possible; c. The priorities of the community representatives will be reconciled with the preliminary engineering plans from previous needs assessments; d. The consultant will prepare designs, an environmental assessment, and a resettlement action plan, based on the provisions of the RPF; e. One or more consultative meetings open to the public will be held with the communities on the design, EA and RAP; f. The RAP will be submitted to the Bank for clearance; and g. The designs will be finalized and the contractor selected. 2.1.5 Component 5: Institutional Strengthening 2.1.5.1 Technical Assistance and Training A project-wide capacity building and training program was carried out under UESP, with assistance from the Nordic Development Fund (NDF). This program ended in January 20033 after substantially completing all the targeted outputs, which mainly consisted of (i) a number of reports, manuals, and guidelines, and samples documents; (ii) training; (iii) provision of office facilities, vehicles, etc.; and (iv) policy dialogue. The impact of these activities was substantial in regard to the creation of functioning Waste Management Departments and on certain topics, such as the promulgation of the National Environmental Sanitation Policy, but achieved only modest results regarding the capability of the Ministry of Local Government and Rural Development (MLGRD) to facilitate and monitor waste management in the Metropolitan and Municipal and District Assemblies and the institutional and financial capacity of the five MAs for sustainable waste management. The underlying causes for the small improvements that were achieved in the sustainability of urban waste management are mainly related to unattractive terms of employment in local governments and insufficient revenues to finance the environmental sanitation services. They are further analyzed in Annex 1. The experience with the capacity building program in UESP has shown again the limitations of attempting to improve the sustainability of urban environmental sanitation through capacity building without the introduction of reforms in the civil service and without a substantial increase in local government revenues. However, without capacity building the situation would have been much worse than it is now, which provides a strong justification for continued support in this area, combined with assistance to the government on civil service reform and fiscal management. The Institutional Strengthening Component will build on the achievements of the PWCBT program and will aim at further improvements in the institutional and financial capacity of all the relevant 50  institutions for the improvement managing of the urban environment. The beneficiary institutions will be (i) the ones that are directly responsible for urban environmental sanitation, namely the Waste Management Department and the Environmental Sanitation Department in the five MAs; (ii) other units in the MAs, such as the Finance and Planning departments and the Environmental Sanitation Subcommittee of the Assembly; (iii) MLGRD (Head office, Environmental Sanitation Department, LGPSU); and (iv) other relevant central government agencies, RCC, local traditional authorities, NGOs, and the private sector. The support to the five MAs will mainly relate to (i) capacity buildinq aimed at institutional and financial improvements in environmental sanitation, and (ii) the necessary skills and facilities for every MA to implement its own share of UESP II. The assistance would be provided mainly in the form of different kinds of training (including on-the-job and workshops), equipment (e.g. computers, motorbikes, communications, etc.), hiring of consultants, and operating support for the additional office expenses due to the project. Facilitating project implementation by MAs. This is aimed at enabling the MAs to implement the portion of UESP II under their responsibility and will include improving key skills needed by the private sector. The assistance can take various forms, including training and the furnishing of model contracts. Review and implementation of studies and guidelines. Follow-up on the use of various model agreements, guidelines, manuals, accounting systems, monitoring systems, MIS systems, computerization, etc., which had been prepared under the PWCBT program and partly implemented (see Annex 12: List of Documents in the Project File). Project-wide monitoring. As a related activity to capacity building, the consultants will monitor the implementation performance of the entire project, including progress on outputs and impact as well as processes, such as procurement, contract management, and financial management. The monitoring function will also cover key aspects of the performance of MAs according the Performance Criteria specified in the MOU (Annex 6) and progress on select environmental performance indicators. A preliminary list of performance indicators is shown in Annex 3, which the consulting team will refine and expand in its inception report. 2.1.5.2 Capacity Building in MLGRD and other central agencies Under the decentralized service delivery system, central agencies have an important role to play in planning, coordination, support and monitoring. For urban environmental sanitation the key agency is MLGRD, and specifically its Environmental Health Unit, which will participate in the implementation of the institutional strengthening component. The support provided to this unit by UESP II will complement the planned institutional support from the Danida assistance program that starts in 2004. Another agency to be supported is the RCC (see above). Other beneficiary agencies, and the specific nature of the assistance to be provided, will be identified at the start of the project. The current haphazard and incomplete system of house numbering makes it difficult to implement a well management refuse collection system with cost recovery, which requires that the customers be identified by their location. The project towns will be assisted with developing a system of house numbering, identifying the owners and renters, numbering the properties, and transferring this system to their data bases. 51  2.1.5.3 Capacity Building in MAs Every MA will prepare annually (for the period of the GOG fiscal year) an institutional strengthening plan to improve its performance on environmental sanitation, in consultation with the RCC, and submit it to MLGRD for approval and support. The project implementation team (PIT) that will be formed to coordinate the portion of the project activities to be implemented by the MA (see Annex 6, MOU) will also be responsible for the preparation of the annual capacity building plans and for coordinating the implementation. 2.1.5.4 Malaria Vector Control and HIV/AIDS Prevention MAs will be provided with technical and financial assistance to organize, in collaboration with the Ghana Health Service - Roll Back Malaria program - (i) a program to eliminate the various types of breeding grounds for mosquitoes (including choked or faulty drains, discarded tires, puddles and pools, and open water containers - whether public or private), and (ii) a campaign to raise public awareness about the need for a comprehensive approach for combating malaria, to include removal of sources, spraying, use of impregnated bed nets (especially for children), and early treatment if infected. In line with the country's policy of requiring a vigorous effort to combat the spread of HIV/AIDS before it assumes epidemic proportions, the project will support HIV/AIDS prevention and control activities. Local government offices participating in the project4, and site offices of consultants and contractors will be the locations where HIV/AIDS awareness materials to promote behavior change and condoms will be distributed to the public. Furthermore, contractors will be required, through provisions in their contract, to give AIDS awareness and protection to their employees, including the distribution of condoms, promoting changes in behavior among them, and making available and financing the distribution of anti-retroviral drugs and drugs to treat opportunistic infections for people who are HIV positive. 2.1.5.5 Monitoring of Landfills Part of the operating plan of sanitary landfills is to monitor certain environmental conditions so that remedial actions can be taken if an unforeseen negative impact on the environment occurs. When restoration work is carried out on old dumps that have been closed, the effect of these works on environmental pollution also has to be monitored. Since this is a new activity in Ghana and a learning experience, it will be included in the project and partly financed by IDA. 2.1.5.6 Reconditioning of Waste Management Equipment The state of the existing waste management equipment in the WMDs will be assessed and those that are still serviceable will be reconditioned, through NDF financing, and the stock of spare parts replenished. The activity will be closely linked to the Institutional Capacity Building component and will include improvements in the transport log of vehicle use and of the maintenance register; training of transport supervisors in vehicle scheduling, tracking and maintenance; and improvements in the spare parts management. The assessment of the equipment and the drawing up of an improvement plan will be done by an expert mechanic on heavy vehicles. 52  2.2 PROJECT AREA OF INFLUENCE The project area of influence comprises parts of the five project towns of Accra, Kumasi, Sekondi- Takoradi, Tamale and Tema. The growth of Accra and Tema has extended to neighboring Ga District, in which one of the two proposed sanitary landfills, Kwabenya, is also located. Within this overall expanse, the actual area of influence depends greatly on the nature of the project component, as explained below. Field surveys conducted as part of the studies enabled the Consultants to determine the area of influence for the respective project components. 2.2.1 Storm Drainage Under the UESP II it has been proposed that secondary and tertiary drains would be constructed in all five project towns. The construction works would basically involve dredging, widening, narrowing, etc. A map depicting some of the areas is presented in plate 1. All these selected communities are built-up communities where there are many commercial and brisk social- economic activities going on every day coupled with both human and heavy vehicular traffic. The areas of influence of the proposed realignment of drains as may be needed, which would involve dredging, widening, narrowing, digging, movement of construction materials and equipments etc may include the following: (a) An improvement of the flood regime of these areas, which has been regular problem, each time there is a heavy down pour of rain; (b) There will be a temporary displacement of people who engage in commercial and economic activities on the shoulders of the roads and spaces where the drains would traverse. Migratory routes of human beings and vehicular traffic within these areas may also be hindered. (c) Provision of utility services such as water pipelines, underground electricity cables and telephone lines could be interrupted. 2.2.2 Sanitation The sanitation facilities to be provided under the UESP II would involve rehabilitation and construction of Household Latrines, Public Latrines and school latrines. These facilities are targeted at communities in Accra, Tema and Ashaiman. A map showing these areas is presented in plate 2. The rehabilitation and construction of the latrines could affect the migratory routes in the public areas or markets where the civil and its related works would be undertaken. There may be stench or bad odour emanating from the latrines into the air shed if adequate management practices and usage of the latrines are not followed. Poor management and usage of the latrine facilities could lead to a potential outbreak of cholera and other public health impacts. 2.2.3 Solid Waste Management As part of the steps being taken by the MLGRD to improve solid waste management in the five MAs, two new sanitary landfills have been constructed in Kumasi and Tamale Municipalities. Another new sanitary landfill, which is half-way completed is under construction in Sekondi- Takoradi. The completion of the final phase of the Sekondi-Takoradi sanitary landfill would be done under the UESP II. Investigations regarding the areas where these three sanitary landfills in Kumasi, Sekondi-Takoradi and Tamale would affect have been conducted in the EIA studies prior 53  to the commencement of the construction works, for which Environmental Permit (see the permits attached in appendix 4) have been obtained from the Environmental Protection Agency (EPA) of Ghana. The environmental concerns relevant to these completed or partially completed sanitary landfills are to do with operational issues and their management. Two (2) New Sanitary Landfills have been proposed for construction in Accra and Tema. As part of the feasibility studies into the proposed landfill development in Accra (Kwabenya) (see plate 3 for the site map), an environmental impact assessment (EIA) was conducted with a funding from another Donor. The EIA process considered the anticipated benefits of the development, the potential adverse environmental impacts, and possible methods of mitigating the adverse environmental impacts. The Environmental Impact Statement was prepared in accordance with the procedures of the Ghana Environmental Protection Agency. Following the completion of the design and the EIA the MLGRD/AMA implemented the first phase of the design, which involved the construction of leachate drains and storm culverts. Unfortunately, the funding for the project dried-up so the project came to a standstill. Under the UESP II, the major aspects of the actual sanitary landfill construction and other related infrastructure would be funded by the World Bank. The proposed Kwabenya Sanitary landfill having been classified as Category A project would have to be fully subjected to the World Bank Safeguard Policies. However, since an earlier EIA of the project has been done and taking note of the time lapse since the EIA was prepared it became pertinent that the EIA and the Design Philosophies of the proposed landfill are reviewed. The proposed Kwabenya sanitary landfill, including all its ancillary aspects such as power supply, site haul road, relocation and access roads may affect some areas. The areas of influence are: (i) Regional Geology The project site is within the Akwapim Range, which extends from Weija north-eastwards to the Volta River and beyond the Togo Range. (ii) Regional Hydrogeology The regional hydrogeology of the area is likely to be strongly influenced by the local topography and underlying geology. To the west of the site the underlying geology consists of gneisses and granites. To the east of the site are gneisses and schists. There are no major groundwater abstractions in the region. Potable water supply for the Accra Metropolitan area is derived from the surface water resources, primarily the River Densu. Flows from the River Densu are utilized via large storage reservoir in the Weija area. The use of surface water resources suggests that no major aquifers exist within the Greater Accra Region. A number of drinking wells are located within 2-3 km of the proposed landfill site. Some of the wells have been abandoned as the water has become "salty". (iii) Hydrology The two hydrological catchments in the region are the Odaw and the Densu. The proposed landfill site is located in the Western end of the Odaw. A schematic representation of the catchment is presented in Figure 11A. 54  Catchment to the South and East of the Site (Odaw): Drainage from Kwabenya Valley heads south towards Ofankor. The water course then continues to drain to the south-east into the Onyasia River. The Onyasia flows into the main Odaw, the lower reaches of which is the city of Accra. The Odaw empties into the Korle Lagoon in the centre of the city. The Lower reaches of the Odaw and Korle lagoon have extremely poor water quality due to continuous, severe, polluting inputs from urban Accra. Catchment to the West of the Site (Densu): To the west of the site is the Nsakyi River, which forms part of the Densu catchment. The Nsakyi River, which is about 21.5km long, takes its source from the hills close to Adusu and generally flows in a south-westerly direction to join the Densu River. The Densu empties into the Weija Lake, several kilometres to the west of Accra. The water within the Densu catchment is typically of high quality and is abstracted extensively for drinking water supply within Accra. The furthest upstream region is Mayera (S4), which is about 4 km downstream of the river source (Plate 13 of 1999 EIS). The river at this point was about 3 metres wide at the time of the visit in the dry season. Flood marks observed along the river indicated that the width of the river could double in size during storm events. The banks are rich in vegetation and the river bottom is sandy. (iv) Land use influences One of the most important potential influences of the landfill development is the effect on existing residents of Kwabenya Valley. The change in use of the site to a landfill will unavoidably result in involuntary resettlement of most or all of the existing residents to another area. The land use pattern as was observed on the day of inspection was a mixed use type. A number of residential units (both old and new) were observed. There were also quarry activities. These two land use types were on opposite sites of the slopes of the valley. Remnants of some old farming activities were also noticed. There was also a school within the site. However, the predominant land-use type observed is residential of various kinds from mud houses through simple single concrete buildings to huge multi-storey modern style architectural edifices were found. 2.2.4 Community Infrastructure Upgrading The community infrastructure upgrading component of the UESP II would mainly involve access roads upgrading, realignment of drains, street lighting, water supply, and sanitation Infrastructure in low-income communities. Many of the roads in these neighbourhoods do not provide adequate vehicular access due to gullies caused by erosion. Existing roads will be leveled and a surfacing dressing applied, and lined with drains. In the process of upgrading the roads and constructing side drains, water pipes that run haphazardly through the neighbourhood will be replaced with supply lines along the drains, with service connections to all existing users. Street lights will be provided where it is a community priority The constructional works relating to the infrastructure facilities would present environmental problems. These include site clearing, excavation and grading, construction of access roads, and 55  the construction of utility services (water supply system and street lights). Most of these activities will have significant impacts (both positive and negative) on the receiving environments. Site clearing activities, excavations, and construction of access roads may accelerate soil and land degradation. Once the soil structure is disturbed, runoff erosion during rains from unprotected excavated areas will result in excessive soil erosion. This can result in siltation of drains and water bodies and consequently trigger flooding in low-lying areas. Depending on the constructional technique adopted, the project activity may have some impacts on both groundwater and surface water quantity and quality. There may be problems created by surface run-off or flooding after heavy rainfall. Noise levels within and outside the project site during the constructional phase may give rise to nuisance to nearby residents. The major sources of noise and vibration at the site will include mobile equipment noise (e.g. trucks and bulldozers). 2.2.5 Institutional Strengthening A very important phase within the implementation of the UESP 11 is the management of the facilities and the systems to be set-up as a result of the project as well as their sustainability. The human capacity within the various stakeholder institutions as well as the linkages among the Municipal Authorities and the related stakeholder Institutions are seriously lacking. The provision of the items identified under this component of the UESP in an attempt to strengthening the relevant institutions to play their lead role would affect the some existing national policies, legislations and institutional structures. The private and informal sectors would also be affected. The key areas to be affected are the objectives and plan of activities of all the institutions involved in environmental sanitation management. 56  3.0 DESCRIPTION OF POLICIES, LEGAL, AND INSTITUTIONAL FRAMEWORKS 3.1 POLICY ISSUES Ghana's National Environment Policy (NEP) is contained within the broader framework of the National Environmental Action Plan (NEAP) Vol. 1, which was adopted in 1991. The principal objective of the NEP is to improve the surroundings, living conditions and the quality of life of the entire citizenry present and future generations. It seeks to ensure reconciliation between economic development and natural resource conservation, to make a high quality environment a key element in supporting the country's economic and social development and natural resource conservation and to make a high quality environment a key element in supporting the country's economic and social development. Among other things, the policy seeks to guide development in accordance with quality requirements to prevent, reduce and as far as possible eliminate pollution and nuisances. * Integrate environmental considerations in sectoral, structural and socio-economic planning at the national, regional, district and grassroots levels; * Seek common solutions to environmental problems in West Africa, Africa and the world at large. 3.1.1 Principles The NEP also invokes a number of principles deemed to be effective for achieving its objectives. Among these are: Use of the most cost-effective means to achieve environmental objectives; Use of incentives in addition to regulatory measures; and * Polluter pays for the cost of preventing and eliminating pollution and nuisances. 3.1.2 Policy Statement Ghana's specific policy statement on environmental protection is that it must be guided by the preventive approach so that socio-economic activity can take place without undermining the integrity of the environment. Specifically, Government has promised to do the following: * Institute and implement an environmental quality control programme by requiring prior environmental impact assessments of all new investments that would be deemed to affect the quality of the environment; * Establish an adequate legislative and institutional framework for monitoring, co-ordinating and enforcing environmental matters. 3.1.3 Waste Management NEP acknowledges that the volume of wastes generated is rapidly increasing, especially in the urban areas. It is stated that a substantial percentage of the urban waste in Ghana is 57  biodegradable and therefore potentially re-useable or re-cyclable for raw material or energy but the appropriate technology and resources are not readily available. With industrialization, an increasing proportion of the waste being generated is toxic or dangerous and deserves special handling. Much of the waste generated is disposed of on land and some into the sea and other water bodies with little or no treatment before disposal. NEP therefore proposes the adoption of a more comprehensive policy for waste management. Such a policy will cover prevention, reclamation and disposal. Additionally, the policy will focus on three broad themes: reduction in the volume of waste, increase of recycling and reuse and safe disposal of unavoidable wastes. The NEAP and the Policy it outlines both need to be updated. Between 1991 when the NEAP was adopted and now, a lot of changes have taken place, which need to inform a review of the NEAP. It is not yet clear why no attempt has been made to carry out a comprehensive review of the NEAP. 3.2 GHANA LANDFILL GUIDELINES The Guidelines is the result of close collaboration between the Ministries of Local Government and Rural Development, Environment and Science and Environmental Protection Agency. The Guidelines cover landfill classification, site identification, design, upgrading of existing dumpsites, operation and maintenance, closure restoration and aftercare. The purpose of the Guidelines is to provide the basis upon which waste management authorities will issue permits for landfill operations in the country. The guidelines have been properly applied in the issuance of permits for the construction of landfills in Kumasi, Takoradi and Tamale. However those landfills are yet to commence operations. The Guidelines are also intended to provide adequate and practical information to enable applicants, license holders and their designated advisors and managers to comply with the policy of the District Waste Management Department and related legislative requirements. Among the objectives that the Guidelines seeks to achieve are to: a. Improve the standard of waste disposal operations in Ghana; b. Set out options for the environmentally acceptable disposal of solid waste; c. Provide a framework of sustainable waste disposal standards within which to operate; and d. Provide a framework for upgrading all landfills in Metropolitan, Municipal and large urban areas to high-density aerobic (HDA) landfills by the end of 2010 and full sanitary landfills by 2020 for existing waste dumps like those at Oblogo, Tema and Mallam. The Guidelines require the following: * Site assessment and planning; * Provision of site drainage; and * Proper decommissioning and aftercare. Work is yet to start on the preparation of legislation to implement the guidelines. 58  The Guidelines are designed to provide the basis for protecting public health and the environment, employing mainly locally available and adaptable techniques, knowledge and resources. Implementation of the Guidelines will be backed by legislation and licensing arrangements. 3.3 ENVIRONMENTAL SANITATION POLICY In 1999 the Ministry of Local Government published an Environmental Sanitation Policy. This Policy was prepared long after the NEAP. Sanitation is construed to have a broader meaning than waste. The Policy describes the objectives of environmental sanitation to include developing a clean, safe and pleasant physical environment in all human settlements, promoting the social, economic and physical well-being of all sections of the population. It comprises of various activities including the construction and maintenance of sanitary infrastructure, the provision of services, public education, community and individual action, regulation and legislation. 3.3.1 Solid Waste Management The Policy confers primary responsibility for solid waste management on the Assemblies. However, the private sector will be invited to provide the actual services under contract or franchise, as appropriate. The Policy lists the following as acceptable technologies for solid waste disposal: * Sanitary landfill; * Controlled dumping with cover; * Incineration; * Composting; and * Recycling On hospital waste, the Policy indicates that all health institutions shall establish an institutional waste management system for primary storage of waste. Where possible, clinical waste must be pretreated (e.g. by autoclaving) prior to storage. Domestic waste must be separated from clinical waste. While the major hospitals and some clinics do indeed segregate these wastes, lack of effective monitoring and surveillance may mean that there are defaulting clinics that are not acting in accordance with the guidelines. Separate collection of hazardous wastes and clinical wastes shall be provided by all District Assemblies or by other arrangements approved by the Assembly. 3.4 GUIDELINES FOR THE SAFE MANAGEMENT OF HEALTH CARE AND VETERINARY WASTE IN GHANA The purpose of these Guidelines is to enable hospital administrators, engineers, environmental health officers and other para-medical professional be aware of the requirements for the proper and safe management of biomedical waste. The main objectives are: 59  * To set out an appropriate institutional and administrative framework and procedures within which to manage and monitor bio-medical waste; and * To make recommendations that will provide the basis for policy formulation and legislation on bio-medical waste management. 3.5 LEGISLATION AND REGULATORY FRAMEWORK Ghana, unlike other jurisdictions in Africa such as Kenya, Gambia, and Uganda has no framework legislation on the environment. Laws that seek to protect the environment are contained in subject specific legislation. The only existing law that can be said to resemble a framework law is Act 490. Act 490 repealed the National Redemption Council Decree (NRCD 239) of 1973. NRCD 239 was Ghana's response to the Stockholm Declaration's request to member states of the United Nations to create national institutions responsible for the management of the environment. NRCD 239 had several shortcomings particularly in the areas of enforcement and control, which were non-existent. By 1994 when Act 490 was adopted, it was clear that a lot of changes have occurred in the field of environmental management, which the drafters of the Decree had not envisaged. The enactment of Act 490 by Ghana's Parliament represents a recognition of the deficiencies in the existing law and the need to adopt a new legislation that took account of new trends in environmental management. Act 490 created a corporate body called the Environmental Protection Agency (the Agency) to replace the Environmental Protection Council, which was created under NRCD 239. Among its functions, the Agency was mandated: "... to ensure compliance with any laid down environmental assessment procedures in the planning and execution of development projects, including compliance in respect of existing projects," section 2(i). Under section 12 (1) of the Act, the Agency: ... may by notice in writing require any person responsible for any undertaking which in the opinion of the Agency, in respect of the undertaking, an environmental impact assessment containing such information within such period as shall be specified in the notice." Section 28 of the Act deals with Regulations. It provides under subsection 2(b) that regulations may be made to provide for: "... the category of undertakings, enterprises, constructions or developments in respect of which environmental impact assessment or environmental management plan is required by the Agency." In order to meet the immediate demand imposed by section 2 (i) of Act 490, the Ghana EIA Procedures were developed, published and launched in 1995. The procedures formed the basis for the Environmental Assessment Regulations, 1999 (Li 1652). 60  3.5.1 Environmental Assessment Regulations Li 1652 follows in broad terms, the procedures for the preparation of an environmental assessment report. It provides a graduated system for determining what will be demanded from a proponent on the basis of the size and likely impacts of a particular project. On receipt of an application, including such information as may be required; the Agency will carry out an initial assessment taking into consideration factors such as: Location, size, and likely output of the undertaking; Technology intended to be used; Concerns of the general public, if any, and in particular concerns of immediate residents if any; and Land use, and other factors of relevance to the particular, undertaking to which the application relates. To enable the Agency make a determination as to the level of environmental assessment of any undertaking, the applicant must submit to the Agency a report on the undertaking and indicate in the report: The environmental, health and safety impact of the undertaking; A clear commitment to avoid any adverse environmental effects which can be avoided on the implementation of the undertaking; A clear commitment to address unavoidable environmental and health impacts and steps where necessary for their reduction; and * Alternatives to the establishment of the undertaking. Where the Agency is satisfied with an initial screening, it registers the activity which is the subject of the application and issues an environmental permit. Since the coming into force of LI 1652, the EIA procedures have been applied fully and effectively to both privately and publicly funded undertakings. The Agency is responsible for the implementation of the Regulations. SCHEDULE 2 OF Li 1652 The Regulations prohibit the commencement of various undertakings listed in a schedule without prior registration with the EPA and the issuance of a permit. The activities listed in Schedule 2 of the Regulations, fall within the ambit of the activities for which an environmental impact assessment is mandatory. Among the activities listed in schedule 2 under waste treatment and disposal are the following: Construction of incineration plant; Construction of recovery plant (off-site); Construction of wastewater treatment plant (off-plant); Construction of secure landfills facility; and Construction of storage facility. 61  The undertakings under municipal solid waste that are subject to full EIA are: * Construction of incineration plant; * Construction of composting plant; * Construction of recovery/recycling plant; * Construction of municipal solid waste landfill facility; and * Construction of waste depots. REPORTING UNDER L.I. 1652 The Regulations provide for a number of reports. These are: Screening report; * Preliminary environmental report; * Scoping report; Environmental Impact Statement; and * Annual environmental report. SCREENING REPORT The screening report is prepared at the earliest stages of the EIA process and allows a determination to be made by the Agency about the level of environmental assessment of a particular undertaking. PRELIMINARY ENVIRONMENTAL REPORT In some instances, the Agency may come to the conclusion that an activity requires a preliminary environmental report (PER). Where such a decision is arrived at, the applicant would be required to submit a PER. The PER will contain details extending beyond that contained in the initial application. The new application must state specifically the detailed effects of the proposed undertaking on the environment. Where a PER is approved, it is registered and an environmental permit is issued. In the event that on receipt of a PER the Agency is satisfied that there will be a significant and adverse impact on the environment, the applicant will be expected to submit an environmental impact statement (EIS) on the undertaking for assessment of the environmental impact of the proposed undertaking. SCOPING REPORT The Regulations require that the EIS shall be outlined in a scoping report. The scoping report sets out the scope or extent of the EIA to be carried out by the applicant and includes draft terms of reference (TOR) which must indicate the essential issues to be addressed in the EIS. Among the issues that the draft TOR must address are the following: 62  Identification of existing environmental conditions; Information on potential, positive and negative impacts from the environmental, social, economic and cultural aspects in relation to the different phases of development of the undertaking; Potential impact on health of people; Proposals to mitigate any potential negative socio-economic, cultural and public health impacts of on the environment; . Proposals for monitoring predictable environmental impact and proposed mitigating measures; Contingency plans; Consultation with members of the public likely to be affected by the operations of the undertaking; Provisional environmental management plan; and Proposals for payment of compensation for possible damage to land or property arising from the operation of the undertaking. On the acceptance of a scoping report by the Agency, the applicant is informed to submit an EIS based on the scoping report ENVIRONMENTAL IMPACT STATEMENT The EIS must address potential direct and indirect impact of the undertaking on the environment at the pre-construction, construction, operation, decommissioning and post-decommissioning phases. Among the items to be addressed are the following: * Concentration of pollutants in environmental media including air, water and land from mobile or fixed sources; . Alteration in ecological processes such as transfer of energy through food chains, decomposition and bioaccumulation which could affect any community, habitat or species of flora and fauna; * Ecological consequences of direct destruction of existing habitats from activities such as dumping of waste and vegetation clearance and fillings; * Noise and vibration levels; * Odour; and * Vehicle traffic generation and potential for increase in road accidents. Additionally, changes in social, cultural and economic patterns must be dealt with in relation to the following: Decline in existing or potential use arising out of matters referred to above; Direct or indirect employment generation; Immigration and resultant demographic changes; Provision of infrastructure such as roads, schools and health facilities; Local economy; Cultural changes including possible conflict arising from immigration and tourism; and Potential land use in the area of the proposed undertaking. 63  ANNUAL ENVIRONMENTAL REPORT A person granted an environmental permit under the Regulations is required to submit an annual environmental report in respect to his undertaking after 18 months from the date of commencement of his operations and thereafter on a 12 monthly basis to the Agency. The EPA is required to define the form and content of the Annual Environmental Report. PUBLIC CONSULTATION Public participation is liberally provided for in the Regulations. These provisions are secured through advertisement of the scoping notice for comments and public hearings. As to whether the rationale for engaging the public has been sufficiently fulfilled, this is dealt with under recommendations. The Technical Review Committee that reviews Environment Impact Statements (ElSs) prior to permitting is not provided for in the regulations. It may be useful to consider an amendment to the law to spell out the membership of this committee rather than leave it to the discretion of the Agency to use an administrative procedure in setting up such an important body. Indeed in some jurisdictions like Kenya, Uganda, Gambia and Mauritius, the EIA law provides for the setting up of Technical Advisory Committees to assist the permitting agency. 3.6 INSTITUTIONAL FRAMEWORK 3.6.1 Ministry of Environment and Science The Ministry of Environment and Science (MES) was established in 1994. Its creation was in response to a national development need to integrate environmental, scientific and technological considerations into the country's sectoral, structural and socio-economic planning processes at all levels. The declared mission of MES is to establish a strong national scientific and technological base for accelerated sustainable development of the country to enhance the quality of life for all. Among other things, this will be done through the development and promotion of cost-effective use of appropriate technologies. Among the main areas of policy thrust for MES, are Sanitation and Waste Management (Technical Options) and Science and Technology promotion, education and acculturation. 3.6.1.1 Functions The functions of MES are: * Protection of the environment through policy formulation and economic, scientific and technological interventions needed to mitigate any harmful impacts caused by development activities; * Standard setting and regulatory activities with regard to the application of science and technology in managing the environment for sustainable development; * Promotion of activities needed to underpin the standards and policies required for planning and implementation of development projects; and * Co-ordination, supervision, monitoring and evaluation of activities that support goals and targets of the Ministry and national sustainable development. 64  It is noted that MES is the political focal point for United Nations Convention on Climate Change (UNFCCC) in Ghana and therefore plays a key role in activities that arise out of the implementation of the Convention. 3.6.2 Ministry of Local Government and Rural Development The Constitution of any country constitutes the basic law of the land and any law that derogates from it could be said to be unconstitutional to the extent of the derogation. Chapter 20 of the Constitution provides for decentralization and local government. It prescribes the features that the decentralized system must possess. Parliament is given power to enact laws and to provide for the taking of such measures as are necessary to enhance the capacity of local government authorities to plan, initiate, co-ordinate, manage and execute policies in respect of all matters affecting the people within their areas with a view to achieving the localization of those activities. The Local Government Act and the Ministry of Local Government and Rural Development are the legislative and institutional expressions of the provisions in Chapter 20 of Ghana's 1992 Constitution. 3.6.2.1 Local Government Act, 1993 (Act 462) The Local Government Act (Act 462) seeks to give a fresh legal expression to government's commitment to the concept of decentralization. It is a practical demonstration of a bold attempt to bring the process of governance to the doorstep of the populace at the Regional and more importantly, the District level. The District Assemblies created under the law, constitute the highest political authority in each district, municipality and metropolis. Among the functions of the District Assembly are the following: * Formulate and execute plans, programmes and strategies for the effective mobilization of the resources necessary for the overall development of the district; * Initiate programmes for the development of basic infrastructure and provide municipal works and services in the district; and * Be responsible for the development, improvement and management of human settlements and the environment. 3.6.2.2 Bye-Laws One of the most important provisions of the law is the power of the District Assemblies to make bye-laws for the purpose of the functions conferred under Act 462 or any other enactment. Most District Assemblies have adopted bye-laws on sanitation and waste. However, there is still no engineered waste disposal currently in place in the country. 65  3.7 INTERNATIONAL LEVEL In Ghana's 1992 Constitution, Government has committed itself to promote respect for international law, treaty obligations and the settlement of international disputes. Government makes further commitment to adhere to the principles derived from the aims and ideals of international organizations to which Ghana is a member. It is pursuant to these ideals that Ghana has worked with other members of the international community to negotiate various international legal instruments, which seek to protect the global environment. It is in this context that Ghana must be seen to translate into national action the obligations it has assumed by becoming a party to several international treaties on the environment. Among these are, the United Nations Framework Convention on Climate Change (UNFCCC) and its Kyoto Protocol, the Montreal Protocol on Substances that Deplete the Ozone layer and the Basel Convention on the Transboundary Movement of Hazardous Wastes and their Disposal. It is worth noting that Ghana is a party to all these environmental treaties. The expectation is that, consistent with its constitutional and international obligations the Ghanaian government will work at the implementation of the obligations it has assumed under these international laws. 3.8 COMMENTS AND RECOMMENDATIONS 3.8.1 Collaboration and Coordination In the implementation of environmental laws, a major conflict may arise as a result of parallel and similar mandates given by statute to two or more institutions. In the case of Act 490 and Act 462, the Environmental Protection Agency and the Metropolitan, Municipal and District bodies have been assigned responsibilities dealing with environmental management. The overlapping of responsibilities creates territorial conflicts and cripples effectiveness in the management of Ghana's waste problems. In Ghana, responsibility for waste management has traditionally been entrusted to local authorities and this position was reinforced by the 1992 Constitution and the Local Government Act of 1993. It is clear from the state of sanitation in and around Ghana that there is little or no compliance and the institutions authorised to enforce the law have not been able to exercise their mandates to the fullest. There is the need for closer collaboration between the waste management departments of the various local authorities and the EPA. The establishment law of the EPA, entrusts the Agency with responsibility to: 66  * Coordinate the activities of such bodies as it considers appropriate for the purposes of controlling the generation, treatment, storage, transportation and disposal of industrial waste; (section 2(c); * Secure in collaboration with such persons as it may determine, the control and prevention of discharge of waste into the environment and the protection and improvement of the quality of the environment. (Section 2 (d). The local authorities were created at a time when domestic waste was their major task and overtime this has changed dramatically without a corresponding change in the structure or functions of these waste management departments. This will have to be addressed urgently. The coordinating role of the Agency can be consolidated through the proactive implementation of its functions under section 2 0) of Act 490. The section requires the Agency to act in liaison and co- operation with government agencies, District Assemblies and other bodies and institutions to control pollution and generally to protect the environment. 3.8.2 District Environmental Management Committees The District Environmental Management Committees (DEMCs) have no statutory basis and this can undermine their authority to act. It can also affect the credibility of their decisions. There is the need to correct this defect if the committees are to function effectively and serve as a bulwark at the local level in the war against unsanitary conditions. 3.8.3 Legislative Gaps Ghana at the moment has no comprehensive legislation that addresses all waste streams. As noted above, there is no institution that can be identified as having responsibility for industrial waste. In such a situation nothing happens and it is the environment and human health that suffers. There is the need to review the various guidelines for various waste streams and craft out of them a comprehensive legislation on waste management with clearly defined roles for institutions to enforce the law. 3.8.5 Public Participation Public participation and consultation in decision making has gained firm roots both nationally and internationally. It constitutes a cornerstone of the concept of democracy. This position is recognised and given adequate attention in the Regulations. Experience has however shown that in practice, the system may be seriously flawed in that the final decision arrived at, may not really reflect the wishes of the desires of the communities that will be most affected by the project to be undertaken. This inadequacy arises out of a number of factors including widespread illiteracy, ignorance of the effects and consequences of the operations of a particular project/activity and sheer apathy which can also be traced back to the search for the means of survival in a harsh economic environment. Steps would have to be taken to fine tune the process including engaging civil society groups with expertise and experience in dealing with rural communities to help ensure the integrity of the EA process. The permitting authority will undermine its neutrality if it engages in this activity. 67  3.8.6 Human Resource Constraints Since the introduction of the EA process in Ghana a lot of effort has been spent on training local consultants to carry out the task of preparing the assessment. The numbers do not appear to be sufficient as yet and the training and capacity development needs to be a continuous exercise so that local ownership of the final product can be assured. 3.8.7 Monitoring and Evaluation One of the most important components of the EA process is monitoring. During project implementation it is important to ensure that the project is being carried out in accordance with the terms and conditions of approval. It is the responsibility of the EPA to execute this task. Lack of adequate personnel, vehicles, and laboratory facilities has impaired the discharge of this function. If the EA process is to achieve its objective of securing environmental sustainability, then the Agency will need to be strengthened to perform this function more effectively. 3.8.8 Compliance and Enforcement Enforcement constitutes the last point in the chain of processes needed for implementation when compliance fails. The EA law criminalizes any breach of the provisions of Li 1652. Fortunately for Ghana, the burden of prosecuting cases has been given to the Agency's lawyers under Executive Instrument E. I. 9 since 1999. It is worth noting that in spite of regular breaches of the law, the Agency has had very little success in securing convictions. This may be due to technical constraints associated with the gathering of evidence to meet the high standard of proof required to secure convictions in criminal cases. The local authority laws are also enslaved by the fixation to custodial sentences. This needs to change and give way to community service as obtains in the United States particularly in relation to offences under environmental laws. 68  I I  4.0 METHODS AND TECHNIQUES USED IN ASSESSING AND ANALYSING THE IMPACTS 4.1 BACKGROUND INFORMATION GATHERING AND LITERATURE REVIEW Prior to the commencement of actual consultancy activities EEMC undertook the following preliminary activities: Requested project documents: * Proposed landfills feasibility reports; * Technical designs of major projects and their sub-components; . Landfills site selection and investigation reports and relevant preliminary permits or licenses; Preliminary Environmental Impact Assessment reports on UESP; Impact study report on the Urban Environmental Sanitation Project (UESP). * Operational Guidelines for New Sanitary Landfills in Kumasi, Takoradi and Tamale. * Other relevant project documents. 4.2 ORIENTATION FOR EEMC In order that EEMC adequately understands the entire project so as to effectively chart a way forward, EEMC was briefed by the MLGRD on the historical records of works done and knowledge of progress of work through visits to project sites where some works have been done or are being done. 4.3 FIELD WORK One of important eligibility criteria for access to funds for the UESP II is community participation. As part of the methodology and approach for the study the consultants have undertaken a series of consultative meetings with varied group of key stakeholders and conducted field visits to major project sites. Prior to the field visits preliminary meetings were held with the UESP II Project Office at the Institute of Local Government Studies (ILGS), Ogbojo, Accra. This meeting afforded the consultants the opportunity to be abreast with the overview of the status UESP II activities at the various cities, namely Kumasi, Takoradi, Tamale, Accra and Tema. Consequently, the consultants were able to revise their work plan for the execution of the assignment. EEMC Consultants have made a number of reconnaissance field surveys to the subcomponent project areas, waste dumps and the proposed new landfill sites. Below are enumerated in a tabular form some of the activities undertaken, project areas visited and the outputs derived from these activities and visits. 70  4.3.1 Findings 1.0 STORM DRAINAGE IN AMA/GDA ACTIVITIES UNDERTAKEN / SITE VISITS PERSONS CONTACTED OUTPUT MADE a) Collected and evaluated the status report on The AMA Chief Executive The visits helped EEMC to know: lining of drains and erosion control The GDA Chief Executive . The environmental impacts of the b) Field visits to selected sites Mr. Awuah drains to be constructed c) Identified environmental and social impacts of . The populations to be affected and lining of drains and erosion control why a resettlement plan cannot be d) Investigated the availability of facilities prepared before appraisal management plans. 2.0 SANITATION IN AMA/GDA ACTIVITIES UNDERTAKEN / SITE VISITS PERSONS CONTACTED OUTPUT MADE Latrines Mr. B.M. Laryea, The visits helped EEMC to know the Collected and evaluated status report on household, Mr. Anderson environmental impacts of the latrines to be public and school latrines in Accra Mr. Blay constructed 3.0 SOLID WASTE MANAGEMENT IN AMA/GDA PROPOSED NEW LANDFILL AT KWABENYA ACTIVITIES UNDERTAKEN / SITE VISITS MADE PERSONS CONTACTED OUTPUT Secured the EIA and Design report for the Mr. Ewool, Reconnaissance visits and facts finding visits proposed landfill at Kwabenya made to Kwabenya landfill site have helped the Mr. Howard consultants to: Environmental Management plan, Operation and > Assess the level of the resettlement issues maintenance plans, including manuals have been Mr. B.M. Laryea and compensation issues to be addressed. obtained. > Know the population of affected people Mr. Blay > Assess the level of the encroachment on the The proposed new landfill site was visited buffer zone around the landfill; > Have knowledge of the access to the landfills and solid waste collection centers > Describe the landfill area of influence > Predict the Potential environmental and social impacts > Facilitate the Socio-economic studies of the project area including census. > Know the eligibility of those affected by the sitting of the landfill > Facilitate the Resettlement measures (relocation, compensation, site selection for relocation, analysis of alternatives, reconstruction of housing and infrastructure, etc.) . Consultation with affected communities and organizations _ _ _ _ _ _ __ Procedures for grievances and disputes 71  4.0 CLOSURE AND REHABILITATION OF EXISTING WASTE DUMPS IN ACCRA ACTIVITIES UNDERTAKEN / SITE VISITS MADE PERSONS CONTACTED OUTPUT (1) Field visits were conducted to the waste dumps Mr. B.M.Laryea, The visits to the existing waste dumps have help site in Accra the consultant to: Mr. Anderson We inspected existing equipments for the . Assess the existing impacts management of the waste dumps in Accra and Mr. Blay (environmental and social, including have information on: scavengers) - List of equipment for the management of the . Draw waste management plan for the waste dumps; decommissioning (including closure, - Operational costs compensation for scavengers, and - Maintenance cost monitoring after closure) - Monitoring to be done on e.g. on leachate, groundwater contamination The description of the landfill or waste dumping sites at: (a) Mallam (b) Djaman (c) Ogblogo Is now known The status of the various waste dumps regarding the: - Capacity - Closure - Rehabilitation was ascertained. i) We discussed AMA's programme or work plan for the decommissioning of the sites or their rehabilitation ii) We were provided with information on the operational plan for the usage of the Ogblogo Site until June 2004 when decommissioning will begin. iii) We were provided with the future decommissioning plans for Ogblogo Landfill iv) We were provided with information on Waste types dumped at the waste dump 72  (2) The consultants have gathered the most recent data on solid waste characterizations in Accra, as of 1999. The Characterization/composition of Solid Waste generated in Accra is currently being carried out in respect to the percentage composition by weight of: - Organic - Paper and cardboard - Plastics - Glass - Metals - Textiles - Miscellaneous - Fines - Inert mats i) Computations of quantities of solid wastes generated in Accra on annual basis from 1999 to 2002 has been done. (3) On Solid Waste Collection we have in collaboration with the Waste Management Department of the AMA compiled a brief report on the pilot private participation in solid waste collection programme in Accra: The report covers: - The collectors and their total numbers; - How they operate and the percentage of waste they are able to collect - The cost of their operation to the AMA: - The problems confronting the programme 73  5.0 INFRASTRUCTURE UPGRADING IN LOW INCOME COMMUNITIES IN AMA/GDA ACTIVITIES UNDERTAKEN/SITE VISITS MADE | PERSON CONTACTED | OUTPUTS Reconnaissance visits have helped the 1. Facilities management report on consultants to: infrastructure upgrading in low-income > Assess the level of the resettlement communities (access roads, roads drains, issues and compensation issues to be street lighting, rationalization of water addressed. supply lies) was not available.. Know the population of affected people > Predict the Potential environmental and 11. Field visits to some of the site where the social impacts facilities are being undertaken were made > Consultation with affected communities and organizations _ Procedures for grievances and disputes TRAINING PROGRAMME 1. We identified training needs of the A draft training programme has been prepared by AMA/GDA under the UESP 11 EEMC 11. Specific areas of interest in terms of training needs were also identified 111. Materials available for training (already in existence) were identified. IV. We have requested to be provided with their expectations after the proposed training required under the TOR (By the end of the completion of the training programme 74  6.0 SANITATION IN TEMA MUNICIPAL ASSEMBLY (TMA) ACTIVITIES UNDERTAKEN / SITE VISITS MADE PERSONS CONTACTED OUTPUT 1. LATRINES We collected copies of the under-mentioned Mr. Ablade, The visits helped EEMC to know: reports: Mr. Mba, . the environmental and social impacts of (a) Status report on Household Latrines in Mr. Ferguson, the latrines that have been constructed Ashaiman/Tema Mr. Nii Ashong Narh in both schools and residential facilities (b) Status report on School Latrines in . the environmental impacts of the Ashaiman/Tema latrines yet to be constructed (c) Copy of the Health and Hygiene education manual for the Schools Field visits to some of these sites were conducted 2. SEWERAGE SYSTEM IMPROVEMENT We secured: Mr. Ablade, The reports and drawings are being studied to (a) The Design report of the Sewerage Handling Mr. Mba, identify: System in Tema Mr. Ferguson, (b) The drainage covering the positions of the Mr. Nii Ashong Narh * The spread and adequacy of the sewer sewer lines, the pumping stations, sewage lines treatment plant and sea ouffalls (c) Status report of the Sewerage System in . The present conditions of the sewerage Tema system The following documents which have been . The environmental and social impacts requested for and are yet to be received from the of the rehabilitation of the sewerage TMA system (a) Management plan for the sewage treatment system including organizational plan for the The consultants then proposed mitigation sewage treatment plant. measures for the above as well as made (b) An operational plan for the sewage treatment suggestions for alternatives. plant. (c) A budget plan for the sewerage treatment plant (d) Any future plan for expansion Field visit to pumping stations, the treatment plant and the sewer liners in Tema were also made. 7.0 NEW LANDFILL AT TEMA ACTIVITIES UNDERTAKEN / SITE VISITS MADE PERSONS CONTACTED OUTPUT Documentation on the following have been Mr. Ablade, The visit has facilitate the provided for study: Mr. Mba, i) Evidence of acquisition of land for the Mr. Ferguson, > Description of the landfill area of influence proposed landfill Mr. Nii Ashong Narh > Prediction of the Potential environmental and ii) Resettlement plan prepared for the social impacts proposed site for new landfill in Tema iii) Preliminary design report for the > Socioeconomic studies of the project area proposed landfill Field visit to the proposal Landfill site and the existing dump site were made. 75  8.0 DECOMMISSIONING OF KPONE LANDFILL, TEMA Discussions have been held with the TMA on the Mr. Ablade, The visits to the existing waste dumps have help decommissioning of the existing dump site at Mr. Mba, the consultant to: Kpone and a write up has been handed over to Mr. Ferguson, . Assess the existing impacts EEMC covering the following areas: Mr. Nii Ashong Narh, (environmental and social, including Mr. Lambert Faabeluon scavengers) i) Description of the existing landfill at Kpone * Draw waste management plan for the ii) The site plan for the site decommissioning (including closure, iii) Description of the status of the landfill compensation for scavengers, and regarding the following: monitoring after closure. - Capacity, Closure, - Rehabilitation - Monitoring (Leachate, groundwater, covering with top soil) iii) Existing decommissioning plan for the Kpone landfill 4.4 CONSULTATIONS / MEETINGS EEMC Consultants consulted and met with the MLGRD, the World Bank, Metropolitan Authorities, Municipal Assemblies, Sub Metros, Assembly members, Unit committee members and other Government Officials. The meetings and the consultations enabled the EEMC to report/discuss the outcome of the reconnaissance visits so as to finalise procedures to be adopted for the studies. Some of the key institutions meetings were held with or personalities consulted by EEMC were: 4.4.1 Consultations EEMC has widely consulted the following relevant stakeholder Institutions and individuals as part of the studies: Ministry of Local Government and Rural Development: Mr Godfrey Ewool-Project Director, UESP II Mr Kofi Howard -Project Office, UESP II Greater Accra Regional Coordinating Council: (Mr Fats T. Nartey); Accra Metropolitan Assembly (AMA); Solomon Darko-Mensah -AMA Chief Executive l.T. Ajovu -AMA Metropolitan Coordinator B. M. Laryea -Waste Management Deartment Anderson Blay -Waste Management Department Ayite Coleman -MMOH Benard Ofori Tawiah - Environmental Health Department A. A.Arde-Acquah -Environmental Health Department 76  Tema Municipal Assembly (TMA) Nii Ashong Narh-Chief Executive S. Y. Akoto- Municipal Engineer E. Sodja Mensah- Environmental Health Department Samuel Ablade- Head, Waste Management Department Mba Fergusson Ga District Assembly (GDA) S. N Attoh (District Chief Executive) P. J. N Yeboah (Presiding Member) P. A.. K. Owusu Sekyere (District Coordinating Director) Victor Mensah ( District Engineer) Jemima Lomotey (District Planning & Coordinating Unit) Derick Tata-Anku (Environmental Health & Sanitation) 4.4.2 Meetings and Minutes EEMC had series of meetings and discussion with the Ministry of Local Government and Rural Development, the Regional Coordinating Council of Accra, The Accra Metropolitan Assembly (AMA), The Tema Municipal Assembly, The Ga District Assembly, the Environmental Protection Agency (EPA). Some of the issues discussed are covered in the minutes in the Appendix. Arising from a series of consultations and discussions held with various identified groups such as the traditional authorities, religious bodies, stone winning associations, individuals of the community, community leaders, assembly members, etc their concerns and views have been compiled for integration into the preparation of a Resettlement Action Plan (RAP, based on the provisions of the RPF) and implementation of the project. Focus group and group discussions were organised by CEDEP, an independent Non Governmental Organisation between the periods of 2001-2002. The EEMC in September 2003 had also interacted with some of the people to be affected and conducted a preliminary assessment of the properties within the buffer zone to be affected by the proposed project. The focus group and group discussions were organised in the Kwabenya Township and Agyeman-Kata for participants drawn from Kwabenya Township and its surrounding communities. As part of the discussions, the participants were taken through the rudiments of landfills. The format of the discussions allowed the participants to actively express their concerns, seek clarifications, analyse the project within the context of their needs and made the necessary recommendations. Several interactions were also held with the staffs and District Chief Executive of the Ga District Assembly. The major issues raised at the discussions were about the provision of basic needs such as portable water, schools, market, clinic, roads and the nature of compensation and relocation of affected people. Concern was also expressed about the potential health impacts and nuisances such as bad odour, vermin, flies, rats etc. A detailed account of the meetings with the various groups identified and their views is complied and presented in Appendix 2. 77  Recommendations that emerged from the discussions suggest that the project would be beneficial to many people including those living outside the project catchment area. However it also came out that there would be loss of assets and means of livelihood due to involuntary resettlement and for that matter provision of adequate compensation for loss of assets and alternative means of livelihood must be ensured. It was also noted that the communities lack some other basic social amenities, which must not be neglected whilst efforts are being made to provide the sanitation infrastructure. 4.5 GENERATION OF BASELINE DATA Arising from the consultations, literature reviews, site inspections and investigations EEMC gathered and updated a comprehensive baseline data on the UESP 11. The EEMC also developed checklists for the RCC, AMA, TMA and the GDA. These checklists enabled the EEMC to generate the relevant baseline data on the various components and sub-components of the UESP 11. The sample of the checklists is presented in the Appendix. 78  PART III: ENVIRONMENTAL & ANALYSIS AND ENVIRONMENTAL MANAGEMENT PLAN FOR THE PROJECT COMPONENTS AND SUB-COMPONENTS 5.0 STORM DRAINAGE The storm drainage project is part of the Urban Environmental Sanitation Project being carried in five main cities of Ghana. The Government of Ghana with the assistance of the World Bank is to improve the secondary and tertiary drains in Accra with a focus on the low-income areas. * Project components of the Storm Drainage The subcomponents are, for all five project towns: (a) Lining of secondary drains, (b) Tertiary drains, and (c) erosion control. * Project area The areas in Accra which are being considered for the lining of storm drains are Mataheko, Castle Road, Adabraka, Circle, Tesano, Chemu, Nima Tributaries, Osu Clottey Tributaries, South Kaneshie, Dansoman, Mampon, Labadi Central, Dzorwulu. Some of these locations are as shown in the map below (Map 1). * Description of the Existing Drainage System The existing drainage system is based on gravity flow with most of the drains being open (i.e. uncovered). Sections of the channels are lined. Along roads, secondary and tertiary drains have been provided to carry runoff and sullage water from abutting houses. Most of the drains in the project area are choked with garbage, especially in crowded and low-income areas. Some of the drains are constricted with weeds and bushes, and in some places the culverts, the secondary and tertiary drains have been damaged by erosion. Many of the secondary and tertiary drains have experienced the same fate with siltation and weed growth. Others have collapsed or been otherwise damaged under the weight of vehicular traffic. Stagnant and foul waters are found in the drains in some of these areas. Little or no maintenance is carried out to remove the garbage and silt in many areas. 79  Map 1. Location of Storm Drainage Sites ;- 1 -? / .z-=_ ' -/. \ Kwabenya -'4. j' /, Site _ 1?, ,. i Pokuase '"-, , ~" * **I~~~~~~~~~I - I~~~~~~~~~~~~~.et ;' -.- -- ',Uain;. a-~~< ,- - a- I. 7 . , , - - 1 - I~~~~~~~ o 5 1 KM E-xtractfrom Sheect0501B3 &0501B4 (Survey of Ghana) Contours in feet 80  5.1 APPLICABLE SAFEGUARD POLICIES The World Bank Safeguard Policies that are triggered are OP 4.01 and BP 4.01-Environmental Assessment, OP 4.01 Annexes A, B, and C on Environmental Assessment, OP 4.12 and BP 4.12- Involuntary Resettlement, and OP 4.12 and BP 4.12-Involuntary Resettlement Instruments. Forestry (OP 4.36, GP 4.36) No Pest Management (OP 4.09) No Cultural Property (OPN 11.03) No Indigenous Peoples (OD 4.20) No Safety of Dams (OP 4.37, BP 4.37) No Projects in International Waters (OP 7.50, BP 7.50, GP 7.50) No Projects in Disputed Areas (OP 7.60, BP 7.60, GP 7.60)* No All the communities proposed for the provision of storm drains are built-up communities where there are commercial and brisk socio-economic activities going on every day coupled with both human and heavy vehicular traffic. The likely outcome of the proposed realignment of the drains, which may involve dredging, widening, narrowing, excavation works, digging, movement of construction materials and equipments, etc. include the following: (a) An improvement of the flood regime of these areas, which has been regular problem every time there is a heavy down pour of rain; (b) There will be a temporary displacement of people who engage in commercial and economic activities on the shoulders of the roads and spaces where the drains would traverse. Migratory routes of human beings and vehicular traffic within these areas may also be hindered. (c) Provision of utility services such as water pipelines, underground electricity cables and telephone lines could be interrupted. (d) There is a risk that the lining of more secondary drains may cause flooding downstream. Some moving or destruction of compound walls, rooms, toilets, or other structures that have encroached on the drains may be necessary, but will be minimized. Table 5.1: Status of Safeguard Work Implement- Status of Safeguard Work Sub-component Location ation EA RPF RAP Analysis/ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ S c o p in g Storm drainage All 5 Towns Construction Done Done To be done N/A _ _ _ _ _ _ _ _ _ _ _ _ _ I I__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ la te r _ _ _ _ _ Note: The preparation of the Resettlement Action Plan (RAP) will be guided by the Resettlement Policy Framework (RPF). N/A: Not Applicable 81  5.2 THE IDENTIFICATION OF POTENTIALLY ADVERSE ENVIRONMENTAL AND SOCIAL IMPACTS The construction of the storm drainage will have both positive and negative impacts on the environment. The negative impacts will emanate from constructional and operational phase of the project. 5.2.1 The Environmental Impacts 5.2.1.1 Construction phase impacts (i) Flora and Fauna Preparation of the secondary drains and its lining would result in the clearing of the vegetation and shrubs which have inhabited the drains. There are no endangered species of flora and fauna along these drains and for that matter the clearance of the vegetation will not have any significant impact. (ii) Soil and Land Degradation Earth-moving equipment such as excavators will be used in digging and excavating. This earth moving equipment or machinery at the site during construction will not only expose the soils, but will also compact the soil and break down the soil structure though this would potentially decrease the drainage of the area. (iii) Visual Intrusion The project will change the natural landscape setting or characters of the area. The clearing of vegetation, construction of drains will impact on the visual amenity of nearby houses and communities or township around the area. (iv) Vehicular Traffic Implication The constructional works at the site will result in increase in traffic volume on the roads in the area. The transport of raw materials will introduce a number of heavy trucks on the main road and this could increase the risk of motor accidents and also result in vehicular-pedestrian conflicts. These impacts are localized and regarded as short term. (v) Noise Levels and Ground Vibration Minimal and intermittent noise would be generated during the construction phase of the project. The background noise levels and ground vibrations at the site will increase as a result of the movement of a number of tipper trucks delivering materials, heavy earthmoving equipment and the use of machinery such as concrete mixers and block molders. The anticipated noise levels and ground vibrations will however, not have devastating effects on the work force and immediate environment. (vi) Construction Wastes Activities at the site will produce constructional wastes such as excavated soils and debris. These collections of constructional wastes could obstruct the movement of the workers, the 82  general public and trucks as well as affect the beauty of the environment. This waste will therefore have to be managed at various times during the construction period. (vii) Slope, Erosion and Drainage If the topography of the project area is hilly, erosion problems during construction are likely to be more severe, as compared to a flat area. However, if the area is flat, water will not drain away easily, and there will be the tendency for pools of water to be created. These pools, if not drained regularly, will provide favourable grounds for the mosquito breeding. (iii) Spoil Disposal Spoil will contain household refuse and human excreta as well as pieces of concrete, stones and soil which will have to be removed during construction. The removal of the household refuse and human excreta will pose a health risk to the workers hired to remove them. The transport of this material to final disposal can also expose others to health risks in the event of spills. Soil disposal will also lead to increased construction of traffic between the excavation and disposal sites. (ix) Occupational Health and Safety Safety of the local population may be at risk during constructional phase. The movement of trucks to and from the site, the operation of the various equipment and machinery and the actual construction will expose the workers to work-related accident and injuries. Pollutants such as dust and noise in the workplace environment could also have negative implications for the health of the workers. (x) Probable flooding downstream There is a risk that the lining of more secondary drains may cause flooding downstream. 5.2.2 Social Impacts of the secondary drainage (i) Disruption of Utility Services The excavation for the storm drainage will cause the temporary disruption of utility services such as electricity and water. Such disruptions will be a nuisance to the affected communities in the area. (ii) Displacement of People The construction of secondary drains may require the demolition of rooms of dwellings, compound walls, kiosks, toilets, wash areas, foot bridges, etc. This could be caused by the realignment and widening of drains in some sections and by the need for access during construction. Some of these structures will be rebuilt in the same location or nearby. Compensation for loss of assets or livelihood may be required. It is unlikely that any involuntary relocation of families will be involved. Resettlement will have a negative impact primarily on those of low socio-economic status, who tend to be the ones living in low-lying areas and near drains.. They do not have the resources to deal with the loss of property and loss of income. 83  (iii) Education Children and youth attending school will experience the difficulty of reaching their school daily as a result of obstruction of their normal routes to their schools. (iv) Livelihood Adults will face disruption in their work especially those that sell items by the road side. Among the kinds of disruptions likely to occur are: * Separation from their kiosk, and need to travel longer distances to reach work, and potential unavailability of transportation; * If a business is moved, separation from established clientele and well known customers; * Separation from usual sources of goods and materials to sell or carry on income generating work. (v) Moving or destruction of compound walls, partial demolition of rooms, toilets or other structures There may be or will be moving or destruction of compound walls, partial demolition of rooms, toilets or other structures that have encroached on the drains but this will be minimized as possible. Sometimes there are demolitions of parts of the houses, which do not cause a particular household to move resulting in the loss of part of a house. This may lead to congestion and possible voluntary termination of the occupation of the rooms by the tenants. These negative impacts of partial demolition will deprive landlords of important rent income. Secondly, shops, barber shops, carpentry shops etc are likely to be affected by the construction of these drains. (vi) Contractors' Camps The contract for the drainage improvement will be awarded to contractors who will have to establish and operate his camp which will house offices, workshops, etc. It should be the responsibility of the contractors to select the camps with the approval of the Project Engineer. The problems that will be encountered may include temporary resettlement of some residents, erosion, and disposal of liquid and solid wastes, etc. The impacts will be minimal as the camps will be small and the work force will live outside of the camp. Other social impacts associated with contractor's camps are theft, alcoholism, and sexually transmitted diseases (especially HIV/AIDS). HIV/AIDS will be addressed as part of the Institutional Capacity Building component. On completion of the project, the camps will be dismantled and the areas fully reclaimed. However, where possible, camps and/or some of their facilities may be handed over to the original land owners or local or national organizations for their use. Hence any short-term inconveniences could be traded off against long-term benefits. 84  (vii) Traffic All the communities selected for the provision of storm drains are built-up communities where there are commercial and brisk socio-economic activities going on daily coupled with both human and heavy vehicular traffic. Construction related activities will create nuisance to the users of the road e.g. storage of construction stones and chips close to the road. The impacts from construction traffic are regarded as short-term. 5.3 ALTERNATIVES AND THEIR POTENTIAL ENVIRONMENTAL IMPACT There are two types of drains which can be constructed in these low-income areas. They are (a) underground storm drainage, and (b) uncontrolled open storm drainage. The potential negative environmental impacts of the underground drainage are limited as compared to the open drains, but the usually have a greater negative impact during construction. The limitations are that the underground ones may have debris choking them more quickly than the open ones. But adequate ventilation must be provided for the workers who maintain these underground drains. The open drains experience choking from wastes as a result of bad practices of people, whereby they dump rubbish in the drains to be carried away by the storm-water. Sometimes wind-blown litter contributes to the choking of open drains. In terms of infrastructure cost it is more expensive to construct the underground drains than the open ones. 5.4 MITIGATION MEASURES 5.4.1 Impacts on peoples' livelihood The drainage improvement project may impact on peoples' livelihood due to the realignment needed, which may involve dredging, widening or narrowing of drains, and the provision of maintenance access reserve along the secondary and tertiary drains as barbers. Temporary access during construction may require the temporary demolition or displacement of structures. Kiosk operators and vegetable growers may lose some land. Mitigation measures that should be taken in respect of the project should involve the following: Compensation for crops or damage to structures; and * Payment for temporary loss of land use/utility; The mitigation measures should be guided by the provisions of the Resettlement Policy Framework, which meets the requirements of the World Bank guidelines on involuntary resettlement. These include the preparation of a resettlement plan which addresses the following: * Institutional responsibility; * Community participation; * Replacement cost, in cash or kind, for lost of assets or income; * Assistance to tenants to find substitute accommodations; * Assistance to those whose livelihood are affected; and; * An implementation plan for resettlement. 85  5.4.2 Slope, Erosion and Drainage Slopes in the project area are gentle and are unlikely to give rise to major erosion hazard. Good construction practices should be followed to minimize localized erosion problems to avoid stagnant waters. Where stagnant water occurs it should be drained so as not to create mosquito breeding sites. 5.4.3 Spoil Disposal The household refuse and human excreta removed from the drains prior to construction should be disposed off separately from the other spoils. It should be carefully handled by the labour force wearing suitable protective clothing. Transportation of such materials should be made to proper disposal sites so as not to create unhygienic conditions and environmental hazards. The large quantity of clean soil which must be disposed of should be used to reclaim low-lying land or to properly rehabilitate old refuse dumps located throughout the city. Any land reclamation opportunity should be analyzed against resettlement requirements for the drainage improvement project. Designated wetlands should however not be used for the disposal of such materials. 5.4.4 Noise and Dust Pollution Construction of drains will generate some noise when heavy machinery is used. This will impact negatively on residents immediately adjacent to the work sites but will only be a temporary inconvenience. No special mitigation is proposed beyond ensuring that all heavy construction machinery is equipped with appropriate and functional noise suppressors (mufflers). Mitigation of dust includes spraying the affected sections with water where dust generation becomes excessive for local receptors. The temporary inconvenience of noise and dust are outweighed by the long term flood reduction benefits of the drainage improvements. 5.4.5 Contractors' Camps The following aspects of the operation of the Contractors' Camps should form part of the contract document. . Entering into agreements with, and payment of appropriate compensation to the rightful land owners; * Supply of potable water in sufficient quantity; * Efficient disposal of both solid and liquid wastes; . Provision of medical services for the labour workforce including HIV awareness campaigns; and * Rehabilitation or sites by reclamation to their previous use or as per agreements. 86  5.4.6 Construction Traffic Operators of vehicles and equipment must be qualified and experienced. They should undergo refresher courses and on-the-job training. They should observe strict maximum speed limits. The Project Contract Document should include a provision obliging the contractor to ensure responsible driving by his staff to enable the Project Engineer to take appropriate measures in case of any complaints. Vehicles should also be regularly maintained. 5.4.7 Maintenance of the drains No special mitigation measures are deemed necessary apart from regular maintenance involving removal of solid wastes, as well as desilting and repairing of both covered and uncovered drains. Refuse removed from the drains should be disposed off in a proper and timely manner and it should not be left adjacent to the drains or roadways. Encroachment on the mandatory access reserve must be prevented at all costs. Encroachments should be reported for immediate action to be taken. 5.5 INTEGRATION OF EMP WITH THE PROJECT The critical point of the storm drainage project is the implementation phase where the immediate environment could be degraded or improved upon. In order to be effective, environmental management must be integrated with the overall project management effort, which in itself should aim at providing a high level of quality control. Environmental Management is carried out during all stages of the project planning, design and implementation. 5.5.1 Objectives of Programme Environmental management deals with how mitigation measures proposed are implemented and assigned the responsibility and costs, if appropriate, in its implementation. The programme has the following objectives: * Protection of the environment from potentially harmful activities, and vice versa; * Enhancement of storm drains attributes, especially with regard to carrying of storm waters; and * Government institutional strengthening in conducting environmental protection and monitoring of storm drains. These objectives can be achieved through environmental management team of the AMA and GDA to be engaged in the following: 87  (a) Checking the progress of the Contractor in implementing the mitigation measures to be outlined in the EIA report of the project. (b) Liaising with an advisory group (e.g. EPA) regarding policies, procedures, and approaches for administering and monitoring environmental protection activities; (c) Coordinating parties involved in the impact mitigation and enhancement process, including: Contractors, Consultants, Governmental and Non-Governmental Officials at all levels, as well as the public; (d) Facilitating environmental monitoring and evaluation of the bio-physical and socio- economic concerns pertaining to the storm; (e) Conducting baseline studies. 5.5.2 Resources for Programme Implementation The resources required for implementing the environmental management programme are basically personnel and finance. The key stakeholders in the environmental management activities are the Project Engineer, the Contractor, AMA and GDA, Ministry of Local Government, EPA and to some extent, the Public. Resources for monitoring the compliance with the EAP will be provided for under the project. 5.5.2.1. Pre-Construction Phase Prior to Contractor mobilization and the commencement of construction, environmental management will cover the following: * Environmental review of the secondary and tertiary storm drainage, * Detailed EIA including Environmental Management and Monitoring Plan, * Preparation of detailed designs which gives due consideration to minimization of adverse impacts and benefit enhancement. 5.5.2.2 Construction Phase Environmental management during the construction phase is essentially concerned with controlling impacts, which could result from the activities of the Contractor. This can be done through the enforcement of Contract Clauses which relate to environmental protection. These clauses will not themselves, however, have any effect unless they are fully implemented and enforced. Mobilization: * Ensure that all staff, including managers and foremen are well informed about all environmental issues of the project. * Train all site managers and foremen in environmentally friendly construction methods. * Establish and maintain environmentally friendly construction camps well provided with sanitary facilities. * Establish a spoil and waste management plan comprising all types of wastes. 88  Construction: Apply environmentally friendly equipment and construction methods. * Ensure occupational health and safety for all workers and visitors to the sites. . Inform the Supervisory Engineer if the occurrence of any unforeseen negative environmental impact should occur. Demobilization: * Ensure that all affected project areas have been properly cleaned of waste. 5.5.2.3 Operation and Maintenance Phase Some of the impacts, which are expected to occur during the operational phase, are essentially related to * Occupational hazards and accidents * De-silting and removal of solid wastes * Repairs to damaged drains * Education of public on wastes dumping into drains 5.5.2.4 Specific Responsibilities of Some Concerned Agencies a. Environmental Protection Agency - Will have the ultimate responsibility of ensuring that recommendations made are fully implemented. b. Ministry of Local Government -To ensure that the Contractor implements the recommendations of the Environmental Expert. c. Accra Metropolitan Assemblies and Ga District Assembly - To ensure that drains are regularly desilted and freed from solid waste to allow free flow of water. 5.6 MONITORING The aim of the monitoring is to establish appropriate monitoring criteria, to verify the predicted impact of the project, and to ensure that any unforeseen impacts are detected and the mitigation adjusted where needed at an early stage. The monitoring will keep relevant records to ensure compliance with sound environmental procedures recommended. The monitoring plan will ensure that mitigating measures and impacts of the project during construction and operational phases are implemented. Adequate funds will e provided for this purpose through the project. The coordinator will oversee and report on all monitoring activities. 5.6.1 The Construction Phase The aim will be to assess the mitigation measures for noise, vibration, water quality, dust, air quality and public safety using visual assessment by the management and feedback from the other stakeholder. 89  The nature and extent of pollution observed will be determined by laboratory analyses of samples taken from site. Appropriate measures should then be taken to rectify the problem. To monitor the filling or drainage of pools and puddles when necessary, the clogging of drains, removal and subsequent destruction of old car tyres. Monitoring should be carried out regularly as required, until baseline conditions are attained. Transportation: Equipment, motor vehicles and transport of materials and personnel shall be closely monitored to include the following activities: * Speed limits of vehicles * Motor vehicles condition and maintenance * Vehicle safety signals * Loading and off-loading procedures * Vehicle license and permit to drive, and