Waste Management in Ghana
Content
Annex F
Waste Report
CONTENTS
F1 F1.1 F1.2 F2 F2.1 F2.2 F2.3 F2.4 F2.5 F2.6 F2.7 F3 F3.1 F3.2 F3.3 F4 F4.1 F4.2
INTRODUCTION INTRODUCTION STRUCTURE OF REPORT OVERVIEW OF WASTE MANAGEMENT IN GHANA LEGISLATION AND REGULATORY REQUIREMENTS INTERNATIONAL AGREEMENTS AND CONVENTIONS WASTE MANAGEMENT INFRASTRUCTURE RECYCLING FACILITIES WASTE TREATMENT AND PROCESSING EXPERIENCE AND CAPABILITIES OF WASTE MANAGEMENT CONTRACTORS INTERNATIONAL SUPPORT INITIATIVES TULLOW GHANA WASTE MANAGEMENT NEEDS WASTE MANAGEMENT PRINCIPLES INTRODUCTION TO WASTE MANAGEMENT NEEDS FACILITIES REQUIRED TO MEET WASTE MANAGEMENT NEEDS WASTE MANAGEMENT OPTIONS AND TULLOW STRATEGY SHORT TERM MEDIUM AND LONG TERM
1 1 1 2 2 4 6 8 8 9 9 11 11 12 13 16 16 17
F1
INTRODUCTION
F1.1
INTRODUCTION Tullow Ghana Limited (Tullow) acting on behalf of the Joint Venture partners, in the course of development and operation of the Jubilee Field will generate a variety of wastes which will require safe and environmentally sound management. The Jubilee Field development will be the first of its kind in Ghana that will produce significant quantities of upstream oil industry waste streams. It is a key responsibility of the Jubilee development team to ensure safe disposal and processing of its waste streams. It is necessary to take into account the current waste management options in Ghana when developing waste management plans and procedures and therefore this report identifies the current situation and identifies key waste management issues. It goes on to consider the options open to Tullow and describes its current strategy for addressing these issues. Within the main EIS there are further details describing waste management to reduce its potential adverse impact in Ghana. This Annex provides background information from a series of site visits and consultations and is intended to provide supporting information.
F1.2
STRUCTURE OF REPORT This report contains the following Sections: Section F2: Overview of Waste Management in Ghana Section F3: Tullow’s Waste Management Needs Section F4: Options and Strategy for Waste Management
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F2
OVERVIEW OF WASTE MANAGEMENT IN GHANA
F2.1 F2.1.1
LEGISLATION AND REGULATORY REQUIREMENTS Waste Management Policy and Legal Framework Although Ghana currently has no specific waste law, general waste regulations or hazardous waste regulations, there is a policy framework that guides the management of hazardous, solid and radioactive wastes. This is embodied in the Local Government Act (1994), Act 462 and the Environmental Sanitation Policy (ESP) of 1999. Ghana established an Environmental Protection Agency (EPA) in 1994 under the auspices of the Ministry of Environment and Science and has developed some environmental legislation, principally the Environmental Protection Agency Act 490 and Environmental Assessment Regulation LI 1652. The main tool of control is then the environmental assessment procedure. The policy framework guiding the management of hazardous, solid and radioactive waste includes the Local Government Act (1994), Act 462 and the Environmental Sanitation Policy (ESP) of 1999. The Environmental Sanitation Policy lays down basic waste management policies with regard to solid wastes and industrial and hazardous wastes. Specifically: • • • disposal of solid wastes must be in accordance with any standards and procedures prescribed by the EPA and any other regulatory agencies; industrial wastes must be conveyed to approved disposal sites; and generators of hazardous wastes must comply with standards prescribed by the relevant regulatory agencies for storage, collection, transportation and final disposal.
While regulatory authority is vested in the EPA, general solid waste (ie domestic waste) management in Ghana is the responsibility of the Ministry of Local Government and Rural Development, which supervises the decentralised Metropolitan, Municipal and District Assemblies (MMDAs). The MMDAs are responsible for the collection and final disposal of solid waste through their Waste Management Departments (WMDs) and their Environmental Health and Sanitation Departments. To summarise, under this framework, the MMDAs are responsible for the collection and final disposal of solid waste through their WMDs and their Environmental Health and Sanitation Departments. Industrial wastes are, as is typically the case in other countries, the responsibility of the industry generating those wastes.
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F2.1.2
Current Laws Governing Waste Management The EPA Act 490 was the enabling legislation and, with regard to waste management, it enables the Minister to make regulations concerning: • • the type, quality or conditions or concentration of substances that may be released into the environment; and the collection, storage, recovery, recycling or disposal of substances which may be hazardous to the environment.
To date, no regulations have been made concerning the handling, treatment and disposal of industrial and hazardous wastes. As indicated, one of the roles of the EPA is to prescribe standards and guidelines concerning the discharge of wastes and control of toxic substances. To date three relevant guideline documents have been published: • • • Ghana Landfill Guidelines, May 2002; Guidelines for the Management of Healthcare and Veterinary Waste in Ghana, 2002; and Best Practice Environmental Guidelines Series No. 3 – Manual for the Preparation of District Waste Management Plans in Ghana, July 2002.
The Ghana Landfill Guidelines published by the EPA are an attempt to promote the phased upgrading of landfills, initially by improving site selection, waste compaction and drainage resulting in ‘High Density Aerobic Landfills’ (target is for all Metropolitan, Municipal and Large Urban landfills by 2010) and culminating in achieving operation of ‘Sanitary Landfills’ by 2020 (again for larger landfills). Progress is being made to achieve these targets. The planning manual refers to the acceptability of disposal of industrial wastes at municipality landfills provided these are “previously identified and quantified by the assembly for handling”. The guidelines do not clarify the meaning of this but it is presumed that this means that if an enterprise has quantified its wastes which are suitable for landfill and the municipality landfill has adequate planned capacity then the wastes can be accepted for landfill. F2.1.3 Waste Classification Systems There is currently no full waste classification system in place in Ghana. The 1999 Environmental Sanitation Policy sub-classifies ‘solid wastes’ as: • • solid wastes; and hazardous and clinical (hospital) wastes.
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The policy covers ‘liquid wastes’ (sewage etc) and also sub-classifies ‘industrial wastes’ as: • • • • F2.1.4 solid wastes; liquid wastes; gaseous wastes; and toxic, radioactive and other special wastes.
Permitting Requirements The EPA is responsible for the environmental and operational permitting of waste management facilities; this includes treatment and final disposal facilities.
F2.2 F2.2.1
INTERNATIONAL AGREEMENTS AND CONVENTIONS MARPOL Convention Ghana is a signatory to the MARPOL Convention (Marine Pollution Convention), although not all parts are ratified yet, and as such is expected to have facilities for the reception of ‘MARPOL wastes’ which include oily wastes and refuse (and sewage when this part is ratified). Ghana currently has limited facilities capable of managing MARPOL wastes although Takoradi port has access to a good standard facility for oily wastes.
F2.2.2
Basel Convention Ghana has acceded to the Basel Convention on transboundary movement of hazardous waste, which implements controls on the movement of hazardous (and certain other) wastes into or between signatory countries. Under the Basel Convention, transboundary movements of hazardous wastes or other prescribed wastes can take place only upon prior written notification by the State of export to the competent authorities of the States of import and each state of transit. Each shipment of hazardous or other prescribed waste must be accompanied by a movement document from the point at which a transboundary movement begins to the point of disposal. Transboundary movements are generally approved, if: (a) the state of export does not have the capability of managing or disposing of the waste in an environmentally sound manner; and (b) the receiving state has appropriate, environmentally sound facilities, and agrees to accept the waste. Ghana acceded to the Basel Convention on 30 May 2003 (accession has the same legal effect as ratification) which means that it must comply with all the requirements of the Convention. Therefore, certain wastes generated in Ghana, or within its territorial waters, that are exported to another country, will be subject to the provisions of the Basel Convention.
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F2.2.3
Bamako Convention Ghana is a signatory to the 1991 Bamako Convention on the Ban of the Import into Africa and the Control of Transboundary Movement of Hazardous Wastes within Africa. This convention is supplementary to the Basel Convention and covers movement of hazardous waste into or between signatory African countries. The Convention has many provisions virtually identical, or analogous, to the Basel Convention provisions.
F2.2.4
Implications Tullow Ghana and its partners are developing the Jubilee Field, which is within Ghanaian territorial waters and therefore any wastes which are produced are considered as being generated in Ghana. Wastes generated from the normal operation of a vessel would be subject to the MARPOL Convention and considered MARPOL wastes, exempt from the requirements of the Basel Convention, and may be discharged at the next port visited (provided suitable facilities are available at that port). Wastes generated onshore and wastes generated offshore which are not as a result of ‘normal operation of a vessel’ and therefore not constituting MARPOL wastes, should be managed in Ghana as far as practicable in an environmentally sound manner. Any waste which cannot be managed, treated and or disposed of in an environmentally sound manner in Ghana will require transportation to another country for management. This is the position will be documented in Tullow’s Waste Management Plan for the project. If those wastes are hazardous under the Basel Convention (and the Bamako Convention if the waste stays in Africa) then a specific management protocol will apply. Typically this involves pre-notification of intending movement, providing evidence of contractual arrangements for the shipment and final management of the waste, obtaining approval from states of transit and final import and tracking of waste movement. It can be problematic finding a country to accept such wastes and the necessary procedures can be time consuming resulting in a need for medium term storage in-country. Even if wastes are non-hazardous, import to other countries can be problematic as the import of any type of waste may be banned, subject to tight controls and/or cause public opposition. However, there have been exports of hazardous waste (pesticide containers for example) from Ghana to Abidjan in Cote D’Ivoire. These were exported in accordance with the requirements of the Basel Convention and the Ghanaian regulatory authorities therefore have experience in the documentation and control of such movements.
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F2.3 F2.3.1
WASTE MANAGEMENT INFRASTRUCTURE Waste Collection and Transportation There are a number of companies in Ghana collecting and transporting domestic-type solid wastes. The largest of these is ZoomLion which has a large number of collection vehicles ranging from tricycles to 40m3 container trucks and compacting waste collection trucks. There are rudimentary capabilities for collection and transportation of liquid and hazardous wastes.
F2.3.2
General Solid Waste Management Waste management treatment and disposal infrastructure is currently underdeveloped in Ghana; for example landfills are still at the stage of municipal dumps rather than sanitary or ‘engineered’ landfills. This is the situation in the Western Region. Whilst these facilities are principally intended for the collection and management of general solid wastes from domestic sources, general solid wastes from commercial and industrial sources are also disposed of at these facilities. Such facilities are therefore generally available for non-hazardous general solid wastes generated by oil and gas companies operating in Ghana (although the planning manual referenced in Section FF2.1.2 specifies that this is acceptable only provided that they have been ‘previously identified and quantified by the Assembly for handling’). The majority of these municipal dumps have no environmental protection measures and therefore are not considered Best Practicable Environmental Option (BPEO) and are unsuitable disposal sites for hazardous or potentially hazardous wastes. The lack of control at these sites and the typical extent of unsafe scavenging and potential for water pollution raises the issue as to whether these are suitable for general, non-hazardous, solid wastes generated by Tullow other than as a short term measure. A sanitary, lined, landfill funded by the World Bank was planned for SekondiTakoradi (with 10 cells and enough capacity for approximately 15 years of waste arisings) and development commenced but the project ceased and construction was never completed. The partially developed landfill at Takoradi remains a potential resource, however, if the project is reactivated. The Sekondi-Takoradi Metropolitan Assembly (STMA) is negotiating to reactivate this project with World Bank funding and a company is currently re-finalising the design. Unfortunately, STMA is currently depositing waste at the site of the stalled World Bank landfill. At present the waste is being deposited away from the partially engineered leachate treatment area of the site but within the Phase 3 fill area. There is a risk that the longer this uncontrolled operation continues the more of the site will be unavailable for Phase 3 or even Phase 2
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development. This waste could of course be moved to Phase 1 when it opens but this will make operations more complex and result in Phase 1 filling very rapidly. If the uncontrolled tipping at the site continues for much longer the World Bank may consider that the original plans to develop the site as a modern engineered landfill are no longer viable. It must be assumed that, in the short term, the only ‘landfill’ which will be available for solid wastes in the Takoradi area will be this site. It is currently operating as an uncontrolled dump; over which the EPA has expressed deep concern. F2.3.3 Industrial and Hazardous Waste Management There are no dedicated facilities for industrial solid waste management or hazardous waste management other than fairly basic oil water separation facilities as described below. Industrial solid wastes are generally disposed of to municipal dumps with or without any form of pre-treatment. There is also believed to be widespread illegal dumping. There is an established procedure for generators of hazardous industrial wastes to inform the EPA (Chemicals Department) who will advise on sampling and analysis of the waste and then advise any necessary treatment and/or disposal procedures to be followed. This may include the supervision of the actual disposal of wastes by EPA staff. This pragmatic approach is commendable, has been adopted as a temporary measure in other countries, and works to a certain degree. However, from our discussions with local waste management operators, it appears that a great many generators of hazardous wastes are bypassing this system and dumping their hazardous wastes in an uncontrolled manner. F2.3.4 MARPOL Waste Management Facilities There are a number of contractors in Ghana offering collection and disposal services for MARPOL Annex 1 wastes (oily and oil/water wastes). The majority of these technologies are very basic, comprising simple gravity separation, with no specific technologies to assist separation and no use of chemical surfactants. The exception to this, in terms of companies operating in Takoradi, is Zeal Environmental, which has an arrangement with the Takoradi Power Station to utilise spare capacity of the power station’s oil/water treatment system. This system features a three stage separation system – gravity separation basin, API(1) separator and a Dissolved Air Flotation (DAF) separator. This facility may be regarded as BPEO for oil and oil/water wastes. The only remaining issues are effluent discharge quality and the disposal of solid/sludge residues (duty of care auditing needed).
(1) The API separator is a proprietary device commonly used in the oil and gas industry to separate oil and water based on their different specific gravities ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW GHANA LIMITED
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Refuse and sewage wastes are dealt with via the Metropolitan Assembly’s normal routes for such wastes with refuse going to the existing waste dump. There are no facilities available for the management of chemical wastes in bulk or packaged form.
F2.4
RECYCLING FACILITIES Basic facilities exist for plastics, glass and metals recycling so there is scope for segregation of general solid waste at source for introduction into the local recycling markets. There are small collectors of waste oils. These oils are however not re-refined and are generally utilised as supplementary fuels in heating applications. Some of these uses are considered acceptable by EPA but many of the other common uses, such as the practice of using oily sludges as wood preservatives, are unacceptable to the EPA and can not be regarded as being appropriate from a health and safety perspective. There are no facilities in country for recycling of dry cell batteries or fluorescent lamps. There is ad hoc recycling of lead-acid batteries however the method of recycling and the treatment/final disposal method and destination of the acids is unclear.
F2.5
WASTE TREATMENT AND PROCESSING There are no known facilities in Ghana for physical/chemical treatment of industrial wastes and no known facilities for thermal treatment of hazardous wastes. With regard to healthcare wastes, it is understood that some hospitals have basic combustors for healthcare wastes but that none of these currently meet European Union Waste Incineration Directive standards. The Takoradi Power Station has a small liquid/sludge incinerator for residues from its oil/water separation system and on-site tank cleaning operations. It is understood however that this incinerator was never fully commissioned and has remained unused. The arrangement between Zeal Environmental and the Takoradi Power Station does not include use of this facility. Cement kilns are now commonly used to dispose of certain hazardous wastes in many countries with higher energy content wastes being used as supplementary fuels in the kilns. Although there is cement production in Ghana (Ghacem and Diamond Cement), the cement is produced from imported clinker and there are no cement kilns in Ghana. Thus, this potential waste management route is not available.
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F2.6
EXPERIENCE AND CAPABILITIES OF WASTE MANAGEMENT CONTRACTORS Waste management contractors are emerging in Ghana with improving experience. These are largely limited to collection and transportation companies serving Metropolitan areas. At stated above the largest and best equipped appears to be ZoomLion. There are also a number of MARPOL waste collection contractors, all of whom are relatively small, relatively recently established organisations with limited capabilities. From discussions with the companies evaluated for the purposes of this assessment, these facilities typically have just gravity separation in storage tanks and no wastewater treatment capabilities to process separated water. Zeal Environmental Technologies has acquired a 6.5 acre site zoned for industrial use well away from residential areas and plans to develop Ghana’s first integrated industrial waste management facility. There are significant challenges in developing an environmentally sound, commercially viable, facility. The current concept is for phased development of a facility which will ultimately include the following. • A MARPOL Annex I oily waste reception and treatment facility (first phase element replacing the facility they currently use within the Takoradi Power Station). • A further tank cleaning waste reception facility for other, principally inorganic waste, transportation tanks (waste would come from Zeal’s own mobile tank cleaning operations) is planned but has yet to be constructed. • Chemical treatment system (details not finalised but probably incorporating acid/alkali neutralisation and metal hydroxide precipitation). • Hazardous waste incineration system (details yet to be finalised). • Other physical treatment systems including washing, shredding and container crushing. • Associated waste reception and storage systems. The management of Zeal Environmental Technologies has expressed its keen interest in developing the proposed waste management facilities but, like many such small enterprising companies, it lacks the practical experience of the required technologies. This may result in a protracted timescale for development of the above facilities. Partnering and international experienced support could be appropriate to bring forward this project and similar ones.
F2.7
INTERNATIONAL SUPPORT INITIATIVES In terms of waste management, international support initiatives have resulted in the funding of two strategic sanitary landfills for domestic-type solid
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wastes. This has clearly been valuable although both the sites have had operational issues related to plant. ERM is not aware of any current international initiatives supporting industrial and hazardous waste management in Ghana.
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F3
TULLOW GHANA WASTE MANAGEMENT NEEDS
F3.1
WASTE MANAGEMENT PRINCIPLES There are a number of key principles which should be considered when determining waste management requirements and these are developed in the following sections.
F3.1.1
The Waste Management Hierarchy The waste management hierarchy is summarised Figure F3.1. The hierarchy ranks the different generic methods of waste management in order of general preference from an environmental perspective and shows that priority should be given to avoidance and minimisation of waste generation followed by recovery, reuse and recycling. The least preferred option being disposal (eg landfill or injection).
Figure F3.1
Waste Management Hierarchy
F3.1.2
The Proximity Principle A second internationally accepted principle of waste management is the ‘Proximity Principle’ which states that waste should be managed as close to the point of generation as is practicable. This can be illustrated in the form of a hierarchy with treatment/disposal at source being the most preferred option and export being the least preferred option (Figure F3.2).
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Figure F3.2
Proximity Principle
F3.1.3
The Use of Best Practicable Environmental Option This is the principle that waste should be managed by the ‘best’ means choosing an option which minimises the impact upon the environment taking into account issues of availability and affordability. In choosing the best environmental practicable option, a balance often has to be struck in that strict application of one principle may result in being unable to comply with another principle. For example, currently in Ghana there is no high temperature incineration facility available, and while this may be deemed to be the best technology option it currently necessitates export which is the least desirable option under the proximity principle.
F3.2
INTRODUCTION TO WASTE MANAGEMENT NEEDS A preliminary waste generation inventory for Tullow is being developed to inform the development of a project Waste Management Plan. Tullow, in common with other companies undertaking oil and gas exploration, development and production need to have access to environmentally acceptable facilities for the management of: • • • • • • • general solid wastes, including recyclables (domestic-type, bio-degradable non-hazardous wastes); oily liquids/sludges and oil/water mixtures (hazardous wastes); oil contaminated solid wastes (hazardous wastes); organic chemical wastes (hazardous wastes); inorganic chemical wastes (hazardous wastes); end of life electronic equipment; and small quantities of healthcare wastes.
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F3.3 F3.3.1
FACILITIES REQUIRED TO MEET WASTE MANAGEMENT NEEDS Summary of Needs Oil exploration and production activities always generate a range of wastes requiring the following waste management options: • • • • • recovery, recycling and reuse; general solid waste landfill; hazardous waste landfill; high temperature thermal treatment; and physical/chemical treatment.
The waste management options required for the most common waste streams are outlined below. F3.3.2 Recovery, Recycling and Reuse In accordance with the waste management hierarchy, environmentally sound reuse, waste recovery and recycling should take precedence over waste treatment and disposal. There may be opportunities to return unused materials, which are surplus to requirements, to the original suppliers thereby enabling their reuse. This is very likely to be the most environmentally sound option if available. There are likely to be local markets for prime recyclables such as metals, cardboard and plastics. There are no suitable facilities for more sophisticated recovery/recycling such as would be required for dry cell batteries, lead-acid batteries, fluorescent light tubes etc. Tullow plans to implement segregated collection of prime recyclables as far as practicable for handling by local recycling contractors. F3.3.3 General Solid Wastes BPEO for disposal of general solid wastes (ie municipal type wastes) would be sanitary landfill or incineration. High density aerobic (HDA) landfill as defined in Ghana’s Landfill Guidelines would be an acceptable second best to sanitary landfills. Currently, disposal of general solid wastes in the Sekondi-Takoradi region is not being undertaken to the defined standards of HDA landfilling and is more akin to uncontrolled dumping. As a result there are associated environmental, health and safety (EHS) risks. However, if the World Bank funded Takoradi landfill project is reactivated a sanitary landfill could be available for these wastes eighteen months to two years from now. Residual concerns over the standard of operation would still exist (there are currently two World Bank funded sanitary landfills operating in other Regions of Ghana, Ashanti and Northern Region, both of which have run into operational difficulties). Apart
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from the potential Takoradi landfill (if it is developed), there is no BPEO option in the Western Region. F3.3.4 Waste Oils and Oil/Water Wastes BPEO for management of waste oil s and oil/water wastes (including MARPOL Annex I Wastes) would be recovery/recycling via purpose built oil water separation systems or re-refining in the case of oils. The Zeal Environmental Technologies arrangement with Takoradi Power Station means that a BPEO solution for oily waste separation is currently available in Ghana. The only residual EHS concerns in relation to this are the pathways for use/disposal of the recovered materials (oil and water) and residual wastes (oily solids). As part of their duty of care, oil companies should aim to ensure, by periodic facility auditing, that: • • • recovered oils are utilised in environmentally acceptable processes; any water that is discharged is compliant with the facility discharge consents; oily sludges are disposed of by environmentally acceptable means (see previous discussion about use as fuel for heating or as wood preservative and discussion in the next sub-section).
F3.3.5
Solid Wastes Contaminated With Oil or Other Organic Compounds BPEO for such wastes would be high temperature incineration for heavily contaminated combustible materials. For inert solid wastes contaminated with oils (drill cuttings for example), low temperature thermal desorption would generally be the BPEO. Neither of these options exists in Ghana at the moment although Zeal Environmental Technologies is considering incorporating high temperature incineration at its newly acquired site. Whether or not such a facility is developed, and the timescale for it to become operational, will depend on several factors such as Zeal’s confidence that there is sufficient market interest in such a service and its technical and financial capabilities. Some wastes with low organic content, such as some drill cuttings, may be suitable for treatment by biological means (eg on land). Other wastes with low levels of contamination may be suitable for hazardous waste landfill, however, this currently does not exist in Ghana.
F3.3.6
Organic Chemical Wastes (Solid and Liquid) BPEO for such wastes is high temperature incineration and the same comments as above apply. These wastes will need to be stored pending export for high temperature incineration.
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F3.3.7
Inorganic Chemical Wastes (Solid and Liquid) Low toxicity non-hazardous solid inorganic wastes may potentially be disposed of to controlled landfill and in the absence of a reuse or recycling option this may be considered to be BPEO. Otherwise BPEO for liquid inorganic chemical wastes would be chemical treatment (not currently available in Ghana) or, in the case of some low concentration, low hazard, inorganic chemical wastes, treatment in wastewater treatment plants. Whilst these options are not currently available in Ghana, Zeal Environmental Technologies has indicated that it is contemplating inclusion of physical/chemical treatment facilities at its newly acquired site. Given that the capital cost for this would be relatively low, there is a reasonable chance that Zeal will be able to develop such a treatment facility and so this option may possibly become available in the medium term (one or two years). Solid and sludge products of chemical treatment would require disposal to sanitary landfill or hazardous waste landfill.
F3.3.8
Healthcare Wastes Small quantities of healthcare wastes are generated by oil and gas companies. These require incineration (preferred) or autoclaving and controlled landfill. A common solution employed is to have these wastes disposed of by a hospital locally. From discussions with the EPA, however, it is understood that none of the local hospitals have modern incinerators but instead use very basic combustors. This is therefore not an ideal route for the disposal of medical wastes although it may be the best practical solution at the moment. In the absence of modern dedicated high temperature incinerators, the use of a hospital waste combustor is acceptable for the very small quantities of healthcare wastes generated by Tullow.
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F4
WASTE MANAGEMENT OPTIONS AND TULLOW STRATEGY
F4.1
SHORT TERM Ghana currently has a BPEO solution for MARPOL Annex I wastes in Takoradi however there are few options for the management of most other types of wastes. There are two sanitary landfills operating in Ghana, in Tamale and Kumasi, although these have operational issues, such as plant breakdown. In Takoradi, general solid waste management is still at the stage of uncontrolled dumping although there may be sanitary waste capacity in eighteen months to two years time. There are no hazardous waste landfill facilities, no chemical waste treatment facilities and no thermal treatment facilities other than basic combustors for medical waste at some hospitals. This situation dictates that, in the short term, Tullow will undertake the following. • Segregate those prime recyclable wastes for which there are recovery and recycling markets in Ghana, periodically auditing the activities of the recovery and recycling contractors to ensure that these wastes are managed in an environmentally sound manner. Use the current STMA service for disposal of general solid domestic-type wastes ensuring that, as far as practicable, hazardous wastes and other wastes unsuitable for landfill are segregated from this waste stream. Investigate the use of the oily waste processing facility at the Takoradi Power Station, and if used then implement a periodic audit to ensure that residual materials are managed in an acceptable manner. Segregate and store industrial and hazardous waste that are unsuitable for landfill in a safe and environmentally sound manner pending export for environmentally sound treatment and disposal. Establish and implement procedures and plans for export of wastes from Ghana.
•
•
•
•
The reliance on export, at least in the short term, will necessitate robust and effective documentation systems and procedures.
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F4.2
MEDIUM AND LONG TERM As the situation in Ghana stands, Tullow have the following four choices in the medium and long term. • Continue to export wastes from Ghana for management in a country with suitable technology options for treatment and/or disposal. Develop additional facilities for their own use. Co-operate with other oil companies to develop shared infrastructure for their own use. Co-operate with municipalities and/or local companies to develop facilities for shared use.
• •
•
While it is possible to continue the export of wastes for the foreseeable future, Tullow is currently considering options for encouraging the development of improved waste management facilities in Ghana. Other international oil companies operating in Ghana are in the same situation and therefore these companies may wish to cooperate with each other in promoting in some way the development of additional facilities. Such support will focus on the development of new treatment and disposal options including some or all of the following. • Development of a hazardous waste landfill (potential for inclusion of a hazardous waste cell in the design of the Takoradi Sanitary Landfill project, the design of which is currently being reviewed by a local company on behalf of STMA for application for World Bank funding). Development of a small-scale high temperature incineration facility. Development of a physical/chemical treatment facility for predominantly inorganic wastes.
• •
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Waste Report
CONTENTS
F1 F1.1 F1.2 F2 F2.1 F2.2 F2.3 F2.4 F2.5 F2.6 F2.7 F3 F3.1 F3.2 F3.3 F4 F4.1 F4.2
INTRODUCTION INTRODUCTION STRUCTURE OF REPORT OVERVIEW OF WASTE MANAGEMENT IN GHANA LEGISLATION AND REGULATORY REQUIREMENTS INTERNATIONAL AGREEMENTS AND CONVENTIONS WASTE MANAGEMENT INFRASTRUCTURE RECYCLING FACILITIES WASTE TREATMENT AND PROCESSING EXPERIENCE AND CAPABILITIES OF WASTE MANAGEMENT CONTRACTORS INTERNATIONAL SUPPORT INITIATIVES TULLOW GHANA WASTE MANAGEMENT NEEDS WASTE MANAGEMENT PRINCIPLES INTRODUCTION TO WASTE MANAGEMENT NEEDS FACILITIES REQUIRED TO MEET WASTE MANAGEMENT NEEDS WASTE MANAGEMENT OPTIONS AND TULLOW STRATEGY SHORT TERM MEDIUM AND LONG TERM
1 1 1 2 2 4 6 8 8 9 9 11 11 12 13 16 16 17
F1
INTRODUCTION
F1.1
INTRODUCTION Tullow Ghana Limited (Tullow) acting on behalf of the Joint Venture partners, in the course of development and operation of the Jubilee Field will generate a variety of wastes which will require safe and environmentally sound management. The Jubilee Field development will be the first of its kind in Ghana that will produce significant quantities of upstream oil industry waste streams. It is a key responsibility of the Jubilee development team to ensure safe disposal and processing of its waste streams. It is necessary to take into account the current waste management options in Ghana when developing waste management plans and procedures and therefore this report identifies the current situation and identifies key waste management issues. It goes on to consider the options open to Tullow and describes its current strategy for addressing these issues. Within the main EIS there are further details describing waste management to reduce its potential adverse impact in Ghana. This Annex provides background information from a series of site visits and consultations and is intended to provide supporting information.
F1.2
STRUCTURE OF REPORT This report contains the following Sections: Section F2: Overview of Waste Management in Ghana Section F3: Tullow’s Waste Management Needs Section F4: Options and Strategy for Waste Management
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F2
OVERVIEW OF WASTE MANAGEMENT IN GHANA
F2.1 F2.1.1
LEGISLATION AND REGULATORY REQUIREMENTS Waste Management Policy and Legal Framework Although Ghana currently has no specific waste law, general waste regulations or hazardous waste regulations, there is a policy framework that guides the management of hazardous, solid and radioactive wastes. This is embodied in the Local Government Act (1994), Act 462 and the Environmental Sanitation Policy (ESP) of 1999. Ghana established an Environmental Protection Agency (EPA) in 1994 under the auspices of the Ministry of Environment and Science and has developed some environmental legislation, principally the Environmental Protection Agency Act 490 and Environmental Assessment Regulation LI 1652. The main tool of control is then the environmental assessment procedure. The policy framework guiding the management of hazardous, solid and radioactive waste includes the Local Government Act (1994), Act 462 and the Environmental Sanitation Policy (ESP) of 1999. The Environmental Sanitation Policy lays down basic waste management policies with regard to solid wastes and industrial and hazardous wastes. Specifically: • • • disposal of solid wastes must be in accordance with any standards and procedures prescribed by the EPA and any other regulatory agencies; industrial wastes must be conveyed to approved disposal sites; and generators of hazardous wastes must comply with standards prescribed by the relevant regulatory agencies for storage, collection, transportation and final disposal.
While regulatory authority is vested in the EPA, general solid waste (ie domestic waste) management in Ghana is the responsibility of the Ministry of Local Government and Rural Development, which supervises the decentralised Metropolitan, Municipal and District Assemblies (MMDAs). The MMDAs are responsible for the collection and final disposal of solid waste through their Waste Management Departments (WMDs) and their Environmental Health and Sanitation Departments. To summarise, under this framework, the MMDAs are responsible for the collection and final disposal of solid waste through their WMDs and their Environmental Health and Sanitation Departments. Industrial wastes are, as is typically the case in other countries, the responsibility of the industry generating those wastes.
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F2.1.2
Current Laws Governing Waste Management The EPA Act 490 was the enabling legislation and, with regard to waste management, it enables the Minister to make regulations concerning: • • the type, quality or conditions or concentration of substances that may be released into the environment; and the collection, storage, recovery, recycling or disposal of substances which may be hazardous to the environment.
To date, no regulations have been made concerning the handling, treatment and disposal of industrial and hazardous wastes. As indicated, one of the roles of the EPA is to prescribe standards and guidelines concerning the discharge of wastes and control of toxic substances. To date three relevant guideline documents have been published: • • • Ghana Landfill Guidelines, May 2002; Guidelines for the Management of Healthcare and Veterinary Waste in Ghana, 2002; and Best Practice Environmental Guidelines Series No. 3 – Manual for the Preparation of District Waste Management Plans in Ghana, July 2002.
The Ghana Landfill Guidelines published by the EPA are an attempt to promote the phased upgrading of landfills, initially by improving site selection, waste compaction and drainage resulting in ‘High Density Aerobic Landfills’ (target is for all Metropolitan, Municipal and Large Urban landfills by 2010) and culminating in achieving operation of ‘Sanitary Landfills’ by 2020 (again for larger landfills). Progress is being made to achieve these targets. The planning manual refers to the acceptability of disposal of industrial wastes at municipality landfills provided these are “previously identified and quantified by the assembly for handling”. The guidelines do not clarify the meaning of this but it is presumed that this means that if an enterprise has quantified its wastes which are suitable for landfill and the municipality landfill has adequate planned capacity then the wastes can be accepted for landfill. F2.1.3 Waste Classification Systems There is currently no full waste classification system in place in Ghana. The 1999 Environmental Sanitation Policy sub-classifies ‘solid wastes’ as: • • solid wastes; and hazardous and clinical (hospital) wastes.
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The policy covers ‘liquid wastes’ (sewage etc) and also sub-classifies ‘industrial wastes’ as: • • • • F2.1.4 solid wastes; liquid wastes; gaseous wastes; and toxic, radioactive and other special wastes.
Permitting Requirements The EPA is responsible for the environmental and operational permitting of waste management facilities; this includes treatment and final disposal facilities.
F2.2 F2.2.1
INTERNATIONAL AGREEMENTS AND CONVENTIONS MARPOL Convention Ghana is a signatory to the MARPOL Convention (Marine Pollution Convention), although not all parts are ratified yet, and as such is expected to have facilities for the reception of ‘MARPOL wastes’ which include oily wastes and refuse (and sewage when this part is ratified). Ghana currently has limited facilities capable of managing MARPOL wastes although Takoradi port has access to a good standard facility for oily wastes.
F2.2.2
Basel Convention Ghana has acceded to the Basel Convention on transboundary movement of hazardous waste, which implements controls on the movement of hazardous (and certain other) wastes into or between signatory countries. Under the Basel Convention, transboundary movements of hazardous wastes or other prescribed wastes can take place only upon prior written notification by the State of export to the competent authorities of the States of import and each state of transit. Each shipment of hazardous or other prescribed waste must be accompanied by a movement document from the point at which a transboundary movement begins to the point of disposal. Transboundary movements are generally approved, if: (a) the state of export does not have the capability of managing or disposing of the waste in an environmentally sound manner; and (b) the receiving state has appropriate, environmentally sound facilities, and agrees to accept the waste. Ghana acceded to the Basel Convention on 30 May 2003 (accession has the same legal effect as ratification) which means that it must comply with all the requirements of the Convention. Therefore, certain wastes generated in Ghana, or within its territorial waters, that are exported to another country, will be subject to the provisions of the Basel Convention.
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F2.2.3
Bamako Convention Ghana is a signatory to the 1991 Bamako Convention on the Ban of the Import into Africa and the Control of Transboundary Movement of Hazardous Wastes within Africa. This convention is supplementary to the Basel Convention and covers movement of hazardous waste into or between signatory African countries. The Convention has many provisions virtually identical, or analogous, to the Basel Convention provisions.
F2.2.4
Implications Tullow Ghana and its partners are developing the Jubilee Field, which is within Ghanaian territorial waters and therefore any wastes which are produced are considered as being generated in Ghana. Wastes generated from the normal operation of a vessel would be subject to the MARPOL Convention and considered MARPOL wastes, exempt from the requirements of the Basel Convention, and may be discharged at the next port visited (provided suitable facilities are available at that port). Wastes generated onshore and wastes generated offshore which are not as a result of ‘normal operation of a vessel’ and therefore not constituting MARPOL wastes, should be managed in Ghana as far as practicable in an environmentally sound manner. Any waste which cannot be managed, treated and or disposed of in an environmentally sound manner in Ghana will require transportation to another country for management. This is the position will be documented in Tullow’s Waste Management Plan for the project. If those wastes are hazardous under the Basel Convention (and the Bamako Convention if the waste stays in Africa) then a specific management protocol will apply. Typically this involves pre-notification of intending movement, providing evidence of contractual arrangements for the shipment and final management of the waste, obtaining approval from states of transit and final import and tracking of waste movement. It can be problematic finding a country to accept such wastes and the necessary procedures can be time consuming resulting in a need for medium term storage in-country. Even if wastes are non-hazardous, import to other countries can be problematic as the import of any type of waste may be banned, subject to tight controls and/or cause public opposition. However, there have been exports of hazardous waste (pesticide containers for example) from Ghana to Abidjan in Cote D’Ivoire. These were exported in accordance with the requirements of the Basel Convention and the Ghanaian regulatory authorities therefore have experience in the documentation and control of such movements.
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F2.3 F2.3.1
WASTE MANAGEMENT INFRASTRUCTURE Waste Collection and Transportation There are a number of companies in Ghana collecting and transporting domestic-type solid wastes. The largest of these is ZoomLion which has a large number of collection vehicles ranging from tricycles to 40m3 container trucks and compacting waste collection trucks. There are rudimentary capabilities for collection and transportation of liquid and hazardous wastes.
F2.3.2
General Solid Waste Management Waste management treatment and disposal infrastructure is currently underdeveloped in Ghana; for example landfills are still at the stage of municipal dumps rather than sanitary or ‘engineered’ landfills. This is the situation in the Western Region. Whilst these facilities are principally intended for the collection and management of general solid wastes from domestic sources, general solid wastes from commercial and industrial sources are also disposed of at these facilities. Such facilities are therefore generally available for non-hazardous general solid wastes generated by oil and gas companies operating in Ghana (although the planning manual referenced in Section FF2.1.2 specifies that this is acceptable only provided that they have been ‘previously identified and quantified by the Assembly for handling’). The majority of these municipal dumps have no environmental protection measures and therefore are not considered Best Practicable Environmental Option (BPEO) and are unsuitable disposal sites for hazardous or potentially hazardous wastes. The lack of control at these sites and the typical extent of unsafe scavenging and potential for water pollution raises the issue as to whether these are suitable for general, non-hazardous, solid wastes generated by Tullow other than as a short term measure. A sanitary, lined, landfill funded by the World Bank was planned for SekondiTakoradi (with 10 cells and enough capacity for approximately 15 years of waste arisings) and development commenced but the project ceased and construction was never completed. The partially developed landfill at Takoradi remains a potential resource, however, if the project is reactivated. The Sekondi-Takoradi Metropolitan Assembly (STMA) is negotiating to reactivate this project with World Bank funding and a company is currently re-finalising the design. Unfortunately, STMA is currently depositing waste at the site of the stalled World Bank landfill. At present the waste is being deposited away from the partially engineered leachate treatment area of the site but within the Phase 3 fill area. There is a risk that the longer this uncontrolled operation continues the more of the site will be unavailable for Phase 3 or even Phase 2
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development. This waste could of course be moved to Phase 1 when it opens but this will make operations more complex and result in Phase 1 filling very rapidly. If the uncontrolled tipping at the site continues for much longer the World Bank may consider that the original plans to develop the site as a modern engineered landfill are no longer viable. It must be assumed that, in the short term, the only ‘landfill’ which will be available for solid wastes in the Takoradi area will be this site. It is currently operating as an uncontrolled dump; over which the EPA has expressed deep concern. F2.3.3 Industrial and Hazardous Waste Management There are no dedicated facilities for industrial solid waste management or hazardous waste management other than fairly basic oil water separation facilities as described below. Industrial solid wastes are generally disposed of to municipal dumps with or without any form of pre-treatment. There is also believed to be widespread illegal dumping. There is an established procedure for generators of hazardous industrial wastes to inform the EPA (Chemicals Department) who will advise on sampling and analysis of the waste and then advise any necessary treatment and/or disposal procedures to be followed. This may include the supervision of the actual disposal of wastes by EPA staff. This pragmatic approach is commendable, has been adopted as a temporary measure in other countries, and works to a certain degree. However, from our discussions with local waste management operators, it appears that a great many generators of hazardous wastes are bypassing this system and dumping their hazardous wastes in an uncontrolled manner. F2.3.4 MARPOL Waste Management Facilities There are a number of contractors in Ghana offering collection and disposal services for MARPOL Annex 1 wastes (oily and oil/water wastes). The majority of these technologies are very basic, comprising simple gravity separation, with no specific technologies to assist separation and no use of chemical surfactants. The exception to this, in terms of companies operating in Takoradi, is Zeal Environmental, which has an arrangement with the Takoradi Power Station to utilise spare capacity of the power station’s oil/water treatment system. This system features a three stage separation system – gravity separation basin, API(1) separator and a Dissolved Air Flotation (DAF) separator. This facility may be regarded as BPEO for oil and oil/water wastes. The only remaining issues are effluent discharge quality and the disposal of solid/sludge residues (duty of care auditing needed).
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Refuse and sewage wastes are dealt with via the Metropolitan Assembly’s normal routes for such wastes with refuse going to the existing waste dump. There are no facilities available for the management of chemical wastes in bulk or packaged form.
F2.4
RECYCLING FACILITIES Basic facilities exist for plastics, glass and metals recycling so there is scope for segregation of general solid waste at source for introduction into the local recycling markets. There are small collectors of waste oils. These oils are however not re-refined and are generally utilised as supplementary fuels in heating applications. Some of these uses are considered acceptable by EPA but many of the other common uses, such as the practice of using oily sludges as wood preservatives, are unacceptable to the EPA and can not be regarded as being appropriate from a health and safety perspective. There are no facilities in country for recycling of dry cell batteries or fluorescent lamps. There is ad hoc recycling of lead-acid batteries however the method of recycling and the treatment/final disposal method and destination of the acids is unclear.
F2.5
WASTE TREATMENT AND PROCESSING There are no known facilities in Ghana for physical/chemical treatment of industrial wastes and no known facilities for thermal treatment of hazardous wastes. With regard to healthcare wastes, it is understood that some hospitals have basic combustors for healthcare wastes but that none of these currently meet European Union Waste Incineration Directive standards. The Takoradi Power Station has a small liquid/sludge incinerator for residues from its oil/water separation system and on-site tank cleaning operations. It is understood however that this incinerator was never fully commissioned and has remained unused. The arrangement between Zeal Environmental and the Takoradi Power Station does not include use of this facility. Cement kilns are now commonly used to dispose of certain hazardous wastes in many countries with higher energy content wastes being used as supplementary fuels in the kilns. Although there is cement production in Ghana (Ghacem and Diamond Cement), the cement is produced from imported clinker and there are no cement kilns in Ghana. Thus, this potential waste management route is not available.
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F2.6
EXPERIENCE AND CAPABILITIES OF WASTE MANAGEMENT CONTRACTORS Waste management contractors are emerging in Ghana with improving experience. These are largely limited to collection and transportation companies serving Metropolitan areas. At stated above the largest and best equipped appears to be ZoomLion. There are also a number of MARPOL waste collection contractors, all of whom are relatively small, relatively recently established organisations with limited capabilities. From discussions with the companies evaluated for the purposes of this assessment, these facilities typically have just gravity separation in storage tanks and no wastewater treatment capabilities to process separated water. Zeal Environmental Technologies has acquired a 6.5 acre site zoned for industrial use well away from residential areas and plans to develop Ghana’s first integrated industrial waste management facility. There are significant challenges in developing an environmentally sound, commercially viable, facility. The current concept is for phased development of a facility which will ultimately include the following. • A MARPOL Annex I oily waste reception and treatment facility (first phase element replacing the facility they currently use within the Takoradi Power Station). • A further tank cleaning waste reception facility for other, principally inorganic waste, transportation tanks (waste would come from Zeal’s own mobile tank cleaning operations) is planned but has yet to be constructed. • Chemical treatment system (details not finalised but probably incorporating acid/alkali neutralisation and metal hydroxide precipitation). • Hazardous waste incineration system (details yet to be finalised). • Other physical treatment systems including washing, shredding and container crushing. • Associated waste reception and storage systems. The management of Zeal Environmental Technologies has expressed its keen interest in developing the proposed waste management facilities but, like many such small enterprising companies, it lacks the practical experience of the required technologies. This may result in a protracted timescale for development of the above facilities. Partnering and international experienced support could be appropriate to bring forward this project and similar ones.
F2.7
INTERNATIONAL SUPPORT INITIATIVES In terms of waste management, international support initiatives have resulted in the funding of two strategic sanitary landfills for domestic-type solid
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wastes. This has clearly been valuable although both the sites have had operational issues related to plant. ERM is not aware of any current international initiatives supporting industrial and hazardous waste management in Ghana.
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F3
TULLOW GHANA WASTE MANAGEMENT NEEDS
F3.1
WASTE MANAGEMENT PRINCIPLES There are a number of key principles which should be considered when determining waste management requirements and these are developed in the following sections.
F3.1.1
The Waste Management Hierarchy The waste management hierarchy is summarised Figure F3.1. The hierarchy ranks the different generic methods of waste management in order of general preference from an environmental perspective and shows that priority should be given to avoidance and minimisation of waste generation followed by recovery, reuse and recycling. The least preferred option being disposal (eg landfill or injection).
Figure F3.1
Waste Management Hierarchy
F3.1.2
The Proximity Principle A second internationally accepted principle of waste management is the ‘Proximity Principle’ which states that waste should be managed as close to the point of generation as is practicable. This can be illustrated in the form of a hierarchy with treatment/disposal at source being the most preferred option and export being the least preferred option (Figure F3.2).
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Figure F3.2
Proximity Principle
F3.1.3
The Use of Best Practicable Environmental Option This is the principle that waste should be managed by the ‘best’ means choosing an option which minimises the impact upon the environment taking into account issues of availability and affordability. In choosing the best environmental practicable option, a balance often has to be struck in that strict application of one principle may result in being unable to comply with another principle. For example, currently in Ghana there is no high temperature incineration facility available, and while this may be deemed to be the best technology option it currently necessitates export which is the least desirable option under the proximity principle.
F3.2
INTRODUCTION TO WASTE MANAGEMENT NEEDS A preliminary waste generation inventory for Tullow is being developed to inform the development of a project Waste Management Plan. Tullow, in common with other companies undertaking oil and gas exploration, development and production need to have access to environmentally acceptable facilities for the management of: • • • • • • • general solid wastes, including recyclables (domestic-type, bio-degradable non-hazardous wastes); oily liquids/sludges and oil/water mixtures (hazardous wastes); oil contaminated solid wastes (hazardous wastes); organic chemical wastes (hazardous wastes); inorganic chemical wastes (hazardous wastes); end of life electronic equipment; and small quantities of healthcare wastes.
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F3.3 F3.3.1
FACILITIES REQUIRED TO MEET WASTE MANAGEMENT NEEDS Summary of Needs Oil exploration and production activities always generate a range of wastes requiring the following waste management options: • • • • • recovery, recycling and reuse; general solid waste landfill; hazardous waste landfill; high temperature thermal treatment; and physical/chemical treatment.
The waste management options required for the most common waste streams are outlined below. F3.3.2 Recovery, Recycling and Reuse In accordance with the waste management hierarchy, environmentally sound reuse, waste recovery and recycling should take precedence over waste treatment and disposal. There may be opportunities to return unused materials, which are surplus to requirements, to the original suppliers thereby enabling their reuse. This is very likely to be the most environmentally sound option if available. There are likely to be local markets for prime recyclables such as metals, cardboard and plastics. There are no suitable facilities for more sophisticated recovery/recycling such as would be required for dry cell batteries, lead-acid batteries, fluorescent light tubes etc. Tullow plans to implement segregated collection of prime recyclables as far as practicable for handling by local recycling contractors. F3.3.3 General Solid Wastes BPEO for disposal of general solid wastes (ie municipal type wastes) would be sanitary landfill or incineration. High density aerobic (HDA) landfill as defined in Ghana’s Landfill Guidelines would be an acceptable second best to sanitary landfills. Currently, disposal of general solid wastes in the Sekondi-Takoradi region is not being undertaken to the defined standards of HDA landfilling and is more akin to uncontrolled dumping. As a result there are associated environmental, health and safety (EHS) risks. However, if the World Bank funded Takoradi landfill project is reactivated a sanitary landfill could be available for these wastes eighteen months to two years from now. Residual concerns over the standard of operation would still exist (there are currently two World Bank funded sanitary landfills operating in other Regions of Ghana, Ashanti and Northern Region, both of which have run into operational difficulties). Apart
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from the potential Takoradi landfill (if it is developed), there is no BPEO option in the Western Region. F3.3.4 Waste Oils and Oil/Water Wastes BPEO for management of waste oil s and oil/water wastes (including MARPOL Annex I Wastes) would be recovery/recycling via purpose built oil water separation systems or re-refining in the case of oils. The Zeal Environmental Technologies arrangement with Takoradi Power Station means that a BPEO solution for oily waste separation is currently available in Ghana. The only residual EHS concerns in relation to this are the pathways for use/disposal of the recovered materials (oil and water) and residual wastes (oily solids). As part of their duty of care, oil companies should aim to ensure, by periodic facility auditing, that: • • • recovered oils are utilised in environmentally acceptable processes; any water that is discharged is compliant with the facility discharge consents; oily sludges are disposed of by environmentally acceptable means (see previous discussion about use as fuel for heating or as wood preservative and discussion in the next sub-section).
F3.3.5
Solid Wastes Contaminated With Oil or Other Organic Compounds BPEO for such wastes would be high temperature incineration for heavily contaminated combustible materials. For inert solid wastes contaminated with oils (drill cuttings for example), low temperature thermal desorption would generally be the BPEO. Neither of these options exists in Ghana at the moment although Zeal Environmental Technologies is considering incorporating high temperature incineration at its newly acquired site. Whether or not such a facility is developed, and the timescale for it to become operational, will depend on several factors such as Zeal’s confidence that there is sufficient market interest in such a service and its technical and financial capabilities. Some wastes with low organic content, such as some drill cuttings, may be suitable for treatment by biological means (eg on land). Other wastes with low levels of contamination may be suitable for hazardous waste landfill, however, this currently does not exist in Ghana.
F3.3.6
Organic Chemical Wastes (Solid and Liquid) BPEO for such wastes is high temperature incineration and the same comments as above apply. These wastes will need to be stored pending export for high temperature incineration.
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F3.3.7
Inorganic Chemical Wastes (Solid and Liquid) Low toxicity non-hazardous solid inorganic wastes may potentially be disposed of to controlled landfill and in the absence of a reuse or recycling option this may be considered to be BPEO. Otherwise BPEO for liquid inorganic chemical wastes would be chemical treatment (not currently available in Ghana) or, in the case of some low concentration, low hazard, inorganic chemical wastes, treatment in wastewater treatment plants. Whilst these options are not currently available in Ghana, Zeal Environmental Technologies has indicated that it is contemplating inclusion of physical/chemical treatment facilities at its newly acquired site. Given that the capital cost for this would be relatively low, there is a reasonable chance that Zeal will be able to develop such a treatment facility and so this option may possibly become available in the medium term (one or two years). Solid and sludge products of chemical treatment would require disposal to sanitary landfill or hazardous waste landfill.
F3.3.8
Healthcare Wastes Small quantities of healthcare wastes are generated by oil and gas companies. These require incineration (preferred) or autoclaving and controlled landfill. A common solution employed is to have these wastes disposed of by a hospital locally. From discussions with the EPA, however, it is understood that none of the local hospitals have modern incinerators but instead use very basic combustors. This is therefore not an ideal route for the disposal of medical wastes although it may be the best practical solution at the moment. In the absence of modern dedicated high temperature incinerators, the use of a hospital waste combustor is acceptable for the very small quantities of healthcare wastes generated by Tullow.
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F4
WASTE MANAGEMENT OPTIONS AND TULLOW STRATEGY
F4.1
SHORT TERM Ghana currently has a BPEO solution for MARPOL Annex I wastes in Takoradi however there are few options for the management of most other types of wastes. There are two sanitary landfills operating in Ghana, in Tamale and Kumasi, although these have operational issues, such as plant breakdown. In Takoradi, general solid waste management is still at the stage of uncontrolled dumping although there may be sanitary waste capacity in eighteen months to two years time. There are no hazardous waste landfill facilities, no chemical waste treatment facilities and no thermal treatment facilities other than basic combustors for medical waste at some hospitals. This situation dictates that, in the short term, Tullow will undertake the following. • Segregate those prime recyclable wastes for which there are recovery and recycling markets in Ghana, periodically auditing the activities of the recovery and recycling contractors to ensure that these wastes are managed in an environmentally sound manner. Use the current STMA service for disposal of general solid domestic-type wastes ensuring that, as far as practicable, hazardous wastes and other wastes unsuitable for landfill are segregated from this waste stream. Investigate the use of the oily waste processing facility at the Takoradi Power Station, and if used then implement a periodic audit to ensure that residual materials are managed in an acceptable manner. Segregate and store industrial and hazardous waste that are unsuitable for landfill in a safe and environmentally sound manner pending export for environmentally sound treatment and disposal. Establish and implement procedures and plans for export of wastes from Ghana.
•
•
•
•
The reliance on export, at least in the short term, will necessitate robust and effective documentation systems and procedures.
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F4.2
MEDIUM AND LONG TERM As the situation in Ghana stands, Tullow have the following four choices in the medium and long term. • Continue to export wastes from Ghana for management in a country with suitable technology options for treatment and/or disposal. Develop additional facilities for their own use. Co-operate with other oil companies to develop shared infrastructure for their own use. Co-operate with municipalities and/or local companies to develop facilities for shared use.
• •
•
While it is possible to continue the export of wastes for the foreseeable future, Tullow is currently considering options for encouraging the development of improved waste management facilities in Ghana. Other international oil companies operating in Ghana are in the same situation and therefore these companies may wish to cooperate with each other in promoting in some way the development of additional facilities. Such support will focus on the development of new treatment and disposal options including some or all of the following. • Development of a hazardous waste landfill (potential for inclusion of a hazardous waste cell in the design of the Takoradi Sanitary Landfill project, the design of which is currently being reviewed by a local company on behalf of STMA for application for World Bank funding). Development of a small-scale high temperature incineration facility. Development of a physical/chemical treatment facility for predominantly inorganic wastes.
• •
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