MINISTRY OF SANITATION AND WATER RESOURCES GREATER ACCRA RESILIENT AND INTEGRATED DEVELOPMENT PROJECT Final Environmental Impact Statement Rehabilitation, Closure and Aftercare Management of the Abloragyei Dumpsite Ga East Municipality Greater Accra Metropolitan Area December 2018 Prepared By: Yaw Amoyaw-Osei CEHRT Consult, Sakumono, Tema. Tel: 0243223864 [Wayoma59@hotmail.com] Abloragyei Dumpsite Capping Project Final ESIA List of Acronyms AIDS Acquired Immunodeficiency Syndrome IDA International Development Association ASIP Accra Sewage Improvement Project ILO International Labour Organisation AER Annual Environmental Report LI Legislative Instrument AGE Average Ground Elevation MinT Materials in Transit AMA Accra Metropolitan Assembly MMDAs Metropolitan, Municipal and District Assemblies ARI Acute Respiratory Infections MSWR Ministry of Sanitation and Water Resources BOD Biochemical Oxygen Demand NCCP National Climate Change Policy COD Chemical Oxygen Demand NEAP National Environment Action Plan CP Construction Phase NESSAP National Environmental Sanitation Strategy and Action Plan DESSAP District Environmental Sanitation Strategy and OP Operational Policies Action Plan EA Environmental Assessment OPD Out Patient Department EAP Environmental Assessment Policy PPE Personal Protective Equipment EHSD Environment Health and Sanitation Directorate PIU Project Implementation Unit EP Environmental Permit P&T Ghana Post and Telecommunication EPA Environmental Protection Agency RAP Resettlement Action Plan ESIA Environmental and Social Impact Assessment SDGs Sustainable Development Goals ESHD Environmental and Sanitation Department SESIP Strategic Environmental Sanitation Investment Plan ESMP Environmental and Social Management Plan STIs Sexually Transmitted Infections ESS Environmental and Social Standards TCPD Town and Country Planning Department E&S Environmental and Social TESL Tema Engineered Sanitary Landfill GAMA Greater Accra Metropolitan Area ToR Terms of Reference GARID Greater Accra Resilient and Integrated UNEP United Nations Environmental Programme Development GEMA Ga East Municipal Assembly WBV Whole Body Vibration GHS Ghana Health Service WHO World Health Organization GoG Government of Ghana WMC Waste Management Company HIV Human Immunodeficiency Virus WMD Waste Management Department Chemical Symbols - Heavy Metals Element Chemical Symbol Element Chemical Symbol Element Chemical Symbol Antimony Sb Cobalt Co Selenium Se Arsenic As Copper Cu Titanium Ti Barium Ba Lead Pb Tin Sn Beryllium Be Mercury Hg Vanadium V Cadmium Cd Molybdenum Mo Zinc Zn Chromium Cr Nickel Ni Ministry of Sanitation & Water Resources i December 2018 Abloragyei Dumpsite Capping Project Final ESIA Executive Summary Background The Government of Ghana (GoG) has applied to the World Bank for assistance in financing the Greater Accra Resilient and Integrated Development (GARID) project. The project aims at supporting critical investments to deal with Climate Change impacts in the Odaw Catchment in the Greater Accra Region. The key interventions focus on challenges with drainage and solid waste issues within the Odaw Catchment. The GARID project is supporting the Ministry of Sanitation and Water Resources (MSWR) to cover the Abloragyei Dumpsite, to prevent further leachate and waste pollution of the Dakobi Stream that discharges into the Odaw, among other projects. Ownership and Current Status The Abloragyei dumpsite and surrounding area, measuring about 50 acres of land was originally acquired by GoG for the operations of the erstwhile Ghana Post and Telecommunications (P&T) Corporation, from the Ablor family in the 1960s. The land was however, turned into an illegal sand winning area, consisting of numerous sand pits. Following closure of the Ogbojo Dumpsite, and the urgent need for a new dumpsite, the then Ga District Assembly converted the area into a dumpsite. The effective area of the dumpsite is now about 20.52 acres, consisting of two separate dumps; and delimited by development of houses and other structures, due to the takeover of the land surrounding the dumpsite by the Ablor family. The footprint of the old dumpsite of almost 12 Acres (Dump 1), is owned by the Ga East Municipal Assembly (GEMA); while Dump 2 of about 8.52-Acre land was acquired in 2006 by Amanee Waste and General Services Limited and Honest Waste Limited for waste disposal, from the Ablor family. Dumping of waste at the Abloragyei dumpsite was officially closed in January 2018. There is currently security presence (arranged by the waste companies) to enforce the closure. Following the closure, waste from the municipality is now disposed of at the Tema Engineered Sanitary Landfill (TESL), Kpone and the Accra Compost and Recycling Plant (ACARP), Adjen Kotoku, which was arranged by GEMA. Purpose of ESIA The purpose of the ESIA is to assess the environmental and social risks and impacts of decommissioning, capping and aftercare management of the dumpsite and to propose and implement measures to avoid, minimize and mitigate the identified risks and impacts. This would lead to potential project benefits such as eliminating: • Continuous abuse of the area and discharge of polluted leachate into the Dakobi and the Odaw; • Hazardous and health threatening exposure of people living close to the dumpsite; and • Routine sedimentation of the Dakobi and Odaw by waste and sediment-laden run-off contributing to seasonal flood events in sections of the Odaw catchment. The key methodologies for the ESIA processes involved stakeholder engagements, extensive pollution surveys and analysis through the Environmental and Social (E&S) Audit of the dumpsite, lessons from previously capped dumps, as well as document review. Ministry of Sanitation & Water Resources ii December 2018 Abloragyei Dumpsite Capping Project Final ESIA Policy and Regulatory Framework Leachate and gas (mainly methane) generation and release from the capped dumps could continue for several years, due to the continuous anaerobic digestion within the dumps. This therefore will require aftercare management of the dumpsite (post-cap), which must be subject to an appropriate assessment with relevant safeguards for sustainable implementation. In line with the Environmental Assessment Regulations, 1999 (LI 1652), the proposed rehabilitation, closure and aftercare management of the dumps is scheduled as Environmental Impact Assessment (EIA) mandatory undertaking; while also classified a Category A project under the World Bank Safeguards Policies, and therefore requires an ESIA study. Accordingly, a Scoping Report for the project was duly submitted to EPA for review and acceptance of the terms of reference (ToR) for the ESIA. The other regulatory and policy requirements applied in the ESIA process included: • Water and sanitation sector policy and requirements - o National Environmental Sanitation Policy, 2010; o National Water Policy 2007; o National Environmental Sanitation Strategy and Action Plan; o District Environmental Sanitation Strategy and Action Plan; • Planning and development requirements - o The Local Governance Act, 1993 (Act 462); o Hazardous and Electronic Waste Control and Management Act, 2016 (Act 917); o Hazardous, Electronic and Other Wastes (Classification) Control and Management Regulations, 2016 (LI 2250) o Ghana Building Codes (2012); o Ghana Landfill Guidelines, 2002; o Land use and Spatial Planning Act, 2016 (Act 125) • Labour, safety and health requirements - o Occupational Safety and Health Policy of Ghana (Draft); o National Workplace HIV/AIDS Policy; o Labour Act, 2003 (Act 651); o Public Health Act, 2012 (Act 851); • Climate Action requirements - o United Nations Framework Conservation on Climate Change; and o National Climate Change Policy. • World Bank Group Guidelines - o General Environmental Health and Safety Guidelines; and o Industry Sector Guidelines for Waste Management Facilities. Project Description The scope of work will comprise activities relating to the rehabilitation and capping of the Abloragyei dumps, which was formally closed in January 2018. Other activities include installation of leachate collecting drains and sumps, gas venting pipes and aftercare processes and management. The project phases will include: • Pre-capping phase of about 8 months duration; • Capping phase of almost 10 months; • Post-cap phase of up to 3 years; and • Aftercare management of recreational development and use of the capped dump. Some key project activities, particularly at the pre-cap and capping phases will include: Ministry of Sanitation & Water Resources iii December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Fencing of the closed dumpsite with linked or barbed wire to secure the boundaries of the sites; • Construction of security post and site office fitted with wash rooms and sample storage room; • Erection of temporary construction camp; • Site storm water diversion and runoff control drain network; • Levelling and contouring of the dump and compaction; • Spreading of capping material, compacting and shaping the dump; • Layout of leachate collector channels and lined sumps; • Access lane for cesspit emptier to evacuate leachate from sumps to TESL/Kpone landfill; and • Layout of gas collection pipe vents The post-cap phase activities will involve monitoring to determine the effectiveness of the leachate and gas emission structures, and the capping to resist erosion, as well as leachate flow and gas emission, in order to take required remedial action. The Aftercare Management phase will commence at the end of the post-cap phase. This phase will involve management activities related to the conversion of the capped, stable dump into beneficial uses. Analysis of Alternatives The project alternatives analyzed are listed below, followed by summary of the preferred alternatives: 1. ‘No project’ alternative; 2. Alternative types of capping material; 3. Alternative sourcing of laterite for capping; 4. Alternative pre-cap dump heights; 5. Alternative thickness of core capping material; 6. Alternative post-cap dumpsite use scenarios; 7. Alternative handling of methane gas produced; and 8. On-site and off-site leachate treatment alternatives. ‘No Project’ Alternative The object of the project to prevent leachate and waste pollution affecting the Odaw channel through the Dakobi Stream would not be realized if the ‘no project’ alternative is adopted. The Abloragyei dumps present other serious health and environmental problems with attendant social and economic costs for the surrounding communities. The risk factors causing communicable diseases (e.g. malaria, diarrhea diseases, acute respiratory infections, hepatitis, etc.), would continue to show an upward trend if there is ‘no project’ implementation. Also, risk factors like hazardous chemicals in the leachate are likely to increase risk of non-communicable diseases like malignancies. Types of Capping Materials The preferred capping material is laterite, which is relatively stable (not swell and shrink or crack). It will also be easy to work with, spread relatively evenly on the dump for levelling and compacting to attain consistent thickness. Sourcing of Laterite for Capping Laterite from both the natural environment and excavated spoil (from construction sites) sources will be relied on. Ministry of Sanitation & Water Resources iv December 2018 Abloragyei Dumpsite Capping Project Final ESIA Pre-cap Dump Heights The area covered by Dump 1 is 12ac, while Dump 2 covers 8.52ac. The average ground elevation (AGE) of Dumps 1 and 2 are 70.00m and 65.00m above MSL respectively. The preferred pre-cap height for: • Dump 1 is 6m (above AGE), corresponding to 76.50m above MSL; and • Dump 2 is 2.68m high (above AGE), corresponding to 67.68m above MSL. Thickness of Core Capping Material The key factors that informed a preference for a 30-inch core cap included: need to withstand erosion over long-term, resist attack by roots, prevent ease of intrusion into the wastes and emission of build- up gas, as well as being consistent with international good practice. Given the eagerness of stakeholders to convert the capped dump into some immediate beneficial use, a 30-inch core cap would support such future developments without readily penetrating the waste. Alternative Post-cap Dumpsite Use Scenarios The preferred development scenarios for Dump 1 include: Astro Turf development for football fields and other games, Event Centre and Amusement/Public Park; while the Dump 2 preferred option include: Event Centre and Amusement/Public Park, as against community market and lorry station. Alternative Handling of Methane Gas Produced The preferred option would be to flare the limited gas releases. On-site and off-site leachate treatment alternatives A major limitation to on-site leachate treatment would be odour nuisance to nearby residents, possible reduction in the future recreational amenity value of the area, and a capped dumpsite with leachate management system as a permanent feature. The off-site option on the other hand, would render leachate generation and management at Abloragyei only as a temporary arrangement. The preferred option therefore would be to evacuate the leachate from the sumps and transfer by cesspit emptier for management at the Kpone landfill. Environmental and Social Baseline Conditions The Ga East Municipality lies in the savannah ecological zone and has a bi-modal rainfall pattern. The mean annual rainfall ranges from 790mm to1288.1mm. Annual average temperature ranges from 25.1oC in August and 28.4oC in February and March. The main vegetation is shrub and grassland. There are several basic dumpsites for solid waste disposal in the GAMA area that in particular produce leachate, which pollutes the Odaw channel. The Dakobi Stream receives leachate from the dumps and flows into the Odaw. Engineered landfills are rather rare in the GAMA area and in Ghana as a whole. The Tema Engineered Sanitary Landfill is for instance, one of its own in the GAMA area, which has special leachate ponds for managing the Kpone landfill leachate. Waste composition of the dumps consists of about 45% organic and 35% plastics, glass, rubber, etc. as compared to 60% organic and 8% plastics, etc. of the known waste composition for GAMA. High concentrations of As, Co and Pb were found at various locations on the dumps. Also results for leachate analysis showed high concentration of Pb, Phosphate and Ammonia above EPA effluent guidelines. The average daily rate of leachate generation at the dumpsite is estimated at 0.1m3. Ministry of Sanitation & Water Resources v December 2018 Abloragyei Dumpsite Capping Project Final ESIA The highest and lowest points on the dumps are approximately 93.52m and 63.68m above mean sea level (MSL), with a height differential of 29.84m. The estimated volume of waste in the dumps is 361,345.20m3, comprising 268,838m3 for Dump 1 (12ac) and 92,507m3 for Dump 2 (8.52ac). The average height of the dumps prior to capping is estimated at 76.50m and 67.68m above MSL respectively for Dumps 1 and 2. The number of project affected persons (PAPs) is 36. The PAPs are grouped into four according to the nature of property affected and whether the impact is permanent or temporary are as follow: • Property affected (permanent) - o Structure (house) on the dump (3 PAPs); o Toilet (2-seator) (1 PAP (owner)) o Parcel of land (3 Acres) adjoining Dump 2 (1 PAP); o Kraal (0.25 Acres) holding 45 cattle (8 PAPs); • Property in the hazard zone (temporarily affected) - o 2 Houses occupied in the hazard zone (8 PAPs); o 2 House unoccupied in the hazard zone (2 PAPs); o 2 structures at foundation stage (2 PAPs) • Businesses temporarily affected - o Drinking spot (3 PAPs); o Food vendor (2 PAPs); o Bakery (3 PAPs); o Provision shop (2 PAPs); • Land temporarily acquired - o Land acquired (1 Acre) for storage of capping material (1 PAP). Stakeholder Involvement The Environmental Assessment Regulations, 1999 (LI 1652) underscore the need for stakeholder consultations, as well as the World Bank Group’s Environmental Assessment Policy (OP 4.01), which addresses the requirements for stakeholder consultation as part of the EA process, in the Ban k’s Environmental and Social Standard 10. The stakeholders engaged included: • Ga East Municipal Assembly; • Environmental Protection Agency; • Tema Engineered Sanitary Landfill, Kpone; • Accra Sewage Improvement Project; • Abloragyei Chief; • Abloragyei Residents’ Association; • Waste Landfill Company Limited; • Amanee Waste and General Service Limited; • Honest Waste Limited; • Tema Metropolitan Assembly, Waste Management Department (TMA, WMD); • Pantang Psychiatric Hospital; and • Abokobi Health Centre. Engagement sessions were held with the PAPs, beside the general consultations with the residents and the disclosure meeting. There were no informal sector operators such as scavengers/waste pickers (with the dumps closed six clear months prior to the ESIA exercise), and also no squatters and scrap dealers operating on the dumps. The main engagement issues and outcomes included: Ministry of Sanitation & Water Resources vi December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Ideal materials for capping – loamy soil and laterite; • Post-cap fallow period before converting to beneficial uses – immediate and 3 to 10 years; • Possible sinking or collapse of structures on capped dump if built on it immediately after capping and examples of collapsed structures on capped dump; • Conditions under which explosion could occur if methane gas is allowed to build-up; • Phases of developing the capped dump – after 3 years fallow period, develop light temporary structures, and then more permanent structures erected after 8 years; • Security presence and fencing as essential to ward off potential dumpers; • Flooding is a major issue at the dumpsite (leachate runoff); • Preliminary Environmental Assessment (PEA) will be required for capping material sourcing, however, if in large quantities or depending on sensitivity of the location an EIA may be required; • Capping material should be stock piling, prior to commencement of capping; • Traffic congestion could occur as a result of haulage activities; and • Workers are at risk of falling from working height on Dump 1. Potential Impact, Mitigation and Monitoring Measures The project impacts are grouped into beneficial and adverse impacts. The potential benefits include: • Elimination of leachate pollution; and • Elimination of health threatening heavy metal exposure sources and risk factors The adverse impacts, which are divided into three include: Construction (pre-cap and capping) Phase Impacts - • Potential land acquisition, socio-economic and livelihoods impacts; • Risk to successful capping; • Public and occupational health and safety risks; • Potential human rights abuse and gender disparity; • Potential air quality impacts; Post-Cap and Aftercare Management Phase Impacts - • Risk of leachate contamination; • Risk to successful aftercare management; • Risk of explosion from gas build-up in the capped dump; and • Potential collapse of constructed structures on the capped dump; Capping Material Sourcing and Haulage – Preliminary Assessment • Potential degradation from sourcing of laterite; and • Potential haulage and traffic impacts. The tables below provide the mitigation and monitoring measures to the assessed impacts. Table 1 Construction Phase Impacts, Mitigation and Monitoring Measures Sources of Impacts Mitigation Monitoring Measures 1.0 Potential Socio-economic and Livelihoods Impacts 1. Land acquisition – The Abbreviated Resettlement Action The ARAP will provide relevant • Parcel of land (3 Acres undeveloped, Plan (ARAP) will fully address the monitoring and evaluation, etc. but walled) adjoining Dump 2 identified socio-economic and measures • Kraal (0.25 Acres) holding 45 cattle; livelihoods (property, short-term land acquisition and inconvenience) 2. Property affected (permanent) - impacts, by providing appropriate Ministry of Sanitation & Water Resources vii December 2018 Abloragyei Dumpsite Capping Project Final ESIA • A housing structure on the dump livelihoods restoration and assistance • A 2-seater toilet on the dump measures. 3. Property in the hazard zone (for temporal relocation) - • 2 houses occupied by 8 PAPs • 2 house newly constructed, but unoccupied • 2 structures at foundation stages 4. Businesses that may temporarily closed down - • Drinking spot (3 PAPs) • Food vendor (2 PAPs) • Bakery (3 PAPs) • Provision shop (2 PAPs) 5. An acre land (walled) to be temporarily acquired for storage of capping materials 2.0 Risk to Successful Capping • Delay in project financing or failure to • Supervised timely and scheduled • Schedule disbursement and work disburse to schedule disbursement delivery • Delay in obtaining and stockpiling • Facilitate timely environmental permit • Record equipment and machinery capping materials when needed acquisition (Preliminary servicing and breakdown rate • Equipment and machinery breakdown Environmental Assessment process) to • Record quantity of resources in and delayed replacement - leading to mine the capping materials. storage and used idleness of the project site and likely • Excavated spoil sources (e.g. on-going • Impromptu checks on security resumption of dumping. construction sites) identified personnel at post • Early stockpile of capping material needs at pre-cap phase • Fencing of dumpsite • Security presence • Equipment and machinery deployed less than 5 years 3.0 Public and Occupational Health and Safety Risks • Accidents related to slips, trips and • Provision and use of personal • Impromptu checks on the usage of falls and piercing of workers protective equipment (PPE) PPE • Odour and VOCs, recurring mosquito • Spraying of dumpsite on regular basis • Impromptu checks on vehicle bites, houseflies and other vermin • Adherence to 20km/hr speed limit on movement • Machinery and vehicle accidents, site and reverse alarm • Records of maintenance noise, etc. • Adherence to scheduled maintenance • Mosquitoes and flies monitoring and effectiveness of spraying 4.0 Potential Human Rights Abuse and Gender Disparity • Discrimination based on ethnicity, • Issuance of employment contract to all • Records of all employee contracts gender, religion, age, disability and workers • Records on reported human rights HIV status • Include workers’ code of conduct in abuse cases filed, etc. • Sexual abuse and harassment their employment contract • Records of workers in unions • Prohibition of unionization • Filing of all cases of human rights • HIV awareness creation workshops abuses and records of attendance • Complaints desk • Provision of condoms 5.0 Potential Air Quality Impacts • Dust from • PPE provision and usage • Impromptu checks on the usage of o Tipping and stockpiling of capping • Covering of capping materials PPE materials stockpiled • Impromptu checks on adherence of o Re-loading and spreading • Adherence to 20km/h speed limit speed limits Ministry of Sanitation & Water Resources viii December 2018 Abloragyei Dumpsite Capping Project Final ESIA o Pushing, filling and levelling • Adherence to scheduled maintenance • Emission from construction machinery of machinery and equipment Ministry of Sanitation & Water Resources ix December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 2 Post-Cap Phase Impacts, Mitigation and Monitoring Measures Sources of Impacts Mitigation Monitoring Measures 1.0 Risk of Leachate Contamination • Leachate generation from rainfall • Construction of leachate/runoff drains • Inspection of leachate pipes and infiltration of capped dump and sumps sumps and function • Depressions holding rain water during • Covering of levelled dumped with • Inspection of the 10-inch layers of cutting, pushing and levelling polythene sheets during rainfall covering/levelling and compaction • Overflow of leachate in sumps • Compaction during capping in 3 layers • Inspection of evidence of erosion • Diversion of leachate in transit • Grassing of slopes of capped dump on capped dumps • Accidental release or leakage of • Logging of leachate evacuated and • Inspection of log books leachate in transit discharged • Adherence to prescribed speed limits 2.0 Risk to Successful Aftercare Management • Lack of resources for post-cap • Extend project funding to post-cap • Records of revenue generation monitoring - phase (3 years) from operators o Leachate overflow and pollution • Raise revenue from operators • Release of funds for monitoring due to non-evacuation managing the developments and and management activities. o Failure of other monitoring facilities approved on capped dump activities • Lack of resources for Aftercare Management activities 3.0 Risk of Explosion from Gas Build-up • Accumulation of methane gas within • Installation of 21 gas wells with • Monitor gas volumes to determine capped dump collection pipes, spread averagely 1 quantity of gas generated • Poor installation of gas pipe per acre on surfaces of dumps • Monitor the integrity of gas vents arrangement • Installation of the pipe about a metre and flaring from the base of dumps to avoid leachate uptake 4.0 Potential Collapse of Constructed Structures on the Capped Dump • High demand to put capped dump to • Institute a 3-year fallow period with no • Monitor the fallow period to ensure beneficial end-use development allowed on the capped no developments takes place • Wrong choice of infrastructure dumps • Monitor type developments developed on the capped area • Erect perimeter fence undertaken, activities and use of • Wrong timing of development • Regulate the type developments the capped dump allowed during the Aftercare period Table 3 Capping Material Sourcing and Haulage – Preliminary Assessment Sources of Impacts Mitigation Monitoring Measures 1.0 Potential Degradation from Sourcing of Capping Materials • Sourcing capping materials from: • Avoidance of the no-go areas • Inspection of records on capping o Arable lands • Sourcing from approved areas covered material sources o Banks of water bodies by permit • Inspection of environmental permit o Fragile ecosystem (sensitive areas) • Reclamation measures to restore land and compliance with permit • Unapproved sources of capping • Sourcing from (construction sites) conditions materials excavated spoil sources • Reclamation process and • Extraction of laterite from potential restoration of land candidate site (Amrahia) creating pits • Quantity of excavated material sourced 2.0 Potential Haulage and Traffic Impacts • Haulage at peak periods • Haulage during off peak periods • Inspection of log book of trucks • Reckless driving • Provision of a contact number on • Review records of haulage truck • Potential conflict at major intersections trucks for reporting reckless driving accidents and complaints received • Breakdown of haulage trucks in transit • Installation of tracking systems on • Monitor functionality of trackers Ministry of Sanitation & Water Resources x December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Use of old or poorly maintained trucks trucks • Inspect maintenance records • Dust emission • Scheduled maintenance of trucks • Impromptu inspection of trucks for • Trucks deployed less than 5 years old the use of tarpaulin • Covering of trucks in transit with tarpaulins Environmental and Social Management Plan The ESMP includes individual plans and the respective objectives to address the evaluated risks and potential adverse impacts associated with the capping and post-cap and aftercare management of the dumps. The specific environmental, social and related safeguards plans and the responsibilities are as follows: 1. Abbreviated Resettlement Action Plan (PIU - MSWR); 2. Capping and aftercare management plan (Contractor / PIU - MSWR); 3. Public and occupational health and safety plan (Contractor); 4. Gender equality and human rights protection plan (Contractor); 5. Air quality control plan (Contractor); 6. Leachate containment and management plan (Environmental Health - GEMA/PIU - MSWR); 7. Gas emission control plan (Contractor / Works Department of GEMA); 8. Post-cap land development plan (Physical Planning & Works Depts of GEMA); 9. Capping materials sourcing plan (Contractor); and 10. Haulage and traffic safety plan (Contractor). The parties and institutions to perform roles in executing the ESMP and activities during project implementation are: • Project contractor(s) (Environmental and Social Specialist and Health and Safety Officer); • Works Department (WD) of GEMA; • Environmental Health Unit; • Development Planning Department (DPD) of GEMA; • Physical Planning Department (PPD) of GEMA; • Project Implementation Unit (PIU) at MSWR; • Environmental Health and Sanitation Directorate; and • Environmental Protection Agency (EPA). The relevant personnel identified for the E&S capacity building are representatives from the following departments of the Assembly: • Development Planning; • Works Department; • Environmental Health Unit; • Procurement; • Department of Urban Roads; • Social Welfare and Community Development; and • PIU Budget for ESMP Implementation The estimated budget for implementation of the ESMP (including the 3-year post-cap phase), amounts to USD33,800. This covers budget for the 9 specific plans in the ESMP as summarized in Table 4. Ministry of Sanitation & Water Resources xi December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 4 Budget Summary Plan Estimated Amount ($) 1 Capping and aftercare management plan 3,500 2 Public and occupational health and safety plan 3,000 3 Leachate containment and management plan 8,000 4 Air quality control plan 2,000 5 Gender and human rights protection plan 1,500 6 Gas emission control plan 4,800 7 Post-cap land development plan 3,000 8 Capping material sourcing plan 5,000 9 Haulage and traffic safety plan 3,000 Total 33,800 Ministry of Sanitation & Water Resources xii December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table of Contents 1.0 INTRODUCTION..................................................................................................................... 2 1.1 Background ............................................................................................................................. 2 1.2 Project Justification ................................................................................................................. 2 1.3 Project and Components ......................................................................................................... 3 1.4 Purpose of the ESIA ................................................................................................................ 3 1.5 Methodology for the ESIA ...................................................................................................... 4 1.6 Deliverables ............................................................................................................................ 5 1.7 Report Organisation ................................................................................................................ 5 2.0 POLICY AND REGULATORY FRAMEWORK ................................................................. 7 2.1 National Environmental Policy and related Requirements ..................................................... 7 2.2 World Bank Requirements ...................................................................................................... 8 2.2.1 Environmental Assessment Policy OP4.01 ..................................................................... 8 2.2.2 Involuntary Resettlement Policy OP4.12 ........................................................................ 8 2.2.3 Natural Habitats OP. 4.04 .............................................................................................. 9 2.2.4 Physical and Cultural Resources OP 4.11 ...................................................................... 9 2.2.5 Gender and Development OP/BP 4.20 ........................................................................... 9 2.2.6 World Bank Group General Environmental Health and Safety Guidelines ................... 9 2.2.7 World Bank Group Industry Sector Guidelines for Waste Management Facilities ...... 10 2.3 Water and Sanitation Sector Policy and Requirements......................................................... 10 2.3.1 National Environmental Sanitation Policy, 2010 ......................................................... 10 2.3.2 National Water Policy 2007 .......................................................................................... 10 2.3.3 National Environmental Sanitation Strategy and Action Plan ..................................... 10 2.3.4 District Environmental Sanitation Strategy and Action Plan ....................................... 11 2.4 Framework for National Planning and Development ........................................................... 11 2.4.1 The Local Governance Act, 2016 (Act 936) .................................................................. 11 2.4.2 Hazardous and Electronic Waste Control and Management Act, 2016 (Act 917) ....... 11 2.4.3 Hazardous, Electronic and Other Wastes (Classification), Control and Management Regulations, 2016 ......................................................................................................................... 11 2.4.4 Ghana Building Codes (2012) ...................................................................................... 12 2.4.5 Ghana Landfill Guidelines, 2002 .................................................................................. 12 2.4.6 Land Use and Spatial Planning Act, 2016 (Act 925) .................................................... 12 2.5 National Labour, Safety and Health Requirements............................................................... 12 2.5.2 Occupational Safety and Health Policy of Ghana (Draft) ............................................ 12 2.5.3 National Workplace HIV/AIDS Policy .......................................................................... 12 2.5.4 Labour Act, 2003 (Act 651)........................................................................................... 13 2.5.6 Public Health Act, 2012 (Act 851) ................................................................................ 13 2.6 Climate Action Requirements ............................................................................................... 13 2.6.1 United Nations Framework Conservation on Climate Change .................................... 13 2.6.2 National Climate Change Policy .................................................................................. 13 2.7 Difference between Ghana and the World Bank’s EA Requirements .................................. 14 3.0 PROJECT DESCRIPTION ................................................................................................... 17 3.1 Project Background ............................................................................................................... 17 Ministry of Sanitation & Water Resources xiii December 2018 Abloragyei Dumpsite Capping Project Final ESIA 3.2 Project Overview .................................................................................................................. 17 3.3 Pre-Cap Phase Activities....................................................................................................... 19 3.4 Capping Phase Activities ...................................................................................................... 21 3.5 Post-Cap Phase Activities ..................................................................................................... 22 3.6 Aftercare Management Phase ............................................................................................... 23 4.0 ANALYSIS OF ALTERNATIVES ....................................................................................... 25 4.1 ‘No Project Alternative ......................................................................................................... 25 4.2 Type of Capping Materials ................................................................................................... 26 4.2.1 Clay Core Alternative for Capping ............................................................................... 26 4.2.2 Laterite Core Alternative for Capping .......................................................................... 26 4.2.3 Preferred Capping Material ......................................................................................... 26 4.3 Sourcing of Laterite for Capping .......................................................................................... 26 4.3.1 Laterite from the Natural Environment......................................................................... 27 4.3.2 Laterite from Excavated Spoil Sources ......................................................................... 27 4.3.3 Preferred Sourcing from Both Sources ......................................................................... 27 4.4 Pre-Cap Dump Heights ......................................................................................................... 27 4.5 Thickness of Core Capping Material .................................................................................... 29 4.6 Post-cap Dumpsite Use Scenarios......................................................................................... 29 4.7 Handling of Methane Gas Generated .................................................................................... 30 4.8 Leachate Treatment Alternatives .......................................................................................... 30 4.8.1 On-site Leachate Treatment Alternative ....................................................................... 31 4.8.2 Off-site Leachate Treatment Alternative ....................................................................... 31 4.8.3 Preferred Leachate Treatment Option .......................................................................... 31 5.0 ENVIRONMENTAL AND SOCIAL BASELINE INFORMATION ................................ 33 5.1 Geographic Location ............................................................................................................. 33 5.2 Physical Features .................................................................................................................. 33 5.2.1 Climatic Conditions (Rainfall and Temperature) ......................................................... 33 5.2.2 Vegetation ..................................................................................................................... 34 5.2.3 Drainage and Hydrology/Water Resources .................................................................. 34 5.3 Historical Context of Dump Development ........................................................................... 35 5.3.1 Origin of the Dumpsite.................................................................................................. 35 5.3.2 Ownership of Dumpsite and Surrounding Land ........................................................... 35 5.4 Current State of Dumpsite..................................................................................................... 36 5.4.1 Properties on the Boundary of the Dump ..................................................................... 36 5.5 Socio-economic Activities .................................................................................................... 36 5.5.1 Project Affected Persons ............................................................................................... 36 5.5.2 PAPs Engaged in Business Activities ........................................................................... 37 5.5.3 PAPs with Land and Structures .................................................................................... 38 5.6 Waste Composition and Heavy Metal Concentration ........................................................... 38 5.6.1 Waste Composition ....................................................................................................... 38 5.6.2 Heavy Metals Concentration ........................................................................................ 38 5.6.3 Leachate Quality ........................................................................................................... 39 5.6.4 Leachate Quality Results and Analysis ......................................................................... 44 5.6.5 Leachate Management Capacities ................................................................................ 45 5.7 Road Network and Traffic .................................................................................................... 48 5.8 Health Data ........................................................................................................................... 51 Ministry of Sanitation & Water Resources xiv December 2018 Abloragyei Dumpsite Capping Project Final ESIA 5.8.1 Top Causes of Out-patient Attendance for Ga East Municipality ................................ 51 5.8.2 Trends in Diseases Associated with Poor Environmental Sanitation ........................... 52 6.0 STAKEHOLDER INVOLVEMENT .................................................................................... 55 6.1 Rationale for Stakeholder Involvement ................................................................................ 55 6.2 Key Stakeholders Engaged ................................................................................................... 55 6.3 Stakeholder Notifications ...................................................................................................... 55 6.4 Consultation Outcomes ......................................................................................................... 56 6.5 Public Disclosure .................................................................................................................. 57 7.0 ASSESSMENT OF POTENTIAL IMPACTS ...................................................................... 59 7.1 Beneficial Impacts ................................................................................................................ 61 7.1.1 Elimination of Leachate Pollution ................................................................................ 61 7.1.2 Elimination of Health Risks posed by the Dumps ......................................................... 61 7.2 Construction (Pre-cap and Capping) Phase Impacts ............................................................. 61 7.2.1 Socio-economic and Livelihoods Impacts ..................................................................... 61 7.2.2 Risk to Successful Capping Operation .......................................................................... 62 7.2.3 Public and Occupational Health and Safety Risks ....................................................... 64 7.2.4 Potential Human Rights Abuse and Gender Disparity ................................................. 66 7.2.5 Potential Air Quality Impacts ....................................................................................... 67 7.3 Post-Cap Phase Impacts ........................................................................................................ 69 7.3.1 Risk of Leachate Contamination ................................................................................... 69 7.3.2 Risk to Successful Aftercare Management .................................................................... 71 7.3.3 Risk of Explosion from Gas Build-up ............................................................................ 72 7.3.4 Potential Collapse of Constructed Structures on the Capped Dump ............................ 74 7.4.1 Potential Degradation from Sourcing of Capping Material ......................................... 75 7.4.2 Capping Materials Haulage Impact.............................................................................. 75 8.0 MITIGATION AND ENHANCEMENT MEASURES ....................................................... 79 8.1 Precautionary Measures for Successful Capping .................................................................. 79 8.1.1 Prompt Project Financing and Scheduled Disbursement ............................................. 79 8.1.2 Timely Availability of Capping Material Needs............................................................ 79 8.1.3 Good State of Equipment and Machinery ..................................................................... 80 8.1.4 Deterring Encroachment............................................................................................... 80 8.2 Public and Occupational Health and Safety Measures ......................................................... 80 8.3 Prevention of Leachate Contamination ................................................................................. 81 8.4 Air Quality Protection Measures........................................................................................... 82 8.5 Gender Equality and Human Rights Protection .................................................................... 82 8.6 Prevention of Degradation from Laterite Sourcing ............................................................... 83 8.7 Haulage and Traffic Safety Measures ................................................................................... 83 8.8 Abbreviated Resettlement Action Plan ................................................................................. 83 8.9 Resource Availability for Aftercare Management ................................................................ 84 8.10 Gas Venting and Flaring ....................................................................................................... 84 8.11 Post-Cap Land Development Control ................................................................................... 84 9.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLANS ....................................... 87 9.1 Introduction ........................................................................................................................... 87 9.2 Institutional Arrangements .................................................................................................... 87 Ministry of Sanitation & Water Resources xv December 2018 Abloragyei Dumpsite Capping Project Final ESIA 9.2.1 Construction Phase E&S Implementation Arrangement .............................................. 88 9.2.2 Post-Cap and Aftercare Management Phase E&S Implementation Arrangement ....... 88 9.3 ESMP Implementation Capacity ........................................................................................... 89 9.4 Implementation Plan ............................................................................................................. 89 9.4.1 Capping and Aftercare Management Plan ................................................................... 90 9.4.2 Public and Occupational Health and Safety Plan ........................................................ 91 9.4.3 Leachate Containment and Management Plan ............................................................. 92 9.4.4 Air Quality Control Plan............................................................................................... 93 9.4.5 Gender Equality and Human Rights Protection Plan ................................................... 94 9.4.6 Capping Materials Sourcing Plan ................................................................................ 94 9.4.7 Haulage and Traffic Safety Plan ................................................................................... 95 9.4.9 Gas Emission Control Plan........................................................................................... 97 9.4.10 Post-cap Land Development Control Plan ................................................................... 97 9.5 Environmental and Social Monitoring Plan .......................................................................... 98 9.5.1 Capping and Aftercare Monitoring Plan ...................................................................... 98 9.5.2 Public and Occupational Health and Safety Monitoring Plan ..................................... 98 9.5.3 Monitoring Plan for Prevention of Leachate Contamination ....................................... 99 9.5.4 Air Quality Monitoring Plan ....................................................................................... 100 9.5.5 Human Rights and Gender Monitoring Plan .............................................................. 100 9.5.6 Monitoring Plan for Laterite Sourcing ....................................................................... 101 9.5.7 Haulage and Traffic Safety Monitoring Plan.............................................................. 101 9.5.8 Gas Emission Monitoring Plan ................................................................................... 102 9.5.9 Post-Cap Land Use Monitoring Plan ......................................................................... 102 9.6 Budget for ESMP Implementation ...................................................................................... 103 REFERENCES .................................................................................................................................. 108 APPENDICES ................................................................................................................................... 110 Ministry of Sanitation & Water Resources xvi December 2018 Abloragyei Dumpsite Capping Project Final ESIA List of Figures Figure 3. 1 DEM of the Abloragyei Dump ...................................................................................... 18 Figure 3. 2 Profile of the Abloragyei Dump .................................................................................... 19 Figure 3. 3 Schematic Diagram of a Capped Dump........................................................................ 22 Figure 5. 1 Map of Ga East Municipality ........................................................................................ 33 Figure 5. 2 Five-Year Interval Rainfall Pattern .............................................................................. 34 Figure 5. 3 Five-Year Interval Average Temperature ..................................................................... 34 Figure 5. 4 Drainage Systems close to Dump 2 ............................................................................... 35 Figure 5. 5 Satellite Imageries of the Dump from 2007 to 2017 ..................................................... 35 Figure 5. 6 Uncompleted Structure and Shack Located on the Boundary of the Dumpsite ............ 36 Figure 5. 7 Locations of Structures Relative to the Dumps ............................................................. 37 Figure 5. 8 Economic Activities close to Dumpsite ......................................................................... 38 Figure 5. 9 Mass Waste Composition of the Dump ......................................................................... 38 Figure 5. 10 Heavy Metal Concentration Sampling Point Locations................................................ 39 Figure 5. 11 Distribution of some Heavy Metals on Dumpsite ......................................................... 42 Figure 5. 12 Leachate Quality Sampling Points ................................................................................ 44 Figure 5. 13 Leachate Treatment Ponds............................................................................................ 46 Figure 5. 14 Anaerobic Thermal Desorption Unit ............................................................................ 48 Figure 5. 15 Access Routes to Dumpsites .......................................................................................... 48 Figure 5. 16 Traffic Census Points .................................................................................................... 49 Figure 5. 17 Trends in Sanitation Related Diseases.......................................................................... 53 Figure 7. 1 Structures on and around Dump ................................................................................... 62 Figure 7. 2 Drains that Connects to the Dakobi Stream ................................................................. 69 Figure 7. 3 Areas around Dumps that Experience Flooding ........................................................... 70 Ministry of Sanitation & Water Resources xvii December 2018 Abloragyei Dumpsite Capping Project Final ESIA List of Tables Table 3. 1 Leachate Generation and Evacuation at the Capped Dumpsite ................................... 21 Table 3. 2 Machinery and Equipment ............................................................................................ 22 Table 4. 1 Evaluation of Dump 1 Height Options .......................................................................... 28 Table 4. 2 Evaluation of Dump 1 Height Options .......................................................................... 28 Table 4. 3 Alternative Development Scenarios .............................................................................. 30 Table 4. 4 Elevated Parameter Levels in Leachate ........................................................................ 30 Table 5. 1 Structures Located on the Boundary of Dumpsite ........................................................ 36 Table 5. 2 Heavy Metals Level on the Dump ................................................................................. 40 Table 5. 3 Physicochemical Analysis of Leachate ......................................................................... 43 Table 5. 4 Heavy Metals Analysis of Leachates ............................................................................. 43 Table 5. 5 Physicochemical Analysis of Water Sampled ............................................................... 43 Table 5. 6 Heavy Metals Analysis of Water Sampled .................................................................... 44 Table 5. 7 Summary of Traffic Data on Abokobi-Ashongman Road .............................................. 49 Table 5. 8 Summary of Traffic Data on Abokobi-Ashongman Road .............................................. 50 Table 5. 9 Summary of Traffic Data on Pantang-Abokobi Road ................................................... 50 Table 5. 10 Summary of Traffic Data on Pantang-Abokobi Road ................................................... 50 Table 5. 11 Top 10 Causes of Out-patient Attendance for Ga East Municipality ........................... 51 Table 5. 12 Trends in the four most Common OPD Cases .............................................................. 52 Table 6. 1 List of Stakeholders Engaged ........................................................................................ 55 Table 6. 2 Stakeholder Notification ............................................................................................... 55 Table 6. 3 Major Issues from the Engagements ............................................................................ 56 Table 6. 4 Summarized Outcome of Joint Disclosure Meeting ...................................................... 57 Table 7. 1 Significance of Risks to Successful Capping ................................................................. 63 Table 7. 2 Significance of Occupational Health and Safety Risks ................................................. 65 Table 7. 3 Significance of Public Health Impacts .......................................................................... 66 Table 7. 4 Significance of Human Rights and Gender Abuse ........................................................ 67 Table 7. 5 Significance of Sources of Air Quality Impacts ............................................................ 68 Table 7. 6 Significance of Contamination from Leachate .............................................................. 71 Table 7. 7 Significance of Causes of Failed Aftercare Management ............................................. 72 Table 7. 8 Significance of Causes of Explosion from Gas Build-up .............................................. 73 Table 7. 9 Significance of Causes of Collapse of Structures ......................................................... 74 Table 7.10 Significance of Sources of Risk of Materials Extraction ............................................... 75 Table 7. 11 Significance of Causes of Haulage Impacts .................................................................. 76 Table 9. 1 Capping and Aftercare Management Plan ................................................................... 91 Table 9. 2 Public and Occupational Health and Safety Plan ........................................................ 91 Table 9. 3 Leachate Containment and Management Plan ............................................................. 93 Table 9. 4 Air Quality Control Management Plan ......................................................................... 93 Table 9. 5 Gender Equality and Human Rights Protection Plan ................................................... 94 Table 9. 6 Capping Materials Sourcing Plan ................................................................................ 95 Table 9. 7 Haulage and Traffic Safety Plan ................................................................................... 95 Table 9. 8 Abbreviated Resettlement Action Plan .......................................................................... 96 Table 9. 9 Gas Emission Control Plan........................................................................................... 97 Table 9. 10 Post-cap Land Development Control Plan ................................................................... 97 Table 9. 11 Capping and Aftercare Monitoring Plan ...................................................................... 98 Ministry of Sanitation & Water Resources xviii December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 9. 12 Public and Occupational Health and Safety Monitoring Measures ............................. 98 Table 9. 13 Monitoring Plan for Prevention of Leachate Contamination ....................................... 99 Table 9. 14 Air Quality Monitoring Plan ....................................................................................... 100 Table 9. 15 Human Rights and Gender Monitoring Plan .............................................................. 100 Table 9. 16 Monitoring Plan for Laterite Sourcing ....................................................................... 101 Table 9. 17 Haulage and Traffic Safety Monitoring Plan.............................................................. 102 Table 9. 18 Gas Emission Monitoring Plan ................................................................................... 102 Table 9. 19 Post-cap Land Use Monitoring Plan .......................................................................... 103 Table 9. 20 Budget for Capping and Aftercare Management Plan ............................................... 103 Table 9. 21 Budget for Public and Occupational Health and Safety Plan .................................... 104 Table 9. 22 Budget for Leachate Containment and Management Plan ......................................... 104 Table 9. 23 Budget for Air Quality Control Plan .......................................................................... 105 Table 9. 24 Budget for Gender and Human Rights Protection Plan ............................................. 105 Table 9. 25 Budget for Gas Emission Control Plan ....................................................................... 105 Table 9. 26 Budget for Post-cap Land Development Control Plan .............................................. 106 Table 9. 27 Budget for Capping Materials Sourcing Plan ............................................................ 106 Table 9. 28 Budget for Haulage and Traffic Safety Plan ............................................................... 106 Table 9. 29 Budget Summary ......................................................................................................... 107 Ministry of Sanitation & Water Resources xix December 2018 Abloragyei Dumpsite Capping Project Final ESIA CHAPTER ONE Introduction � Background � Project Justification � Project and Components � Purpose of the ESIA � Methodology for the ESIA � Deliverables � Report Organization Ministry of Sanitation & Water Resources 1 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 1.0 INTRODUCTION 1.1 Background The Government of Ghana has applied to the World Bank for assistance in financing the Greater Accra Resilient and Integrated Development (GARID) project. The project aims at supporting critical investments to deal with Climate Change impacts in the Odaw Catchment in the Greater Accra Region. The key interventions focus on challenges with drainage and solid waste issues in the Odaw Channel. There have been major challenges with the collection and disposal of solid waste nationally, and it is estimated that about 30% of the solid waste generated is uncollected in the Greater Accra Metropolitan Area (GAMA). There are several disposal sites for solid wastes in the GAMA area, including open dumps, semi-engineered dumpsites and the engineered landfill site at Kpone (Tema Sanitary Landfill) in the Kpone-Katamanso District. There is another semi-engineered dumpsite, and a number of other basic dumpsites in the region. These dumpsites in particular produce leachate that pollutes the Odaw channel, in addition to the volumes of solid waste carried along into the channel when it rains. The GARID project is supporting the Ministry of Sanitation and Water Resources (MSWR) to decommission and cap the Abloragyei Dumpsite (among other projects), and to prevent further leachate pollution of the Odaw via the Dakobi Stream. The dumpsite occupies 20.52 acres, consisting of two separate dumps (Dumps 1 and 2). Housing development and other land use activities have taken over the remainder of the 50-acre land, on the instrumentality of the Ablorh Family. About 12 acres portion of the land occupied by Dump 1 is owned by GEMA, and was managed by Waste Landfills Limited, on the Assembly’s behalf. Two other waste management companies - Honest Waste and Amanee Waste and General Services Limited own and managed the remaining dump - over 8 acres (Dump 2), which was acquired from the Ablorh Family in 2006 for the GEMA franchised waste collection and disposal operations. Dumping of waste at the dumpsite officially closed in January 2018 with security presence to enforce the closure. GEMA arranged for waste in the municipality to be disposed at the Tema Engineered Sanitary Landfill at Kpone and Accra Compost and Recycling Plant (ACARP) at Adjen Kotoku. 1.2 Project Justification Besides polluting the Dakobi Stream and the Odaw, leachate from the dumps flow through the Abloragyei community, increasing danger to life (humans and livestock) and serious potential health effects, with attendant social and economic costs. The spiteful visual intrusion and unsightly dump surroundings, abundant presence of flies, prevalence of parasites due to unsanitary conditions, bad odour and persistent burning and smoke emission from the poorly managed dump, were key detestable features of the dumpsite and surroundings. These constituted some of the major sources of discomfort and health and safety risks to nearby residents, the Abloragyei and the Pantang Hospital communities, leading to sustained protestation to decommission the dumps. The key objectives of the decommissioning and capping of the Abloragyei Dumpsite are to: • Avoid the continuous abuse of the area and discharge of polluted leachate into the Dakobi; Ministry of Sanitation & Water Resources 2 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Avoid the hazardous and health threatening exposure of people living close to or on the dumpsite and surroundings; • Avoid sedimentation of the Dakobi and Odaw through waste and sediment-laden run-off contributing to extreme flood events occasionally experienced in sections of the Odaw catchment; and • Create opportunities for the sound and sustainable aftercare management and use of the capped dumps. 1.3 Project and Components Waste dumping at the Abloragyei Dumpsite began in 1998 and closed in January 2018, following protests and petition about the unsanitary state of the dumpsite and the associated health threats to the communities nearby. The rehabilitation, closure and capping activities will require: • Setting up of temporary construction areas/work camp; • Constructing site facilities, including – o Site office fitted with washrooms, store rooms, etc. o Fencing of the dump to contain windblown litter and prevent unauthorized access; • Sourcing and heaping of capping materials; • Storage of capping materials; • Use of heavy duty equipment for – o Pushing, filling and levelling, and heavy machinery for compacting of the waste dumps; o Spreading, levelling and compacting the capping material (laterite); and • Spreading of covering material (loamy soil) for grassing. Other associated infrastructure and activities will include: • Managing the grass to fully cover the capped dump; • Constructing site drainage for runoff and storm water; • Constructing a 1.5km access lane around the dumpsite; • Constructing leachate collector channels and 2 sumps; and • Installing gas collection pipe vents. The post-cap and Aftercare Management activities will involve: • Managing evacuation, transfer and treatment of leachate at TESL to prevent further pollution of the Dakobi and the Odaw; • Managing gas collection installed vents and gas production; • Managing runoff from the capped dump, site drainage and potential erosion; • Managing post-cap end use of the area for recreational purposes; and • Managing other users and activities in the area surrounding the capped dump. 1.4 Purpose of the ESIA Leachate and gas (mainly methane) generation and release from the capped dumps could continue for months, due to the continuous anaerobic biological decomposition within the dumps. This therefore will require aftercare management of the dumpsite post-cap. Without an assessment and the introduction and implementation of appropriate safeguards and mitigation measures, the imminent risks and impacts of the proposed rehabilitation and capping of the dumps for the surrounding landscape, the environment and people would be significant. Ministry of Sanitation & Water Resources 3 December 2018 Abloragyei Dumpsite Capping Project Final ESIA The Environmental Protection Agency (EPA) Act, 1994 (Act 490) mandates the Agency to ensure compliance with laid down regulations governing project development. In line with Ghana’s Environmental Assessment Regulations, 1999 (LI 1652), the proposed rehabilitation and closure of the dumps, though a significant mitigation intervention, its implementation could lead to significant impacts and risks, and therefore considered Environmental Impact Assessment (EIA) mandatory undertaking. The GARID Project (including the Abloragyei dump rehabilitation and closure and aftercare management) is also classified a Category A project under the World Bank Safeguards Policies (Environmental Assessment Policy OP4.01 and the Involuntary Resettlement Policy OP4.12), and therefore requires an Environmental and Social Impact Assessment (ESIA) study. The required scoping notices (Appendix 5) were served at the scoping stage to elicit active participation of stakeholders in the process. A Scoping Report with the terms of reference (Appendix 11) for the ESIA was duly submitted to EPA for review and acceptance, in accordance with Section 11 of LI 1652, to guide the assessment process. The draft Environmental Impact Statement submitted to EPA as required, was reviewed and approved for finalization. This final report therefore incorporates EPA’s review comments (Appendix 12). 1.5 Methodology for the ESIA The key methodologies for the ESIA processes involved stakeholder engagements, analysis of extensive pollution surveys from the Environmental and Social (E&S) Audit of the dumpsite, and E&S Audit findings, as well as document review. Stakeholders involved in the ESIA engagements included the following: • Environmental Protection Agency (EPA); • Ga East Municipal Assembly (GEMA); • Waste management companies – o Amanee Waste Limited; o Honest Waste Limited; o Waste Landfills Ghana Limited; • Accra Sewage Improvement Project (ASIP); • Tema Engineered Sanitary Landfill; • Waste Department of TMA; • Abloragyei Chief; • Project Affected Persons (PAPs); and • Residents’ Association. Some documents reviewed included the following: • Ghana landfill guidelines; • Emergency solid waste management improvement programme in GAMA; and • Technical report on sustainable management of e-waste in Ghana. Environmental media pollution surveys and analysis covered the following areas: • Water resource quality; • Leachate quality; and • Heavy metals distribution and relative concentration on the dumps and surrounding area. Ministry of Sanitation & Water Resources 4 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Leachate quality analysis involving the following parameters: • pH • BOD • TSS • As • Hg • NO3 • COD • Conductivity • Pb • Cu • PO4 • Turbidity • Cr Analysis of key heavy metals concentration and mapping of the relative distribution in the waste dump and surrounding areas included: • Antimony (Sb) • Cadmium (Cd) • Lead (Pb) • Selenium (Se) • Arsenic (As) • Chromium (Cr) • Mercury (Hg) • Titanium (Ti) • Barium (Ba) • Cobalt (Co) • Molybdenum (Mo) • Tin (Sn) • Beryllium (Be) • Copper (Cu) • Nickel (Ni) • Zinc (Zn) 1.6 Deliverables The main deliverables of the assignment include: • Scoping Report which included an Environmental and Social Audit; • Environmental and Social Management Plan; • Draft ESIA Report ; and • Final ESIA Report. The other deliverables contained in the ESIA report include: • Satellite imageries of the dumpsite surroundings and trends; • Table of concentration of heavy metals; • Water resource quality; • Leachate quality; • Maps of heavy metal distribution; • Diagrams/drawings of – o Delineated boundaries of the dumps; o Boundary of the dumps with a 10m hazard buffer; o The dumps (schematic diagram) with gas vents and leachate pipes; o Digital Elevation Model (DEM) of the dumps; and o Profile (cross-sectional heights) of the dumps. 1.7 Report Organisation The final ESIA Report is organised into nine main chapters, preceded by an Executive Summary, as follows: • Chapter 1: Introduction; • Chapter 2: Key policies and regulatory framework; • Chapter 3: Capping project description; • Chapter 4: Analysis of alternatives; • Chapter 5: Baseline environmental and social conditions; • Chapter 6: Stakeholder involvement; • Chapter 7: Assessment of potential impacts; • Chapter 8: Mitigation measures for significant impacts; and • Chapter 9: Environmental and social management plan. Ministry of Sanitation & Water Resources 5 December 2018 Abloragyei Dumpsite Capping Project Final ESIA CHAPTER TWO Policy and Regulatory Framework � Environmental Policy and Related Requirements � World Bank Requirements � Water and Sanitation Sector Policy and Requirements � National Planning and Development Requirements � National Labour, Safety and Health Requirements � Climate Action Requirements � Difference Between Ghana and the World Bank’s EA Requirements Ministry of Sanitation & Water Resources 6 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 2.0 POLICY AND REGULATORY FRAMEWORK The policy and regulatory framework relevant to sanitation, waste and water pollution sectors, and particularly relating to the proposed decommissioning and closure of the Abloragyei dumpsite and aftercare management reviewed, were grouped under six broad themes. Gap analysis of key differences reviewed. The broad themes are as follow: • Environmental policy and related requirements; • World Bank requirements and other guidelines; • Water and sanitation sector policy and requirements; • National planning and development requirements; • National labour, safety and health requirements; • Climate action requirements; and • Difference between Ghana and the World Bank’s EA requirements. 2.1 National Environmental Policy and related Requirements The policy and regulatory areas applied in the assessment were: • Ghana’s Environmental Policy; • Environmental Protection Agency Act, 1994 (Act 490); and • Environmental Assessment Regulations 1999 (LI 1652). • Ghana Landfill Guidelines, 2002 The policy is fashioned for a holistic management of the environment, where people have access to clean air and water, decent housing and other necessities of life. The policy supports a new paradigm of sustainable development, based on coordinated environmental management to ensure quality of life of citizens and their living and working environments, as well as participation in decision-making. The LI 1652 and its parent Act 490 grants EPA environmental enforcement and standard setting powers (such as the Ambient Noise Level and Effluent Discharge Guidelines), and the power to ensure compliance with the Environmental Assessment requirements and procedures. Additionally, the Agency, among others, is required to control the generation, treatment, storage, transportation and disposal of waste. The Agency is vested with the power to require Environmental Assessments (EAs), Environmental Management Plans (EMPs), Annual Environmental Reports (AERs), of ‘undertakings’, to regulate and serve Enforcement Notice for any offending or non-complying undertakings. This ESIA has been prepared to comply with these requirements. Under the requirements for EMP, the contractor would prepare the ‘construction phase’ ESMP, while GEMA prepare the post - cap/aftercare management phase ESMP. Also under the requirement for AERs, quarterly monitoring reports may be submitted by the contractor, while GEMA reports to the EPA and the Ministry of Sanitation and Water Resources. Ministry of Sanitation & Water Resources 7 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 2.2 World Bank Requirements 2.2.1 Environmental Assessment Policy OP4.01 This policy ensures that projects proposed for World Bank financing have undergone environmental assessment and are environmentally feasible and viable, and that decision making is improved through appropriate analysis of actions and their probable environmental impacts. This policy is triggered if the project is likely to cause potential (negative) environmental risks and impacts in its area of influence. The OP 4.01 takes into account the following, among others: • Impacts on the physical environment (air, water and land); • Life environment, health and safety of populations; and • Cultural and physical resources. The Bank undertakes environmental screening to determine the appropriate extent and type of environmental assessment to be conducted; classifies the proposed projects into categories, depending on the type, location, project sensitivity, scale of the projects, and the nature and magnitude of their potential environmental impacts. This project falls under category A. Projects considered as category A have potential adverse environmental impacts on human populations or environmentally important areas that could be significant. These impacts may affect an area broader than the sites or facilities subject to physical works. The environmental assessment has to examine the project's potential negative and positive environmental impacts and recommend any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance. 2.2.2 Involuntary Resettlement Policy OP4.12 The main objectives of the Resettlement Policy are: • Avoid or minimize involuntary resettlement whenever feasible; • Develop resettlement activities as sustainable development programs, providing sufficient investment resources to enable the displaced persons to share in project benefits; • Meaningfully consult displaced persons and give them opportunities to participate in planning and implementing resettlement programme; • Assist displaced persons in their efforts to improve their livelihoods and standards of living or at least to restore them, or to pre-displacement levels or to levels prevailing prior to the beginning of project implementation, whichever is higher. The Annex A (Paragraphs 17-31) of the policy describes the scope (level of detail) and the elements that a resettlement plan should include. These are the objectives, potential impacts, socioeconomic studies, legal and institutional frameworks, eligibility, valuation and compensation of losses, resettlement measures, relocation planning, community participation, grievance management procedures, implementation schedules, costs and budgets, and monitoring and evaluation. Properties and businesses that will be affected by the project have been identified and the social and livelihoods impacts assessed. An appropriate resettlement action will be carried out to fully address the concerns of property owners and the others. Ministry of Sanitation & Water Resources 8 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 2.2.3 Natural Habitats OP. 4.04 The conservation of natural habitats, like other measures that protect and enhance the environment, is essential for long-term sustainable development. The Bank therefore supports the protection, maintenance, and rehabilitation of natural habitats and their functions in its economic and sector work, project financing, and policy dialogue. The Bank supports, and expects borrowers to apply, a precautionary approach to natural resource management to ensure opportunities for environmentally sustainable development. The capping project presents a potential for contamination of water resources (e.g. the Dakobi Stream) with lead-laden leachate. The ESIA assesses this potential impact and provides measures to avoid leachate contamination of the Dakobi in particular, and the Odaw. 2.2.4 Physical and Cultural Resources OP 4.11 This policy addresses physical cultural resources, which are defined as movable or immovable objects, sites, structures, groups of structures, and natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural significance. The Bank supports countries to avoid or mitigate adverse impacts on physical cultural resources from development projects that it finances. In the context of this project, the policy could be triggered during sourcing of laterite as capping material. Provision has been made to facilitate consideration of measures to avoid adversely impacting physical cultural resources by the contractor (when preparing the laterite sourcing impact assessment). 2.2.5 Gender and Development OP/BP 4.20 The Bank country director oversees the preparation of the gender assessment for the country. The gender assessment is based on analytic work and consultations conducted by the Bank or by other organizations. In the case where the need for priority gender-responsive action is relevant for a project financed by the World Bank, it is relevant to integrate gender assessment action to ensure the project design addresses the following aspects appropriately: • Local circumstances that may affect the different participation of females and males; • Contribution that females and males each could make to achieve the project's objectives; • Ways in which the project might be disadvantageous to one gender relative to the other; and • Proposed mechanisms for monitoring the different impacts on females and males. 2.2.6 World Bank Group General Environmental Health and Safety Guidelines The World Bank Group (WBG) General Environmental Health and Safety (EHS) Guidelines is a technical reference document containing information on cross-cutting environmental, health and safety issues potentially applicable to all industry sectors. The General EHS guidelines, which prescribe performance levels and measures, are designed to be used together with the relevant Industry Sector EHS Guidelines. These documents are to be the reference for EHS measures implemented for WBG-funded projects. The General guidelines are in 4 main groups: Environmental; Occupational Health and Safety; Community Health and Safety; and Construction and Decommissioning. When a host country’s regulations differ from the levels and measures presented in the EHS Guidelines, projects will be required to achieve whichever is more stringent. The Abloragyei waste Ministry of Sanitation & Water Resources 9 December 2018 Abloragyei Dumpsite Capping Project Final ESIA dump capping project straddles the Construction and Decommissioning as well as the Environmental categories and as such this ESIA took into account the prescribed performance guidelines. 2.2.7 World Bank Group Industry Sector Guidelines for Waste Management Facilities The EHS Guidelines for Waste Management cover projects dedicated to the management of municipal solid waste and industrial waste. The document provides guidelines for landfill management, closure and post-closure care. Some of the guidelines that were applied in this ESIA are: • Application of closure methods consistent with post-closure use: capping thickness of 30inches to enable use for recreational facilities; • Application of final cover to meet local climatic conditions: capping done to minimize infiltration of precipitation and generation of leachate; • Post-closure management facilities: landfill gas collection facilities and leachate collection ponds; • Financial instruments for closure and post-closure care: an aftercare management plan has been developed to incorporate post closure care and monitoring. 2.3 Water and Sanitation Sector Policy and Requirements 2.3.1 National Environmental Sanitation Policy, 2010 The Environmental Sanitation Policy (2010) addresses the limitations of the old policy (1999) to reflect the changing context of national and international development priorities. The policy covers all components of environmental sanitation such as drainage, safe water, food hygiene and safety, health inspection, housing safety, etc. The policy focuses on ten principal components of environmental sanitation of which three are relevant to this project: 1) Collection and safe disposal of wastes – solid and liquid wastes, excreta, hazardous wastes, etc; 2) Monitoring the observance of environmental standards; and 3) Control of rearing and straying of animals. 2.3.2 National Water Policy 2007 The National Water Policy aims at promoting an efficient and effective management system and environmentally sound development of water resources to achieve sustainable development, and use of Ghana's water resources to improve health and livelihoods. The policy expects to achieve these goals by addressing relevant issues under urban water supply and community water and sanitation. Focus areas include environmental sanitation and decentralized delivery of water and sanitation services. The policy objectives under the focus areas seek to: • Minimize the pollution of water sources from poor environmental sanitation services; and • Support District Assemblies to meet their statutory obligations of providing services to communities within their jurisdictions. 2.3.3 National Environmental Sanitation Strategy and Action Plan The National Environmental Sanitation Strategy and Action Plan (NESSAP) is a response to the need to refocus attention on environmental sanitation in Ghana. It provides proposals and action plans with a country-wide scope, laying the basis for working towards the achievement of the Environmental Sanitation Policy objectives. NESSAP translates the policy objectives into actionable targets and implementation packages for Metropolitan, Municipal and District Assemblies (MMDAs). Ministry of Sanitation & Water Resources 10 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 2.3.4 District Environmental Sanitation Strategy and Action Plan The purpose of the District Environmental Sanitation Strategy and Action Plan (DESSAP) is to establish a framework for developing an effective and locally feasible environmental sanitation strategy and action plan, in line with the national policy. The DESSAP is focused at the districts as the primary service delivery and each district has been supported to develop their own. DESSAP also takes into account the availability of sufficient institutional capacity for the practical operation of environmental sanitation facilities and systems at the local level. This plan provides the framework for collaboration between the Ministry of Sanitation and Water Resources is undertaking this project to prevent further pollution of the Odaw from the Abloragyei Dumpsite. 2.4 Framework for National Planning and Development 2.4.1 The Local Governance Act, 2016 (Act 936) The Act mandates the MMDAs to ensure proper waste and sanitation management in their respective jurisdictions through their Waste Management Departments (WMDs) and their Environmental Health and Sanitation Departments (EHSD). Under this Act, the assembly is: • The planning authority - responsible for physical/spatial planning of customary land in conjunction with the Stools; • Responsible for approval of planning schemes before it can take effect within the district; and • Responsible for development control through the grant of permit for development. 2.4.2 Hazardous and Electronic Waste Control and Management Act, 2016 (Act 917) This Act provides for the control, management and disposal of hazardous, electrical and electronic waste and related purposes. Under the Act, a person shall not deposit hazardous waste or other wastes on any land in the country or in the territorial waters of the country. The Act also states that a person involved in the management of hazardous wastes or other wastes shall: • Take the steps that are necessary to prevent pollution from hazardous wastes and other wastes arising from the management; and • Where pollution occurs, minimize the consequences of the pollution on human health and the environment. 2.4.3 Hazardous, Electronic and Other Wastes (Classification), Control and Management Regulations, 2016 The regulations apply principally to waste generators, waste transporters and waste managers, but not to the generation of domestic waste which is collected by a District Assembly. The purpose of the regulations includes: • Regulating the classification, control and management of wastes; • Prescribing general duties of waste generators, waste transporters and waste managers; and • Prescribing requirements for the disposal of wastes. A key requirement for a waste generator is to ensure that the waste generated is classified in accordance with the Ghana Waste List specified in the First Schedule, among others. Ministry of Sanitation & Water Resources 11 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 2.4.4 Ghana Building Codes (2012) The Ghana Building Code contains regulations that can be adopted or enacted for use by various departments, metropolitan, municipal and district assemblies, private and public bodies. It lays down a set of minimum regulations designed to protect the safety of the public with regard to structural efficiency, fire hazards and health aspects of buildings. The Code achieves the foregoing by covering aspects of administrative regulations; development control rules and general building requirements; stipulations regarding structural loads and design; materials; building services; measures to ensure safety of workers and the public during construction and rules for erection of signs and outdoor display structures. 2.4.5 Ghana Landfill Guidelines, 2002 The uncontrolled disposal of solid waste in inappropriate places in the country (such as abandoned quarry sites, valleys, beaches and drains), lead to the formulation of the Ghana Landfill Guidelines, with the objectives to: • Improve standard of waste disposal in Ghana; • Set out options for the environmentally acceptable disposal of solid waste; and • Provide a framework of sustainable waste disposal standards within which to operate. The Guideline emphasized on site closure and aftercare management of a landfill site when it ceases operation. The management involve shaping, final cover, and vegetating and drainage maintenance. It agrees on restoring closed solid waste landfill site to productive agricultural uses or passive recreational uses but prohibit buildings due to the inherent problems of settlement, corrosion of foundations by leachate and safety risks from landfill gas emissions. 2.4.6 Land Use and Spatial Planning Act, 2016 (Act 925) This Act revises and consolidates the laws on land use and spatial planning, provides for sustainable development of land and human settlements, ensures judicious use of land in order to improve quality of life, and promotes health and safety in respect of human settlements. 2.5 National Labour, Safety and Health Requirements 2.5.2 Occupational Safety and Health Policy of Ghana (Draft) The Occupational Safety and Health Policy is formulated to prevent accidents and injuries arising out of or linked with or occurring in the course of work. The intention is to minimize as far as reasonably practicable, the cause of hazards in the working environment and risk to which employees and the public may be exposed. The policy is derived from provisions of the International Labour Organization (ILO) Conventions 155 and 161. The policy document has specific sections on objectives, scope, strategies, activity promotion and awareness creation which ensure that workers engaged at the construction and operation stages of the project are protected. 2.5.3 National Workplace HIV/AIDS Policy The objectives of the policy are among others, to: • Provide protection from discrimination in the workplace to people living with HIV and AIDS; • Prevent HIV and AIDS spread amongst workers; and • Provide care, support and counselling for those infected and affected. Ministry of Sanitation & Water Resources 12 December 2018 Abloragyei Dumpsite Capping Project Final ESIA HIV/AIDS prevalence is a national problem. The policy is very relevant in helping to address the problem of stigmatisation, among others, and project contractors will be committed to comply with the following: • HIV and AIDS screening will not be required from job applicants or persons in employment (thus, standard medical forms will not request HIV status of employee or prospective employee); • Persons with HIV-related illness will be allowed to work for as long as medically fit and persons impaired by HIV-illness will be provided with reasonable alternative working arrangements and/or assignments; • All workers with HIV will be entitled to affordable state-sponsored healthcare services; and • Promote dissemination of information on HIV/AIDS in the workplace and the necessary precautions taken to reduce risk of transmission among workers and to the community. 2.5.4 Labour Act, 2003 (Act 651) The Act was enacted to amend and consolidate existing laws relating to labour, employers, trade unions and industrial relations. It provides for the rights and duties of employers and workers; legal or illegal strike; guarantees trade unions and freedom of associations and establishes the Labour Commission to mediate and act in respect of all labour issues. The Part XV (Occupational Health, Safety and Environment) of the Act explicitly indicates that it is the duty of an employer to ensure that every worker works under satisfactory, safe and healthy conditions as it has been catered for at the construction and operation phase of the project. 2.5.6 Public Health Act, 2012 (Act 851) The Public Health Act of Ghana was passed to prevent disease, promote safeguard, maintain and protect the health of humans and animals, and provide for related matters. The Act has various groupings that deal with the many aspects of Public Health. The groupings include communicable diseases, vaccination, quarantine, vector control, environmental sanitation, food and drugs, clinical trials and miscellaneous provisions such as international health regulations. The policy also outlines the role of the Health Minister, health officials and individuals involved, as well as regulations, penalties and measures to take to contain and control public health emergency. 2.6 Climate Action Requirements 2.6.1 United Nations Framework Conservation on Climate Change The framework seeks to prevent human interference with global climate by stabilizing atmospheric greenhouse gases at a level. Formulation of this convention was as a result of the urgent need to scale up global response to climate change. It was a negotiation reached by member countries (launched in 2011) to develop a legal instrument – climate actions – applicable to all parties to cut greenhouse gases emissions by 2020. The actions are to be implemented by governments, cities, regions, businesses, and investors. 2.6.2 National Climate Change Policy The National Climate Change Policy is Ghana’s contribution towards responding to the global climate change challenge requiring concerted effort by all nations to address the causes and effect of climate change. It considered the socio-economic and the opportunities, benefits of green economy in its context. The policy defined pathways to tackle challenges of climate change. The project is expected to release gas such as methane and carbon dioxide from the anaerobic digestion of waste (in the capped dump). Measure will be put in place to trap the dominant methane Ministry of Sanitation & Water Resources 13 December 2018 Abloragyei Dumpsite Capping Project Final ESIA gas in order to flare it and minimize its Climate Change impact; rather than release it into the atmosphere, given its high Climate Change potential. 2.7 Difference between Ghana and the World Bank’s EA Requirements The broad areas of differences addressed in Table 2.1 include the following: • Impact category; • Social assessment; • Stakeholder consultation; and • Minimization of displacement. Table 2. 1 Key Differences in Ghana and World Bank EA Requirements Topic National WB OP 4.12 Policy Gaps Strategies in ESIA Requirements Impact LI 1652 groups OP 4.01 classifies proposed projects into The World Bank Decision on level of Category undertakings into four categories: uses more assessment was based Schedules 1, 2 and 5- • Category A: project likely to have detailed criteria of on the type, location, related siting to significant adverse environmental categories of sensitivity, scale of the facilitate screening impacts that are sensitive, diverse, or assessment for project and the nature into: No EA required unprecedented and may affect screening decision of its potential beyond Screening, broader area - requires EIA making than environmental impacts, PEA or EIA • Category B: potential adverse Ghana legislation, especially for the post- impacts are less adverse than but Ghana’s is cap and aftercare Category A projects. Impacts are site more precise, management phase. specific - requires EA where the Both project screenings • Category C: project likely to have Schedules specify required ESIA minimal or no adverse the projects. environmental impacts. Beyond screening, no further EA action is required. • Category FI: if proposed project involves investment of Bank funds through a financial intermediary, in sub-projects that may result in adverse environmental impacts. Social Legislation has Assessment incorporate detailed social Ghana has no Social aspect Assessment general guidelines for provision, especially if it involves explicit provision, incorporated into the carrying out ESIA, involuntary resettlement, indigenous therefore the WB assessment, but an but has no specific peoples, and physical cultural resources. requirements on Abbreviated RAP will detailed provision for Social aspects be carried out to meet carrying out social should be adopted WB criteria. impact assessments Stakeholder Section 17(1) of LI Affected/displaced persons should be The WB Developed and used a Consultation 1652 mandates EPA meaningfully consulted throughout the provision appears stakeholder to hold Public assessment and stakeholder engagement more structured engagement Plan for Hearing, especially plan prepared and followed and systematic this ESIA. where impacts The RAP will follow extensive or involve detailed stages of: (i) dislocation, planning (ii) relocation and implementation and resettlement of (iii) monitoring and communities, in evaluation. Also addition to the develop normal stakeholder comprehensive consultations grievance mechanism. Minimization Section 5(1) of LI Requires avoidance of resettlement The LI is quite Attention was paid to Ministry of Sanitation & Water Resources 14 December 2018 Abloragyei Dumpsite Capping Project Final ESIA of 1652 requires an where possible and where impossible, open on minimizing Displacement applicant to show a minimized to the extent possible. minimizing displacement by clear commitment to resettlement, declaring only a 10m avoid any adverse while the WB’s is hazard zone from the environmental effects much more edge of the dump for which can be avoided explicit resettlement consideration Another important area of difference is the scope provided for or definition given to the chapter on ‘Environmental and Social Management Plan’ (ESMP) in the ESIA. While The World Bank EA expects a substantive ESMP coverage in the ESIA, the Ghana EA requirement provides for a Environmental Management Plan in the ESIA (Section 12(m) in the LI 1652). The Ghana system, however, requires a substantive ESMP or EMP at the implementation or operation stage of project; as stated in Section 24(1) of the LI, ‘The person responsible for an undertaking in respect of which a preliminary environmental report or an environmental impact statement has been approved shall submit to the Agency and environmental management plan in respect of his operations within 18 months of commencement of operations and thereafter every 3 years.’ Thus, the Provisional ESMP provides the framework from which a substantive ESMP is derived at the implementation stage. The other areas of comparison will be provided in the RAP, including: • Entitlement and cut-off date; • Eligibility: property owners with legal or customary titles; • Eligibility: building tenants and encroachers; • Livelihood restoration; and • Grievance management. Ministry of Sanitation & Water Resources 15 December 2018 Abloragyei Dumpsite Capping Project Final ESIA CHAPTER THREE Project Description � Project Background � Project Overview � Pre-Capping Phase Activities � Capping Phase Activities � Post-Cap Phase Activities � Aftercare Management Ministry of Sanitation & Water Resources 16 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 3.0 PROJECT DESCRIPTION 3.1 Project Background The general area, of which the Abloragyei dumpsite occupies a small part, was acquired by the Government of Ghana (GoG), originally for the operations of the erstwhile Ghana Post and Telecommunications (P&T) Corporation. The total land area was about 50 acres, acquired from the Ablor family in the 1960s. However, the site was never utilized, and rather turned into an illegal sand winning area. Dumping of waste at the site began in 1998 on the authorization of the then Ga District Assembly, upon cessation of dumping at the Ogbojo dumpsite and consequent urgent need of a new site. The site seemed ideal to the Assembly then, for the reason that it had a number of pits (created by illegal sand winners), which had to be filled up. The effective area of the dumpsite is now about 20.52 acres, consisting of two separate dumps. Housing development and other land use activities now occupy the remaining land, on the instrumentality of the Ablorh Family. About a 12-acre portion of the land (occupied by part of the Abloragyei dumpsite – Dump 1) was managed mainly by Waste Landfills Limited, on behalf of the Ga East District Assembly (GEMA). Two other private waste management companies - Honest Waste and Amanee Waste and General Services Limited - also managed the remaining dump, over 8ac (Dump 2); acquired by the two companies from the Ablorh Family in 2006, for the GEMA franchised waste collection and disposal operations. Dumping of waste at the dumpsite officially closed in January 2018 with security presence (by the waste companies) to enforce the closure. The highest and lowest points on the dumps are approximately 93.52m and 63.68m above mean sea level (MSL), with a height differential of 29.84m. The estimated volume of waste in the dumps is 361,345.20m3, comprising 268,838m3 for Dump 1 (12ac) and 92,507m3 for Dump 2 (8.52ac). The estimated volume does not include waste dumped below the original ground level, which consisted of several sand pits of up to 3m depth with unspecified surface area. The average height of the dumps prior to capping is estimated at 76.50m and 67.68m above MSL respectively for Dumps 1 and 2. Figures 3.1 and 3.2 show a Digital Elevation Model (DEM) (i.e. relative elevations on the dump), and profile (cross-sectional height) respectively of the dumps. Figure 2.2 also shows the preferred pre-capping heights (i.e. dump levelled heights prior to capping). 3.2 Project Overview The purpose of the rehabilitation and capping is to safeguard the environment and the Dakobi Stream (and the Odaw) from further pollution and the attendant public health implications. The prevalence of parasites due to the unsanitary dump conditions created malaria endemic enclave and also intestinal worms, as well as upper respiratory infections from the persistent burning and smoke emission, among other health problems in the area. These constituted some of the major sources of discomfort and health and safety risks to nearby residents and the Abloragyei community, as well as the Pantang Hospital, leading to vehement protestation and agitation to decommission the dump. The scope of work will comprise activities relating to the closure and capping of the Abloragyei dumpsite and installation of leachate collecting drains and sumps (2), to curtail the current average daily rate of 0.1m3 leachate flow into the Dakobi Stream, 700m away. There will also be installation Ministry of Sanitation & Water Resources 17 December 2018 Abloragyei Dumpsite Capping Project Final ESIA of gas venting pipes and aftercare processes and management. The project phases, involving an estimated workforce of 70, will include the following: • Pre-capping phase of about 8 months duration; • Capping phase of almost 10 months; • Post-cap phase of up to 3 years; and • Aftercare management phase. The estimated quantities of laterite and loamy soil would be 61,674.81m3 and 4111m3 respectively, and in terms of haulage to the project storage site will involve 1,371 truck-trips (of 45m3 capacity truck) for laterite and 91 truck-trips for loam. An acre of walled space at the northern section of Dump 1 will be used for laterite and loamy soil storage. Figure 3. 1 DEM of the Abloragyei Dump Ministry of Sanitation & Water Resources 18 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Legend Preferred height for Dump1 Preferred height for Dump 2 Existing height Figure 3. 2 Profile of the Abloragyei Dump The specific key activities will include conceptual outline and components of the rehabilitation and capping of the waste dumps, including: • Site storm water diversion and runoff control drain network; • Positioning of access roads around the dumps; • Height of the dump for levelling (prior to capping); • Levelling and contouring of the dump and compaction; • Thickness of core capping material to apply; • Spreading of capping material, compacting and shaping the dump; • Layout of leachate collector channels and two lined sumps; • Access lane for leachate evacuation by cesspit emptier to the Kpone landfill; and • Layout of gas collection pipe vents Other activities will include the following: • Delineation of limits of the dumpsite and setting some buffer area around the dumps for dump-toe infrastructure, access lane and green buffer; • Fencing of dumpsite with linked or barbed wire to secure the boundaries of the sites; • Construction of security post and site office fitted with wash rooms and sample storage room; • Posting of security guard for the sites; • Erection of temporary construction camp; • Designation of storage area for capping materials; and • Sourcing and hauling of covering materials (laterite and loamy soil) from sources to the designated storage area within the dumpsite. 3.3 Pre-Cap Phase Activities The pre-capping or construction phase activities will involve: 1. Final engineering design and layout based on the ESIA findings and safeguards requirements which will be built into the design, such as - a. Fencing of the dumpsite; Ministry of Sanitation & Water Resources 19 December 2018 Abloragyei Dumpsite Capping Project Final ESIA b. Capping height and contours; c. 30-inch core laterite capping material; d. 6-inch loamy soil covering and grassing; e. Leachate collector channel and positioning of sumps; f. 2 sumps of 4m3 capacity each (with 25% extra capacity); and g. Run-off control and storm water drain dimensions and layout. 2. Preparation of contract documents for the contract ward (request for proposal), which will incorporate environmental and social management plan (ESMP) and clear provision for contractors to demonstrate an understanding of required E&S obligations. 3. Implementation of the Abbreviated Resettlement Action Plan (RAP), including - a. Compensation and other assistance for affected structures; b. Compensation for any land/property considered rather close to the dump and assessed to be significantly adversely impacted; and c. Compensation for land that is temporary rented for capping material storage, etc. 4. Setting in motion processes to facilitate quick/early - a. Securing of environmentally approved sites to source laterite and loamy soils from the natural environment; b. Access to construction sites to examine quality of excavated spoil (laterite and loam) for possible use. 5. Preparation of ‘Construction Phase’ Environment and Social Management Plan (ESMP) by the contractor to guide implementation of relevant project E&S safeguards and mitigation measures. 6. Arrangement initiated and agreement made with TESL for the evacuation and transfer of leachate from the Abloragyei capped dumps to the Kpone landfill. 7. Extension of support to the Kpone landfill facility to improve the system to be able to manage the leachate from Abloragyei by the following - a. Activation of the recirculation system to enable the functioning of the leachate pumping from the Facultative Lagoon II onto the solid waste in the cells; b. Installation of the pumping machine to drain leachate daily from the cells into the lagoons; and c. Installation of reading meters in the Facultative Lagoons I and II for leachate generation monitoring. 8. Additional support to the Kpone landfill in the preparation/updating of the landfill ESMP towards renewal of operational Environmental Permit from the EPA. The other key pre-cap activities will include the following: 1. Mobilization of machinery and equipment; 2. Recruitment of workers. 3. Boundary limits determination of dump for capping and clearing a 6m buffer surrounding the dump for dump-toe infrastructure; 4. Erection of a 4m high construction fence to screen off the dumpsite and capping material storage area from adjoining facilities and activities; 5. Construction of leachate collector channels and lined sumps (2 number); 6. Construction of drain network of specified capacities; 7. Sourcing, hauling and heaping/storage of capping and other construction materials; 8. Assembling of leachate pipes and gas vents, etc; 9. Construction of security guard post and office and temporary construction yard; and Ministry of Sanitation & Water Resources 20 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 10. Construction of 1.5km access lane around the dumps. The estimated average rate of leachate generation at various stages of the life of the dumpsite (during capping and post-cap), and the expected periods of evacuation using a 6m3 capacity cesspit emptier is provided in Table 3.1. This shows that there would be 3 substantive evacuations from the 2 sumps (of 4m3 capacity each) within 6 months of capping the dumps, with the 4th evacuation not expected until after 24 months. Thereafter, leachate flow would virtually dry up (as in the case of the capped Mallam Market and Old Kpone dumps). However, contingency evacuation will be provided for any accumulated leachate in the sumps over time. A certified cesspit emptier operator will be commissioned for the leachate evacuation and transfer services. Table 3. 1 Leachate Generation and Evacuation at the Capped Dumpsite Stage of Leachate Average Daily Rate of Duration Expected Periods of Evacuation Generation Leachate generation (m3) (Weeks) Volume (m3) Current average flow 0.10 - - - During preparation and 0.15 12 12.6 • 1st evacuation – end of capping (levelling and Month 1 compaction) of dumps • 2nd evacuation – end of Month 3 2 month after capping 0.05 8 2.8 • 3rd evacuation – end of From 3rd – 6th month 0.025 16 2.8 Month 6 after capping From 7th -12th month 0.01 24 1.68 • 4th evacuation – expected From 13th – 18th month 0.001 24 0.168 after Month 24 After 18th month Virtually ceases/Dries up Leachate recirculation is the method used for leachate management at the landfill. The leachate transferred from Abloragyei would also be sprinkled on the solid waste in the cells, rather than direct release into the leachate ponds/lagoons. Consultations at TESL indicated that the estimated total leachate volume of 18m3 transferred from the Abloragyei dumpsite over a 6-month period could be easily accommodated at the Kpone landfill. 3.4 Capping Phase Activities The approximately 10-month capping phase activities will involve mainly: 1. Setting lines defining heights for levelling, that follow defined contours (slope angles); 2. Levelling of the dumps – cutting, filling and pushing following the pre-determined contours and heights; 3. Compacting the dump; 4. Spreading the laterite in 3 distinct layers, with each layer of 10 inches followed by compaction; 5. Compacting the slopes and edges; 6. Sinking of the leachate pipes (perforated) in the dump; and 7. Installing gas vents within the dump (about 20 in number – one vent per almost an acre). A schematic diagram (cross-section) of a capped dump showing the following is given in Figure 3.3: • Loam soil cover; • Impermeable cap; • Vertical recharge cell and gas collection system with gas flare; • Leachate collection pipes with sand drainage layer; and Ministry of Sanitation & Water Resources 21 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Leachate storage sump/tank. Figure 3. 3 Schematic Diagram of a Capped Dump A list of machinery and equipment that may be used in the capping phase is provided in Table 3.2. Table 3. 2 Machinery and Equipment Machinery/Equipment No. Function Bulldozer 2 Pushing and levelling Landfill Compactor 2 Leveling and compacting Tipper trucks 3 For conveying capping material CAT 140k Grader 1 For creating flat surfaces during levelling of the dump Pay loader truck 1 Loading of capping materials into trucks Compacting Roller CAT CS74 2 For compacting levelled surfaces Other vehicles 4 On-site and off-site movement The contractor undertaking the capping and other construction activities will be supervised in the implementation of ESMP and other mitigation measures and specific plans. This will be to ensure compliance with all safeguards commitments, as outlined in the Construction Phase ESMP. 3.5 Post-Cap Phase Activities The post-cap phase activities will involve mainly monitoring to determine the effectiveness of the leachate and gas emission structures, and the capping to resist erosion (wind and rainwater), as well as leachate flow and gas emission patterns, in order to take required remedial action. The post-cap phase ESMP that has been developed will be updated by the PIU to guide the monitoring and other E&S safeguards implementation. The specific areas will include: • Leachate flow monitoring; • Gas emission monitoring; • Runoff and storm water and erosion monitoring; and • Height of capped dump change monitoring. Ministry of Sanitation & Water Resources 22 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 1. Leachate flow monitoring will involve: a. Effectiveness of the collecting channels; b. Adequacy of the sumps; c. Sampling and analysis of leachate; d. Analysis of flow rate and records of dislodgement/evacuation; e. Transfer for treatment at TESL; f. Analysis of generation/declining pattern; 2. Gas emission monitoring - a. Effectiveness of the vents; b. Emission rate monitoring; c. Fire-related and burning activities brought close to the dump; 3. Runoff and storm water and erosion monitoring - a. Adequacy of the drains and appropriateness of positioning diversions; b. Erosion monitoring and any capped dump breaches; and 4. Height of capped dump change monitoring – a. Any drop in height of the dump or depressions emerging; and b. Remedial measures involving monthly re-capping, covering and grassing of such sections. The post-cap phase will last up to about 3 years. Within this period the gas build up in the capped dump is expected to have completely dissipated. The gas emission rate and pattern of flow will confirm whether the gas is exhausted. The dump would also be said to have settled, after the voids created by the evacuated gas has dispersed, and the capped dump attained a stable height. Leachate flow would also be nil or insignificant. These would signal the end of the post-cap phase. Financing for the project will cover the pre-cap, capping and post-cap phases, except the aftercare management phase. This implies that funding will be available for the key monitoring and other management activities, until the capped dump is stable and safe for conversion to beneficial uses. 3.6 Aftercare Management Phase The Aftercare Management phase will commence at the end of the post-cap phase. This phase will mainly involve activities related to the conversion of the capped, stable dump into beneficial uses. The main uses and activities to promote on the dumps include: • Astro Turf development for football fields and other games; • Recreational facilities; • Event centre; and • Amusement/public park. Management activities will cover: • Supervision of the development of planned uses of the capped dump; • Activities and uses by the allocated private operators; and • Continuation of the capped dump monitoring and management. Ministry of Sanitation & Water Resources 23 December 2018 Abloragyei Dumpsite Capping Project Final ESIA CHAPTER FOUR Analysis of Alternatives � ‘No Project’ Alternative � Types of Capping Material � Sourcing of Laterite for Capping � Pre-Cap Dump Heights � Thickness of Core Capping Material � Post-Cap Dumpsite Use Scenarios � Handling of Methane Gas Produced � Leachate Treatment Alternatives Ministry of Sanitation & Water Resources 24 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 4.0 ANALYSIS OF ALTERNATIVES The project alternatives considered and analyzed in order to select preferred alternatives included the following: 1. ‘No project’ alternative; 2. Types of capping material; 3. Sourcing of laterite for capping; 4. Pre-cap dump heights; 5. Thickness of core capping material; 6. Post-cap dumpsite use scenarios; 7. Handling of methane gas produced; and 8. Leachate treatment alternatives. 4.1 ‘No Project Alternative The primary object of the project is related to leachate and waste pollution affecting the Odaw channel through the Dakobi Stream. However, the Abloragyei dumps present other serious health and environmental problems as well as other attendant social and economic costs for Abloragyei and other surrounding communities. The unsightly nature of flowing leachate and windblown litter from the high plastic waste content of the waste, adverse visual intrusion from the mountain of waste, and the emanating bad odour from the poorly managed dump are some key detestable features of the dumps. The poor surroundings give little value to the area and property in the area, especially as neither a development scheme exists for the area nor planning/building approvals for developments. The flow of leachate within the community increases danger to humans and livestock. The abundant flies and also rodents, scavenging birds and humans, and the prevalence of parasites due to unsanitary conditions give rise to common infections. These include recurring malaria and intestinal worms, as well as upper respiratory infections from the persistent burning and smoke emission, among other health problems. The above constituted some of the major sources of discomfort to the nearby communities, leading to vehement protestation against the presence of the dump. The risk factors, including vectors like mosquitoes, flies and other vermin, causing communicable diseases (e.g. malaria, diarrhea diseases, acute respiratory infections, hepatitis, etc. as described under impacts), would continue to show an upward trend if there is ‘no project’ implementation. Also risk factors like hazardous chemicals in the leachate are likely to increase risk of non-communicable diseases like malignancies. On the other hand if the project is implemented: • Pollution of the Dakobi Stream and the Odaw by leachate and waste would cease; • The risk factors contributing to the serious health outcomes and exposures of the population, especially to malaria, upper respiratory infections, etc. would come down; • Value of land and property in the area would rise, as the area would begin to benefit from development controls and a planning scheme; and • Abloragyei and Pantang communities and other residents would live at peace with GEMA. Ministry of Sanitation & Water Resources 25 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 4.2 Type of Capping Materials Clay and laterite were the two main alternative materials considered for core capping, in order to select the preferred option. The main consideration is to use soils that would avoid percolation of water, hence a desired feature of a suitable soil should be one that is impermeable or able to control water infiltration. Other features included ability to: • Prevent intrusion into the wastes; • Control the emission of build-up gas; • Be stable to erosion; and • Resist attack by roots. 4.2.1 Clay Core Alternative for Capping Clay is naturally occurring, made up primarily of fine-grained crystalline minerals below 2μ, which is plastic within an appropriate moisture content range. For capping purposes, clay is robust and relatively dense. It also has the capacity to absorb cations and anions from leachate. However, certain features of clay could impose limitation in its use as capping material, including the following: • Susceptibility to shrinkage and swelling; • Susceptibility to leachate attack; • Protective covering required to avoid dehydration; and • Weather conditions influencing workability, compatibility and stability. The capping works would involve stockpiling (storage) of the material, loading onto trucks for even spreading on the dump, followed by levelling of the material and series of compaction. Clay could present a challenge with ease of working with; once stockpiled for a period could form larger lumps. This will make it difficult to re-load onto trucks, and for even spreading on the dump. Again, levelling the spread clay with rollers and compacting to given consistent thickness could also be problematic. 4.2.2 Laterite Core Alternative for Capping Laterite is also naturally occurring, generally with low hydraulic conductivity, adequate shear strength and minimal shrinkage upon reduction of moisture content. Additionally, the following properties of laterite are obvious advantages as a capping material: • Better workability; • Adequate chemical resistance; • Low dispersivity; and • Adequate attenuation/retardation capacity. 4.2.3 Preferred Capping Material Laterite, with a good plasticity is a preferred choice as capping material. It will be relatively stable, not crack, easy to work, spread evenly on the dump and to level and compact to attain consistent thickness. 4.3 Sourcing of Laterite for Capping Two alternative sources of laterite are considered - laterite sourced from the natural environment in burrow pits and as excavated spoil from construction sites (especially in deep excavated foundations for heavy infrastructure construction). Ministry of Sanitation & Water Resources 26 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 4.3.1 Laterite from the Natural Environment This option considers sourcing laterite and loamy soils entirely from the natural environment. The common tendency could be to obtain the materials from any convenient sources irrespective of fragility or sensitivity of the area (e.g. forest or agricultural lands or banks of water bodies), without EA approval, perhaps in an attempt to save time, in meeting project schedule. The extraction of such large volume of soils could lead to significant impact on the natural environment with ecological, hydrological and socio-economic consequences, including pollution of water resources, degradation of natural habitats and prime agricultural lands, etc. Unfortunately, also, the unavailability of ready approved sources of supply of laterite and loamy soil by contractors, unlike quarry materials, etc. is a major concern. This is because it is often unappealing for a single project’s limited laterite need to have to go through the EA process for approval. Furthermore, a long haulage distance, involving some 1,500-truck trips (with 45m3 capacity truck), to the project site could cause significant vehicular traffic impacts and increase the risk of accidents. This is beside emissions impacting air quality and carbon foot print on climate impacts. 4.3.2 Laterite from Excavated Spoil Sources Excavated spoil from construction sites are often dumped in inappropriate locations such as wetlands and stream channels or depressions or some isolated areas. This irresponsible waste disposal practices is because most MMDAs do not have provisions or designations for construction waste disposal. Such inappropriate excavated waste disposal create several environmental problems, including obstruction of water flow, reduced water holding capacity, perennial flooding during the raining season, etc. The excavated materials may however, contain useful materials, including lateritic soils with varying amounts of clay and sandy loam clay soils which will be useful for the dump capping, as was the case (in significant part) in the Kpone dump capping. A selective mechanism will however, have to be in place for testing and selecting the best material. Using the excavated materials from construction sites will mitigate the environmental damage associated with the practice of inappropriate disposal. Given the huge amount of materials required, however, it may be difficult to obtain the materials entirely from construction site excavations over a short period of time. 4.3.3 Preferred Sourcing from Both Sources The preferred option would be to source the capping materials partly from the natural environment and excavated spoil (from construction sites). The potential environmental damage from natural environment sourcing would be minimal or mitigated since materials would come from approved sources only; while safeguarding the environment by using excavated waste materials, otherwise destined for environmentally unsound disposal. 4.4 Pre-Cap Dump Heights The total area covered by the dumps is 20.52ac, with Dump 1 covering 12ac and Dump 2 covering 8.52ac. The average ground elevation (AGE) of Dumps 1 and 2 are 70.00m and 65.00m above MSL respectively. The dump areas are delimited by residential structures that have encroached, Therefore there is not much room for extending the surface area of the dumps, hence variation in height of the dump after levelling is inversely proportional to the surface area (holding the volume of waste constant). Ministry of Sanitation & Water Resources 27 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Dump 1 Height Options The four dump height options (prior to capping) considered for Dump 1 and evaluated in Table 4.1 included the following: • 78.5m above MSL (corresponding to a dump area of 8.30ac); • 77.5m above MSL (corresponding to a dump area of 9.49ac); • 76.5m above MSL (corresponding to a dump area of 12ac); and • 75.5m above MSL (corresponding to a dump area of 13.28ac). Table 4. 1 Evaluation of Dump 1 Height Options Height (m) Height Corresponding Area Gained / Evaluation of Options Above MSL (m) Above Surface Area Lost (Acre) AGE (Acre) 8m high pre-cap dump will make available 3.7ac area around the dump for dump-toe infrastructure. The 78.50 8 8.30 3.70 elevated height, however, presents safety risk for machinery and personnel during capping and post-cap, as well as risk of accelerated dump erosion Dump height 7m also provides 2.51ac space for dump- toe infrastructure, but high enough and presents safety 77.50 7 9.49 2.51 risk for the capping and post-cap activities, and also potential high risk of erosion 6m high corresponds to the largest dump surface area, with relatively minimal safety risk in terms of working 76.50 6 12.00 0.00 height (capping, and post-cap) operations, also with minimal risk of erosion along dump slopes A 5m dump height would present the safest working height (capping, and post-cap) operations, and the least 75.50 5 13.28 -1.28 erosion risk along dump slopes. However, the lack of space around the dump makes height reduction to 5m non-feasible The preferred pre-cap height for Dump 1 is therefore 6m high dump (above AGE), which corresponds to 76.50m above MSL. Dump 2 Height Options The Dump 2 pre-cap height options considered were as follows (and further evaluated in Table 4.2): • 67.68m above MSL (corresponding to 8.52ac dump area); • 69.00m above MSL (corresponding to 5.71ac dump area); and • 70.00m above MSL (corresponding to 4.71ac dump area). Table 4. 2 Evaluation of Dump 1 Height Options Height (m) Height Corresponding Area Evaluation of Options Above MSL (m) Above Surface Area Gained AGE (Acre) (Acre) 2.68m high corresponds to the current average dump height, and largest dump surface area, with the minimal safety risk in 67.68 2.68 8.52 0.00 terms of working height (capping, and post-cap) operations, and also the least erosion risk along dump slopes 69.00 4.00 5.71 2.81 4m dump height will provide 2.81ac space for dump-toe Ministry of Sanitation & Water Resources 28 December 2018 Abloragyei Dumpsite Capping Project Final ESIA infrastructure, but relatively high enough to present safety risks for capping and post-cap activities, and as well as some potential erosion risk. Pre-cap dump height of 5m will make available 3.81ac area around the dump for dump-toe infrastructure. However, this 70.00 5.00 4.71 3.81 presents some relative high safety risks for capping and post- cap activities, as well as risk with dump erosion The preferred pre-cap (dump levelling) height for Dump 2 is therefore 2.68m high (above AGE), which corresponds to 67.68m above MSL. 4.5 Thickness of Core Capping Material The alternative thickness of capping material considered were 6-inch (as given in the project ToR) and 30-inch core of capping material. Examples of capping of landfills show that the thicknesses is often accordance to the design of the class of landfill. Generally, however, the capping thickness should not be less than 20 inches (about 0.5m). The dumps at Abloragyei are quite old; active dumping started in 1998 and closed in January 2018. A significant portion of the organic content could already have decomposed. Also the practice of open and constant burning of the dump implies that most combustible fractions of the waste (including organic materials) would be largely unavailable for anaerobic digestion. With such characteristics, a 6-inch core of capping material, overlaid with loamy soil and then grassed would be quite suitable. The following were however, key considerations that informed a preference for a 30-inch core cap: need to withstand erosion over long-term, resist attack by roots, prevent ease of intrusion into the wastes and emission of build-up gas, as well as being consistent with international good practice (i.e. not less than 20 inches core cap). Furthermore, under ideal conditions, a capped landfill would lie fallow for a period between 10 to 30 years, to ensure the gas build up is fully dissipated. This ensures safety against potential drop in height of the dump, following the void created as the built up gas disperses. Structures on the dump could collapse if the dump is not allowed to stabilize before use. Given the high state of eagerness of stakeholders, particularly the Ga East Municipal Assembly, to convert the capped dump into some immediate beneficial use, a 30-inch core cap would support such future developments without readily penetrating the waste. Also the post-cap fallow period could be up to 3 years for this dump, on the basis of the expected limited and short period of gas generation. 4.6 Post-cap Dumpsite Use Scenarios The post-cap development and use options as expressed by the stakeholders (particularly GEMA) and considered, included: Astro-turf (improved football fields), other recreational facilities such as Event Centre and Amusement Park, and also community market and lorry station. The development scenarios based on relative space allocation, potential revenue generation and stakeholder preferences are presented in Table 4.3. In order to ensure sustainable aftercare management of the capped dumps, it was desirable to allocate the spaces and facilities to operators for commercial operation to generate adequate revenue. These operators would be levied by the Assembly accordingly. Though Community Market and Lorry Ministry of Sanitation & Water Resources 29 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Station were among the felt needs of stakeholders, these activities were however opposed to by other property owners in the area. The main concern was that Community Market and Lorry Station generate a lot of waste, and could potentially result in the area returning to its previous state as a waste disposal site. The preferred development scenarios therefore eliminated options providing spaces for Community Market or Lorry Station as follows: • Preferred development option for Dump 1 is the Alternative 1; and • Preferred development option for Dump 2 is the Alternative 1. Table 4. 3 Alternative Development Scenarios Key Developments Description Dump 1 Dump 2 / Facilities Alternative Areas Alternatives Areas Allocated (Acres) Allocated (Acres) 1 2 1 2 1. Game Centre Astro Turf development for Football fields 4 5 - 1 and other Games 2. Recreational Facilities Event Centre 2 - 3 - Amusement/Public Park 4 2 3 - 3. Community Market Market Sheds - 2 - 3 4. Lorry Station Station Lots (Lorry Station) - - 3 5. Space for other uses Access roads, Gas vents and other 2 3 2 1 structures (including advertisement and beautification), etc. Total Area 12 12 8 8 4.7 Handling of Methane Gas Generated The informal dump was routinely set on fire. Burning combustible fractions of the dump (including organic components), meant that only relatively low organic content would be available for anaerobic digestion and gas production. Thus, not much gas production could be expected, either over any significant period of time post-cap, nor to justify elaborate investment for capturing the gas for any beneficial use. The preferred option would be to flare the limited gas releases from the installed gas vents. 4.8 Leachate Treatment Alternatives The current 0.1m3 average daily generation of leachate, showed elevated concentrations of Lead, Ammonia and Phosphate and other parameters significantly above EPA recommended guidelines (Table 4.4). Table 4. 4 Elevated Parameter Levels in Leachate High Reading Pb PO4 NH3 BOD COD Cond Turb TSS Parameters (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (µS/cm) (NTU) (mg/l) Sampling Point with 0.285 73.6 865.00 1514 6624 26500 1310 1210 Highest Values EPA Guidelines 0.1 2 1 50 250 1500 75 50 Consultations with the Waste Management Department of TMA and TESL indicated that a recently capped dumpsite at Mallam, and also the Kpone old dump show almost dry leachate collector channels and sumps (after one year). Very limited leachate generation occurs even in the rainy season, most of which tend out to be runoff. Ministry of Sanitation & Water Resources 30 December 2018 Abloragyei Dumpsite Capping Project Final ESIA A common mechanism of leachate treatment involves collection in sumps and recirculation (on a section of the deposited waste) to allow for dispersion and treatment through natural stabilization processes on the dump/landfill. The process will result in a more rapid stabilization of the organic fraction due to the accelerated growth of anaerobic bacteria population; and also with increased moisture content of the waste will result in a corresponding maximized anaerobic microbial activity. The preference for leachate recirculation treatment process is for the following reasons: • No need for additional space, • No disposal difficulties with treated leachate; • Avoidance of expensive treatment facility for only limited leachate generation, and for a relatively short duration of less than 2 years; and • Rarity of leachate treatment facilities in Ghana and potential high risk of operational and management failure. 4.8.1 On-site Leachate Treatment Alternative About half an acre section of Dump 2 would be left uncapped, and reserved for the leachate recirculation process. The collected leachate would be pumped to this recirculation area of the deposited waste on Dump 2 to undergo dispersion and natural stabilization processes. However, the limitations to an on-site treatment are mainly problems with: • Leachate odour, especially during the post-cap/aftercare management phase when the area is converted into recreational use, and affecting neighbouring residents: and • Leaving a portion of the dump exposed (not capped), would allow rain water infiltration, generating more leachate, which would become a permanent feature of the capped dumps, with associated problems. 4.8.2 Off-site Leachate Treatment Alternative The leachate will be evacuated and transferred in a cesspit emptier 40km to TESL, where it would be sprinkled onto the solid waste in the cells to allow for dispersion. Leachate in the cells is pumped into the first lagoon (anaerobic lagoon), which then flow by gravity into the facultative 1 lagoon, and continues into the final one (facultative 2). From the facultative 2 lagoon, the leachate is re-circulated onto the solid waste in the cells, which aid in the decomposition and settlement of the organic waste, while some of the treated leachate is use to abate dust on the access roads and the working phase at the landfill 4.8.3 Preferred Leachate Treatment Option The preferred off-site leachate management alternative of evacuation and transfer to TESL to be managed together with the landfill leachate would render the Abloragyei leachate generation and management only a temporary activity; as compared to an on-site option which would be largely a permanent feature of the dumpsite. Ministry of Sanitation & Water Resources 31 December 2018 Abloragyei Dumpsite Capping Project Final ESIA CHAPTER FIVE Environmental and Social Baseline Conditions � Geographic Location � Physical Features � Historical Context of Dump Development � Current State of Dumpsite � Waste Composition and Heavy Metal Concentration � Road Network and Traffic. � Health Data Ministry of Sanitation & Water Resources 32 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 5.0 ENVIRONMENTAL AND SOCIAL BASELINE INFORMATION The environmental and social baseline information covered the following broad areas: • Geographic location; • Physical features; • Historical context of dump development; • Current state of dumpsite; • Status of land ownership; • Socio-economic activities; • Waste composition and heavy metal concentration; • Road network and traffic; and • Health data 5.1 Geographic Location The Ga East Municipality is located at the northern part of Greater Accra Region and covers a land area of about 85.7km2. The municipality shares boundaries with the Ga West Municipality to the west, La- Nkwantanang Municipality to the east, Accra Metropolis to the south and the Akwapem South District to the north (Figure5.1). Figure 5. 1 Map of Ga East Municipality 5.2 Physical Features 5.2.1 Climatic Conditions (Rainfall and Temperature) The municipality lies in the savannah ecological zone and has a bi-modal rainfall pattern. The mean annual rainfall ranges from 790mm to1288.1mm. Annual average temperature ranges from 25.1 oC in Ministry of Sanitation & Water Resources 33 December 2018 Abloragyei Dumpsite Capping Project Final ESIA August and 28.4oC in February and March. February and March are normally the hottest months. A 5- year interval (2007, 2012 and 2017) rainfall and temperature patterns for the area are illustrated in Figure 5.2 and 5.3 respectively. 250.0 200.0 150.0 100.0 50.0 0.0 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 2007 2012 2017 Figure 5. 2 Five-Year Interval Rainfall Pattern 45.0 40.0 35.0 30.0 25.0 20.0 15.0 10.0 5.0 0.0 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 2007 2012 2017 Figure 5. 3 Five-Year Interval Average Temperature 5.2.2 Vegetation The vegetation of the municipality is shrub and grassland. The shrub lands occur mostly in the western outskirts and in the north towards the Aburi hills and consist of dense clusters of small trees and shrubs that grow to an average height of about 5m. The grassland is located to the southern parts of the municipality. There are isolated shrubs and thicket vegetation close to the dumpsite. 5.2.3 Drainage and Hydrology/Water Resources The Dakobi Stream is located in the municipality and discharges into the Odaw. The stream is located about 700m westwards of the dumpsite. The Dakobi is used for activities, such as washing of cars and swimming. Leachate from the dump flows into a drain that connects to the stream (Figure 5.4A). The leachates also pond at various sections, particularly at the south-eastern portion of Dump 1 and around Ministry of Sanitation & Water Resources 34 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Dump 2. There is a marshland (Figure 5.4B) on the western boundary of dump 2. About 6 hand dug wells (covered) are located within the immediate vicinity of the dumpsite. A. Earth Drain that Connects to the Dakobi B. Marshland on the Western Boundary of Dump 2 Figure 5. 4 Drainage Systems close to Dump 2 5.3 Historical Context of Dump Development 5.3.1 Origin of the Dumpsite The Abloragyei dumpsite and surrounding area, measuring about 50 acres of land was originally acquired by GoG for the operations of the erstwhile Ghana Post and Telecommunications (P&T) Corporation, from the Ablor family in the 1960s. The land was however, turned into an illegal sand winning area, consisting of numerous sand pits. Following closure of the Ogbojo Dumpsite, and the urgent need for a new dumpsite, the then Ga District Assembly converted the area into a dumpsite. Dumping of waste at the Abloragyei site began in 1998 and officially closed in January 2018. 5.3.2 Ownership of Dumpsite and Surrounding Land The effective area of the dumpsite is now about 20.52 acres, consisting of two separate dumps; and delimited by development of houses and other structures, due to the takeover of the land surrounding the dumpsite by the Ablor family. The footprint of the old dumpsite of almost 12 Acres (Dump 1), is owned by the Ga East Municipal Assembly (GEMA); while Dump 2 of about 8.52 acre land was acquired in 2006 by Amanee Waste and General Services Limited and Honest Waste Limited for waste disposal, from the Ablor family. Dumping at the Abloragyei site was officially closed in January 2018. Private developers started building on the area adjoining the dumpsite from 2005 without obtaining development permits from the assembly. Figure 5.5 shows satellite imageries depicting pattern of dumpsite change from 2007 to 2017. Dump in 2007 Dump in 2017 Figure 5. 5 Satellite Imageries of the Dump from 2007 to 2017 Ministry of Sanitation & Water Resources 35 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 5.4 Current State of Dumpsite 5.4.1 Properties on the Boundary of the Dump There are 79 structures with an estimated 200 people within a 25m radius from the boundary of the dumpsite. Table 5.1 gives a breakdown of the structures and Figure 5.6 shows uncompleted structure and shacks located on the boundary of the dumpsite. Figure 5.7 shows the positions of the structures relative to the dumpsite. Table 5. 1 Structures Located on the Boundary of Dumpsite Type of Structure Section Northern Eastern Southern Western Completed cement block 10 4 9 3 Uncompleted cement block 8 2 9 2 Foundation building - 4 - Shack 10 7 7 2 Total 29 13 30 7 Figure 5. 6 Uncompleted Structure and Shack Located on the Boundary of the Dumpsite There are 3 housing structures located on the dumpsite, which is currently unoccupied. Structures located 10m proximity to the dumpsite were considered as falling within a hazard zone. The 4 structures identified to be rather close to the dumpsite in this category all fell less than 10m from the periphery of the dumpsite. 5.5 Socio-economic Activities 5.5.1 Project Affected Persons There are 36 project affected persons (PAPs), made up of 25 PAPs who will be permanently affected and 11 PAPs who will be temporarily affected by the project implementation. The four types of project affected persons (PAPs) according to the nature of property affected and whether the impact is permanent or temporary are as follow: • Property affected/land acquisition (permanent) - o Structure (house) on the dumpsite (3 PAPs); o Toilet (2-seator) (1 PAP) o Parcel of land (3 Acres) adjoining Dump 2 (1 PAP); o Kraal (0.25 Acres) holding 45 cattle (8 PAPs); • Property in the hazard zone (temporarily affected) - o Two (2) houses occupied in the hazard zone (8 PAPs); o Two (2) houses unoccupied in the hazard zone (2 PAPs); Ministry of Sanitation & Water Resources 36 December 2018 Abloragyei Dumpsite Capping Project Final ESIA o Two (2) structures at foundation stage (2 PAPs) • Businesses temporarily affected - o Drinking spot (3 PAPs); o Food vendor (2 PAPs); o Bakery (3 PAPs); o Provision shop (2 PAPs); • Land temporarily acquired - o Land acquired (1 Acre) for storage of capping material (1 PAP). Figure 5. 7 Locations of Structures Relative to the Dumps 5.5.2 PAPs Engaged in Business Activities Business activities located close to the dumpsite are drinking spot, food vendor, bakery shop and provision shop. A kraal that occupies an area of about 0.25 acres and owned by 6 people with 2 herders is situated on the eastern section of the dump. Figure 5.8 shows some economic activities close to the dump. Business activities that are now flourishing were not patronized when the dump was active, due to presence of flies and smoke from the dump. Ministry of Sanitation & Water Resources 37 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 5.5.3 PAPs with Land and Structures There are 3 structures on the dumpsite, which are currently unoccupied. Four (4) structures are located 10m to the dumpsite, which is considered as the hazard zone. There is an elongated plot of land along the Dump 2 and a parcel of land beside a waste landfill container in the northern side of the Dump 1. Provision Shop Kraal Food vendor Figure 5. 8 Economic Activities close to Dumpsite 5.6 Waste Composition and Heavy Metal Concentration 5.6.1 Waste Composition The waste composition of the dump is as estimated in the Figure 5.9. This consists of about 45% organic waste as compared to the known composition for GAMA, which is about 60%. Plastics and rubber account to about 35% of waste compared to about 8% of GAMA’s waste. Construction waste (including excavated and dredged spoil) form 1% of the waste; relative to GAMA’s 4%. 70 60 50 40 30 20 10 0 Abloragyei GAMA Figure 5. 9 Mass Waste Composition of the Dump 5.6.2 Heavy Metals Concentration Dump surface and surrounding areas analysis from 57 sampling points (Figure 5.10) on and around the dumpsite identified some heavy metals. Table 5.2 shows the results of heavy metal analysis from Ministry of Sanitation & Water Resources 38 December 2018 Abloragyei Dumpsite Capping Project Final ESIA selected sampling point and the recommended WHO levels. Areas with high concentration of Pb, As, Co and Mn have been mapped out in Figure 5.11. The sampling areas on the south-western side of the Dump 1 showed high concentration of As and Co. High concentrations of Pb was found on the south- eastern, northern and south-western sides of the Dump 1, whereas Mn was detected mainly in the northern and southern parts of the previously dumped area. Figure 5. 10 Heavy Metal Concentration Sampling Point Locations 5.6.3 Leachate Quality Results for leachate analysis showed high concentration of Phosphate and Ammonia above Ghana EPA effluent guidelines of 2mg/l and 1mg/l respectively. The BOD, COD, Total Dissolved Solids and Turbidity were above the EPA guideline as shown in Table 5.3. The results also indicate that Arsenic, Chromium, Mercury and Copper were within the EPA guidelines values of 1mg/l, 0.5mg/l, 0.001mg/l and 5mg/l respectively. However, values for Lead were above EPA guidelines of 0.1mg/l at three sampling points (Points 1, 2 and 3). Table 5.4 outlines the results for heavy metal analysis in leachate. Figure 5.12 shows the sampling point locations. The average daily rate of leachate generation is 0.1m3, which discharges directly into the Dakobi. Ministry of Sanitation & Water Resources 39 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 5. 2 Heavy Metals Level on the Dump Sampling Points Pb Cr Co Fe Ti Mn Cu Zn Rb Zr Sr Mo Ag As_ Sn Sb 1 - - - 6255 2979 152 - 165 13 111 44 - - - - - 2 74 1190 4115 - 9016 - 569 372 90 182 36 44 - - - - 3 16 - - 727 - - - 58 20 31 23 40 - - - - 4 382 - 244 10881 3368 - 88 326 14 202 121 - - - - - 5 144 - - 15933 2383 685 232 999 24 153 297 - - - - - 6 67 - - 9962 14970 420 140 813 21 80 302 - - - - - 8 153 - - 18273 0 245 268 633 15 220 140 - - - - - 9 62 - 221 10374 1137 304 91 540 17 99 127 15 - - - - 10 912 - - 100531 1511 401 374 59 18 107 184 90 - - - - 11 116 - - 16689 2035 535 0 2297 0 156 152 - - - - - 12 49 - 199 7637 - 165 88 488 15 127 197 - - - - - 14 656 - 398 24765 2931 585 436 1240 48 245 231 - - 169 - - 18 50 - - 17209 - 143 63 179 74 235 35 - - - - - 19 91 - - 12697 - 188 198 186 28 156 33 - - - - - 23 - - - 5061 - - 57 - 12 66 9 - 62 - - - 24 94 317 326 11794 - 334 192 388 25 168 128 - - - - - 26 100 - 556 20269 - 189 112 236 24 209 91 - - - - - 27 1552 - 2504 - - - 2660 1927 35 32 105 - - - 598 1052 30 58 - 380 19571 - 423 111 1606 17 124 140 - - - - - 32 142 226 - 17623 2476 307 146 1160 26 179 218 - - - - 107 33 51 - - 12591 - 201 64 0 21 105 92 - - - - - 35 196 - - 16917 1878 242 1060 549 50 187 154 - - 39 - - 36 - - 467 17874 - - - 23 18 325 31 - - - - - 37 24 - - 7205 - - 45 101 23 64 36 - 61 - - - 39 14 - - 5937 - 121 49 - 14 266 94 - - - - - 41 56 - - 15540 - - 58 272 42 124 77 - - - - - 42 - - 395 17520 1828 161 0 118 9 234 51 - - - - - 44 290 - - 13304 - 333 148 561 11 158 110 - - - - - 46 40 - 438 24766 2434 234 82 528 13 202 77 - - - - - 54 42 - 1019 57646 2161 514 93 610 22 131 142 - - - - - 56 139 - 885 56196 4881 224 130 835 16 136 118 - - - 136 - 57 - - - 5923 - - - 33 7 70 43 - - - - - 58 23 - 229 14342 - 273 152 3269 32 154 122 - - - - - 62 27 - - 18335 3494 0 62 74 21 278 29 - - - - - Ministry of Sanitation & Water Resources 40 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 65 181 - - 26743 2839 324 268 1324 21 218 251 - - - 93 - 66 20 - - 24696 - - - 77 103 210 53 - - - - - WHO Guidelines 420 3000 24 543000 4300 16 57 75 34 0.53 **Results in ppm Arsenic Concentration Cobalt Concentration Ministry of Sanitation & Water Resources 41 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Lead Concentration Chromium Concentration Manganese Concentration Figure 5. 11 Distribution of some Heavy Metals on Dumpsite Ministry of Sanitation & Water Resources 42 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 5. 3 Physicochemical Analysis of Leachate Sample ID Cond Turb TSS NO3 PO4 NH3 BOD COD pH Units (µS/cm) (NTU) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) 1 8.11 21400 1280 1130 10.0 34.7 115.00 534 4048 2 7.88 16430 575 680 1.44 28.8 545.00 528 2320 3 8.03 26500 1310 1210 17.5 73.6 865.00 1514 6624 4 7.94 19110 790 905 3.75 22.0 534.0 910 3888 5 7.40 11200 278 251 0.625 8.11 472.0 51.0 824 5 7.70 5410 19.0 64.0 0.225 2.14 122.0 177 432 EPA Guidelines 6-9 1500 75 50 50 2 1 50 250 Table 5. 4 Heavy Metals Analysis of Leachates Sample ID As (mg/l) Mn (mg/l) Cr (mg/l) Pb (mg/l) Hg (mg/l) Cu (mg/l) 1 0.189 0.761 0.372 0.285 <0.001 0.657 2 0.149 0.766 0.199 0.114 <0.001 0.192 3 0.008 0.816 0.335 0.124 <0.001 0.38 4 0.026 0.640 0.219 0.015 <0.001 0.341 5 0.008 0.571 0.028 <0.005 <0.001 0.052 6 0.011 0.229 <0.010 <0.005 <0.001 <0.010 Ghana EPA Guidelines 1 - 0.5 0.1 0.005 5 The physicochemical results for water sampling showed that the pH, Nitrate, Phosphate and Chemical Oxygen Demand were within the WHO guidelines for drinking water for all the samples analysed. However, the results showed that the turbidity of samples from the Dakobi Stream were above the WHO guidelines of 5mg/l. Total coliform levels for the three wells were also above the WHO guidelines. Tables 5.5 and 5.6 show the results of physical, chemical and bacteriological analysis of water samples. Arsenic, Chromium, Mercury, Lead and Copper levels in the water samples were within the WHO guidelines for drinking water. Table 5. 5 Physicochemical Analysis of Water Sampled Sample ID Cond TC(cfu FC(cfu Turb TSS NO3 PO4 NH3 BOD COD /100ml) /100ml) pH (µS/c Units (NTU) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) m) Upstream Dakobi 7.50 918 20.0 24.0 0.069 0.185 0.931 7.42 51.2 - - Down Stream 7.57 1088 15.0 20.0 0.139 0.158 2.48 7.96 46.4 - - Dakobi Well 3 6.15 1770 4.00 4.00 1.39 0.060 <0.001 2.56 15.5 37200 1100 Well 1 6.42 944 1.00 5.00 2.02 0.072 <0.001 3.82 18.2 15200 0 Well 2 6.23 872 1.00 1.00 1.61 0.051 <0.001 4.00 20.2 1300 0 WHO 6.5- - 5 - 10 2.5 2.5 - 250 0 0 Guidelines 8.5 Ministry of Sanitation & Water Resources 43 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 5. 6 Heavy Metals Analysis of Water Sampled Sample Id As (mg/l) Mn (mg/l) Cr (mg/l) Pb (mg/l) Hg (mg/l) Cu (mg/l) Upstream Dakobi <0.001 0.20 <0.010 <0.005 <0.001 <0.010 Down Stream Dakobi <0.001 0.146 <0.010 <0.005 <0.001 <0.010 Well 3 <0.001 0.012 <0.010 <0.005 <0.001 <0.010 Well 1 <0.001 0.018 <0.010 <0.005 <0.001 <0.010 Well 2 <0.001 0.015 <0.010 <0.005 <0.001 <0.010 WHO Guidelines 0.01 0.4 0.05 0.01 0.001 2 Figure 5. 12 Leachate Quality Sampling Points 5.6.4 Leachate Quality Results and Analysis The pH of the leachate samples was in the alkaline range (7.40 and 8.11 pH units) and values were within the acceptable limit of 6–9 for wastewater (EPA-Ghana, 2001). The observed values might be attributed to the low degradation of organic compounds. The alkaline pH could come from the mineralization of hydroxides, carbonates and bicarbonates in the leachate, indicating the methanogenic phase of the dump (Maqbool et al. 2011). According to Umar et al. (2010), old landfill leachate has pH of > 7.5, while young leachate has a pH of 6.5, therefore, the Abloragyei dumps could be classified as old. High conductivity values were encountered, varying from 5,410 to 26,500μS/cm; far in excess of the EPA guideline value of 1500μS/cm. The high values might be attributed to the existence of dissolved ions from the decomposed inorganic and organic salt deposits percolating from the leachate flow (Egbi et al., 2015). The percolation of leachate into groundwater aquifers with elevated levels of electrical conductivity could Ministry of Sanitation & Water Resources 44 December 2018 Abloragyei Dumpsite Capping Project Final ESIA disturb the water and salt balance in children, aesthetic problems, laxative effects and increase the blood pressure of renal and heart patients (DWAF 2001). Turbidity reflects the transparency in water and is caused by the presence of substances in water. Except Site 6, which satisfied the EPA guideline of 75 NTU, the other sites exceeded this value (278 NTU for Site 5 and 1,310 NTU for Site 3). Except Site 6, which was relatively low (64.0 mg/L) in total suspended solids (TSS), all the other measured values (251 to 1,130mg/L) were above the EPA guideline value of 50mg/L. Concentrations of total dissolved solids (TDS) varied between 3,030mg/L and 14,840mg/L, exceeding the EPA guideline value of 1,000mg/L. The high TDS values might be due to the inorganic materials present in the leachate, indicating that the site might still undergoing biodegradation. These results are further reflected by the results of COD which suggest that the wastes are not totally degraded, and thus having high organic strength. High TDS in the groundwater close to the landfill sites was harmful to human health and might affect those suffering from heart and kidney problems (Sasikaran et al. 2012). In order to assess the nutrient status of the leachates, nitrate-N, ammonia-N and phosphates were determined. In the analyzed leachates, all the nitrate-nitrogen concentrations satisfied the EPA guideline value. However, concentrations of ammonia-nitrogen (89.3 - 672mg/L) and phosphate (236 – 349mg/L) grossly exceeded the EPA guideline values of 1 and 2mg/L, respectively. As observed for phosphate and ammonia, levels of COD and BOD in the leachates were far above the EPA guideline values of 250 and 50mg/L, respectively, with a range of 432 – 6,624mg/L for COD and 51.0 – 1,514mg/L for BOD. The presence of high COD in leachate indicates the presence of a threat of high contamination of ground water. With regards to the heavy metals, concentrations of arsenic, chromium and mercury were below the EPA guidelines. However, levels of lead from Sites 1, 2 and 3 (0.114 – 0.285mg/L) were over the EPA guideline value. The levels of Pb in the leachate could indicate the disposal of lead batteries, lead based paints, plastics, and pipes at the dumps. 5.6.5 Leachate Management Capacities The following facilities provide liquid waste management services that can potentially treat leachate: 1. Accra Sewage Improvement Project; 2. Tema Engineered Sanitary Landfill; 3. Zeal Environmental Technologies Limited; and 4. ZOIL Services Limited. Accra Sewage Improvement Project The Accra Sewage Treatment Project (ASIP) is located in the Accra metropolis and about 23km from the Abloragye dumpsite. The company was established in 2005 from the erstwhile Ghana Water and Sewage Company to treat municipal waste water. The facility provides services for industries which are close to their pipelines, such Accra Breweries. ASIP has a treatment plant at Legon. The facility handles only pre- Ministry of Sanitation & Water Resources 45 December 2018 Abloragyei Dumpsite Capping Project Final ESIA treated liquid waste using biological system. Therefore, for ASIP to handle the Abloragyei leachate would require pre-treatment of the leachate. Tema Engineered Sanitary Landfill The Tema Engineered Sanitary Landfill is located at Kpone and about 40km from the Abloragyei Dumpsite. The landfill was developed in 2012 under the Second Urban Environmental Sanitation Project with support from the World Bank, and was designed and envisaged to provide a well-managed and healthy disposal of solid waste. The landfill is managed by the Waste Management Department of the Tema Metropolitan Assembly and has the following facilities: • Four waste cells with provision for – o Gas harvesting facilities; o Special waste cell; o Lined leachate collection facilities; • Leachate and waste water treatment facilities • Wheel wash facility and recycler’s shed; as well as • Access and site roads, entrance control building and fencing; Special waste managed at the landfill includes: • Industrial waste; • Hospital waste; • Slug; • Chemical waste; and • Incinerator ash Treatment of leachate at the landfill involves an anaerobic lagoon and two other lagoons - facultative 1 and facultative 2 lagoons (Figure 5.13). HDPE pipes installed at the base in a sewerage manner in all the 4 cells and linked by gravity to cell 1 where a centrifugal pumping machine is installed. Through the pumping machine, the leachate reaches the first lagoon (anaerobic lagoon), which then flow by gravity into the second lagoon (facultative lagoon I), and continues into the final one (facultative II). From the facultative II lagoon, the leachate is re-circulated onto the solid waste in the cells, which aids in the decomposition and settlement of the organic waste, while some of the treated leachate is use to abate dust on the access roads and the working phase. Anaerobic Pond Facultative Pond I Facultative Pond II Figure 5. 13 Leachate Treatment Ponds Ministry of Sanitation & Water Resources 46 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Due diligence carried out to ascertain TESL’s suitability to manage additional leachate from the Aboragyei capped dumps revealed that: • The recirculation (centrifugal) pump required to pump leachate from the facultative lagoon II onto the solid waste in the cells was non-functional; • Due to non-functionality of the recirculation pump leachate from the facultative lagoon II sometimes overflow during heavy down pour (from both generated leachate and runoff); • In the dry season however, the lagoons operate at optimally; • Pumping machine draining leachate from the cells into the lagoons is also not operational; • Leachate therefore escapes from the cells into the surroundings; • There are no reading meters installed in the lagoons to help monitor leachate generation; • Environmental permit for the landfill was not on display, as required, and its availability or whereabouts unclear; and • Verification at the EPA indicated that the Environmental Permit for the operations had expired and yet to be renewed. A 2015 audit also reported of challenges with some lining materials in some of the cells. In spite of these difficulties, it was confirmed that given the limited leachate quantities under consideration (18m3 in 6 months from Abloragyei), the Kpone landfill could easily handle that in addition to its own generated leachate; more so if the necessary support is extended to TESL to fix the current challenges. The evidence supporting the assertion could readily be seen from the level of the leachate ponds (far less than ¾ full), even in the minor rainy season (Figure 5.13). Zeal Environmental Technologies Limited Zeal is located at Nyankrom in the Shama District of the Western Region, about 210km from Accra. The company has the capacity to treat between 400 to 600m3 and 50 to 100 tons of liquid and solid drilling wastes (including hazardous waste) respectively generated in the country’s offshore operatio ns daily, as well as transboundary oily waste from Benin, Togo, Liberia, Sierra Leonne, Mauritania and Equatorial Guinea. Other services include: • Processing and management of oil-based mud; • Processing of contaminated hydrocarbons and water; • Gas condensate processing management; • Incineration of hazardous materials; • Oil spill emergency response; • Supply vessels and oil rig activities support; • Confined space, vessel tank cleaning and inspection; • Oily and other hydrocarbons mixed with water recycling; and • Oil and gas pipe line cleaning. ZOIL Services Limited ZOIL is located at Nyankrom in the Shama District of the Western Region, about 210km from Accra. The company is capable of treating waste materials such as: • Crude oil tanker bottoms and marine waste; Ministry of Sanitation & Water Resources 47 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Drill cuttings; • Oily sludge; • Filter cakes; • Engine and hydraulic oil; and • Galley grease. The company specializes in oil and hazardous waste treatment, oil spill recovery services, tank cleaning and general oil and gas waste management advisory services. ZOIL has a state-of-the-art Anaerobic Thermal Desorption Unit (Figure 5.14), capable of treating up to 8 tonnes of drilling waste per hour. Figure 5. 14 Anaerobic Thermal Desorption Unit 5.7 Road Network and Traffic The dumpsite is accessible from the Pantang Junction (from the north-eastern section) and Ashongman Junction (from the northern section) respectively (Figure 5.15). The Pantang Junction, which is about 2.86km from the dumpsite is located along the Madina-Aburi Highway. The road from the junction to the dumpsite is a single carriage untarred road and has a width of about 7.5m. Pantang Junction Ashongman Junction Figure 5. 15 Access Routes to Dumpsites The Ashongman Junction is located along Ashongman-Abokobi Road. The link road from the junction to the dumpsite is single carriage untarred road and has a length of about 1.82km and a width of about 7.5m. Ministry of Sanitation & Water Resources 48 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Traffic count on the Abokobi-Ashongman Road heading towards Abokobi from Pantang and Ashongman (Figure 5.16) showed that private vehicles and light/medium trucks dominated the number of vehicles using the road. Traffic volumes were highest between 7am and 10am (with an average of 210 vehicles/hour). The average number of vehicles using this direction of the road per minute within the peak period was 2.7 (Table 5.7). Figure 5. 16 Traffic Census Points Table 5. 7 Summary of Traffic Data on Abokobi-Ashongman Road Time Traffic Volumes Day 1 Day 2 Average Volumes 6:15-7:00 0 119 59.5 7:15-8:00 128 171 149.5 8:15-9:00 181 210 195.5 9:15-10:00 151 128 139.5 10:15-11:00 110 138 74 11:15-12:00 87 106 96.5 12:15-13:00 89 109 99 13:15-14:00 81 103 92 14:15-15:00 127 135 131 15:15-16:00 210 105 16:15-17:00 177 88.5 17:15-18:00 78 39 Traffic count on the Abokobi-Ashongman Road approaching Ashongman from Abokobi showed that private vehicles dominated the number of vehicles using the road. Traffic volumes were highest between 7am and 10am (maximum of 285 vehicles/hour). The average number of vehicles using this direction of the road per minute within the peak period was 3.5 (Table 5.8). Ministry of Sanitation & Water Resources 49 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 5. 8 Summary of Traffic Data on Abokobi-Ashongman Road Time Traffic Volumes Day 1 Day 2 Average 6:15-7:00 55 194 124.5 7:15-8:00 285 245 265 8:15-9:00 184 210 197 9:15-10:00 165 158 161.5 10:15-11:00 145 139 142 11:15-12:00 128 140 134 12:15-13:00 115 128 121.5 13:15-14:00 133 133 133 14:15-15:00 148 154 151 15:15-16:00 153 148 150.5 16:15-17:00 178 192 185 17:15-18:00 98 174 136 Traffic count on the Pantang-Abokobi Road heading towards Pantang from the Aburi-Madina Road showed that private vehicles and light buses (Trotro) dominated the number of vehicles using the road. Traffic volumes were highest between 7am and 9am (maximum of 374 vehicles/hour).The average number of vehicles using this direction of the road per minute within the peak period was 3.7 (Table 5.9). Table 5. 9 Summary of Traffic Data on Pantang-Abokobi Road Time Traffic Volumes Day 1 Day 2 Averages 6:15-7:00 123 76 99.5 7;15-8:00 265 125 195 8:15-9:00 374 116 245 9:15-10:00 238 99 168.5 10:15-11:00 224 47 135.5 11:15-12:00 245 88 166.5 12:15-13:00 210 72 141 13:15-14:00 217 96 156.5 14:15-15:00 215 75 145 15:15-16:00 264 82 173 16:15-17:00 283 95 189 17:15-18:00 297 69 183 Traffic count on the Pantang-Abokobi Road approaching Pantang traffic light on the Aburi-Madina Road showed that private vehicles and light buses dominated the number of vehicles using the road. Traffic volumes were highest between 7am to 10am (maximum of 404 vehicles/hour). The average number of vehicles using this direction of the road per minute within the peak period was 3.7 (Table 5.10). Table 5. 10 Summary of Traffic Data on Pantang-Abokobi Road Time Traffic Volumes Day 1 Day 2 Averages 6:15-7:00 155 70 112.5 7:15-8:00 404 89 246.5 8:15-9:00 358 95 226.5 9:15-10:00 291 112 201.5 Ministry of Sanitation & Water Resources 50 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 10:15-11:00 263 60 161.5 11:15-12:00 225 87 156 12:15-13:00 217 67 142 13:15-14:00 217 79 148 14:15-15:00 247 81 164 15:15-16:00 297 65 181 16:15-17:00 266 87 176.5 17:15-18:00 286 76 181 5.8 Health Data 5.8.1 Top Causes of Out-patient Attendance for Ga East Municipality Commonly reported diseases at out-patients’ departments (OPD) clinic of government health facilities in the Ga East Municipality (where Abloragyei waste dump is located) were analysed. Malaria topped OPD attendance cases between 2013 and 2016. In 2017, it dropped to the second position. Acute Respiratory Infections (ARI) was the second reported OPD case from 2013 to 2014, however, anaemia became the second reported OPD case in 2015. From 2016 to 2017, ARI overtook anaemia to the second position again. Hypertension was the third reported OPD case for the same period, but was replaced by ARI in 2015 and skin diseases and typhoid respectively in subsequent years. The top 4 causes of ill-health reporting to health facilities over the 5 year period were malaria and sanitation related diseases namely upper respiratory infections, diarrhoea and skin diseases. These four diseases constituted 31% to 42% of OPD attendance. After a reduction from 2013 (66%) to 2015 (31%), there was a sharp increase to 42% in 2016, which coincided with one of the peak periods of dumping at the waste dumpsite. Thereafter, there is a reduction to 36% in 2017. This may be attributed to a reduction of activities at the dumpsite from early 2017. The top ten causes of morbidity in Ga East Municipality have been outlined in Table 5.11. Table 5.12 highlights the trends in the 4 most commonly occurring OPD cases (malaria, diarrhoea, upper respiratory diseases and skin infections. Table 5. 11 Top 10 Causes of Out-patient Attendance for Ga East Municipality 2013 2014 2015 Total No of % No of % Diseases Diseases Diseases cases % Cases cases Cases cases 1 Malaria 29169 43.4 1 Malaria 5576 17.8 1 Malaria 11189 16.3 Upper Respiratory 14.6 Upper Respiratory 17.8 9843 2 5562 Anaemia 1337 1.9 2 Tract Infections Tract Infections 2 Upper Hypertension 4750 7.1 3 Hypertension 1982 6.3 Respiratory 5946 8.7 3 3 Tract Infections 4.1 6.3 Acute Urinary Skin Diseases 2788 4 Skin Diseases 1975 2205 3.2 4 4 Tract Infection 3.8 8.0 Diarrhoea Diarrhoea Diseases 2579 5 Diarrhoea Diseases 2493 2055 3.0 5 5 Diseases Pregnancy Related 3.4 Pregnancy Related 5.0 2265 6 1547 Hypertension 1961 2.9 6 Complications Complications 6 Acute Urinary Tract 2.8 Acute Urinary Tract 5.4 1900 7 1694 Skin Diseases 1863 2.7 7 Infection Infection 7 Gynaecological 2.7 Gynaecological 5.6 Rheumatism & 1830 8 1746 1787 2.6 8 conditions conditions 8 Other Joint Ministry of Sanitation & Water Resources 51 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Pains Rheumatism & 2.7 Rheumatism & 4.6 1826 9 1447 Typhoid Fever 1275 1.9 9 Other Joint Pains Other Joint Pains 9 Pregnancy Typhoid Fever 1822 2.7 10 Typhoid Fever 1043 3.3 Related 1140 1.7 10 10 Complications 12.7 19.8 All other All other Diseases 8512 All other Diseases 6182 37835 55.2 Diseases Total 67284 100.0 Total 31247 100.0 Total 68593 100.0 Table 5. 12 Trends in the four most Common OPD Cases 2016 2017 No of % Data % Organisation unit No of Cases % cases Diseases Cases Cases 1 Malaria 22812 22.6 1 Malaria 23198 19.1 2 Acute Urinary Tract Infection 4490 4.5 2 Upper Respiratory Tract Infections 10344 8.5 3 Skin Diseases 4232 4.2 3 Hypertension 9293 7.7 4 Hypertension 3723 3.7 4 Rheumatism & Other Joint Pains 5847 4.8 5 Rheumatism & Other Joint Pains 3700 3.7 5 Anaemia 5510 4.5 6 Diarrhoea Diseases 3500 3.5 6 Skin Diseases 5219 4.3 7 Anaemia 3089 3.1 7 Diarrhoea Diseases 4900 4.0 8 Typhoid Fever 2572 2.6 8 Typhoid Fever 4316 3.6 9 Upper Respiratory Tract Infections 11806 11.7 9 Acute Urinary Tract Infection 3787 3.1 10 Septiceamia 1684 1.7 10 Diabetes Mellitus 2559 2.1 8 All other Diseases 39145 38.9 All other Diseases 46171 38.1 Total 100753 100.0 Total 121144 100.0 5.8.2 Trends in Diseases Associated with Poor Environmental Sanitation Some of the key conditions related to poor environmental management are malaria and sanitation related conditions, including diarrhoeal diseases, intestinal worms, skin diseases, acute /upper respiratory infections, typhoid. The 4 most commonly occurring of these diseases from 2013-2017 are shown in Figure 5.17. The general observation is that, while the cases reported at regional level (Greater Accra Region) showed downward trends over the 5 year period, Ga East had a stable or showed an upward trend. This may be attributed to a reduction of activities at the dumpsite from early 2017. It is likely that the presence of the waste dump is a contributory factor to these upward trends observed in the municipality. Trend For Malaria 800000 759404 700000 600000 Number of Cases 500000 449327 394522 400000 357162 342896 Greater Accra Ga East 300000 200000 100000 29169 22812 23198 5576 11189 0 2013 2014 2015 2016 2017 Years Ministry of Sanitation & Water Resources 52 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Trend For Skin Diseases 180000 165000 158947 150000 135000 115203 115068 120000 Number of Cases 100263 105000 95277 90000 Greater Accra 75000 Ga East 60000 45000 30000 15000 5219 2788 1975 1863 4232 0 2013 2014 2015 2016 2017 Years Trend For Diarrhoea Diseases 150000 140000 133443 130183 130000 125176 119586 120000 110000 104047 100000 Number of Cases 90000 80000 70000 Greater Accra 60000 Ga East 50000 40000 30000 20000 10000 3500 4900 2579 2493 2055 0 2013 2014 2015 2016 2017 Years Trend For Upper Respiratory Tract Infections 350000 320072 294995 300000 289576 269952 257222 250000 Number of Cases 200000 Greater Accra 150000 Ga East 100000 50000 9843 11806 10344 5562 5946 0 2013 2014 2015 2016 2017 Years Figure 5. 17 Trends in Sanitation Related Diseases Ministry of Sanitation & Water Resources 53 December 2018 Abloragyei Dumpsite Capping Project Final ESIA CHAPTER SIX Stakeholder Involvement � Rationale for Stakeholder Involvement � Key Stakeholders Engaged � Stakeholders Notifications � Consultation Outcomes � Public Disclosure Ministry of Sanitation & Water Resources 54 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 6.0 STAKEHOLDER INVOLVEMENT 6.1 Rationale for Stakeholder Involvement The Environmental Assessment Regulations, 1999 (LI 1652) underscore the need for stakeholder consultations in the EA process, failure of which may trigger public complaints to EPA and possibly Public Hearing. The World Bank Group’s Environmental Assessment Policy (OP 4.01) (1999) also addresses the requirements for stakeholder consultation as part of the EA process. The key principles are incorporated into the World Bank Environmental and Social Standard 10 - Stakeholder Engagement and Information Disclosure (ESS 10). Effective stakeholder engagement can: • Improve the environmental and social sustainability of projects; • Enhance project acceptance; and • Make a significant contribution to successful project design and implementation. 6.2 Key Stakeholders Engaged Table 6.1 gives the list of stakeholders that were engaged. The schedule and plan used for the stakeholder engagements is provided in Appendix 6. Table 6. 1 List of Stakeholders Engaged Category Stakeholders (Groups/ Individuals) Environmental Protection Agency Institutions Accra Sewage Improvement Project Project Affected Parties Residents Local Government Ga East Municipal Assembly Waste Landfill Co. Ltd Waste Management Companies Amanee Waste Ltd (WMCs) Honest Waste Ltd Tema Metropolitan Assembly, Waste Management Department (TMA, WMD) Capping Experience Tema Engineered Sanitary Landfill Pantang Psychiatric Hospital Health Facilities Abokobi Health Centre Traditional Authority Abloragyei Chief 6.3 Stakeholder Notifications The stakeholders identified through a mapping exercise were notified for a face-to-face engagement and/or multi stakeholder meetings. Table 6.2 provides the types of notification served the respective stakeholder groups. The notification or consultation appointment request letters are presented in Appendices 2 and 3. Table 6. 2 Stakeholder Notification Type of Notification Use Introductory letters Formal letters of introduction from the Ministry of Sanitation and Water Resources were sent to the municipal assembly introducing the consultant for the preparation of the ESIA for the Proposed Rehabilitation and Decommission of Abloragyei Dumpsite. Invitation letters Formal letters of invitation from the consultant were sent by hand to Amanee Waste Ministry of Sanitation & Water Resources 55 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Ltd, Honest Waste Ltd, Waste Landfill Co. Ltd, the Ga East Municipal Assembly, traditional authority and resident association informing them of the consultation process and proposing dates and time for face-face meetings. Another letter was sent inviting stakeholders to the disclosure workshop. Scoping Notice A Scoping Notice was prepared in English and posted at visible locations at the Assembly, dumpsite and in the community around the dump. The Notice provides contact details in order for stakeholders to provide comments on the project during the assessment process and even after the engagement meetings. 6.4 Consultation Outcomes Highlights of the issues from the stakeholder engagements and disclosure meeting are summarized in Tables 6.3 and 6.4 and presented in details in Appendices 6 to 8. Table 6. 3 Major Issues from the Engagements Stakeholder Key Environmental and Social Issues TMA WMD • Ideal material for capping is loamy clay and laterite • Post cap fallow period should be 10 years • Capped land could sink if structures are built on it immediately after capping. • Explosion may occur if methane gas is allowed to build-up • Leachate flow from capped dumps tends to dry up soon after capping – with examples such as Mallam and Kpone Old Dump showing no leachate flow at all (especially in the dry seasons) • What is observed in the rainy season tends to be runoff rather than leachate GEMA • After a fallow period of 3 years light structures could be erected and after 8 years other structure. • Security and fencing are very important so as to ward off potential encroachers and those who would want to come back to dump. Abloragyei • The original land was acquired by Government for P&T from the Ablor family in the 1960s Chief • Between the 1960s and 1998, the land was not utilised but turn into illegal sand winning pits • The Assembly converted illegal sand winning area into dumpsite to the displeasure of the Ablor family, since it was not the intended use of acquisition • The family took over the surrounding land of the dumpsite (Dump 1) and released to developers • The land for the other dump (Dump 2) was acquired by other waste management companies for waste disposal Residents • Flooding is a major issue at the dumpsite (leachate runoff) • Financial assistance would be preferred if there is the need for relocation PAPs • PAPs are in favour of closure and capping of the dump • Businesses around the dump (provision shop, bakery, drinking spot, food vendors) were not patronised when the dump was active due to flies and smoke from the dump • Kraal owners and cattle herders are willing to relocate EPA • A PEA is required for capping material sourcing but if in large quantities then an EIA may be required • A separate assessment process for laterite mining must be followed since it falls in a separate category • Unlike quarry materials where contractors have been permitted, laterite contractors are not common • Capping material should be stock piling at a designated area • Traffic assessment would be required • Enquiry about Environmental Permit status of the Kpone Landfill indicated that the permit had expired and yet to be renewed ASIP • ASIP is in the process of acquiring environmental permit Ministry of Sanitation & Water Resources 56 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Only pre-treated leachate can be treated at ASIP Tema • The landfill has special cells for leachate treatment (3 ponds; Anerobic Lagoon, Facultative 1 Engineered and Facultative 2 Lagoons) Sanitary • Challenges with the landfill include - Landfill o Non-functional centrifugal pumping machine o Overflow of leachate during heavy downpour o Daily pumping of leachates from the cells into the lagoons ineffective due to no- functional pumping machine o Unavailable Environmental Permit (required to be displayed) on site • Leachate from Abloragyei Dumpsites could be brought for treatment • The leachate would be sprinkled on the deposited solid waste which would eventually go through the leachate treatment system Health facilities • Traffic congestion could occur as a result of haulage activities • Workers are at risk of fall from height • Leachate could contaminate surface water Table 6. 4 Summarized Outcome of Joint Disclosure Meeting Stakeholder Issues of Concern/ Expectations Responses Residents Reason for reduction in open defecation This is because active dumping has ceased since Association January 2018, therefore the scavengers have left the area GEMA The ability of the capping material to prevent Laterite and loamy clay can resist infiltration to a infiltration large extent. Drains will be constructed to also channel water away from the capped area. Slopes will be grassed to also prevent erosion. Waste Landfill When will the vent pipes be decommissioned? The gas extraction will be monitored. When the Co. Ltd levels of gas have been exhausted then the pipes would be decommissioned. Amanee Will there be the need to re-dump at certain The material on the dump would be used to fill all Waste areas if some parts of the dump have to be depression so there would be no need to dump there filled? again. Abokobi Will the gas be harvested and sold? It is unlikely that the gas would be in commercial Assembly quantities so it would be flared Man Residents The potential for the site to become a dump The Assembly would manage the post cap land use Association again is high if the post cap land use is a activity so as to prevent the possibility of the area station. It’s a common thing for waste dumps becoming a dump again and this has been addressed to develop near vehicle stations since you in the assessment. have table top vendors coming to sell there. 6.5 Public Disclosure This draft report will be reviewed by EPA, with the opportunity for review input by the public. A 21-day public notice will be served through newspaper advertisement, indicating where copies of the report could be accessed and reviewed for EPA’s attention. The report will also go to the World Bank for review. Upon approval by EPA, copies of the final report will be circulated to GEMA including the Ministry of Sanitation and Water Resources and EPA library at the Head office for public access and information. The document will also be disclosed electronically on the World Bank’s InfoShop and Ghana's EPA website. Ministry of Sanitation & Water Resources 57 December 2018 Abloragyei Dumpsite Capping Project Final ESIA CHAPTER SEVEN Assessment of Environmental and Social Impacts � Opportunities/Beneficial Impacts ➢ Eliminate Leachate Pollution ➢ Eliminate Health Threatening Heavy Metal Exposure Sources � Potential Adverse Impacts ➢ Socio-economic and Livelihoods Impacts ➢ Risks to Successful Capping ➢ Public and Occupational Health and Safety Risks ➢ Potential Human Rights Abuse and Gender Disparity ➢ Potential Air Quality Impacts ➢ Risk of Leachate Contamination ➢ Risk to Successful Aftercare Management ➢ Risk of Explosion from Gas Build-Up ➢ Potential Collapse of Constructed Structures on Capped Dump ➢ Potential Degradation from Sourcing of Capping Material ➢ Potential Traffic Disruption and Associated Accidents Ministry of Sanitation & Water Resources 58 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 7.0 ASSESSMENT OF POTENTIAL IMPACTS The potential environmental and social impacts that could arise from the capping and aftercare management of the dumps, both beneficial and adverse impacts were assessed. The beneficial impacts included, elimination of leachate pollution of the Dakobi, and also health threatening risk factors and heavy metal hazard exposure of the affected population. The potential adverse impacts and risks were grouped under three main areas as follows: • Construction (pre-cap and capping) phase impacts - o Potential land acquisition, socio-economic and livelihoods impacts; o Risks to successful capping; o Public and occupational health and safety risks; o Potential human rights abuse and gender disparity; and o Potential air quality impacts. • Post-cap and Aftercare Management phase impacts - o Risk of leachate contamination; o Risk to successful aftercare management; o Risk of explosion from gas build-up in the capped dumps; and o Potential collapse of constructed structures on the capped dumps. • Capping material sourcing and haulage impacts – preliminary assessment o Potential degradation from sourcing of capping material; and o Potential haulage impacts. The likelihood of occurrence of adverse environmental and social risks and impacts associated with the project as well as the level of significance were evaluated, based on a modified methodology for assessing and ranking impacts adapted from the ISO 14001 Environmental Systems Handbook (Whitelaw, 2004). The ranking system used eight assessing criteria, qualitatively scoring ‘low’, ‘medium’ or ‘high’ scores for ranking variously the likelihood of occurrence and significance of particular impacts. The criteria included: • Level of risk of impact; • Knowledge about similar/past projects; • Actual or potential nuisance; • Spatial scale of impacts (spatial extent); • Time-scale of impacts (temporal extent); • Inducing future incompatible activities; • Legislative requirements and standards; and • Information availability. Level of Risk of Impact This looked at the probability of impact (or risk) occurrence (i.e. likelihood), and the likely consequences should an incident occur. It also assessed concerns such as whether there could be associated risks before and even after mitigation measures are taken (residual risks). Knowledge of Similar/Past Projects Ministry of Sanitation & Water Resources 59 December 2018 Abloragyei Dumpsite Capping Project Final ESIA The history of similar projects/operations in relation to various aspects of the capping project was applied. Aspects and related activities that have had environmental and social problems in the past would have a higher score, since they would have a higher likelihood of occurrence as compared to incident- free record of other activities. Likewise, aspects that generated complaints in the past were deemed significant. Actual or Potential Nuisance The criterion was based on actual or potential damage or nuisance to surrounding areas or recipients. Impacts addressed related to any potential nuisance resulting from the proposed activities to the public or other sensitive receptacle within the area of influence, such as the leachate haulage route. Spatial Scale of Impacts The criterion related to the spatial extent of impacts, grouping impacts (both direct and indirect) into local and regional effects. Local effects were those occurring within the local vicinity of the cause; regional effects extended beyond the locality of the cause (though still spatially limited); while national effects hoped to consider those occurring on a national scale (there was none). Time Scale of Impacts The duration over which impacts occurred or would be experienced was considered (duration of exposure). Impacts which were intermittent or occasional, but had no acute or long-term consequence were viewed as less serious than effects likely to occur frequently with serious and/or long-term consequences. Furthermore, occasional impacts, but which could have acute or long-term consequence was viewed as significant. Future Activities This considered the likelihood of induced activities or adverse situations that may arise in the future due to the presence of the project, and what the nature or scale of these potential activities or situations could be social- or environmental- or health-wise. The likelihood of future incompatible activities or situations around the area of influence that may defeat the objective of the project was also considered. Legislative Requirements and Standards The available legislation, policy, standards/discharge limits or guidelines in place to facilitate evaluation of significance and management of impacts were considered; where available the relevant aspects or impacts were considered less significant, or otherwise (where there were none in place) would be considered significant. Information Availability Where there was lack of information on which to base a satisfactory assessment, then the relevant aspect or impact was considered significant. In other words, knowledge gaps in the assessment meant it was based on inadequate information/data, potentially introducing a high degree of uncertainty, hence an evaluation of significance. Ministry of Sanitation & Water Resources 60 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 7.1 Beneficial Impacts 7.1.1 Elimination of Leachate Pollution The key focus of the project is to address the leachate drainage and solid waste pollution in the Odaw Channel, of which the Dakobi Stream is a tributary. Leachate from the Abloragyei Dumpiste, found to have high concentrations of Pb and other chemical compounds, among others continues to pollute the Dakobi Stream and groundwater in the surrounding area. The strong odour producing leachate also run through the Abloragyei community posing both environmental and health hazard to life (humans and livestock). Capping of the dump will entail collection and treatment, prior to disposal of the leachate; thereby eliminating leachate contamination of groundwater and surface water resources in the area, as well as the health risks posed. 7.1.2 Elimination of Health Risks posed by the Dumps A survey of concentration of heavy metals on the dump and surroundings revealed elevated levels of toxic element such as As, Co and Pb. Heavy metals could be picked up by cattle and other livestock that forage on the dump, and subsequently end up in the food chain and in humans. The health survey revealed that risk factors arising from the presence of the dumps, include vectors like mosquitoes and flies and vermin, which cause communicable diseases, such as malaria, diarrheal diseases, acute respiratory infections, hepatitis, etc. The potential risk of these diseases continuing to show an upward trend in the municipality exist. Other risk factors like the hazardous chemicals in the leachate could also increase the risk of non- communicable diseases like malignancies. The situation, however, would improve and revert to the regional trend in diseases associated with poor environmental sanitation, if the dumps are capped. 7.2 Construction (Pre-cap and Capping) Phase Impacts 7.2.1 Socio-economic and Livelihoods Impacts The developments that have surrounded and delimited the dumpsite include mainly structures for housing. Some of the structures literally sit on remnants of deposited waste (as can be seen on the foundations of some structures). These structures, without planning authorization sprang up and gradually pushed the dump to its present 20.52-acre space. The original owners of the land (the Ablor Family) indicated they resumed ownership of the land surrounding the dumpsite and gave out leases to interested persons to develop them. The capping of the dumps would displace about 36 PAPs. There will be nine (9) structures affected consisting of 3 permanent and 6 temporary affected structures, and also 2 parcels of land, one permanent and the other only temporarily affected (Figure 7.1). Additionally 4 businesses will be temporarily disrupted. The breakdown of PAPs and affected property include the following: • Property affected (permanent) - o Structure (house) on the dump (3 PAPs); o Toilet (2-seator) (1 PAP (owner)) o Parcel of land (3 Acres) adjoining Dump 2 (1 PAP); o Kraal (0.25 Acres) holding 45 cattle (8 PAPs); • Property in the hazard zone (temporarily affected) - o 2 Houses occupied in the hazard zone (8 PAPs); o 2 House unoccupied in the hazard zone (2 PAPs); Ministry of Sanitation & Water Resources 61 December 2018 Abloragyei Dumpsite Capping Project Final ESIA o 2 structures at foundation stage (2 PAPs) • Businesses temporarily affected - o Drinking spot (3 PAPs); o Food vendor (2 PAPs); o Bakery (3 PAPs); o Provision shop (2 PAPs); • Land temporarily acquired - Land acquired (1 Acre) for storage of capping material (1 PAP). Figure 7. 1 Structures on and around Dump These socio-economic, property and livelihoods impacts are all significant issues and trigger the World Bank’s Policy on Involuntary Resettlement. 7.2.2 Risk to Successful Capping Operation The following factors could disrupt the rehabilitation and capping activities and possibly frustrate project implementation, leading to resumption of waste dumping: • Delay in project financing or non-disbursement according to schedule; • Unavailability of capping materials or extended supply shortages; and • Equipment and machinery breakdown, and difficulty in timely replacement. Timely project financing or disbursement challenges could cause failure to successfully complete, breaking the implementation schedule, and leaving the site idle, which could immediately attract waste dumpers. The main contributory factors could include: Ministry of Sanitation & Water Resources 62 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Inability to secure the full project implementation budget; • Passive commitment and low level of accountability; • Ineffective or delayed disbursement (out of schedule, frustrating smooth implementation); • No sanctions for delayed disbursement or delayed schedule of work on the part of both parties; The difficulty in securing timely availability of capping materials could be due to inability to navigate the process of obtaining environmental permit to mine the materials from approved sites. The process could be lengthy and frustrating depending on the competency of the contractor performing the Impact Assessment, which could lead to delayed permitting. There could also be supply shortages if the source runs out of the desired quantity and quality of materials. These could cause serious project implementation delays, especially when capping materials would be most needed. Equipment and machinery such as bulldozers, compactors and grader which will be used, could suffer breakdown in such a mechanical-intensive project. Where difficulties exist in replacing parts or whole new ones on timely basis, could hamper work delivery, affecting effective covering of the dumps. Existing security arrangements have succeeded in warding off waste dumpers, but which would discontinue as soon as the project contract is awarded; with a high risk of dumping resuming if the dumpsite is found lying idle or ‘deserted’ for even a short period. The ranking of significance of causes of risk to successful capping is shown in Table 7.1. Table 7. 1 Significance of Risks to Successful Capping Potential causes of disruption Ranking and risks to capping operation Likelihood of occurrence Significance of impact Reason L M H L M H 1. Delay in or irregular project Failure to successfully complete financing or non- the decommissioning and capping disbursement (according to of dump. But World Bank source schedule) X X of funding, entailing close and structured releases and supervision, will ensure uninterrupted project 2. Equipment and machinery High frequency of breakdown, (on-site) breakdown and due to old age of machinery difficulty of timely X X However fixing and operating replacement them is quite routine and affordable 3. Unavailability or extended Project will delay as securing supply shortages of the environmental permit could be a capping materials X X limiting factor to ready supply of capping materials from approved sources L = Low M = Moderate H = High Ministry of Sanitation & Water Resources 63 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 7.2.3 Public and Occupational Health and Safety Risks Occupational Health and Safety Impacts There would be about seventy workers on the project who could be exposed to potential safety and health risks for up to 18 months. During the pre-cap phase (first 8 months), workers could be affected by: • Odour and volatile organic compounds (VOCs) from leachate, decomposing organic waste and faecal matter during pushing and levelling of the dump, etc. which may cause eye, nose, throat and lung irritation, dizziness and nausea. • Rampant mosquito bites resulting in increased transmission of malaria re-infection. • Marauding houseflies and other vermin could cause sanitation-related diseases such as diarrhoea, typhoid and worm infestation. Movement of construction machinery, trucks and operations on-site could result in knockdowns and run- over, by maneuvering (reversing, turning, etc.) trucks, careless driving, and speeding. The dumps contain waste substances such as broken glass and bottles, pieces of metals and other sharp objects that could be sources of danger in case of slips, trips and falls, and also piercing of workers during dump levelling, contouring, laterite spreading and capping-related activities. The tipping, storage, loading and spreading of capping materials could involve accidents with machinery and equipment use, affecting workers on the ground and dumps, and those directing operations. Accidents could also result from falling off the dump at a height of 6m. Musculoskeletal disorders commonly in the form of sprains and strains are very common among construction workers. Low back pain may occur as a result of repetitive forceful movements, awkward postures or over-exertion on the back of workers through lifting of heavy items. Use of cement with its irritant and corrosive properties, especially when wet, on the skin, and also, due to its alkalinity, moistened cement could produce eye irritation; allergic dermatitis; and severe blistering, and could therefore be harmful for construction workers. Servicing of vehicles and other equipment is expected to generate a considerable amount of waste oil which could cause dermatitis (inflammation of the skin) and other skin disorders when in contact with it. Waste oil inhalation may result in chemical pneumonitis (inflammation of the lungs). Noise and Vibration Impacts The use of compactors, bulldozers and excavators during construction, as well as vehicle engines could produce noise levels ranging between 74 – 88dBA within a 15m radius. The acceptable noise level on construction sites is 75dBA (EPA Guidelines). Workers near heavy equipment and machinery could be exposed to high noise levels for about 8 working hours per day, for up to 18 months. Prolonged exposure to such noise levels beyond 85dBA could impair the hearing of workers, especially for those working with or close to the noisy equipment. Similarly, prolonged exposure to vibration from these machinery over the period could result in whole body vibration (WBV). WBV is transmitted through the seat, feet or hands of workers who operate these machines over rough and uneven surfaces as a main part of their job. This in some cases could result in musculoskeletal disorders such as back pains. Table 7.2 presents the evaluation of significance of health and safety risks of workers. Ministry of Sanitation & Water Resources 64 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 7. 2 Significance of Occupational Health and Safety Risks Potential Sources of Ranking Occupational Health and Likelihood of occurrence Significance of impact Reason Safety risks L M H L M H 1. Accidents related to slips, Dump surface is replete with trips and falls, and broken glass and bottles, pieces of piercing of workers metals and other sharp objects, and uneven, hence accidents can occur X X easily. But only a handful of workers expected to mount and work/direct operations on the dump. Work will be largely mechanical 2. Falling off the dump Maximum working height of 6m is quite high and falling off could be X X disastrous. However, falling is not likely as the records of scavengers falling from such height are rare 3. Odour and VOCs, General malaise, eye, nose, throat recurring mosquito bites, and lung irritation, recurring houseflies and other X X malaria, and sanitation-related vermin illnesses. The most affected people are the nearby residents 4. Machinery, truck and Knockdown of workers. Only few vehicle operational X X people could be exposed accidents on-site 5. Lifting heavy items and Sprains and strains and low back awkward posture in X X pain which could occur over 8- constructional activities month period. 6. Contact (skin and eye) Irritant and corrosive (allergic with cement, especially dermatitis and severe blistering), wet cement X X and harmful to workers – only a handful of workers potentially exposed 7. Compactors, bulldozers, Prolonged noise exposure (8hr a etc. operating noise range day per day, for about 15 months) of 74 - 88dBA within a over the safety threshold would X X 15m radius lead to hearing impairment. Workers close to machinery are at a higher risk 8. Compactors, bulldozers, Prolonged exposure use (8hr a day rollers, etc. operating per day, for about 15 months) could X X vibration result in whole body vibration condition L = Low M = Moderate H = High Public Health Impacts Stench has been a longstanding problem for communities near the dumpsite; from 2010, for instance, the intense, offensive odour from the dumpsite gravely affected the Pantang Hospital and other communities, such that people even lost appetite to eat, especially during the rainy season. The population of vermin breeding and their activities stretched within 1km radius of the hospital, particularly the blue flies and house flies. Swarms of the blue flies were attracted to smell of food, and swarmed food preparation areas, Ministry of Sanitation & Water Resources 65 December 2018 Abloragyei Dumpsite Capping Project Final ESIA etc. The open burning of waste compromised air quality in the vicinity, with the hospital constantly engulfed in smoke that kept staff and some patients awake all night, which also provoked cases of cough and cold. The construction phase is expected to experience flies-fueled, sanitation-related diseases such as diarrheal diseases and typhoid. Also persistent inhalation of odour and VOCs could lead to some noted health problems. Throughout the period 2013 – 2017, 31% to 66% of OPD cases were caused by 4 communicable diseases: malaria, acute/upper respiratory tract infections, diarrheal and skin diseases. These are all conditions caused/aggravated by poor environmental and unsanitary conditions. Intense activity at the construction phase could equally trigger increase the presence of disease vectors (flies and mosquitoes) which have the potential to increase the transmission of the associated communicable diseases. Noise and Vibration Impacts Noise could also affect people (estimated 200) living in about 79 structures within the 25m buffer of the dumps (Table 5.1). This could result in annoyance and irritability and headaches and in susceptible persons could result in non-communicable diseases like hypertension and anxiety related mental conditions. The transient noise could also temporarily affect pedestrian communication. Evaluation of significance of health impacts is presents in Table 7.3. Table 7. 3 Significance of Public Health Impacts Potential Sources of Public Ranking Health and Safety risks Likelihood of occurrence Significance of impact Reason L M H L M H 1. Odour and VOCs from General malaise, eye, nose, throat and the dump during cutting, lung irritation and sanitation-related pushing, levelling and X X illnesses. About 200 people within spreading of capping the 25m buffer of the dumps would material be affected 2. Machinery, truck and Knockdown of people and livestock vehicle operational that freely roam the dump. The X X accidents on-site worksite will be closed off to the public 3. Compactors, bulldozers, Minimum distance of the working etc. operating noise range area to surrounding activity centres X X of 74 - 88dBA within a would be more than 30m, and noise 15m radius nuisance will be short-term 4. Mosquito bites and Intense malaria and sanitation-related houseflies from intense diseases cases, as well as fly nuisance initial activities on the X X dump (pushing, levelling, etc.) 7.2.4 Potential Human Rights Abuse and Gender Disparity Labour and working conditions are put in place to promote fair treatment, non-discrimination and equal opportunity for all workers. People will not be discriminated based on ethnicity, gender, religion, age, disability and HIV status during employment. Vulnerable people are also to be protected such as people Ministry of Sanitation & Water Resources 66 December 2018 Abloragyei Dumpsite Capping Project Final ESIA forced to work and women. Women in particular are under-represented in all construction occupations and activities, mainly due to cultural and structural barriers such as harassment and discrimination, limited networking opportunities and long and inflexible working hours. These often result in poor career prospects and high levels of stress for women. The existing economic activities women engage in, such as selling and provision of services, will be disrupted by the project. Women employees may be exposed to awkward situations when faced with sharing the washrooms or changing rooms with their male colleagues. They may feel they have no privacy and be uncomfortable. This could create a hostile working environment because women feel neglected or more inferior to their male colleagues. An estimated 50 workers (out of the total 70 workforce) would be expected to come from neighbouring communities like Adenta, Madina, Agbogba and Abokobi. There is the likelihood of workers striking acquaintance with and enticing female community folks with money to engage in casual sexual relationships. This could result in increased prevalence of HIV/AIDS infections and other sexually transmitted infections (STIs). Workers may be prohibited from joining trade unions of their own. This could result in intimidation, harassment, fear of reprisal from complaining and lack of collective bargaining power. The significance of the sources of human rights and gender abuse is presented Table 7.4. Table 7. 4 Significance of Human Rights and Gender Abuse Potential Sources of Human Ranking Rights and Gender Abuse Likelihood of occurrence Significance of impact Reason L M H L M H 1. Discrimination based on Vulnerable people such as ethnicity, gender, religion, women, children and the aged are age, disability and HIV under-represented in all status construction occupations and X X activities, mainly due to physical constraints, limited networking opportunities and long and inflexible working hours 2. Sexual abuse and harassment Enticement of female community folks by higher-earning workers, workers indulging in sexual X X activities with multiple partners leading to HIV/AIDS, STIs, unwanted pregnancies, etc. 3. Prohibition of unionization Intimidation, harassment, fear of X X reprisal from complaining, lack of collective bargaining L = Low M = Moderate H = High 7.2.5 Potential Air Quality Impacts The potential sources of impact on air quality during the capping phase would include: • Dust from tipping and stockpiling of capping materials; Ministry of Sanitation & Water Resources 67 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Dust from reloading and spreading of capping materials; • Dust from cutting, filling, pushing and levelling of dump; • Dust generation from construction of drains and road; and • Emission from construction machinery. The tipping and stockpiling of laterite and quarry dust will generate dust in the project site and the immediate environment. This will elevate the levels of PM10 in the project area. The nearby houses, shops, bakery, general public and the 70 workers on site who would be involved in the capping activities will be at risk of dust inhalation. Capping processes such as cutting, filling, pushing and levelling of dump will generate dust. The subsequent reloading, spreading, filling levelling and compaction of laterite and quarry dust would generate a considerable amount of dust on the project site. In addition, the construction of roads, drains and other facilities on the project site will also increase dust levels in the area. These activities will be of great health concern as dust smaller than 10 micrometre in diameter (PM10) can be inhaled deep into the respiratory system and cause health problems as well as temporary discomfort such as gritty eyes. The 70 workers on site, the nearby houses, shops, general public could be at this health risk and nuisance when exposed to dust in and around the site. Emissions from construction machinery such as bulldozers, excavator and compactor will increase emission levels in the project area. Fumes from machinery used for road construction will also add up to the gaseous emissions in the project area. The emissions from these activities will be of nuisance and health risk to the general public. The significance of the sources of air quality impacts is presented in Table 7.5. Table 7. 5 Significance of Sources of Air Quality Impacts Potential Sources of Ranking Air Quality Impacts Likelihood of occurrence Significance of impact Reason L M H L M H Dust from tipping and Tipping and stockpiling of 61,674 m3 of stockpiling of capping capping material will generate a lot of X X materials; dust, Nearby houses, general public and businesses could be affected Dust from reloading Reloading and spreading of 61,674 m3 and spreading of of capping material will generate a lot capping materials; X X of dust. However, only a few workers will be involved in reloading and spreading of the materials. Dust from cutting, Only a few workers will be involved in filling, pushing and reloading and spreading of capping X X levelling of dump; materials. Dust generation from Workers, worshippers and businesses construction of drains X X close to the dump could be affected. and road Emissions from Only a limited number of construction construction machinery X X machinery will be used. Emissions will be localized Ministry of Sanitation & Water Resources 68 December 2018 Abloragyei Dumpsite Capping Project Final ESIA L = Low M = Moderate H = High 7.3 Post-Cap Phase Impacts 7.3.1 Risk of Leachate Contamination This impact would manifest both at the pre-cap and post cap phases of the project and cover the following: 1. Potential contamination of the Dakobi and flood risks; and 2. Potential contamination risks of leachate in transit. Potential contamination of the Dakobi and flood risks Sections with even surfaces on the dumps could allow for high rainwater infiltration with corresponding high leachate flow, especially during the rainy season (of mean rainfall of about 70mm). The inadequate drains around the dumps have resulted in frequent flooding of the southern section of the Dump1 with pool of water around Dump 2. Leachate flows together with runoff through drains around the toes of the dumps in the western direction, into the Dakobi Stream, about 700m west of Dump 2. Figures 7.2 and 7.3 show the project area with marshland, drains, existing structures and some areas that experience flooding. Samples of leachate and water (from the Dakobi Stream and wells) showed elevated level of lead (Pb) above the EPA effluent guidelines for leachate, but within WHO guidelines for drinking water for the water samples. Figure 7. 2 Drains that Connects to the Dakobi Stream Ministry of Sanitation & Water Resources 69 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Figure 7. 3 Areas around Dumps that Experience Flooding The dump would continue to trap rainwater percolating into it during 10 months of the 18-month project period, and continue to release leachate into the Dakobi Stream. The rate of water percolation could even be higher in depressions created during cutting and levelling, and in the levelled areas, awaiting spreading of laterite and compaction. Compaction activities could lead to a much higher release of leachate. The capping of the dump, meant to create impervious surface to rainwater infiltration, would lead to the generation of about 5,229.27m3 of runoff from the capped dump in the peak rainy months of May, June and July. The cumulative effects of runoff from the north-eastern and south-eastern sections of the dump and excessive runoff from the capped dump could increase flooding situation experienced in the project area. The floods could have significant effects on the lives and properties of over 100 households in the south-eastern and north-western portions of the dumpsite. The flood could also erode and breach the lower portions of the capped dumps, and potentially wash leachate from sumps into the Dakobi Stream. The capped dumps could be susceptible to erosion even after grassing from increased surface runoff due to steep slopes. This could breach the capped dump at any weak points on the slopes, gradually forming sheet, and possibly gullies. Infiltration of the dump by rainwater could release more leachate, coupled with eroding runoff-laden decomposing waste, into the Dakobi, as well as adversely affecting the surrounding houses. Potential contamination risks of leachate in transit The transfer of leachate from the capped dumps to the Tema Engineered Sanitary Landfill (TESL) treatment facility at Kpone poses some potential environmental and health risks in terms of: • Deliberate diversion of leachate to dump at an unapproved location; and • Accidental release of leachate. Cesspit emptier truck drivers may divert truck-loads of leachate to other locations aside the Kpone facility to avoid travelling the about 40km distance. Persons who perpetrate this kind of unauthorized dumping usually dump their loads at various spots along the Accra-Tema Motorway, which is the easiest access from Abloragyei to Kpone. Most of the areas along the Motorway fall within the catchment of the Onukpawahe and Mamahuma Streams which drain into the Sakumo Lagoon that recharges the Sakumono Ramsar Site. The lead-laden leachate, if dumped at any of these spots, could end up in the streams and subsequently the Lagoon; with the potential of Pb being picked up by children who swim in the lagoon, fish and other aquatic biota. Lead, when it enters the human body in quantities above recommended levels can cause anemia, weakness, and kidney and brain damage. Very high lead exposure can cause death. Ministry of Sanitation & Water Resources 70 December 2018 Abloragyei Dumpsite Capping Project Final ESIA A cesspit emptier truck could spill its contents while in transit either as a result of it being involved in a vehicular accident or a failed containment system. Vehicular accidents could be the result of recklessness or over speeding on the part of the driver; whereas a failed containment system may be from poor truck maintenance or the truck being over-aged. Either of these incidences would cause foul-smelling leachate to be spilled in the immediate surroundings causing nuisance to the public. Table 7.6 outlines the significance of leachate contamination and human health risks. Table 7. 6 Significance of Contamination from Leachate Sources/causes of leachate Ranking contamination and flood Likelihood of Significance of Reason risk occurrence impact L M H L M H 1. Leachate generations Leachate release into the during capping and post Dakobi would be much higher cap. during levelling and compaction. Pb levels, from X X leachate analysis, were high, however, the levels of lead in Dakobi Stream sampled were within WHO recommended guidelines for drinking water. 2. Diversion of leachate Cesspit emptier drivers would want an easier way of dumping X X their load instead of going all the way to Kpone and to avoid paying a dumping fee 3. Accidental release or leakage Many cesspit waste management of leachate companies operate with old X X vehicles and do not enforce strict health and safety measures. 4. Flooding of lower Runoff from capped dump in portions of dumps as well addition to run off from project as leachate sumps X X area. This could breach the lower portion of the capped dump. 5. Erosion of surface and High runoff generation over a slopes of capped dump X X steep slopes during rainy season L = Low M = Moderate H = High 7.3.2 Risk to Successful Aftercare Management The Aftercare Management will involve mainly monitoring and quick remedial actions for effective post- cap management. Monitoring will include the following: Ministry of Sanitation & Water Resources 71 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Leachate flow and quality, transfer and treatment; • Gas emission monitoring; • Runoff and erosion breaches; • Storm water drain network; and • Changes in height of capped dump. The main potential risk to effective Aftercare Management would be lack of available of resources (mainly financial) to carry out the above listed activities, among others. The expected beneficial use of the capped dump will not only be lost, but the capped dump could fail. For instances, through run off and storm water, gullies could develop along the slopes and breaches to the dump bases, releasing both leachate and decomposing solid waste (assessed in detail at Section 7.3.1). A major threat of unavailability of funds to evacuate the leachate could lead to leachate overflow of the sumps that could cause pollution of the immediate neighborhood. This would defeat the very objective of the project. The nearby residents who find it convenient to dispose of their refuse on the dumps, could continue the practice of dumping in the area, even after capping. This would expose the area to the risk of resumption of dumping. The significance of potential causes of failed Aftercare Management and risk of resumption of dumping are presented in Table 7.7 Table 7. 7 Significance of Causes of Failed Aftercare Management Potential Causes of Unsuccessful Ranking Aftercare Management Likelihood of Significance of Reasons occurrence impact L M H L M H 1. Unavailability of funds for Substantial amount of money required leachate evacuation which may not be readily available. X X Leachate spill over would pollute Dakobi Stream and immediate environment. 2. Lack of resource for post-cap Continuous leachate overflow and erosion monitoring (residual) pollution of immediate environment as a X X and remedial action of dump result of lack of/ inadequate resources for breaches monitoring and required remedial action. 3. Lack of resource for post-cap Gas ignition and spontaneous combustion monitoring for remedial actions on the dump due to natural gas build-up • Gas vent pipes after constructing the vertical gas wells; • Leachate collector drains X X and over flow of leachate sump as a result • Leachate sumps of resources not readily available. • Runoff and storm water drains 4. Risk of resumption of dumping Due to close proximity to the dumps and the convenience of disposal, there is a high X X tendency to continue the practice by the neighbours. L = Low M = Moderate H = High 7.3.3 Risk of Explosion from Gas Build-up Decomposition of biodegradable waste in a dump generates a complex mixture of gases; the major ones being methane (64%) and carbon dioxide (34%), with the remaining 2% made of ammonia, hydrogen Ministry of Sanitation & Water Resources 72 December 2018 Abloragyei Dumpsite Capping Project Final ESIA sulphide and other trace gases. The gases are released on the open dump into the atmosphere. Gases can also migrate through soil over a distance of up to 80m and accumulate in confined spaces (Bour, Taffoureau and Therrien, 2014). The dominant methane gas, emitting from the dump could ignite and undergo spontaneous combustion on the dump. Landfills (in temperate regions such as Ireland) typically generate between 7 and 10 cubic meters of gas per annum for every tonne of waste deposited. This is for waste with a putrescible fraction exceeding 60% and under temperature conditions of 50C - 150C (average temperature in Ireland). Gas generation is mainly influenced by temperature, humidity, organic matter load of waste and age of the dump (Ireland EPA, 2013). Higher temperature, humidity and organic matter promote higher rates of gas generation; the quantity of gas however, reduces with age. For a dump volume of 361,345m3, the Abloragyei dumps is estimated to hold 151,765tonnes (15.2million kg) of waste, assuming a waste density of 420kg/m3 (UNEP, 2008). Gas generation (under Ireland conditions), would therefore be in the order of 1,062,355m3 – 1,517,650 m3 per annum, assuming a putrescible waste fraction of 60% [ the average for waste generated in Accra (Boadi & Kuitunen 2003)]. The dump is however, old (20years). The extensive, regular burning (a common practice with such crude dump), is expected to ash considerable portion of the organic content. Furthermore, a good fraction of the deposited waste consisted of sand and silt (from the E&S audit survey), which estimated the putrescible content on the dump as less than 45%, three-fourth of the 60% average. The per annum volume of gas generation on the dump could therefore, be expected to be about half or less of the ideal volume (given the higher temperature conditions) and emission duration over just a couple of years (about 3 years). Capping would prevent emission of the gases from the surface of the dump. Retention of the accumulated gases, especially methane, could result in explosion on the dump should there be an ingress of air into the capped dump. Explosion could also occur in buildings located up to 80m from the dump when methane gas migrates through the soil and accumulates in confined spaces in the buildings. Explosion and the resulting fires would cause injuries and loss of lives and also damage to properties. Short-term exposures (typically up to about two weeks) to elevated levels of ammonia and hydrogen sulphide components of landfill gas that find their way into nearby buildings can cause coughing, irritation of the eyes, nose, and throat, headache, nausea, and breathing difficulties. After mitigation provisions, the installed gas pipes (to vent the gas) could immerse in leachate, in the lower sections of the capped dump. The vents would then fail to evacuate the gas, which could allow the gas to accumulate leading to potential residual risk of explosion. A poor arrangement of the venting pipes could also result in uneven evacuation of the gas, allowing gas accumulation in some section, also with potential residual explosion risk. Table 7.8 presents significance of causes of explosion from methane gas build-up Table 7. 8 Significance of Causes of Explosion from Gas Build-up Potential Causes of Explosion Ranking from Gas Build-up in the Likelihood of occurrence Significance of impact Reason Ministry of Sanitation & Water Resources 73 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Capped Dump L M H L M H 1. Continuous generation and Accumulated, trapped methane in a accumulation of methane X X capped dump could explode. This within the capped dump would ignite fire and cause injuries 2. Poorly or inadequately Residual risk of explosion due to installed gas vents/ pipes for pipes submerged in leachate and managing venting of the gas. unable to function (evacuate the (Residual risk) gases). Only some of the pipes could be affected this way. X X Poorly arranged venting pipes resulting in uneven evacuation, hence gas accumulation in sections of the capped dump, leading to explosion. L = Low M = Moderate H = High 7.3.4 Potential Collapse of Constructed Structures on the Capped Dump Capped landfills in temperate regions (e.g. Ireland) are known to reduce in height by about 25% of their original height in a settlement process; with most settlement occurring in the first 5 years post-cap (Ireland EPA, 2003). Differential settlement is a result of decomposition of organic matter on the dump and attendant gas generation causing voids within the dump and consequently, uneven drop in height of the dump surface. Decomposition and gas generation process is directly affected by temperature, moisture and organic matter content. The Aboragyei dump being old (20years) and having undergone continuous burning; is expected to have low organic matter content. The period for maximum gas generation and settlement, therefore is expected to be far less (about 3 years) than the stipulated 5-year period. Differential settlement could pose damage risk firstly to capping infrastructure on the dump, e.g. the cap lining, leachate ponds, drain, access road, etc. A capped dump is estimated to require up to 20 years for complete settlement and stability adequate for construction of larger structures such as buildings. It will be risky and unsafe therefore to attempt developing heavy structures such as buildings on the capped dump soon after capping. Structures may collapse suddenly as a result of uneven settlement with fatal consequence. The evaluation of significance of causes of collapse of constructed structures on the capped dumps is given in Table 7.9. Table 7. 9 Significance of Causes of Collapse of Structures Potential Causes of Collapse of Ranking Constructed Structures on the Likelihood of occurrence Significance of impact Reason Capped Dumps L M H L M H 1. Gas evacuation and Rapid decomposition of organic associated creation of voids matter causing differential within dump settlement on dump with potential to unbalance and damage X X structures on the dump. Collapsed structure will cause injuries and lead to incurrence of financial cost 2. High demand to put capped In a haste to put capped area to waste dump to beneficial X X good use, developments end-use leading to rushed incompatible with after-cap land Ministry of Sanitation & Water Resources 74 December 2018 Abloragyei Dumpsite Capping Project Final ESIA development and associated use would be undertaken without challenges recourse to safety considerations L = Low M = Moderate H = High 7.4 Preliminary Assessment of Potential Candidate Site for Laterite Sourcing 7.4.1 Potential Degradation from Sourcing of Capping Material Laterite deposits are widespread in the Greater Accra and Eastern Regions of Ghana. The nearest natural sources to Abloragyei are in the Amrahia and Dodowa areas, as well as the upland areas on the Akwapem hills. An extensive area located at Amrahia (about 17km from the Abloragyei Dumpsite) in the Kpone Katamanso Municipality has been identified as a potential site for material extraction, based on proximity to Abloragyei. The proposed site is a fallow land with patches of thicket vegetation (Figure 7.4), which has suffered extensive surface degradation from sand wining over the past years, exposing the laterite layer beneath. The proposed site is owned by private owners and for entry to the land and extraction of the materials, the necessary consultations and negotiations will be required. Figure 7.4 Satellite Imagery Showing Area of Laterite Deposit Site with Thicket Vegetation Extraction of laterite materials even for small volume could result in the creation of pits, which could collect water and provide breeding grounds for disease vectors such as mosquitoes. The borrow pits could also pose a major public safety risk, where humans and animals, especially livestock could drown into it. The significance of sources of risk of extraction of capping materials is in Table 7.10. Table 7.10 Significance of Sources of Risk of Materials Extraction Potential Sources of Risk to Ranking Sourcing of Capping Materials Likelihood of occurrence Significance of impact Reason L M H L M H 1. Creation of pits Water collected in pits and trenches could result in safety X X risks and drowning of humans and animals; and create breeding grounds for mosquitoes L = Low M = Moderate H = High 7.4.2 Capping Materials Haulage Impact Haulage of about 60% of the required capping material (61,674.81m3) from the Amrahia Site will involve a total of about 822 (x 2) haulage truck trips to and from the dumpsite over a 3-month period. This will Ministry of Sanitation & Water Resources 75 December 2018 Abloragyei Dumpsite Capping Project Final ESIA translate into 3 trips by 4 trucks (45m3) daily. The movement of these vehicles could pose the following risks to other road users, pedestrians and the general public: • Potential accidents on roads and major junctions; • Potential increased traffic congestion especially at peak periods; • Accelerated road deterioration especially at sections in bad state; and • Breakdown of haulage vehicles in transit, obstructing traffic and causing accidents. Other potential impacts include air quality and carbon emission and foot print on climate impact. Vehicular traffic volumes on the Dodowa Junction and Pantang-Abokobi main road, which are located on the haulage route from the material extraction site to the dumpsite record high traffic volumes during the morning and evening rush hours. The introduction of haulage vehicles on these routes could impact the existing traffic situation during rush hours. This can create delays for residents and commuters travelling to their place of work. Reckless driving of haulage trucks which includes over speeding, tailgating, aggressive driving, drunk driving, distracted driving, failing to use turn signals and failure to yield the right-of-way can cause road accidents and potential injuries and fatalities. This could be as a result of the nonchalant attitude of drivers or the lack of understanding of the code of driving, road signs and signals. Driver fatigue could also result in road accidents. Driving in fleets can significantly slow down traffic and create a traffic backlog especially when entering and exiting these roads since haulage trucks are known to manoeuvre rather slowly. Attempts to overtake such fleets or failure of the trucks to cede or give way to overtaking vehicles could pose accident risks, especially on single carriage roads. The cumulative effect of overloaded trucks using the road daily over 69 days would accelerate pavement damage and reduce the service life of the road. In the case where the road is already in a deplorable state (e.g. Pantang-Abokobi road), the situation would be worsened. Overloaded trucks would also release more carbon emissions. A more hazardous road environment would also be created because of the limitations in vehicle dynamics and braking performance of overloaded trucks. Breakdown of haulage trucks along the route could lead to traffic congestion, delayed delivery of materials and serve as death traps especially at night for other road users. The loading of laterite from borrow pits into haulage trucks will generate some amount of dust. The subsequent haulage of the capping materials especially where the roads are untarred would also generate a substantial amount of dust. Fly-offs and dust blow-ups from uncovered haulage trucks during transporting of capping materials would also generate substantial amount of dust creating a nuisance for the general public. Table 7.11 presents the significance of causes of haulage impacts. Table 7. 11 Significance of Causes of Haulage Impacts Causes of Haulage Impacts Ranking Ministry of Sanitation & Water Resources 76 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Likelihood of occurrence Significance of impact Reason L M H L M H 1. Driving at peak periods and Poor nature of access roads and reckless driving X X high volume of vehicles on road during peak periods 2. Breakdown of haulage Increased traffic congestion on trucks narrow roads and could serve as X X death trap especially at night for other road users 3. Driving in fleets Traffic backlog could slow down X X traffic and cause accidents during attempts to overtake. 4. Cumulative effect of Acceleration of road deterioration overloaded trucks X X over the 3 months haulage period on already poor access roads 5. Use of old or poorly Increased carbon emissions from maintained trucks 5 trucks transporting earth X X material 6 days of the week over 3 months 6. Dust from untarred road The properties of the earth during haulage as well as material as well as the nature of X X laterite loaded in trucks in the access roads makes them transit susceptible to blow-ups L = Low M = Moderate H = High Ministry of Sanitation & Water Resources 77 December 2018 Abloragyei Dumpsite Capping Project Final ESIA CHAPTER EIGHT Environmental and Social Mitigation Measures � Precautionary Measures for Successful Capping � Public and Occupational Health and Safety Measures � Flood Prevention and Protection of Dakobi Stream � Air Quality Protection Measures � Human Rights Abuse Prevention and Gender Equality � Prevention of Degradation from Materials Sourcing � Haulage and traffic Safety � Livelihood Restoration Measures � Resource for sustainable aftercare management � Gas Management and Control � Post-Cap Land Development Control Ministry of Sanitation & Water Resources 78 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 8.0 MITIGATION AND ENHANCEMENT MEASURES The assessment considered a number of mitigation and enhancement measures for implementation or incorporation into project design. This section presents the appropriate mitigation measures that will be implemented to address the potential significant adverse impacts, in order to make the project socially acceptable, environmentally sound and sustainable. The mitigation measures considered include: 1. Abbreviated Resettlement Action Plan; 2. Precautionary measures for successful capping; 3. Public and occupational health and safety measures; 4. Prevention leachate contamination; 5. Air quality protection measures; 6. Gender equality and human rights protection; 7. Resource availability for aftercare management; 8. Gas venting and flaring measures; 9. Post-cap land development control. 10. Prevention of degradation from laterite sourcing; and 11. Haulage and traffic safety measures. 8.1 Precautionary Measures for Successful Capping 8.1.1 Prompt Project Financing and Scheduled Disbursement The funds for full project implementation budget would be secured and available for timely and scheduled disbursement. Structured releases against performance and supervisory arrangement for uninterrupted and scheduled disbursement would be accounted for, to the Minister and the World Bank. Pre-determined sanctions for delayed disbursement or delayed schedule of work implementation would be agreed to by both parties. 8.1.2 Timely Availability of Capping Material Needs The process of securing capping materials from both natural and construction site sources (excavated spoil) would be assisted by the Assembly. The process will begin very early by the contractor once the contract award is made. Ample space (over an Acre of storage area) will be provided for stockpiling of capping materials (about 61,674,806m3 of laterite and 4111m3of sandy clay loam soils). For materials from natural sources: • The Assembly would support the contractor to procure the services of a competent environmental consultant; and • The consultant would be given timelines to complete the Impact Assessment process and to secure an environmental permit to mine the materials. For materials from construction site sources (excavated spoil): • The Assembly will notify other Assemblies within GAMA about such capping material need and request to be furnished with information about approved construction projects (about to commence); • The contractor will be accordingly notified of such projects to make necessary contacts; Ministry of Sanitation & Water Resources 79 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • The contractor will dispatch relevant experts to the construction site to examine the suitability of the excavated (waste) material; • The contractor will arrange to cart the excavated materials to the capping project site for storage; and, • Stored capping materials will be protected from rain and elements of nature to ensure there is no contamination of the Dakobi stream and Odaw river. 8.1.3 Good State of Equipment and Machinery The contract would specify age limit for the construction equipment and machinery to be deployed by the contractor (not older than 5 years). 8.1.4 Deterring Encroachment In order to deter potential attempt to secretly or otherwise dump waste at or near the dump, as well as ward off any encroachment, the following key measures will be among the first set of activities to implement: • Fencing of the dumpsite prior to commencement of the project; and • Provision of security post and positioning of security guard. 8.2 Public and Occupational Health and Safety Measures Measures to be taken to ensure public and occupational health and safety will include the following: Personal Protective Equipment Use • Workers will be provided with reflector jackets during construction to make them visible; • Boiler suits will be provided to workers to reduce their exposure to wet cement; • Gloves will be worn to reduce the occurrence of cuts and effects of cement on skin; • Safety boots will be worn by workers to protect them against broken glass and other item that may pierce them, as well as prevent trips and falls; • Wheelbarrows will be used in lifting heavy items to minimize lower back pain; • Nose masks would be provided for all workers to minimize the odour nuisance; and • Workers on-site will be provided with and required to use ear plugs. Noise Abatement Measures • Operators of noisy and vibratory equipment and machinery will operate a 4-hour scheduled shift; • Operators of machinery and vehicles will be required to switch off idling engines; and • Machinery will undergo scheduled maintenance. Vibration Containment Measures • Padded seats will be fitted in mobile equipment and worn-out pads promptly replaced to limit the effect of vibration transmission to drivers; and • Vibration reduction gloves will also be provided for handheld equipment operators. Ministry of Sanitation & Water Resources 80 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Public Protection Measures • The dumpsite will be cordoned off before construction works begin to prevent the public from accessing the site; • The dump and surroundings will be sprayed before work commences to minimize nuisance of mosquitoes and flies; Accident Prevention Measures • Trucks will be equipped with reverse alarms to alert workers when trucks are backing up; • Drivers of haulage trucks will adhere to speed limit of 20km/h on site; • Haulage trucks will undergo scheduled maintenance; and, • Truck drivers will undergo training on health and safety and safe driving before they are mobilized. First Aid Provision • First aid kits will be provided to cater for injured workers before they are sent to a nearest clinic depending on the level of injury; and • Some workers will be trained to act as first aid personnel to respond immediately to all work related injuries. 8.3 Prevention of Leachate Contamination Measures to prevent leachate contamination include: • Installation of leachate pipes and drains to channel leachate from the dump; • Construction of runoff drains to channel runoff from the project area; • Provision of lined sumps for the collection of leachates; • Compaction of levelled dump prior to spreading of laterite; • Covering of levelled areas yet to be capped with polythene sheets during rainfall to reduce infiltration; • Use of certified cesspit waste management company for leachate evacuation; • Use of logbook to record quantity and time of loading (evacuation) and discharge at the Kpone Landfill respectively (of the cesspit emptier); • Regulation of cesspit emptier truck speed limit (80km/hr on Motorway and 40km/hr on other roads); • Support provided to fix the Kpone Landfill to improve leachate treatment; • Effective functioning of the leachate treatment ponds and system; • Compaction of 30inch core capping material after spreading; and • Grassing of the capped dump and slopes, and green buffer on the periphery to prevent erosion. Leachate pipes would be installed in the dumps to channel leachate into covered leachate drains that would be constructed around the periphery of the dump. The leachate drains would be separated from runoff drains and channeled into 2 lined 10m3 sumps that will be located at the south-western section of Dump1. Construction of runoff and leachate drains and sumps would precede capping activities. Leachate Ministry of Sanitation & Water Resources 81 December 2018 Abloragyei Dumpsite Capping Project Final ESIA sumps would be dislodged for treatment and disposal once every month for the first six month, and quarterly afterwards. The dumps would be covered with polythene sheets after levelling during rainfall to prevent infiltration. Cutting, pushing and levelling activities will be done in 4 sections to avoid exposing the entire surface to rainfall. Laterite would be compacted in three layers (10in each) after spreading, taking into consideration gradients of 1V:50H and 1V:3H respectively for the capped dump surface and slopes (where V and H are vertical and horizontal distances respectively). In order to improve TESL’s leachate treatment performance to take on the additional leachate from the Abloragyei dumpsite, the following support would be provided: • Activate the recirculation system to enable the functioning of the centrifugal pump from Facultative II unto the solid waste in the cells; • Activate the pumping machines to drain leachate daily from the cells into the lagoons; • Install reading meters in the facultative lagoons I and II for leachate monitoring; and • Assist to prepare/update the landfill ESMP for renewal of operational environmental permit from the EPA. 8.4 Air Quality Protection Measures The following air quality protection measures would be put in place during the capping: • Workers would be provided with and required to use nose masks and eye goggles and boiler suits; • Capping materials will be covered after stockpiling to reduce blow offs and to prevent the stockpiles from contaminating Dakobi Stream and Odaw River; • Adherence to speed limit of 20km/h at the site; • Construction machinery would be serviced regularly to reduce exhaust emissions; • Workers will undergo health screening to detect potential respiratory infections for early treatment; and • Green buffer along the dumpsite periphery will be established to protect the nearby residents from dust emission. 8.5 Gender Equality and Human Rights Protection Human resources, labour improvement and gender equality measures will be put in place to ensure fairness. These will include: • Issuance of employment contract to all workers with code of conduct for workers included in the contract. As part of the requirement, the employer/ contractor will sign to protect the human rights and entitlements of the employees; • Provision of extensive education on human rights protection to the contractor’s team during the kick-off meeting; • Provision of complaints desk for workers and public; • Provision of changing areas/washrooms for women; • Filing of all cases of human rights abuses and appropriate sanctioning of offenders; • Formation of trade unions to protect the interests of the workers; Ministry of Sanitation & Water Resources 82 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Provision of condoms to workers and availability at vantage points; • Punishing of workers who discriminate against and harass women and children; act violently against women employees; and sexually abuse women; and • Education of locals to allow female family members to avail themselves for construction activities as well as unskilled labour. 8.6 Prevention of Degradation from Laterite Sourcing The following measures will be put in place to prevent potential degradation of the environment from capping material sourcing: • The topsoil of the site will be stockpiled prior to excavation works at a dedicated area and later used for rehabilitation works; • The disturbed area of the site will be reclaimed by grading the surrounding areas to fill depressions created to achieve a uniform surface; • Stockpiled topsoil will be used for cover the reclaimed portion of the land for revegetation ; and • More than 50% of the capping material will be obtained from construction site excavated spoil sources to reduce the volume of materials extracted from natural environment. 8.7 Haulage and Traffic Safety Measures The following mitigation measures would be employed to reduce the incidence/risk of accidents, congestion, road deterioration and traffic disruption during the haulage and pre-haulage phase of the project: Pre-haulage Phase • The contractor to undertake haulage operations will be hired based on their ability to satisfy environmental and social requirements in the contract; • A “Heavy Trucks Turning� sign which is also visible at night will be placed at the major junctions (e.g. Pantang) to warn road users; • Trucks procured or rented for haulage activity would not be older than 5 years; • Tracking systems will be installed into all haulage trucks in order to monitor their speed during a haulage trip; • Licensed drivers will be employed (Class E); and • Truck drivers will undergo a training on safe driving and health and safety before they are mobilized. 8.8 Abbreviated Resettlement Action Plan The Project Affected Persons (PAPs) are only 36 and therefore an Abbreviated Resettlement Action Plan (ARAP) will be required to adequately address all issues on resettlement or compensation. The ARAP to be prepared separately will cover five types of properties and/or businesses, some permanently and others temporary, and include the following: 1) Land acquisition – a. Parcel of land (3 Acres undeveloped, but walled) adjoining Dump 2; b. Kraal (0.25 Acres) holding 45 cattle; Ministry of Sanitation & Water Resources 83 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 2) Property affected (permanent) - a. A housing structure on the dump; b. A 2-seater toilet on the dump; 3) Property in the hazard zone (for temporal relocation) - a. 2 houses occupied by 8 PAPs; b. 2 house newly constructed, but unoccupied; c. 2 structures at foundation stages; 4) Businesses that may temporarily closed down - a. Drinking spot (3 PAPs); b. Food vendor (2 PAPs); c. Bakery (3 PAPs); d. Provision shop (2 PAPs); 5) An acre land (walled) to be temporarily acquired for storage of capping materials. 8.9 Resource Availability for Aftercare Management The effective Aftercare Management activities will rely mainly on the availability of financial resources (by the Assembly) to perform, among others: • Timely leachate evacuation (contingency measure); • Monitoring of runoff and erosion breaches for timely remedial action; • Storm water drain network and flood monitoring; and • Capped dump height change detection and corrective action. The estimated cost of evacuation of leachate to TESL could for instance be upwards of GHS2,000.00 per trip. The 3-year post-cap phase could rely on project funding, where funding is extended to cover this phase. Funds for the aftercare management phase would come from operators of facilities and end users of the capped dumps, who will be levied by the Assembly to generate adequate revenue for the sustainable aftercare management activities. 8.10 Gas Venting and Flaring The gases from the capped dumps will be collected via some 12 vertical gas wells on Dump 1 and 9 vertical wells on Dump 2 (1 well per acre in each case); placed about 50m apart that will be drilled into the waste mass. The wells will be 5m deep; 1m clear of the bottom of the estimated 6m dump depth in the case of Dump 1and 2m with a 0.68m clearance for Dump 2. PVC or HDPE pipes with diameters of 8 inches each will be fitted in the wells and then back filled and stabilized with stones. The pipes will be interconnected by a network of pipes linked to a blower unit that will extract the gas for flaring in a central flare unit. A gas measuring device will be installed to measure and monitor the amount of gas extracted over a period of time. 8.11 Post-Cap Land Development Control Consideration for after-cap use are in favour of light activities; the main ones being recreational facilities and public park, and football fields. A 3-year fallow period would be allowed for initial settlement after Ministry of Sanitation & Water Resources 84 December 2018 Abloragyei Dumpsite Capping Project Final ESIA which implementation of planned facilities would start. Heavier structures such as a shopping mall, offices, etc., would be considered after at least 10 years of capping. Ministry of Sanitation & Water Resources 85 December 2018 Abloragyei Dumpsite Capping Project Final ESIA CHAPTER NINE Environmental and Social Management Plans � Institutional Arrangements � Construction Phase E&S Arrangement � Post-Cap Phase E&S Arrangement � ESMP Implementation Capacity � Implementation Plan � Environmental and Social Monitoring Plan � ESMP Implementation Budget Ministry of Sanitation & Water Resources 86 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 9.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLANS 9.1 Introduction The Environmental and Social Management Plan (ESMP) for the Closure and Rehabilitation and Aftercare Management of the Abloragyei Dumpsite outlines the mitigation and monitoring measures and other related safeguards commitments in an actionable mode for sustainably project implementation. The ESMP includes individual Action Plans and respective objectives to address the evaluated risks and adverse impacts associated with the project. The risks and adverse impacts cover the construction (pre- cap and capping) phase and the post-cap and aftercare management phase. The construction (pre-cap and capping) phase risks and impacts include: 1. Land acquisition, socio-economic and livelihoods impacts; 2. Risk to successful capping; 3. Public and occupational health and safety risks; 4. Risk of leachate contamination; 5. Potential air quality impacts; 6. Potential human rights abuse and gender disparity; 7. Potential degradation from sourcing of laterite; and 8. Potential capping material haulage impacts. The post-cap and aftercare management phase risks and impacts include: 1. Risk to successful aftercare management; 2. Risk of explosion from gas build-up in the capped dump; and 3. Potential collapse of constructed structures on the capped dump. The specific environmental, social and related Action Plans cover the following: 1. Abbreviated Resettlement Action Plan; 2. Capping and aftercare management plan; 3. Public and occupational health and safety management plan; 4. Leachate containment and management plan; 5. Air quality control plan; 6. Human rights and gender management plan; 7. Capping materials sourcing plan; 8. Haulage and traffic safety plan; 9. Gas emission control plan; and 10. Plan for neighbouring land use development. 9.2 Institutional Arrangements The parties and institutions to perform roles in executing the ESMP and activities during project implementation are: • Project contractor (contractor’s Environmental and Social Specialist and Health and Safety Officer); Ministry of Sanitation & Water Resources 87 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Works Department (WD) of the Ga East Municipal Assembly; • Planning Department (PD) of the Ga East Municipal Assembly; • Project Implementation Unit (PIU) of MSWR (Supervision Consultant and Environmental and Social Specialist); • Environmental Health and Sanitation Directorate; and • Environmental Protection Agency (EPA). Implementation of the Abloragyei capping project will involve E&S activities at the Construction (pre- capping and capping) Phase as well as the Post-cap Phase. 9.2.1 Construction Phase E&S Implementation Arrangement 1. The Project Implementation Unit (PIU) of the MSWR will request for bids from prospective contractors with environmental and social requirements incorporated; 2. Supervision Consultant to assist PIU in implementation supervision; 3. Successful contractors will be selected after a competitive bidding process; 4. Planning Department (PD) of GEMA will issue permit to work; 5. Works Department of GEMA will monitor and supervise construction activities and report to the PIU; 6. Contractors will be required to prepare the C-ESMP, including relevant specific plans mentioned in section 9.1 7. Contractor prepares quarterly E&S safeguards implementation report and submits to WD, who in turn forwards it to the PIU. 8. Works Department compiles the quarterly reports into an AER for submission to EPA and MSWR; 9. Contractor hands over completed works to GEMA who takes over ownership of the project; and 10. PIU hands over supervision and oversight responsibilities to EHSD. 9.2.2 Post-Cap and Aftercare Management Phase E&S Implementation Arrangement 1. WD undertakes monitoring of gas emission and keeps records of monitoring results; 2. Environmental Health (EH) Unit undertakes monitoring of leachate sump/ponds and keeps records of monitoring results; 3. EH facilitates evacuation of leachate ponds; frequency of evacuation determined after first two evacuation procedures; 4. WD undertakes all other monitoring requirements elaborated in the monitoring plan (Section 10); 5. WD & EH compile quarterly monitoring reports and submits to EHSD (forming the basis for quarterly performance monitoring by EHSD); 6. EHSD compiles reports from WD and WMD and reports of its own compliance monitoring and prepares Annual Environmental Reports (AER) for submission to EPA and MSWR; 7. EPA reviews AER and takes appropriate action, including conducting its own monitoring activities on the operations. Ministry of Sanitation & Water Resources 88 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 9.3 ESMP Implementation Capacity The availability of qualified personnel with the requisite capacity is essential to effectively cap and manage the site. The broad capacity building areas include E&S safeguards implementation and regulatory compliance, as well as institutional and reporting requirement. The relevant personnel identified for the E&S capacity building are representatives from the following departments of the Assembly: • Development Planning; • Works Department; • Environmental Health Unit; • Finance Department; • Department of Urban Roads; • Social Welfare and Community Development; and • Project Implementation Unit. Regulatory Compliance and Institutional Requirements The scope of capacity building for regulatory compliance for the S&E Safeguards section include the following: • Screening and scoping of projects; • Initial, Preliminary and full-scale IA; • Construction phase ESMP; • E&S monitoring and safeguards supervision; • Annual E&S report preparation; • E&S safeguards commitments for inclusion in contract documents; • Stakeholder engagement and disclosure procedures; Safeguards Compliance Capacity Building The identified safeguards capacity building areas with roles in safeguards compliance are as follows: • Leachate management; • Groundwater monitoring; • Surface water (Dakobi) monitoring; • Methane emission management; • Runoff and storm water and erosion monitoring; and • Height of capped dump change monitoring; • Supervision of developments and planned uses of the capped dump; • The continuation of the capped dump monitoring; and • Developments within the dump surroundings. 9.4 Implementation Plan The Action Plans (grouped into pre-cap and capping and post-cap and aftercare management) with corresponding objectives cover areas listed below. Ministry of Sanitation & Water Resources 89 December 2018 Abloragyei Dumpsite Capping Project Final ESIA The Pre-cap and Capping Action Plans will be carried out by the contractor (E&S Specialist and H&S) and are as follows: 1. C-ESMP; 2. Capping phase management plan; 3. Public and occupational health and safety plan; 4. Air quality control plan; 5. Capping materials sourcing plan; 6. Haulage and traffic safety plan; 7. Gender equality and human rights protection plan; The Post-cap and Aftercare Management Plans will be carried out by the PIU in collaboration with the Safeguards Committee of GEMA, and include the following: 1. Leachate containment and management plan; 2. Sustainable aftercare management plan; 3. Gas emission control plan; and 4. Plan for neighbouring land use development. 9.4.1 Capping and Aftercare Management Plan Capping and Aftercare management of the dump will be carried out to ensure project sustainability. The objective of the project is to avoid disruption to project implementation. Table 9.1 provides the responsibility and supervision roles for the various measures needed to be put in place. The Contractor (E&S Specialist and H&S Officer), PIU (Supervision Consultant, E&S Specialists), Operations Manager, Works Department, Waste Management Department, and the Physical Planning Department will be responsible for the pre-capping, post-cap and aftercare management of the project. Ministry of Sanitation & Water Resources 90 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 9. 1 Capping and Aftercare Management Plan Cause of Impact Objective Mitigation Implementation Responsibility Supervision (Period) • Delay to funds To avoid disruption • Timely disbursement Pre-cap phase • PIU MWRS disbursement to Project Implementation • Equipment and • Fencing of dumpsite • E&S Officer of Works Dept machinery breakdown • Establishing and functioning Security post the Contractor (Safeguards • Unavailability of Committee) • Equipment/machinery not older than 5 years • Operations capping materials • Capping material need supplied at pre-cap phase Manager • Provision of adequate storage area Lack of resources for To ensure • Timely disbursement for resource acquisition • Post-cap (within 3 • PIU MWSR post-cap monitoring sustainable years after activities Aftercare capping) Management Aftercare Management • Levy post-cap end-users • Aftercare • Waste Mgt • Provide services and amenities and charge Management phase Dept facility owners and activities • Works Dept & Urban Roads • Regularize facilities by giving planning permits • Planning Dept and charge property rates 9.4.2 Public and Occupational Health and Safety Plan The plan is intended to protect the public and workers from potential harm from the project. The key measures to safeguard occupational and public health and safety are outlined in Table 9.2 Table 9. 2 Public and Occupational Health and Safety Plan Cause/Source Objective Mitigation Implementation Responsibility Supervision (Period) • Accidents related to To avoid injuries of • Use of safety boots and protective gloves Pre-capping phase slips, trips and falls, and workers • Training of workers on H & S before they are PIU (E&S piercing of workers mobilized Contractor Specialist) and (E&S • Falling off the dump To avoid fall of • Use of safety boots and protective gloves Pre and post-cap Safeguards Specialist and workers from height of • Training of workers on H & S before they are phase H&S Officer) Committee 6m mobilized (Works Dept.) • Odour and VOCs, To minimize nausea, • Use of nose masks Pre-cap phase Ministry of Sanitation & Water Resources 91 December 2018 Abloragyei Dumpsite Capping Project Final ESIA recurring mosquito discomfort; prevent • Spraying of dump before work begins to bites, houseflies and malaria, sanitation- minimise effect on workers, public other vermin related diseases, death • Machinery, truck and To prevent accidents • Reverse alarm on trucks Post-cap phase vehicle operational and fatalities • Use of reflector jackets accidents on-site • Cordon off site • Speed limit 20km/h on site • Reporting of accidents • Training of workers on H & S before they are mobilized • Lifting heavy items and To prevent low back • Use of wheelbarrows Pre and post-cap awkward posture in pains • Training of workers on H & S before they are phase constructional activities mobilized • Contact (skin and eye) To avoid skin • Use of boiler suits and gloves with cement, especially irritations like allergic wet cement dermatitis and severe blistering • Compactors, bulldozers, To avoid hearing • Use of ear plugs etc. operating noise impairments • Switching off idle machinery and vehicles range of 74 - 88dBA • Training of heavy equipment operators on H & within a 15m radius S before they are mobilized • Adherence to scheduled maintenance of machinery and equipment • Compactors, bulldozers, To prevent WBV and • Use of vibration reduction gloves rollers, etc. operating back pains • Provision of padded seats in machinery vibration • Training of heavy equipment operators on H & S before they are mobilized 9.4.3 Leachate Containment and Management Plan The objective of the plan is to ensure the protection water resources (the Dakobi, Onupkawahe and Mamahuma and Sakumo) from leachate contamination through the sumps and in transit. Table 9.3 outlines the responsibilities and supervisory roles for safeguards actions required Ministry of Sanitation & Water Resources 92 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 9. 3 Leachate Containment and Management Plan Cause/Source Objective Mitigation Implementation Responsibility Supervision (Period) • Leachate generation from To reduce rainwater • Levelling and capping operations would rainfall infiltration infiltration into the be done in four sections. A section at a • Cutting and levelling with capped dump time. depressions • Covering of levelled dumped with • Compaction processes polythene sheets during rainfall • Installation of leachate pipes, drains and lined sumps • Compaction of capping material in 3 layers PIU Capping, Post-cap and Safeguards Overflow of leachate in To prevent leachate • Construction of runoff drains (Supervision sumps/tanks collected from • Monthly transport of leachate to the Aftercare Committee Consultant) and getting into the Kpone landfill leachate treatment system Management phases (Environmental Safeguards Dakobi Stream • Design the sumps based on the expected Health Unit) Committee volume of leachate with 15 to 20% allowance. • Inadequate drains around To prevent flooding • Draining of the ponds of water around the the dump and erosion of the dumps • Compacted impervious capped dump which • Provision of runoff drains to channel capped dump surface could breach the runoff water away from the dump. resulting in high runoff portion of the capped • Grassing of the capped dump to prevent generation erosion dump 9.4.4 Air Quality Control Plan The objective of the Air Quality Control Plan is to reduce dust and emissions from capping activities so as not to negatively impact the air quality in the project area. Table 9.4 provides the required mitigation actions, the department or personnel responsible for implementation and supervision. Table 9. 4 Air Quality Control Management Plan Source Objective Mitigation Implementation Responsibility Supervision (Period) Dust from tipping and To reduce dust • PPE provision and usage Pre-cap and E&S Specialist PIU (Supervision stockpiling of capping emission from capping • Covering of stockpiled capping Capping Phases and H&S Officer Consultant) and materials activities materials of the Contractor Safeguards Ministry of Sanitation & Water Resources 93 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Dust from reloading and • Adherence to 20km/h speed limit on Committee (Works spreading of capping site Dept.) materials • Establish green buffer around periphery of the capped dumps Dust from pushing, filling • Training of workers on H & S and levelling of dump before they are mobilized. Dust from construction of • PPE provision and usage access road and drains • Training of workers on H & S before they are mobilized. Emission from construction To reduce emissions • Adherence to scheduled machinery from construction maintenance of machinery and machinery equipment 9.4.5 Gender Equality and Human Rights Protection Plan The plan outlined in Table 9.5 will ensure fairness; freedom of association and collective bargaining; economic and social rights of all employees and members of nearby communities identified within the project area. Table 9. 5 Gender Equality and Human Rights Protection Plan Cause/Source Objective Mitigation Implementation Responsibility Supervision (Period) • Discrimination based on To promote fair treatment, non- • Issuance of employment contract to all ethnicity, gender, discrimination and equal opportunity workers with workers’ code of conduct religion, disability and for all workers • Filing of all cases of human rights abuses HIV status • Complaints desk • Privacy invasion To ensure the privacy of women • Provision of changing areas/washrooms Contractor PIU (E&S employees for women Pre-cap and (E&S Specialist) and • Sexual abuse and To minimise incidence of prostitution • Workers’ code of conduct included in the Capping Phases Specialist and Safeguards harassment and prevalence of HIV/AIDS, STIs employment contract H&S Officer) Committee • Education and Training of Workers (Works Dept.) • Provision of condoms • Prohibition of To ensure freedom of association and • Worker unions unionization collective bargaining 9.4.6 Capping Materials Sourcing Plan The objective of the plan (Table 9.6) is to prevent potential degradation of the environment from capping material sourcing. Ministry of Sanitation & Water Resources 94 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 9. 6 Capping Materials Sourcing Plan Cause/Source Objective Mitigation Implementation Responsibility Supervision (Period) Creation of pits • To prevent • Reclamation of disturbed area of material extraction site PIU (Supervision degradation of • Revegetation of reclaimed land E&S Specialist Consultant) and the • Obtaining more than 50% of capping material from and H&S Officer Safeguards environment Pre-cap Phase of the Contractor Committee construction site excavated spoil sources. (Works Dept) 9.4.7 Haulage and Traffic Safety Plan The objective of the haulage and traffic safety plan (Table 9.7) is to ensure that mitigation measures identified to reduce potential accidents and traffic congestion, accelerated road deterioration and carbon emissions and air quality impacts are implemented effectively and timely by designated personnel to achieve the objective. Table 9. 7 Haulage and Traffic Safety Plan Causes Mitigation Objective Implementation Responsibility Supervision (Period) Reckless Driving • Provision of contact number for reckless driving To ensure prevent Pre-cap Phase on the haulage trucks accidents and • Enforcement of driving speed limits in promote public settlement areas at 20km/h safety at all times • Mandatory training for all drivers on safe driving during haulage and health and safety before they are mobilized PIU (Supervision • Tracking systems will be installed into all E&S Specialist and Consultant) and haulage trucks H&S Officer of the Safeguards Breakdown of haulage • Trucks deployed for haulage activities would be Contractor Committee (Dept truck less than 5 years of Urban Roads) • Record scheduled maintenance of trucks Driving at peak periods • Haulage during off peak periods Potential conflict at • Mounting traffic signs at sensitive junctions major intersections Driving in fleets Use of a vehicle fleet management system Ministry of Sanitation & Water Resources 95 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Emissions • Covering of trucks in transit with tarpaulins • Trucks deployed for haulage activities would be less than 5 years Overloading of trucks Inspection of haulage trucks before haulage 9.4.8 Abbreviated Resettlement Action Plan The objective of the Livelihood Restoration Management Plan is to prevent loss of property and livelihood as a result of the implementation of the capping project. This is to avoid potential hardship to property owners and businesses around the dumpsite during the 18 months implementation period. Table 9.8 provides the required actions, the department or personnel responsible for monitoring as well as supervision. Table 9. 8 Abbreviated Resettlement Action Plan Cause Objective Mitigation Implementation Responsibility Supervision (Period) 1. Land acquisition – • Parcel of land (3 Acres undeveloped, but walled) adjoining Dump 2 • Kraal (0.25 Acres) holding 45 cattle; 2. Property affected (permanent) - • A housing structure on the dump • A 2-seater toilet on the dump To ensure that the 3. Property in the hazard zone (for temporal relocation) - Implementation of PAPs are not made • 2 houses occupied by 8 PAPs an Abbreviated worse off by the MSWR (World Resettlement Pre-cap Phase PIU • 2 house newly constructed, but unoccupied project Bank and EPA) Action Plan • 2 structures at foundation stages implementation (ARAP) 4. Businesses that may temporarily closed down - • Drinking spot (3 PAPs) • Food vendor (2 PAPs) • Bakery (3 PAPs) • Provision shop (2 PAPs) 5. An acre land (walled) to be temporarily acquired for storage of capping materials Ministry of Sanitation & Water Resources 96 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 9.4.9 Gas Emission Control Plan The objective of the plan is to ensure effective gas collection and flaring on the capped dump to reduce the risk of gas build up and explosion to the barest minimum. Table 9.9 provides the required actions, the department or personnel responsible for monitoring and supervision. Table 9. 9 Gas Emission Control Plan Cause/Source Mitigation Objective Implementation Responsibility Supervision (Period) Accumulation of methane within Installation of a total of 21 gas wells To efficiently collect gas PIU (Supervision capped dump with gas collection pipes on dumps; generated on the dump to Consultant) and H&S Officer of the wells linked via connecting pipes prevent accumulation, Pre-cap Phase Safeguards the Contractor to a central flaring point for migration and explosion Committee controlled flaring (Works Dept) Poor gas management arrangement After care management arrangement To preserve the integrity (potentially leading to failure of gas to ensure supervising the integrity of of gas collection and PIU (Supervision Post-cap Phase Works Dept collection and flaring system) gas collection and flaring flaring system Consultant) 9.4.10 Post-cap Land Development Control Plan The objective of the plan is to implement development activities that are compatible with the properties of the capped land. It entails arrangements for implementation of measures to reduce the risk of collapse of any structure constructed on the dump after capping. Table 9.10 provides the required actions, the department or personnel responsible for enforcement as well as supervision. Table 9. 10 Post-cap Land Development Control Plan Cause/Source Mitigation Objective Implementation Responsibility Supervision (Period) High demand to put capped waste Education of stakeholders on the To enforce a 3-year dump to beneficial end-use reasons and need to allow the capped fallow period of the area to go through a fallow period. land after capping. Safeguards Construction of a physical barrier( Committee PIU perimeter fence) around dump Post-cap Phase (Works and (Supervision Physical Planning Consultant) Wrong choice of infrastructure Enforce development control on the To avoid the risk of Departments) developed on the capped area and capped dump and surrounding collapse of heavy wrong timing of development structures Ministry of Sanitation & Water Resources 97 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 9.5 Environmental and Social Monitoring Plan 9.5.1 Capping and Aftercare Monitoring Plan The capping and post-cap monitoring plan for the dumpsite is presented in Table 9.11. Records on activities monitored by the Safeguards Committee will be compiled and submitted to MSWR and EPA. Table 9. 11 Capping and Aftercare Monitoring Plan Mitigation Monitoring Measures Parameters Frequency Responsibility Reporting for Monitoring Arrangement • Timely financial • Record of funds disbursed • Amount of funds • As per contract Safeguards Records to be disbursement • Inspect integrity of fence received schedule Committee compiled into AER • Fencing of site • Record equipment and • Number of intruders • Daily (Works and submitted to • Equipment and machinery machinery servicing and • Number of servicing • Weekly Department) GEMA, EPA and deployed less than 5 years breakdown • Presence of security • Daily MSWR • Security post established and • Impromptu checks on security team/personnel at post functioning • Timely disbursement for • Record amount, date and time of • Date, time and • As per contract PIU MSWR resource acquisition funds disbursement amount of funds schedule received • Levy post-cap end-users • Record of levy collected Amount paid; date and • Monthly GEMA Finance Records to be time received Department compiled submitted (Revenue to GEMA Section) 9.5.2 Public and Occupational Health and Safety Monitoring Plan The plan is to ensure effective compliance with occupational and public health and safety monitoring measures outlined in Table 9.12. Table 9. 12 Public and Occupational Health and Safety Monitoring Measures Mitigation Monitoring Measures Parameters Frequency Responsibility for Reporting Monitoring Arrangement PPE provision and usage Impromptu checks Records of provision and use Weekly Adherence to 20km/hr speed Impromptu checks Records of offenders Impromptu Records to be Environmental Health limit on site compiled AER and Department Reporting of accidents Record time of Records of accidents Monthly submitted to GEMA, accidents, vehicle and MSWR and EPA person involved Ministry of Sanitation & Water Resources 98 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Adherence to scheduled Records of Compliance with Quarterly maintenance of machinery maintenance maintenance schedule Spraying of dumps Time of spraying Area covered, type of Monthly chemical used Reverse alarm on trucks Impromptu checks Records of offenders Impromptu Switching off idle machinery Impromptu checks Records of offenders Impromptu and vehicles 9.5.3 Monitoring Plan for Prevention of Leachate Contamination The actions to be monitored to prevent leachate contamination of water resources (Dakobi, Onukpawahe, Mamahuma and Sakumo) are provided in Table 9.13. Table 9. 13 Monitoring Plan for Prevention of Leachate Contamination Mitigation Monitoring Measures Parameters Frequency Responsibility for Reporting Monitoring Arrangement Installation of leachate pipes Evaluation of the number of Number of leachate Quarterly leachate pipes installed pipes installed Construction of: • Review of records of Flow rate, Pb, Hg, As, Quarterly • Underground leachate drains leachate characteristics Cu, Cr, Mn, • Runoff drains • Leachate sumps • Covering of levelled dumped • Quantity of polythene Availability of Monthly with polythene sheets to sheets available polythene sheets Compiled into annual prevent rainwater infiltration • Review of records of Environmental Health report by Safeguards surface area levelled pre- Surface area levelled Committee and Unit cap submitted to EPA, Evacuation of leachate when • Inspection of sumps to Volume of leachate Monthly GEMA and MSWR full for treatment determine quantity of leachate • Review records of evacuation Records of evacuation Yearly Use of certified cesspit waste Validity of certification Certification stamp Annually management company Volumes of leachate evacuated Recording of volumes in log Records of volumes Monthly and discharged book Ministry of Sanitation & Water Resources 99 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 9.5.4 Air Quality Monitoring Plan Monitoring plan for reducing dust and other emissions is provided in Table 9.14. The plan provides monitoring measures/parameters, frequency of monitoring, personnel responsible and reporting arrangement. Table 9. 14 Air Quality Monitoring Plan Mitigation Monitoring Measures Parameters Frequency Responsibility for Reporting Monitoring Arrangement PPE provision and usage Impromptu checks • Records of stock Weekly Adherence to 20km/hr speed Impromptu checks • Records of defaulters Impromptu limit on site Adherence to scheduled Records of maintenance • Compliance with maintenance Quarterly maintenance of machinery schedule schedule Compiled in annual Health screening of employees Review medical records • Records on number of workers Impromptu Environmental report and submitted to of employees involved in screening Health Unit MSWR, EPA and GEMA Covering of stockpiled capping Impromptu checks of • Compliance to Impromptu materials stockpiled materials Green buffer around dumpsite Existence and state of • Growth rate Monthly periphery green buffer 9.5.5 Human Rights and Gender Monitoring Plan The gender equality and human rights monitoring plan in Table 9.15 covers frequency, personnel responsible and reporting arrangement to facilitate effectiveness implementation of the plan. Table 9. 15 Human Rights and Gender Monitoring Plan Mitigation Monitoring Measures Parameters Frequency Responsibility for Reporting Monitoring Arrangement Issuance of employment Records of all employee Review of employee contracts Half-yearly contract to all workers contracts Filing of all cases of Records on reported human Review records of human right Monthly Compiled in annual human rights abuses rights abuse cases filed abuse cases E&S Specialist of report and submitted to Provision of changing Reports on adequacy of Review reports on adequacy of Monthly the Contractor MSWR, EPA and areas/washrooms for washrooms washrooms GEMA women Worker unions Records of workers in unions Number of workers in union Quarterly Ministry of Sanitation & Water Resources 100 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Complaints desk Records of complaints Review of complaints addressed Monthly Education HIV awareness creation Review of records of workshop Quarterly workshops and records of attendance attendance Provision of condoms Assess use of condoms Availability and supply of Monthly condoms 9.5.6 Monitoring Plan for Laterite Sourcing The monitoring plan for laterite sourcing is to covers frequency, personnel responsible and reporting arrangement to facilitate effectiveness implementation of the plan. Table 9. 16 Monitoring Plan for Laterite Sourcing Mitigation Monitoring Measures Responsibility Frequency Responsibility for Reporting Monitoring Arrangement • Reclamation of disturbed • Inspection of the reclaimed E&S Specialist of Weekly PIU (Supervision Compiled in annual area of material extraction area the Contractor Consultant) and report and submitted to site Safeguards Committee EPA, GEMA and • Revegetation of reclaimed • Inspection of vegetation Monthly (Works Dept.) MSWR. area growth monthly • Obtaining more than 50% • Records of capping Quarterly of capping material from materials obtained from construction site excavated construction site excavated spoil sources. spoil sources. 9.5.7 Haulage and Traffic Safety Monitoring Plan Table 9.17 represents the plan to effectively monitor mitigation measures to prevent accidents, promote public safety and to ensure scheduled haulage operations. Ministry of Sanitation & Water Resources 101 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 9. 17 Haulage and Traffic Safety Monitoring Plan Mitigation Monitoring Measures Parameters Frequency Responsibility for Reporting Monitoring Arrangement Tracking systems installed Monitor functionality of Accuracy of tracker Weekly in haulage trucks tracker Trucks used to be less than Inspect vehicle registration Age of vehicle Before haulage Compiled in annual 5 years old documents begin H&S Officer of report and submitted Provide maintenance Inspect records of Records of maintenance Monthly Contractor to MSWR, EPA and schedule for trucks maintenance GEMA Covering of trucks in Check the integrity of the Fully covered trucks impromptu transit with tarpaulins tarpaulin 9.5.8 Gas Emission Monitoring Plan The aspects of mitigation measures to be monitored, and actions to execute the monitoring in order to facilitate effectiveness of implementation are addressed in Table 9.18. Table 9. 18 Gas Emission Monitoring Plan Mitigation Monitoring Measures Parameters Frequency Responsibility for Reporting Monitoring Arrangement Install 21gas wells, Monitor gas volumes to • Volumes of gas Twice weekly connected by pipes to a determine quantity of gas captured central point for captured in reference to • Condition of gas flaring. volumes expected capture set up Compiled in annual report and Run an efficient Monitor the integrity of gas Works Department submitted to MSWR, EPA and aftercare management capture and flaring set up GEMA of gas capture facility to ensure continued proper functioning 9.5.9 Post-Cap Land Use Monitoring Plan The aspects of mitigation measures to be monitored, and actions to execute monitoring activities in order to facilitate effectiveness of implementation are presented in Table 9.19. Ministry of Sanitation & Water Resources 102 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 9. 19 Post-cap Land Use Monitoring Plan Mitigation Monitoring Measures Parameters Frequency Responsibility Reporting for Monitoring Arrangement • Construct perimeter • Monitor the integrity • Stability and strength of the • Twice on a Works Depart. • Compiled in annual report and fencing on Dumps 1 of the fencing fencing weekly basis and submitted to MSWR, EPA and 2 • Monitor • Signs of encroachment on the • One time Physical and GEMA • Enforce unauthorized capped area or breach of the • Once every Planning • Half yearly reports on development control developments and fence quarter Department compliance with permit on the capped dump activities in the areas • Facilitate issuing of permits acquisition; reports to be and surrounding surrounding the • Inspection of permits obtained shared with PIU and EHSD of areas capped dumpsite by developers MSWR 9.6 Budget for ESMP Implementation The estimated budget for implementation of the ESMP (Tables 9.20-9.28) covers the following: 1. Capping and aftercare management plan; 2. Public and occupational health and safety plan; 3. Leachate containment and management plan; 4. Air quality control plan; 5. Gender and human rights protection plan; 6. Gas emission control plan; 7. Post-cap land development plan; 8. Capping material sourcing plan; and 9. Haulage and traffic safety plan. Table 9. 20 Budget for Capping and Aftercare Management Plan Mitigation Monitoring Responsibility Supervision Reporting Budget (USD) Source of Funding • Supervision of timely disbursement • Scheduled disbursement and PIU MSWR Records 3,000 GARID • Facilitation of timely environmental work delivery compilation and permit acquisition • Environmental permit secured Contractor & PIU & Safeguards and • Early identification of excavated spoil and compliance with conditions Safeguards Committee AER GEMA sources • Quantity of materials in storage Committee preparation • Early stockpile of capping material and used Ministry of Sanitation & Water Resources 103 December 2018 Abloragyei Dumpsite Capping Project Final ESIA • Fencing of dumpsite • Integrity of perimeter fence and Contractor Safeguards • Security post and presence established security operations (impromptu) Committee • Deployment of less than 5-year old • Machinery servicing records and equipment and machinery breakdown rate • Levy post-cap end-users Record of levy collected and Physical Finance GEMA 500 GEMA performance planning Department (GEMA) (GEMA) Table 9. 21 Budget for Public and Occupational Health and Safety Plan Mitigation Monitoring Responsibility Supervision Reporting Budget Source of (USD) Funding • Provision and use of PPE • Availability and usage of PPE Contractor PIU Record 3,000 GARID • Spraying of dumpsite on monthly basis • Presence of mosquitoes and flies and (E&S Specialist (E&S Specialist) compilation and • Adherence to 20km/hr speed limit on effectiveness of monthly spraying and H&S Officer) and AER site and reverse alarm • Vehicle movement (impromptu) Safeguards preparation • Adherence to scheduled maintenance • Records of maintenance Committee (Works Dept.) Table 9. 22 Budget for Leachate Containment and Management Plan Mitigation Monitoring Responsibility Supervision Reporting Budget (USD) Source of Funding • Construction of leachate/runoff drains • State and functioning of GARID and sumps leachate pipes and sumps • Covering of levelled dumped with • The 10-inch layers of Compiled into polythene sheets during rainfall covering/levelling and annual report Safeguards PIU (E&S • Compaction during capping in 3 layers effectiveness of compaction Committee Specialist) and by Safeguards • Grassing of slopes of capped dump • Evidence of erosion on capped Committee and 8,000 (Environmental Safeguards • Logging of leachate evacuated and dumps Health Unit) Committee submitted to discharged • Records of volume of leachate EPA, GEMA • Adherence to prescribed speed limits for each of 4 evacuations (in 2 and MSWR years) • Inspection of log books Ministry of Sanitation & Water Resources 104 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 9. 23 Budget for Air Quality Control Plan Mitigation Monitoring Responsibility Supervision Reporting Budget (USD) Source of Funding • PPE provision and usage • Availability and usage of PPE Contractor PIU Record 2,000 GARID • Covering of capping materials stockpiled • Adherence of speed limit (E&S Specialist (E&S Specialist) compilation • Stipulate 20km/h speed limit on-site • Adherence to maintenance and H&S and and • Scheduled maintenance of machinery schedule Officer) Safeguards AER and equipment Committee preparation (Works Dept.) Table 9. 24 Budget for Gender and Human Rights Protection Plan Mitigation Monitoring Responsibility Supervision Reporting Budget (USD) Source of Funding • Issuance of employment contract to all • Records of all employee workers contracts • Include workers’ code of conduct in • Records on reported human PIU Contractor (E&S Record their employment contract rights abuse cases filed, etc. (E&S Specialist and Specialist) and compilation and • Filing of all cases of human rights • Records of workers in unions 1,500 GARID H&S Officer) Safeguards AER abuses • HIV awareness creation Committee preparation • Complaints desk • Condom availability (Works Dept.) • Worker education • Provision of condoms Table 9. 25 Budget for Gas Emission Control Plan Mitigation Monitoring Responsibility Supervision Reporting Budget (USD) Source of Funding Run an efficient aftercare • Monitor gas volumes of gas twice weekly to Safeguards PIU Report management of gas determine quantity of gas captured in reference to Committee (Supervision Compilation and 4,800 GARID capture facility to ensure volumes expected Works Department Consultant) AER continued proper • Monitor the integrity of gas capture and flaring preparation functioning set up twice weekly Ministry of Sanitation & Water Resources 105 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 9. 26 Budget for Post-cap Land Development Control Plan Mitigation Monitoring Responsibility Supervision Reporting Budget (USD) Source of Funding Enforce development Monitor unauthorized developments and activities Physical Planning Supervision Half yearly reports 3,000 GEMA control on the capped in the areas surrounding the capped dump once Department Consultant on compliance with dump and surrounding every quarter permit acquisition; areas reports to be shared with PIU and EHSD of MSWR Table 9. 27 Budget for Capping Materials Sourcing Plan Mitigation Monitoring Responsibility Supervision Reporting Budget Source of (USD) Funding • Reclamation of disturbed area • Inspection of the reclaimed area weekly E&S Specialist PIU (Supervision Compiled in • Revegetation of reclaimed area • Inspection of vegetation growth monthly of the Consultant) and annual report and • Obtaining more than 50% of capping • Records of capping materials obtained Contractor Safeguards submitted to EPA, 5,000 GARID material from construction site from construction site excavated spoil Committee GEMA and excavated spoil sources. sources. (Works Dept.) MSWR. Table 9. 28 Budget for Haulage and Traffic Safety Plan Mitigation Monitoring Measures Responsibility Supervision Reporting Budget Source of (USD) Funding • Tracking systems installed in trucks • Monitor functionality of tracker E&S Specialist PIU (Supervision Compiled in • Maintenance schedule for trucks • Inspect records of maintenance and H&S Consultant) and annual report and • Tarpaulin covering for trucks • Check the integrity of the tarpaulin Officer of the Safeguards submitted to EPA, 3,000 GARID Contractor Committee (Works GEMA and Dept.) MSWR. The total estimated budget for the ESMP implementation, amounting to USD 33,800, is given in Table 9.29. Ministry of Sanitation & Water Resources 106 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Table 9. 29 Budget Summary Plan Estimated Amount ($) 1 Capping and aftercare management plan 3,500 2 Public and occupational health and safety plan 3,000 3 Leachate containment and management plan 8,000 4 Air quality control plan 2,000 5 Gender and human rights protection plan 1,500 6 Gas emission control plan 4,800 7 Post-cap land development plan 3,000 8 Capping material sourcing plan 5,000 9 Haulage and traffic safety plan 3,000 Total 33,800 Ministry of Sanitation & Water Resources 107 December 2018 Abloragyei Dumpsite Capping Project Final ESIA REFERENCES Boateng, T. K., Opoku, F. and Akoto, S. (2018)-Quality of leachate from the Oti Landfill Site and its effects on groundwater: a case history. Environmental Earth Sciences, 77:435. DWAF (2001)- Quality of domestic water supplies vol 1. Assessment guide. Department of Water Affairs and Forestry, Pretoria. 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(Online) Available at: http://americanlandfill.wm.com/landfill-design-construction/landfill-closure-and-waste-capping.jsp (Accessed 10th August, 2018) Wijesekara S, Mayakaduwa SS, Siriwardana A, de Silva N, Basnayake B, Kawamoto K, Vithanage M (2014)- Fate and transport of pollutants through a municipal solid waste landfill leachate in Sri Lanka. Environ Earth Sci 72:1707–1719. Ministry of Sanitation & Water Resources 109 December 2018 Abloragyei Dumpsite Capping Project Final ESIA APPENDICES Appendix 1.0 Introductory Letter Appendix 2.0 Invitation to Stakeholder Consultation Meeting Appendix 3.0 Invitation to Stakeholder Disclosure Workshop Appendix 4.0 Schedule for Stakeholder Engagement Appendix 5.0 Scoping Notice Appendix 6.0 Stakeholder Engagement/ Audit Engagement Appendix 7.0 Needs Assessment - GEMA Appendix 8.0 Consultation with Residents near the Dump Appendix 9.0 Outcome of Stakeholder Disclosure Workshop Appendix 10.0 Outcome of Consultation with TESL Appendix 11.0 Terms of Reference of Scoping Report Appendix 12.0 EPA Review Comments on Draft EIS Ministry of Sanitation & Water Resources 110 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 1.0 Introductory Letter Ministry of Sanitation & Water Resources 111 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 2.0 Invitation to Stakeholder Consultation Meeting Ministry of Sanitation & Water Resources 112 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 3.0 Stakeholder Disclosure Workshop Invitation Letter Ministry of Sanitation & Water Resources 113 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 4.0 Schedule for Stakeholder Engagement Date Activity (Meeting / Stakeholders Time Location Engagement) GEMA Conference July 3, 2018 Targeted Interview GEMA 10:23am – 12:30 pm Room, Abokobi • Residents Random Interview • Scrap dealers Dump site July 5, 2018 12.15pm – 2.00pm • Squatters surrounding area • Scavengers Abloragyei July 5, 2018 Targeted Interview Abloragyei Chief 1:15pm – 1:40pm Community July 5, 2018 Focus Group Discussion • Amanee Waste Ltd 1:30pm – 2:15pm Zoomlion Office • Honest Waste Ltd Abloragyei Office of the Works July 9, 2018 Targeted Interview GEMA 10:35am – 12:55pm Engineer, GEMA Abokobi EPA Head Office - July 13, 2018 Targeted Interview EPA 1:00pm – 2:00pm Accra July 13, 2018 Targeted Interview TMA WMD 3:00pm – 4:00pm WMD, Tema Accra Metro July 16, 2018 Targeted Interview ASIP 2:00pm – 3:00pm Sewage Unit Office, Accra • Resident Association • Rep. of traditional authority • Honest Waste Ltd • Amanee Waste Ltd GES Conference July 20, 2018 Disclosure Meeting 11:00am – 1:30pm • Premko Waste Room, Abokobi • GEMA • Waste Landfill Co Ltd • Abokobi Assembly Man Appendix 5.0 Scoping Notice at GEMA Ministry of Sanitation & Water Resources 114 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 6.0 Stakeholder Engagement/Audit Outcomes Appendix 6.1 Environmental Protection Agency (EPA) Venue: EPA Office, Head Date:13-07-2018 Time: 3pm – 4pm Participant Kwabena Badu-Yeboah CEHRT Team Yaw Amoyaw-Osei – 0247062902 Prince Ofori-Boateng – 0244985953 Issues Comment Permits required to extract large A Preliminary Environmental Assessment will be required. However, if the quantities of capping material? location is a sensitive site, an Environmental Impact Assessment will be required. Obtaining capped materials from If there is no use for the excavated material, it will be a good source. Excavate construction site or dredging materials from construction sites are normally duped indiscriminately, e.g. materials? construction waste from the Marine Drive Project is being dumped at the Ramsar Site at Weija. The physical planning department of MMDA can help identify construction activities excavating large quantities of earth materials. Mechanisms to receive excavated There should be a dedicated location to stockpile capped materials. and dredged spoil materials? Traffic impacts from conveying There should be a traffic count baseline to assess the potential traffic impact from capped materials? the project implementation. If the source of the capping material is from the Aburi or Dodowa and its environs, there will be no need to conduct traffic count. However, if the materials are coming from westwards from Accra, a traffic count will be required for the Pantang site. Sourcing of the capping material Contractor’s responsibility Land use enforcement EPA has sent eviction notice to unauthorised developments around the Agbogbloshie dumpsite, but the city authority (AMA) failed to collaborate. The only option was to apply for a court suit for eviction. Appendix 6.2 Accra Sewage Improvement Project Venue: Accra Sewage Improvement Programme project office Date: 16/07/2018 Participants Stephen Ackon Accra Metro Sewage Unit 0244418114 CEHRT Team Bennett Akuffo - 0244203401 Nana Osei Amoyaw-Osei - 0260926705 Issue Response What does ASIP do? Currently we handle municipal waste water, not for the whole Greater Accra When was ASIP established? We came out of Ghana Water somewhere 2005 Do you provide this service to Yes, we do. This would happen when the sewer lines are close to the company in question private companies? Septic tanks are the responsibility of the various assemblies. But because of lack of capacity we support the assemblies What facilities do you have at We have a treatment plant at Legon and about 30 pump stations due to the topography of the ASIP? area. We also have another treatment plant at Ogblogo. Has ASIP been treating leachate? When it come s to leachate which is not that common, (only in Ogblogo landfill site). We recommended that system be pre-treated but it was limited to only the assembly. We have not Ministry of Sanitation & Water Resources 115 December 2018 Abloragyei Dumpsite Capping Project Final ESIA be involved so much in the treatment of leachate Which companies do you treat For industrial waste, we treat that of Accra Breweries but we do that in collaboration with the their waste? EPA. The company pre-treat and then it’s checked by EPA and then we receive it into our system. Can ASIP handle the waste? Whenever its waste water if we are given the mandate we can handle it So, if the dump is capped there Yes. When we know the characteristics of the leachate we can do that. I would have to discuss would be a lot of leachate. Can this issue with Mr Tony Mensah the Director for Environment, Health and Sanitation you treat it? Directorate, Ministry of Sanitation and look at the leachate characteristics. I know for Ogblogo it’s very serious because it’s going downstream of the Weija Dam and people are fishing downstream. We had plans to do a treatment facility there but along the line we had to stop because we know that place is a Ramsar site. In terms of transportation of the There is another treatment plant near the Korle being handled by a private company. We used leachate to the treatment facility to handle that plant until the government changed the arrangement. Where the capping is what would be the most suitable being done we have some pipes close by about a meter underground which takes for the whole arrangement? Accra. When we find a solution for the leachate its likely to be channel into this pipe` Any comments or suggestions I think there is the need to do some pre-treatment before it comes to our end. We use biological system for treatment so if we introduce heavy metals it would create problems. We can go through the water if we are using HDP pipes to connect to our pipes. Appendix 6.3 Tema Metropolitan Assembly (Waste Management Department) Venue: TMA WMD Office Date:13-07-2018 Time: 3pm – 4pm Participant Ing. Solomon Noi – 0265910079 Head of Waste Management Department (TMA) CEHRT Team Yaw Amoyaw-Osei – 0247062902 Prince Ofori-Boateng – 0244985953 Issues Response Measures to consider when It must be done professionally taking into consideration the type of capping material and its thickness. capping a dumpsite Ideally, before capping begins, room should be made for gas collection pipes. However, if the site is not engineered, it can be done after capping. Suitable material for capping? Loamy clay and laterite are ideal materials for capping. Loamy clay is ideal, if the after use will involve planting activities, while laterite is suitable for construction activities Venting of gas If the dump is not engineered, there will be no values to collect the leachate. So the pipe will collect both gas and leachate, since leachate (liquid) is heavier than the gas. Can venting gas be measured? Gas venting can be measured. EPA is having equipment to measure gas venting. Trapping and collection of A drainage channel should be drilled around the capped dump with thin lining. Beneath the leachate drainage channel, there should be small holes drilled to allow the leachate to flow through a valve and discharge in a sump. There will the need sink two lined hand dug wells to linked the sump for temporary storage of leachate. How long methane gas can be It will take 10 years taking into consideration the biodegradability factor (climate) and the fact harvested after capping? that municipal solid waste in Ghana contains between 55% - 60% of organic waste and 25% inorganic waste. The organic waste will undergo four basic chemical processes (i.e. hydrolysis, acidogenesis, acetogenesis and methanogenesis) Fallow period to reuse land Development can be done on the capped land after 30 years by which gas and leachate will be taken out completely before proper compaction and remediation like grassing can be done. The after capping capped dump will drop about three-fourth of its height. If enough time in not given for the gas and leachate to, there could be explosion and sinking of the capped site. Discharging of leachate Cesspit emptier should be used to collect leachate in the hand dug well. The leachate however, should meet a discharge limit. Leachate with heavy metal concentration should be sent to Mudor Sewerage Treatment Plant located at James Town for treatment. Treatment of methane gas Methane gas vented can be used for generation of electricity as being done in Kumasi Landfill. Alternatively, the methane gas can be flared to produce CO2 to reduce its potential contribution to climate change. Appendix 6.4 Ga East Municipal Assembly Ministry of Sanitation & Water Resources 116 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Venue: Conference Room, GEMA Date:03-07-2018 Time: 10:23am:12:30pm Participant Derrick Tata-Anku – Head of Department, Environmental Health and Sanitation Department – 0244016563 CEHRT Team Yaw Amoyaw-Osei - 0247062902 Godfred Allotey – 0244871353 Joshua Wemegah – 0249742014 Issues Comment Historical Account of Dump Establishment and Management How was the dump established? The dump started in 1998. We were previously dumping at Obojo but they stopped us. The need for a dump site led us to Abloragyei. The area was isolated with pits as a result of sand mining. When was the dump started? The main dump started in 1998. In 2007, Amanee Waste, Honest Waste and Southern Express acquired portions of the land from the Ablor Family to be used as waste dumps. Did it start by accident or design? Started by accident because they were no consultation done before using the area as a dump site What was area (size of land) available for the About 50 acres dump? Ownership of the land and tenure The land is a government property. The Assembly is the owner of the dump Who was responsible for managing the dump? Initially the Assembly was managing it. (1998-2005) The Assembly later engaged the services of a contractor –Teriwhite, a waste management company in Tema (2006) Teriwhite operated the land fill for a year. Zoomlion is currently the manager of dump (2007 - Date) Was the area fenced? No Role of GEMA in the dumpsite management The Assembly was spraying the dump and surrounding houses against rodents, reptiles, insects, etc. quarterly Role of the Assembly in regulating development The Assembly has not given any permit to any development of the of the adjoining area adjoining area. All those development are encroachers. Encroachment started in the year 2005 Land use scheme for the area, and formal zoning The area has not been zoned of the dump site Dumpsite Management Systems How did site management change over time? The site was under the management of the then Ga District Assembly from 1998-2005. Ga East District Assembly was created and took charge of the management from 2005- Date. Ga East is now a Municipal Assembly Who were responsible for managing the site? The Assembly was responsible for managing the site (1998 – 2005). Terriwhite, a waste management company was contracted to manage the dump. In 2007, Zoomlion was contracted to manage. How serious were the above problems (intensity, The major problems were odour, fires and smoke and the spatial distribution, etc.)? encroachers Dump Management Measures Type of equipment and facilities developed payloader, crusher ,compactor Number of personnel Not Available Type of waste allowed All types of waste with the exception of clinical waste Was the waste screened before dumping? No Was the waste weighed and recorded before No weigh bridge; we estimate the volumes using the volumes of the dumping trucks. No records available Was leachate from the site controlled (collected and analysed No Ministry of Sanitation & Water Resources 117 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Did the leachate from the site find its own way into public drains? Yes What distance did leachate travel? N/A Was the route within human settlements? Yes Any map showing the leachate and run-off route Yes Do people rely on the receiving stream/water body People may rely on it down stream Were any measures taken to control fly and rodent proliferation Quarterly spraying of the dump Were any measures taken to control odour nuisance? No Performance of the Management Measures How were the managers of the dumpsite selected? Managers submit proposals to manage the dump Were there any capability criteria for evaluating prospective No managers? Were the selection process open and competitive? Yes How successful were the managers of the dump? Quite successful Were there any guidelines and standards to adhere to? No Who monitored/supervised the dump operations by the managers? The Assembly Were there any written records of performance? No Were their contracts renewable based on performance? No What were the The major problems were fire. The fire was attributed to the scavengers who occasionally set fire to problems (effects) extract metals. Fumes from the dump site almost led to the dismissal of the DCE in 2008 after arising from the demonstration by residents, Pantang Hospital Staff, etc. dumping and the Encroachment is also an issue. We have not permitted any development around the dump. dumpsite? A recent flood destroyed unauthorised structures near the dump and spread the waste to nearby houses. Mosquitoes breed on the stagnant pool of leachate in and around the dump. Appendix 6.5 Amanee Waste and Honest Waste Venue: Zoomlion Office at Abloragyei Date:03-07-2018 Time: 10:23am:12:30pm Participant Achaempong Yaw Asafo – Amanee Waste – 0245378571 Awatey Wilson – Operations Manager –Honest Waste – 0204343717 Derick Tata-Anku – EHO -0244016563 CEHRT Team Yaw Amoyaw-Osei - 0247062902 Godfred Allotey – 0244871353 Joshua Wemegah – 0249742014 William Amelorku - 0243631936 Presentation of Project The Government of Ghana proposes rehabilitation and closure, and aftercare management of the Abloragyei dumpsite. This will involve capping of the dump. It is understood that portions of the dump is managed by you (Amanee and Honest Waste) Response and Discussion We welcome the project and are ready to cooperate. I (Amanee waste) bought the land from the Ablor family and sold a portion to Honest waste. We started operations in 2006. There was a huge pit as a result of illegal sand mining activities. The main idea was to fill the pits with garbage. During our active operations, we brought in machines to crush and compress the waste. We have met with the Abloragyei Residents Association on several occasions and have discussed what to use the land for after decommissioning and capping. We concluded we use it for a lorry station and a market since there is no such facility in and around this community Ministry of Sanitation & Water Resources 118 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 7.0 Needs Assessment - GEMA Venue: Office of Works Engineer Date: 09-07-18 Time: 10:35am – 12:55pm Participants Peter Bah-Lano – Works Engineer - 0248387856 Alex Amoah – Planning Officer - 0244516173 Derick Tata-Anku – EHO -0244016563 Aboagye Foster – Urban Roads Engineer - 0244909243 CEHRT TeamYaw Amoyaw-Osei - 0247062902 Godfred Allotey – 0244871353 Joshua Wemegah – 0249742014 1. Special waste cell for managing hazardous fractions Responses Any need for creation of special waste cell for managing hazardous waste Not applicable. There are no special waste here fractions on-site or off-site (say the Kpone Landfill)? 2. End use after capping a) Total area covered by the waste dump is about 20 Acres (About 9 Acres of The private individuals will continue to be the the dumpsite is regarded as Government land, while about 11 Acres is owners of their portions of land after capping owned by private waste contractors (Amanee and Honest)). The use of the land for market and lorry station is b) How will the Assembly handle the ownership issues with the two smaller in line with the Assembly’s developmental agenda. dumps after capping? We will partner them to convert the area into c) The Assembly prefer to convert the capped area into Astro Turf (football market and lorry station. park/mini-stadium) - In Nii Boi Town for instance, the lorry station was i. Are there any other possible end-use options by GEMA? once a dump site ii. Assuming the whole capped area is converted for use as directed by the Assembly, what fair compensation arrangement could be anticipated? d) The waste companies owning about half the dumpsite intended to convert the area into a market and lorry station (since there is none of these in the area, and the residents through their Association are in favour of the proposal). i. What is the Assembly’s view? ii. Would the Assembly support such a proposal, and on what likely terms? 3. Capacity for E&S management responsibilities a) Leachate management (during capping and post-cap monitoring, etc.). Environment Health Department and Works Whose responsibility? Department. There must be a collaboration with b) Ground water monitoring (during capping and post-cap monitoring, etc.) Water Resource Commission (WRC) Whose responsibility? 4. Construction Phase ESMP (Contractor’s responsibility) Assembly’s direction/supervision in preparation of CP ESMP: A safeguard team will be set up to oversee the a) Review of ToR for the CP ESMP and facilitate CP ESMP preparation management of the area during construction and b) Review and accept the prepared CP ESMP (take custody of report) after construction. The team will be made up of c) Monitor construction phase implementation (mitigation measures, etc.)/E&S representatives from the following department performance monitoring/ management during capping (of the capping • Development Planning (lead) contractor), including – • Works i. Clay and other materials sourcing; • Environmental Health ii. Clay quality (plasticity) and compaction desired • Urban Roads iii. Related E&S capping civil works • Social Welfare & Community iv. Haulage of materials and traffic assessment Development 5. Operation Phase ESMP a) Assembly’s responsibility to prepare OP ESMP The capping project is new in the Municipality. We will need capacity (post-cap) building for the Safeguard Team. b) Submission of OP ESMP to EPA for approval and support We suggest the bank provide funds for the monitoring activities for a c) E&S management of the capped dump - period of five years (2 years for construction and 3 years after capping). i. Erosion, landslide, run-off (incl. storm-water) A total of USD80,000 per year may be desirable. The capped area will be control dormant/fallow within this 3-year period. ii. Gas emission structures and effectiveness iii. Leachate collection and analysis (monitoring Light development on the capped land must start three years after quality and quantity) capping. Then 5 years after the development of the light activities (8 years iv. Receiving stream/water quality after capping), other development may be encouraged. Ministry of Sanitation & Water Resources 119 December 2018 Abloragyei Dumpsite Capping Project Final ESIA v. Flooding/inundation of adjoining areas We suggest the area be fenced(block) before construction begins vi. Action to control odour nuisance, mosquitoes, We will need spraying machines to regularly spray the area. houseflies, etc. and documentation Vehicle must be provided for regular visit to the site. Security must be provided (CCTV) and electricity 6. Awarding Contract - selection criteria Selection criteria for awarding contracts - Guidelines and standards to demonstrate The Safeguard Team and Procurement Contractors/Managers’ understanding of required sustainable E&S obligations for: Officer. a) Capping contract (for construction contractors) b) Facility management (of prospective managers of facilities on the capped dump) Development Planning will play the lead role. 7. Land use control around the capped dump a) Will it be necessary to control development in the neighbourhood of the Yes capped dump? b) What will it take to introduce sanity in the development of the area abutting The Assembly will zone the area after capping for the capped dump? proper uniformity. c) Who will be responsible for such control measures? Works Department, Physical Planning and Urban Roads Appendix 8.0 Consultation with Residents near the Dumpsite Appendix 8.1 Respondent 1 Details of Respondent Name: Wilson Akle (Cowherd) – 0549230155 Date: 5th July, 2018 Project Information The MSWR plans to cap the Abloragyei dumpsite and provide aftercare management of collection and treatment of leachate as part of a national project to improve sanitation. In line with the requirement of the environmental assessment regulations LI 1652, consultations are being held with residents within 25m from the boundary of waste dump, to solicit their views and concerns about the project. Period of Staying/Working onsite 1 year Number of Dependants (staying or working with) No dependant but work with one other colleague as cowherd. The cows (45 in number), are owned by 6 people. Period Intended to Stay/Work Onsite Do not know. Purpose of Structure As a sleeping place for the 45 cows. The structure is made up of wood and is one main Kraal divided into two compartments. Main Activities Engaged in Taking care of the cows Alternative Source(s) of Income No alternative source of income. Average Income Earned Do not receive physical money but at the end of every year, I receive one young cow from my boss. Currently that young cow cost about GH₵ 1,500.00. If Evicted, What is Your Alternative My boss will decide where to relocate the kraal. Source of Water From the dam at Paraku junction. The cows are sent there to drink water. Source of Feed Leftover market waste from Madina market. Health Problems (with respect to Odour nuisance, Mosquitoes, Houseflies, Rodents and Snakes) and Seriousness of situation There are lots of mosquitoes and houseflies around. We sometimes get malaria Toilet Situation in the Area There is a toilet in the house I am staying. Appendix 8.2 Respondent 2 Details of Respondent Name Boubacar Djibo (Scrap dealer) 5th July, 2018 Project Information The MSWR plans to cap the Abloragyei dumpsite and provide aftercare management of collection and treatment of leachate as part of a national project to improve sanitation. In line with the requirement of the environmental assessment regulations LI 1652, consultations are being held with residents within 25m from the boundary of waste dump, to solicit their views and concerns about the project. Ministry of Sanitation & Water Resources 120 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Period of Staying/Working onsite 2 years now Number of Dependants (staying or working with) No dependant but currently works with 3 colleagues who, currently, have travelled. Period Intended to Stay/Work Onsite Not decided yet but will not be a permanent place since the landowner can evict us at any time. Purpose of Structure Used for sleeping and working. Main Activities Engaged in Selling of scraps. Use mini truck to go from house to house to collect waste plastics, metals, etc. (called yawuyawu) and send them to Tema for sale. Alternative Source(s) of Income No alternative source of income. Average Income Earned Irregular income but we sometimes get about GH50 to 100 per day depending on materials we get per day. Sometimes too, we get nothing. If Evicted, What is Your Alternative Will go back home (Niger). I have been here due to hardship. The plan was to stay with an extended relative but things did not go as expected. Suggested Type of Aid Appropriate for Eviction Financial assistance to go home if possible. Number of Scavengers Working Onsite Currently, people do not come and scavenge on the dump. Frequency of Dumping About 2 year ago, dumping onsite was very frequent but now, no one is seen dumping refuse. Source of Water We buy sachets water to drink but fetch well water nearby for bathing. Potential Flooding of the Area The area get flooded when it rains. Health Problems (with respect to Odour nuisance, Mosquitoes, Houseflies, Rodents and Snakes) and Seriousness of situation There are lots of mosquitoes and houseflies around but I have never fall sick due to the mosquito net and coil I use. Toilet Situation in the Area We defecate on the dump. Appendix 8.3 Respondent 3 Details of Respondent Name Vida Oforiwaa (Squatter) - 0541432152 5th July, 2018 Project Information The MSWR plans to cap the Abloragyei dumpsite and provide aftercare management of collection and treatment of leachate as part of a national project to improve sanitation. In line with the requirement of the environmental assessment regulations LI 1652, consultations are being held with residents within 25m from the boundary of waste dump, to solicit their views and concerns about the project. Period of Staying/Working onsite 4 months Number of Dependants (staying or working with) 3 children and a husband as dependants. Period Intended to Stay/Work Onsite We intend staying until it is time for us to move from the place; i.e. when the owner of the land asks us to move. Purpose of Structure Single room kiosk. Used for sleeping. Main Activities Engaged in Not working currently (due to the relocation from Akati house to current place) but used to do cleaning job. Alternative Source(s) of Income No alternative source of income. Average Income Earned No earning of income personally but from my husband. If Evicted, What is Your Alternative Will relocate but will need few month notice to prepare before relocation. Suggested Type of Aid Appropriate for Eviction Financial assistance. Number of Scavengers Working Onsite Do not see people scavenging onsite yet. Ministry of Sanitation & Water Resources 121 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Frequency of Dumping No idea. Source of Water We buy sachets water to drink but fetch well water nearby for bathing. Potential Flooding of the Area The area get flooded when it rains with leachates runoff. Health Problems (with respect to Odour nuisance, Mosquitoes, Houseflies, Rodents and Snakes) and Seriousness of situation No odour in the area but lots of mosquitoes, houseflies and saw few rats in my room. Although I normally use coil, within the 4 months we relocated here, I have fallen sick once from malaria. Have not visited hospital around but in case of emergency, I will go to Pantang hospital. Toilet Situation in the Area We defecate on the dump. Appendix 8.4 Respondent 4 Details of Respondent Name Amina Isshaku (Tenant) - 0248784276 5th July, 2018 Project Information The MSWR plans to cap the Abloragyei dumpsite and provide aftercare management of collection and treatment of leachate as part of a national project to improve sanitation. In line with the requirement of the environmental assessment regulations LI 1652, consultations are being held with residents within 25m from the boundary of waste dump, to solicit their views and concerns about the project. Period of Staying/Working onsite 9 months Number of Dependants (staying or working with) 5 children. Period Intended to Stay/Work Onsite No intention to relocate now. Purpose of Structure Single room block building (partially completed). Used for sleeping. Main Activities Engaged in Trader (selling fried yam and meat). Alternative Source(s) of Income No alternative source of income. Average Income Earned Irregular source of income. I cannot estimate the amount but that is what we depend on daily for food. If Evicted, What is Your Alternative Will be a problem since we have nowhere to relocate to. Suggested Type of Aid Appropriate for Eviction Financial assistance and adequate period of notice. Number of Scavengers Working Onsite Lots of scavengers initially but now, I do not see people scavenging onsite. Frequency of Dumping No dumping now. Source of Water We buy sachets water to drink but fetch well water nearby for bathing. Potential Flooding of the Area The area gets flooded when it rains with leachates runoff. My area get flooded with leachate from the dump. Health Problems (with respect to Odour nuisance, Mosquitoes, Houseflies, Rodents and Snakes) and Seriousness of situation No odour in the area but lots of mosquitoes especially when it rains and presence of houseflies. Mice sometime enter the room. We use mosquito net. In case of emergency when sick, Pantang hospital will be the first option. Toilet Situation in the Area We defecate on the dump. Appendix 8.5 Respondent 5 Details of Respondent Name Nii Abloragyei (Abloragyei Chief) – 0242923403/0244389233 Date: 5th July, 2018 Project Information The MSWR plans to cap the Abloragyei dumpsite and provide aftercare management of collection and treatment of leachate as part of a national project to improve sanitation. In line with the requirement of the environmental assessment regulations LI 1652, consultations are Ministry of Sanitation & Water Resources 122 December 2018 Abloragyei Dumpsite Capping Project Final ESIA being held with residents within 25m from the boundary of waste dump, to solicit their views and concerns about the project. History of the area and the dump The land for the house and church structure were acquired from the traditional authority before the dump spread to this section. The land being used for dump was acquired in the 60s by the Ghana government for use in developing the then Ghana Post and Telecommunication. It was not acquired for use as a dump. It was somewhere in 1998 that the dump started. The residents and traditional authority have never been pleased with the siting of the dump on our land and therefore started to protest until it was declared closed in January 2018.We are aware of a directive given during the administration of President Kuffuor that all lands acquired by government which have not been used for the purpose for which they were acquired for over 10 years be given back to the land owners. Dumping stopped due to the vigilance of the community members. Plans for use of the dump land after capping We welcome the capping project. We have plans of developing the land and discussions are being held by the Abloragyei Residents Association on the possible uses; a lorry park, supermarket, etc. Health Problems (with respect to Odour nuisance, Mosquitoes, Houseflies, Rodents and Snakes) and Seriousness of situation We had serious issues with odour, flies and smoke when the dump was active and we still have flies and mosquitoes issues. Appendix 8.6 Respondent 6 Details of Respondent Name: Francis Frimpong – 0505372263/0243910413 (Resident) Date: 5th July, 2018 Project Information The MSWR plans to cap the Abloragyei dumpsite and provide aftercare management of collection and treatment of leachate as part of a national project to improve sanitation. In line with the requirement of the environmental assessment regulations LI 1652, consultations are being held with residents within 25m from the boundary of waste dump, to solicit their views and concerns about the project. Period of Staying/Working onsite 13 years now Number of Dependants (staying or working with) 4 dependants but total of 10 people stay in the house Period Intended to Stay/Work Onsite No intention to relocate now. Purpose of Structure Two sets of chamber and hall block buildings used for sleeping. Main Activities Engaged in I scavenged for metal and plastic scraps for sale when the dump was in operation but now, not working due to closure of the dump. Alternative Source(s) of Income I work as a handy man, engaging in masonry and carpentry work periodically Average Income Earned Irregular source of income between GH₵ 20 to 50 per day. If Evicted, What is Your Alternative Will be a problem since I have nowhere to relocate to. Suggested Type of Aid Appropriate for Eviction Provision of alternate place of abode and financial assistance to aid relocation. Number of Scavengers Working Onsite Lots of scavengers operated on the dump when the site was in operation. But now, no scavenging activity goes on. Frequency of Dumping Frequent when dumping activity was going on but now, no dumping activity goes on. Source of Water We buy sachets water to drink but fetch well water nearby for bathing. Potential Flooding of the Area The area get flooded when it rains with leachates runoff. Health Problems (with respect to Odour nuisance, Mosquitoes, Houseflies, Rodents and Snakes) and Seriousness of situation No odour in the area but lots of mosquitoes especially during the rainy season and presence of houseflies. Mice sometime enter the room. We normally buy medicine from drug stores but in case of emergency when sick, Pantang hospital is the first option. Expectations for site usage after Capping The place can be used as football park Toilet Situation in the Area We have a toilet. Ministry of Sanitation & Water Resources 123 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 8.7 Respondent 7 Details of Respondent Name Jacob Addo – 0554134105 (Resident) Date: 5th July, 2018 Project Information The MSWR want to cap the Abloragyei Dumpsite and provide aftercare management of collection and treatment of leachate to prevent further pollution in the Pantang area. In line with the requirement of the environmental assessment regulations LI 1652, consultations are being held with residents within 25m from the boundary of waste dump, to solicit their views and concerns of the project. Period of Staying/Working onsite I’ve been staying for15 years Number of Dependants (staying or working with) Stay with 6 other people. Period Intended to Stay/Work Onsite Permanent Purpose of Structure Structure is used for sleeping. Main Activities Engaged in Scrap business at Tema. Alternative Source(s) of Income Engage in any construction activity. Average Income Earned Cannot estimate If Evicted, What is Your Alternative There will be a problem since I am not prepared to relocate now. Suggested Type of Aid Appropriate for Eviction Financial assistance to aid in relocating. Number of Scavengers Working Onsite Lots of scavengers when dump was in operation but now, no scavenging activity going on. Source of Waste No idea. Frequency of Dumping A lot of dumping (from individual and trucks) occurred onsite when the place was in operation but now, no one dumps here. Source of Water We buy sachets water to drink but fetch well water nearby for bathing. Potential Flooding of the Area The area get flooded when it rains with leachates runoff. Health Problems (with respect to Odour nuisance, Mosquitoes, Houseflies, Rodents and Snakes) and Seriousness of situation No odour in the dry seasons but we experience unpleasant smell during raining seasons. Also, there are lots of mosquitoes especially when it rains and presence of houseflies. Expectations for site usage after Capping No idea. Toilet Situation in the Area We defecate on the dump. Appendix 9.0 Outcome of Stakeholder Disclosure Workshop Name/Surname Organization Position Phone No. Email Emmanuel Kpobi Waste landfills supervisor 0501509123 enok77@yahoo.com Daniel K. Asante Waste landfills Landfill supervisor 0501509005 daniel.asante@wastelandfill.com.gh Samuel Ato Arhin Waste landfills Landfills supervisor 0501509033 samuel.arhin@wastelandfill.com.gh Richard Omani-Mensah Waste landfills Operations manager 0208630837 richard.omani-mensah@wastefill.com.gh Osumanu M. Basiru Ga East M.A 0208186351 basirugh@yahoo.com Hon. Moses Dowuna Abokobi Assembly man 0243156884 dmosesola@yahoo.com Hon. Jacob Ablorh Ablorh and Adjei Member 0209758235 dmencese@yahoo.com Akyeampon Yaw Asafo Amanse Waste Director 0245378571 amanee@yahoo.com Yaw Amoyaw-Osei CEHRT Director 0243223864 wayoma59@hotmail.com William Amelorku CEHRT Consultant 0243631936 williamamelorku@gmail.com Ministry of Sanitation & Water Resources 124 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Kwame O.S. Prempeh Premko Waste Director 0571145803 kwameosprempeh@gmail.com Seth Adzraku Zoomlion Operations manager 0205630956 skdzru@zoomliom.com Dr. K.Doku-Amponsah University of Ghana 0205164254 kdoku@ug.edu.gh Godfred Allotey CHERT Consultant 0244871353 gnallotey@yahoo.com Wemegah Joshua CEHRT Consultant 0249742014 popsiwems@gmail.com Aboagye Foster DUR Municipal road engineer 0244909243 abofos@yahoo.com Peter Bah-lame GEMA Worlu engineer 0248387856 pbahlano.pbl@gmail.com J.G. Adu- Akoh Residence Member 0208223961 Association Lincoln Agyemang EP Dowu Chairman 0244721106 mclinconsults@yahoo.com Derick Tata-Anku GEMA MEHO 0244016563 dtataridco@yahoo.com Nii Ablor Aditi Abloragyei Chief 0242923403 Kofi Hnang Abloragyei 0240884406 Wilson T. Awatey Honest Waste Manager 0244343717 wilsonteye@yahoo.com Fritz Akotia Abladjei Resident 0558703333 edemakotia@gmail.com Venue: GA East Municipality, Abokobi – Ghana Education Date: 20/07/2018 Time: 11am -1.30pm Service Conference Room Deliberations: a. Ownership of land: It was concluded that the land is owned by the government and it was acquired during President Kuffour’s government for telecommunication purposes. b. Name of Dumpsite: The dumpsite is popularly known as Abokobi Dumpsite and not Abloradjei, but in a previous document that was filed by the court, the name for the site was Pantang dumpsite. The name Abloradjei was confirmed by the assembly during consultation, and so the assembly will be consulted again as to the name being Abloradjei, Pantang or Abokobi. c. Gas Emissions The gas to be produced from the site will not be in commercial quantities making it economically unsound to harvest the gas. d. Post cap land use It was agreed that light structure can be constructed on the capped land after 3 years and more permanent structures after 10 years. Questions: a. What is the percentage of the heavy metals on the dumpsite and what method was used for your analysis? All the information gathered will be shown of the screen and also emailed to all those interested. b. What caused the reduction of the open defecation? There is reduction in open defecation because there is no active dumping. Scavengers and squatters who used to be there during active dumping were the people responsible for the open defecation c. Will the land be grass after three years and will the vent pipes be left in the ground? The vent pipes will show whether or not there is gas in the dump during monitoring. The vents will be decommissioned and removed when monitoring results show that all the gas has been evicted. d. Will there be a need for redumping during capping if filling needs to be done? There will be no need for redumping of waste at the site. The already existing refuse will be used to fill and level to an appreciable height, then capping material will be used to fill whatever gaps are left Closing remarks by Mr Anku Ministry of Sanitation & Water Resources 125 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 10.0 Outcome of Engagement with TESL Venue: Office of the Landfill Supervisor, Tema Date: 7-10-18 Time: 1:30 – 2:20pm Engineered Sanitary Landfill, Kpone Participant Ernest Nlason Ijawan – 0246791549 – Landfill Supervisor, TMA CEHRT Team Yaw Amoyaw-Osei - 0247062902 Joshua Wemegah – 0249742014 Prince Ofori Boateng - 0244985953 Introduction The Government of Ghana through the GARID Project is proposing rehabilitation and closure and aftercare management of the Abloragyei and Old Fadama Dumpsites. Capping of the dumpsites is expected to generate leachate which will be collected into sumps and evacuated monthly for a period of about 6 months. Is there a leachate treatment system at The landfill has special cells for the treatment of leachate (3 ponds: your facility? Anaerobic Lagoon, Facultative I and Facultative II Lagoons Can leachate be brought here for It depends on the volume of leachate and the frequency of disposal. Since treatment? the leachate will be evacuated monthly, it could be brought here and sprinkled on the dump which will eventually go through the leachate treatment system. What is the installed capacity or There was no metre installed to determine the volume of leachate to be maximum volume of leachate to be treated. treated? What are the challenges facing leachate • The recirculation pump that pumps leachate from the Facultative II management at the facility? Lagoon back to the dump is not functioning. • Due to that, leachate overflows during heavy rainfall. • Daily pumping of leachate from the cells into the lagoons is ineffective due to defective pumping machine From your experience, how long will Usually, leachate flow after capping takes not more than 3 months as in leachate flow after capping of the the case of the capped dump at Mallam market and the Kpone old dump. dumpsites? The sumps get dried after 3 months. What usually collects in the sump is runoff after rainfall. Ministry of Sanitation & Water Resources 126 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 11.0 Terms of Reference of Scoping Report DRAFT TERMS OF REFERENCE Legal, Regulatory and Policy Framework The relevant national and international policies, laws and regulations as identified in Chapter Four will be assessed in the EIS, where the relevance to the capping and post capped use will be established. Project Description Gaps identified in the project description information (as described in Chapter 2) will be filled as appropriate during the Draft EIA phase. The project description will cover the following: • Project overview; • Purpose of the project with benefits; • Pre-capping phase activities; • Construction phase activities; and • Post-capped phase activities. Analysis of Alternatives The analysis of alternatives will consider a number of options and compare them with the preferred options. Comparative analyses will be made to determine Best Practicable Environmental Options (BPEO). Analysis will cover aspects such as: • The ‘no project’ implementation alternative • Capping material alternatives • Post-cap land use alternatives Baseline Information Site-specific baseline information identified during scoping as relevant reference data for the analysis and evaluation of impacts, and impact significance will be collected via site investigations. The data will also form the basis for the consideration of mitigation measures and for future monitoring purposes. The baseline information will cover the following: • Brief description of the environment; • Waste characterization and composition; • Socio-economic environment; • Leachate flow and quality; • Groundwater quality; • Air quality; • Heavy metals analysis of soil on the dump; • Overview of the Management of the Dump; and • Geology and Topography of the Area. Assessment of Identified Impacts and Mitigations The scoping identified the important potential impacts and concerns likely to be associated with the capping of the dumpsite and post-capped operations. This includes beneficial impacts and adverse impacts. Opportunities/Beneficial Impacts Potential benefits to be derived from the project include: 1. Eliminate leachate pollution; 2. Eliminate health threatening heavy metal exposure sources; and Ministry of Sanitation & Water Resources 127 December 2018 Abloragyei Dumpsite Capping Project Final ESIA 3. Strengthen the management of the site to ensure sanity. Potential Adverse Impacts The main adverse impacts that may result from the implementation of the project would fall under construction phase and post-cap phase. Construction Phase Impacts 1. Potential degradation from sourcing of capping material; 2. Potential traffic disruption and associated accidents; 3. Risks to successful capping operation; 4. Public and occupational health and safety risks; 5. Potential human rights abuse and gender disparity; and 6. Potential air quality impacts. Post-Cap Phase Impacts 1. Potential impacts on livelihoods; 2. Risk of continual leachate contamination of the Odaw 3. Potential flood risk of adjoining areas and the capped dump 4. Potential risk of erosion on the capped dump 5. Risk of explosion from gas build-up in the capped dump 6. Lack of control and orderly activities 7. Potential collapse of constructed structures on the capped dump The potential sources of the impact with their effects have been identified in Section 7.3 and 7.4 of this Scoping Report. These will be further assessed and approprite mitigation measures will be provided in the EIS. Environmental and Social Management Plan The Environmental and Social Management Plan (ESMP) will be in line with the Word Bank Environmental and Social Management Plan OP 4.01; and will cover the following: • Set of mitigation responses to potentially adverse environmental and social impacts; • Institutional structures and capacity building required to ensure mitigation measures are fully implemented; and • Monitoring programme to implement to verify compliance with recommended mitigation measures. The tool for the Needs Assessment and Capacity Building is provided in the Table 1 below. Table 1 Needs Assessment for E&S Monitoring 1. Capacity for E&S management responsibilities a) Leachate management (during capping and post-cap monitoring, etc.). Whose responsibility? b) Ground water monitoring (during capping and post-cap monitoring, etc.) Whose responsibility? 2. Construction Phase ESMP (Contractor’s responsibility) Assembly’s direction/supervision in preparation of CP ESMP: d) Review of ToR for & facilitate preparation of CP ESMP e) Review & approve prepared CP ESMP (take custody of report) Ministry of Sanitation & Water Resources 128 December 2018 Abloragyei Dumpsite Capping Project Final ESIA f) Monitor construction phase implementation (E&S performance monitoring, etc. during capping, including – v. Clay and other materials sourcing vi. Compaction & related E&S capping civil works vii. Haulage of materials and traffic assessment 3. Operation Phase ESMP (Assembly’s responsibility) d) Prepare & submit OP ESMP to EPA for approval e) E&S monitoring of the capped dump - vii. Erosion control viii. Gas emission structures and ix. Leachate collection/analysis and disposal x. Receiving stream/water quality xi. Flooding/inundation of adjoining areas xii. Action to control mosquitoes, houseflies, etc. f) Prepare and submit bi-monthly monitoring returns 4. Awarding Contract - selection criteria Selection criteria for awarding contracts - Guidelines and standards to demonstrate Contractors’ understanding of required E&S obligations for c) Capping contract (for construction contractors) 5. Land use control around the capped dump d) Will it be necessary to control development in the neighbourhood of the capped dump? e) What could be the E&S risks for allowing developments to continue in the old way? f) What will it take to introduce sanity in the development of the area abutting the capped dump? g) Who will be responsible for such control measures? Public Consultation and Stakeholder Engagement Plan Stakeholder disclosure workshop will be held to disclose key findings of the ESIA to key stakeholders in order to reach a consensus. An Action Plan for further consultation during preparation, rehabilitation and closure, and aftercare management will be provided to avoid the risk of social conflicts. Ministry of Sanitation & Water Resources 129 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Appendix 12.0 EPA’s Review Comments on Draft EIS Ministry of Sanitation & Water Resources 130 December 2018 Abloragyei Dumpsite Capping Project Final ESIA Ministry of Sanitation & Water Resources 131 December 2018