Professional Documents
Culture Documents
EIA
EIA
STUDY REPORT
For
THE PROPOSED WASTE PLASTIC AND TYRE
PYROLYSIS PLANT IN THIKA
ON PLOT L.R. No. L.R. Thika Municipality Block 29/653
February, 2017
This project report on Environmental Impacts Assessment has been prepared by Environ Consulting
Ltd a NEMA registered and licensed EIA/EA Firm of Experts.
This report has been done with reasonable skills, care and diligence in accordance with the
Environmental Management and Coordination Act, 1999 and the Environmental (Impact
Assessment and Audit) Regulations 2003.
We the undersigned, certify that the particulars given in this report are correct to the best of our
knowledge.
Date
Firm of Experts
PROPONENT
Date
Ja Recycling Ltd is planning to install a plastic and tyre pyrolysis plant in Thika Township – Kiambu
County adjacent to the Kang‟oki dump site on plot L.R. No. Thika Municipality Block 29/653, to
convert waste tyre to diesel oil. The process will involve molecular breakdown of larger molecules
into smaller molecules in presence of heat and in the absence of oxygen, a process also known as
thermal cracking, thermolysis, depolymerization. During the process, object‟s molecules are
subjected to very high temperatures leading to very high molecular vibrations. At these high
molecular vibrations, every molecule in the object is stretched and shaken to such an extent that
molecules starts breaking down into smaller molecules.
The company plans to rent one of the go-downs and a space within a 0.4199ha plot adjacent to
Kang‟oki dump site on rental basis. This means that Ja-Recycling will not be conducting any
construction activities except to install the proposed plant in an open shade. An Environmental
Impact Assessment (EIA) licence for the construction of ware houses has been granted by NEMA
and indeed warehouse construction is currently in progress. The purpose of this EIA report to be
submitted to the National Environment Management Authority (NEMA) is the proponent to install
and operate as highlighted above. The site has good geological structure in a remote location
bordering a dump site which is a positive step in waste management process.
The availability of such waste recycling facility is not only a critical environmental issue, but also an
essential economic factor for a country that aspires to grow its industrial base. Most international
companies expect a hazardous waste management program to be in place that is both economical
and meets international standards, especially ISO 14001 considerations. Besides, without the means
to such wastes as tyres, it is not possible to enforce the current environmental legislation.
Plastic and tire pyrolysis involves subjecting plastic and tire to high temperature of 400 to 450
degree Celsius, in absence of oxygen. This will ensure that raw materials are broken down into
smaller molecules of pyrolysis oil, pyrolysis gas and carbon black. Like plastic and tire, pyrolysis
end products are also known as hydrocarbons compounds. The process is great way of recycling
waste plastics and tires which are becoming an eye sore in various parts of the country especially
towns which has seen a major increate of plastic and tyre waste. The construction of this company
will ensure: -
In compliance to the Environmental Management and Coordination Act (EMCA), 1999 as well as
the related regulations, JA Recycling Ltd has undertaken this ToR as a prelude to the conduction of
EIA through a NEMA registered Lead EIA Expert for review and necessary approval purposes.
Our investigation examined the potential impacts of the project on the immediate surrounding with
due regard to all the phases from installation through to completing, operation and decommissioning.
It encompasses all aspects pertaining to the physical, socio-cultural, health and safety conditions at
the site and its environs during and after installation of the project. During the screening exercise,
issues identified as those that may be impacted upon by the project activities include: air quality,
health and safety, and other environmental hazards and socio-economic welfare of the surrounding
communities.
The site
At the time of the assessment, the one acre piece of land had been approved for construction of go-
downs for industrial use in readiness of the same and a space has already been identified within the
site for the construction of an open shed. The plot is already fenced with a boundary wall to ensure
security and restrict movement in and out of the site.
Electricity needs will be met from the KPLC grid whereas having a power generator backup
whenever necessary. The main road access to the facility is an all weather road off Thika – Garissa
road at Posta area of Makongeni. This road is all weather murram road serving local residents within
the area and more so waste trucks off loading at the dumpsite. The proponent will improve the road
to the site to ensure accessibility and safe delivery of raw materials and taking of finished products.
The site is expected to be designed such as to ensure optimal utilization of space, ensure minimal
waste movement, easy and safe movement for the forklifts and other machines wherever applicable.
At full operations the plant is expected to help recycle a lot of waste from within the country. Wastes
will be segregated and contained safely at specific locations around the premises. Spills, emissions
and friable materials will be contained in the premises.
1. INTRODUCTION
The availability of a commercial hazardous waste management facility is not only a critical
environmental issue, but also an essential economic factor for a country that aspires to grow its
industrial base. Most international companies expect a hazardous waste management program to be
in place that is both economical and meets international standards, especially ISO 14000
considerations. Besides, without the means to treat and dispose hazardous wastes, it is not possible to
enforce the current environmental legislation.
The project design and technology shown eco-friendly and cost-effective waste pyrolysis plant with
the world class design and technology. The waste pyrolysis equipment has been designed to have a
lower cost and higher fuel oil output. The waste tyre pyrolysis machine combines continuous and
batch type pyrolysis plant. The continuous pyrolysis machine is to feed the raw materials, such as
tyre and plastic, on one side and discharge the carbon black continuously from the other side.
However, the batch type is to feed the machine with a batch of raw material and take the process and
start the next process after cooling down the machine and discharging the carbon black. The
proposed plant is based on the green technology (pyrolysis) to achieving the environmentally
friendly process, which is the excellent waste tyre management solution for tyre recycling.
The plant process environmentally friendly designed to solve tyre and other environment pollution
which are becoming the serious issues in the current industrial dispensation. Due to multiplicity of
end products from the process including heat, electricity, steam and so on, the plant will therefore be
of benefit to the economy of the country in its operation. Further distillation of the oil by
professional pyrolysis oil distillation plant, the end product can be used for vehicle powering.
The main parts of the system includes reactor, transmission device, catalytic chamber, cooling tube,
manifold, heavy oil tank, light oil tank, oil condenser, oil-water separator, safety device, vacuum
system, dedusting system.
Tyre refining device decomposes waste tyres through high temperature process into kinds of useful
resources, such as fuel oil, carbon black, steel wires and fuel gas. Meanwhile, tyre pyrolysis
equipment will make renewable resources out of black pollution. During this process, scrap tyres are
put into production as raw material, which not only controls environment pollution but also achieves
resource regenerating and recycling. What is more, batch tyre pyrolysis plants are suitable for raw
materials within 120mm.
The management of hazardous wastes in Kenya is regulated under the Environmental Management
and Co-ordination Act (EMCA, 1999)), EMCA (Waste Management) Regulations (2006) and other
related regulations controlling the all wastes which poses hazardous attributes to the environment
and the environmental occupants as a whole. These regulations establish an order of preference for
the management of hazardous wastes to be: minimization, recycling, treatment, and land filling. The
facility will therefore offer recycling aspect in fulfillment of the regulation‟s aim.
The installation of the plant will also make the already undesirable land useful from the eyesore of
waste in the dumpsite.
1.2.1. Objectives
The purpose of this EIA is to ensure adequate identification of potentially negative environmental
impacts. Secondly to propose workable mitigation measures and thirdly to formulate an
environmental management plan (EMP) articulating envisaged impacts.
The overall objective of the study on the other hand is to ensure that all environmental concerns are
integrated in all the project development processes with an aim of managing hazardous waste
without compromising the natural environment and the ecology of the area.
iii. To assess the relative importance of the impacts of relative plan designs, and sites
iv. To propose preventive mitigation and compensative measures for the significant negative
impacts of the project on the environment.
v. Generate baseline data for monitoring and evaluating how well the mitigation measures are
being implemented during the project cycle.
vii. To present the results of the EIA that can guide informed decision making
1.2.2. Scope
The Environmental Impact Assessment was conducted at the site and the surrounding area. The
assessment involved the physical examination, interviews with beneficiaries, neighbouring
communities, relevant consultants and government agencies.
The project assessment investigates and analyses the anticipated environmental impacts of the
proposed development in line with the Environmental (Impact Assessment and Audit) Regulations
of 2003.
Nature of the project and describing the project and associated works together with the
requirements
The location of the project including the physical area that may be affected by the project
activities
The potential environmental impact of the project and mitigation measures to be undertaken
during and after the project cycle
An action plan for prevention and management of possible accidents during the project cycle
Identify, assess and specify methods, measures and standards, to be included in the detailed
design, construction and operation of the project which are necessary to mitigate these
environmental impacts and reducing them to acceptable levels.
Provide information on the consideration of alternatives/ options for site locations and
layouts of the project to avoid and minimize potential environmental impacts; to compare
environmental pros and cons of each of the options and to provide reasons for selecting the
preferred option
Any other information that the proponent may be requested to provide by NEMA
1.2.3. Criteria
The EIA approach was structured so as to cover the requirements under the EMCA, 1999 as well as
the Environmental Management and Coordination (Environmental Impact Assessment and Audit)
Regulations, 2003 and amended 2009 regulations. The approach mainly involved an understanding
of the project background, technology and processes, implementation plan, operation activities. In
addition, baseline information was obtained through detailed physical and biological investigation of
the proposed project and its surrounding areas, stakeholder consultations (which included
discussions with area residents, private sector, county administration) photography and, continuous
discussions with the proponent.
Following the preliminary visit of the proposed site, the following was undertaken
(i) Screening of the project, a process that identified the project as being among those
that requiring EIA under schedule 2 of the EMCA 1999
(ii) A scoping exercise that identified the key issues to be identified in the study
Documentary review on the nature of the proposed activities, policy and legal framework,
environmental setting of the area and other available relevant data/information
Detailed discussions with the proponent and the consultation with the relevant officials in the
regulatory authorities
Reviewing the proposed project designs and implementation plan/schedules with a view to
suggesting suitable alternatives
The environmental Impact (EIA) report considered the following aspect and other that proved of
significance during the study
2. Social implications of the development within the locality, region and nationally. This
included:
Economic implications of the development
Security, risk and safety
Employment
Livelihoods
Public health implications
Demand and development of infrastructures and social amenities
5. Develop an environmental management plan (EMP) that would mitigate the possible impacts
on the environment
The report emphasizes the duties of the proponent and the contractor/supplier during the project
phase. It will be the duty of the proponent to ensure that all legal requirements pertaining to the
development are met as specified by the law.
Prepare and maintain an approved time and progress chart showing clearly the period
allowed for each section of the work
The contractor/supplier is to comply with all regulations and by-laws of the local authority
including serving notices and paying of the fees
The contractor shall make good at his own expense any damage he may cause to any public
and private roads and pavements in the course of carrying out his work
The contractor/supplier shall be responsible for all the action of the sub-contractor in the first
instance
The contractor or supplier shall take all possible precaution to prevent nuisance,
inconvenience or injury to the neighbouring properties and to the public generally, and shall
use proper precaution to ensure that safety of willed traffic and pedestrian
All work which may produce under level of noise, dust vibration or any other discomfort to
the workers, and/or guest of the client must be undertaken with care with all necessary
precautions taken
The contractor or supplier shall upon completion of working remove and clear away all plant
rubbish and unused materials and shall leave the site in a clean and tidy state to the
certification of the site engineer. He shall also remove from the site all rubbish and dirt as it
is produced to maintain the tidiness of the premise and its immediate environs
All the materials and workmanship used the execution of the works shall be of the best
quality and description. Any material condemned by the site engineer shall immediately be
removed from the sit at the contractor/supplier expense
2. PROJECT DESCRIPTION
The plant process environmentally friendly designed to solve tyre and other environment pollution
which are becoming the serious issues in the current industrial dispensation. Due to multiplicity of
end products from the process including heat, electricity, steam and so on, the plant will therefore be
of benefit to the economy of the country in its operation..
The proposed project is will be located in an open shade whereas, the adjucent go-downs already
approved for construction in an acre piece of land on rental basis from the current owner situated
parcel - L.R. No. Thika Municipality Block 29/653, at Kang‟oki dumpsite in Thika – Kiambu
County.
At the time of the assessment, the one acre piece of land had been approved for construction of go-
downs for industrial use in readiness of the same and a space has already been identified within the
site for the construction of an open shed. The plot is already fenced with a boundary wall.
The site is expected to be designed such as to ensure optimal utilization of space, ensure minimal
waste movement, easy and safe movement for the forklifts and other machines. At full operations the
plant is expected to help recycle a lot of waste from within the country. Wastes will be segregated
and contained safely at specific locations around the premises. Spills, emissions and friable materials
will be contained in the premises.
The proposed site had been fence off from any interference using a perimeter wall. Adjacent to the
site is a dumpsite commonly called “Kang‟oki dumpsite”. Electricity needs will be met from the
KPLC grid whereas having a power generator backup whenever necessary. The main road access to
the facility is an all weather road off Thika – Garissa road at Posta area of Makongeni. This is road is
all weather murram road serving local residents within the area and more so waste trucks off loading
at the dumpsite. The proponent will improve the road to the site to ensure accessibility and safe
deliver of raw materials and taking of finished products.
Less than two hundred meters of radius are residential apartments to the east of the site.
At the site, there will be go-downs and an open shed for the installation of the main plant. A
provision of waste sorting yard will be made to allow for manual sorting using human labor and a
storage facility for the finished product. One of the go-down will cater for office space for staff
within the site.
(i) Offices,
(ii) Sanitation facilities (toilets, bathrooms, hydrants, wastewater drains,
(iii) Health and safety provisions (fire extinguishers, hydrants, signage, exits, first Aid points
etc.,
(iv) Security arrangements
(i) The land is legally owned and the proponed has gone into contractual agreement with the
proponent to utilize the facility on tenant basis. This makes the development more
feasible to the proponent,
(ii) Due to the presence of a dumpsite on the east side of the project site can make it possible
to present a case of appropriate zoning in future to the Local Government Authorities to
ensure minimal social impacts
(iii) There are no significant environmental sensitive features around the site (no surface
water bodies, no forest cover, no wetlands, not sensitive habitats noted, etc.). It is,
therefore, likely to have minimal environmental impacts,
(iv) The proponent is ready to abide by the law for a long term suitability of the site.
The consideration of alternatives to a proposal is a requirement of many E.I.A systems. It lies at the
heart of the E.I.A process and methodology. During the scoping process, alternatives to a proposal
can be generated or refined, either directly or by reference to the key issues identified. A comparison
of alternatives will help to determine the best method of achieving project objectives while
minimizing environmental impacts or, more creatively, indicate the most environmentally friendly or
best practicable environmental option.
From an environmental perspective, not carrying out this development may be the best option.
Without the development, the area would remain a relatively undisturbed area providing a habitat for
the varied flora and fauna presently observed. This area will continue to be impacted, although
minimally, by anthropogenic and natural factors. From a socio-economic perspective the “no action”
alternative may not be the best alternative as the numerous benefits to be gained from the
development both locally and nationally would not be realized and the resources in the area would
continue to be underutilized
In order to enable the proposed project to seek different ways of minimizing its impacts on the
environment and at the same time achieve its objectives several alternatives were assessed through
its architectural and engineering designs and environmental planning through this EIA. This not only
The proceeding subsections review these alternatives in the subjects of: location, time, design,
inputs, existence and the base case with mitigation.
This option entails carrying out the proposal at a later time thereby offsetting its impacts to that time.
Only benefit is if there be improvements in baseline conditions and technologies that may be
involved with the proposal. However these are not guaranteed and it may only lead delays in
development, therefore carrying out the proposed project with mitigation would be a preferred
option due to this uncertainty. In addition carrying out the proposed project at later time may lead to
more operational and logistic costs due to increasing inflation and standards of living.
This option curtails undertaking the project but with different infrastructural designs that encompass:
buildings, roads, power, water and sewerage. The presented project design was however achieved by
considering the options available that would ensure cost-effectiveness and avoid or reduce
environmental and social impacts as much as possible.
For the execution of the project and its associated accessories, several options were explored as
where they can located and it was preferred to locate the site near the already designated area for
waste handling i.e. dumpsite area, to shield the local tenants of the area from pollution. Additionally
several of the other proposed designs would result in higher building densities and less internal
transport/path optimization. This would mean the project would use more energy and resources as
compared to the preferred project option. Additionally the alternative possible designs would also
reduce the project‟s commercial viability as well as its targeted balance with nature that will create
Alternatively the project may use different combinations of inputs such as: transport systems; water;
electric and power. This may reduce the project‟s impacts in several cases but as compared to the
project‟s preferred options for these services they may result in extensive costs and bottlenecks since
several of these options/inputs are at a techno-commercial infancy stage and have a varying set of
impacts.
2.5.6 Utilities
Electricity
The proposed project had various options for its sources of the electricity and these are reviewed in
contrast to the preferred option
Materials
The project will be installed in an open space and this means that there will be no major construction
except of foundation works for raise a platform for machine installation. Alternative for the materials
that will be used in the project involve using locally procured materials (base case) with the
exception of not using timber and the second option involves primarily importing materials and
using timber. The former alternative is preferred option since it will ensure the project contributes to
the national economy by creating business opportunities for the suppliers of these materials while
conserving the environment by ensuring the most environmentally friendly suppliers are contracted.
This option will also not use timber since most of the hardwoods available in Kenya come from the
DRC where forestry is largely unregulated while local timber sources are in most cases not
sustainable
This alternative means forfeiting the proposed development avoiding all its impact both positive and
negative. The only benefit of this option would be negative impacts would be avoided such as losses
in flora & faunal habitats, waste generation and pressure on infrastructure. However positive gains
from the project on the economy and specifically on waste tyre management would also be lost
including employment creation, revenue generation, tourism development, capital injection into the
economy and infrastructure developments that may result from the project.
The proposed project will involve installation of the plant in already secured place as aforesaid under
open shade. The owner of the premise is currently in the process of building go-downs after seeking
approvals from relevant authorities.
The project installation is scheduled not to be more than three months from the time approvals are
obtained.
3.1 Introduction
The Environmental Impact Assessment is a useful tool for protection of the environment from the
negative effects of developmental activities. It is now accepted that development projects must be
economically viable, socially acceptable and environmentally sound. It is a condition of the Kenya
Government for developers to conduct Environmental Impact Assessment on the development
Projects.
Kenya has a policy, legal and administrative framework for environmental management. Under the
framework, the National Environment Management Authority (NEMA) is responsible for ensuring
that environmental impact assessments (EIAs) are carried out for new projects and environmental
audits on existing facilities as per the environmental management and coordination Act 1999.
EIAs are carried out in order to identify potential positive and negative impacts associated with the
proposed project with a view to taking advantage of the positive impacts and developing mitigation
measures for the negative ones. The guidelines on EIAs are contained in Sections 58 to 67 of the
Act.
According to Section 68 of the Environmental Management and Coordination Act (EMCA) 1999,
The Authority will be responsible for carrying out environmental audits on all activities that are
likely to have a significant effect on the environment.
Environmental auditing (EA) is a tool for environmental conservation and has been identified as a
key requirement for existing facilities to ensure sustainable operations with respect to environmental
resources and socio-economic activities in the neighbourhood of the facilities.
There is an existing policy, legal and administrative framework regulating the proposed project. The
government has established regulation to facilitate the process of EIA study and EA. The regulations
are contained in the Kenya Gazette supplement No. 56, legislative No. 31, legal notice No. 101 of
13th June 2003. In addition, the government has a number of National Policies and statutes to
enhance environment and sustainable development. Some of the policies and legal provisions are
discussed below
In the past, the government has established a number of National policies and legal statutes to
enhance environmental conservation and sustainable development. The proponent will need to
observe the provisions of the various statutes that are aimed at maintaining a clean, healthy and
sustainable environment. Some of the policy and legal provisions are briefly discussed in the
following sub-Sections
Environmental Impact Assessment (EIA) is a methodology used to identify the actual and probable
impacts of the projects and programmes on the environment and to recommend alternatives and
mitigating measures. The assessment is required at all stages of project development with a view to
ensuring environmentally sustainable development for both existing and proposed public and private
sector development ventures. The National EIA regulations were issued in accordance with the
provisions of Environmental Management and Co-ordination Act (EMCA) of 1999. The EIA
Regulations must be administered, taking into cognizance provisions of EMCA 1999 and other
relevant national laws. The intention is to approve and license only those projects that take into
consideration all aspects of concern to the public as they impact on health and the quality of the
environment.
The NEAP for Kenya was prepared in mid 1990s: It was a deliberate policy effort to integrate
environmental considerations into the country‟s economic and social development. The integration
process was to be achieved through a multi-sectoral approach to develop a comprehensive
framework to ensure that environmental management and the conservation of natural resources are
an integral part of societal decision-making
While the National Policy on water resource management and development (1999) seeks to enhance
systematic development of facilities in all sectors for the promotion of the country‟s socio-economic
progress, it also recognizes the by-product of this process as wastewater. It, therefore, calls
development of appropriate sanitation systems to protect people‟s health and water resource from
any source of pollution.
In addition, the policy provides charging levies on waste on basis of quantity and quality. The
“polluter-pays-principle” applies in which case parties contaminating water are required to meet the
appropriate cost of remediation. The policy provides for establishment of standards to protect water
bodies receiving waste water, a process that culminated in the enactment of the environment
Management and Coordination (Waste Management) Regulations 2006.
To ensure that from the onset, all development policies, programs and projects takes
environmental consideration into account.
To ensure that independent environmental impact assessment (EIA) report prepared for any
industrial venture or other development before implementation
To come up with effluent treatment standards that will conform to acceptable guidelines.
This has already been done by NEMA through the Environmental Management and
Coordination Waste Management) Regulations 2006, and environmental Management and
Coordination (water Quality) Regulations 2006.
The key National laws that govern the management of environmental resources in the country have
been briefly discussed in the paragraph below. Note that whenever any of the laws contradict each
other, the environmental management and coordination act prevails
The environment Management and Coordination Act of 1999 received a presidential assent on
January 6th, 2000 and was gazetted on January 14th, 2000.
Provide guidelines for the establishment of a legal and institutional framework for the
management of environment in Kenya
Provide a framework of legislation for over 77 statutes in Kenya that contain environmental
provisions
Provide guideline for environmental impact assessment, environmental audit and monitoring,
environmental quality standards and environmental protection orders
In 2001, the government established the administrative structure to implement the act. The two main
administrative structures are:
The National Environmental Council (the council) is responsible for policy formulation and
directions for the purpose of the Act. The Council also sets national goal and objectives and
determines policies and determines policies and priorities for the protection of the environmental.
In addition to NEMA, the act provides for the establishment and enforcement of environmental
quality standards to be set by the technical committee of NEMA known as the standards and
Enforcement review Committee (SERC).
The second schedule of the Act lists the projects for which an EIA and/or EA must be carried out.
Section 68 of the Act specifies that accurate records should be maintained and annual reports
submitted to NEMA, as required.
The regulations were gazetted in September 2006 and come into force in 1st April, 2007. The
regulation details the waste management requirements and also requires application of a license to
all those premises discharging the waste to the environment.
The purpose of the Water Act is to provide the management, conservation and use and control of
water resources and for the acquisition and regulations of use of water, to provide for the regulation
and management of water supply and sewerage supply. Except for waters that are wholly situated in
a private landowner‟s domain, the act vests the right over all surface and ground water in the state.
This is only subject to the rights which users may acquire under license from time to time.
The overall power for the control for the control of every body of water is exercised by the minister.
The minister has the duty to promote the investigation, conservation and proper use of water
resources throughout Kenya.
The act provides for a water resource management authority whose functions include, inter-alia,
developed principles and procedures for allocation for water resources, monitor national water
resource management strategy, determine applications for permits for water use, regulate and protect
water resources quality from adverse impacts, manage and protect water catchments, e.t.c. In
addition, under the water (catchments board) rules promulgated by the minister, the country is
divided into six catmint boards, vis-avis Tana Catchments board, Rift Valley Catchment‟s Board,
Athi River Catchment‟s Board, Ewaso-Nyiro Catchment‟s Boar, Lake Victoria (North) Catchment‟s
Board and Lake Victoria (South) Catchment‟s Board. But these boundaries are subject to variation
depending on available hydrological information.
Under the act, the minister may declare an area to be a conservation area and direct that special
measures be taken for the conservation for the ground water therein. Every person who has been
using ground water in an area declared to be a conservation area and who desires to continue with
the use must obtain a permit within six months of the order. It‟s an offence to disobey such an order.
Protection of water supply is clearly a critical issue under the act. Accordingly, whenever the
minister is satisfied that special measures are necessary for the protection of a catchment area from
An in-depth analysis of the new water Act reveals that the Act has created an integrated water
resources management framework in Kenya which is participatory and likely to have a wider
acceptance and implementation than the predecessors. Part II, section 18 of the act provides for the
National monitoring and information systems on water resources. Following on this, sub-section 3,
allows the water resource management authority to demand from any person or institution specified
information documents samples or materials on water resources. Under these rules, specified
information document, samples or materials on water resources may be kept by a water user and the
information thereof furnished by the authority.
Section 73 of the Act allows a person with a license (licensee) to supply water and make regulations
for purposes of protecting against degradation of water resources. Section 75 and Sub-section 1
allows the licensee to construct and maintain drains, sewers and other works for intercepting,
treating or disposing any foul water arising or flowing upon land for preventing pollution of water
sources within his/her jurisdiction.
Section 94 of the Act makes it an offense through or convey or cause or permit to be thrown or
conveyed, any rubbish, dirt, refuse, effluent, trade waste or other offensive or unwholesome matter
or thing into or near to water resources in such a manner as to cause or be likely to cause pollution of
water resource.
Section 23 indicates that the authority shall approve community projects after they are approved by
the persons owning or occupying at least two thirds of the particular area concerned in the project
and that provision is made by the project for an adequate alternative supply of water when and if the
available levels to other users is.
It also prohibits cancellation of a permit of a community project without the consent of the minister.
Section 24 requires all beneficiaries of a community project whose construction is funded in full or
in part by the government, if the minister so determines, to pay a rate or charge for that benefit.
Part IX, Section 115 of the Act states that no person or institution shall cause nuisance or condition
liable to be injurious or dangerous to human health. Section 116, requires local authorities to take all
lawful, necessary and reasonable practicable measures to maintain areas under their jurisdiction
clean and sanitary to prevent occurrence of nuisance or condition liable for injurious or dangerous to
human health.
On the responsibility or local authorities, Part XI section 129 of the Act states in part “it shall be the
duty of every local authority to take all lawful, necessary and reasonable practicable measures for
preventing any pollution dangerous to health of any supply of water which the public within its
district has a right to use and does use for drinking or domestic purposes………”
Part XII section 136 states that all collection water, sewage, rubbish, refuse and other fluids which
permits or facilitates the breeding or multiplication of pests shall be deemed nuisance and are liable
to be dealt with in the manor provided by this act.
The local Authorities are empowered under section 29 of the act to serve and maintain all land
planned for open spaces, parks, urban forests and green belts, the same section therefore, allows for
prohibition or control of the use and development of land and building in the interest of proper and
orderly development of an area.
Section 30 states that any person who carries out development without permission will be required
the land to its original state. It also states that NO licensing Authority shall grant land license for
commercial or industrial use or occupational or any building without development permission
granted by the respective local authority.
Finally, section 36 states that if in connection with a development application, local authorities is of
the opinion that that the proposed development activity will have injurious impact on the
environment, the applicant shall be required to submit together with the application of the
environmental impact assessment (EIA) report. EMCA, 1999 echoes the same by requiring that such
an EIA is approved by the National Environmental Management Authority (NEMA) and should be
followed by annual environmental Audits.
The Act delegates the Energy Regulatory Commission right to regulate the production,
transportation, storage and use of all petroleum products in the country. Section 95 (1) states that:
“Petroleum imported or produced locally for use in Kenya, petroleum products, equipment, facilities
and installations shall conform to the relevant Kenya Standard: Provided that where no such standard
exists, the relevant international standards approved by the Kenya Bureau of Standards shall apply.”
In addition, the act provides that: “A person who offers for sale in Kenya or transports or stores
petroleum meant for use in Kenya shall ensure that the specifications of such petroleum is in
accordance with subsection (1)”
The act ensures that a person who engages in petroleum business shall comply with the relevant
Kenya Standard and in the absence of such standard, any other standard approved by the
Commission from time to time on environment, health and safety in consultation with the relevant
authorities and in conformity with the relevant statutes touching on environment, health and safety
standards. In the event of a fire, explosion, oil spill, injury or fatality occurring in the course of
operating a petroleum facility or transportation of petroleum, either by accident or through
negligence, the operator or person transporting petroleum shall forthwith clean up the polluted or
damaged environment, at his own expense, to the satisfaction of the Commission and other relevant
authorities. Provided that any person engaged in the transportation of petroleum and petroleum
products shall have an oil clean-up plan in compliance with the national oil policy.
It is the duty of The Commission to ensure that, at any given time, the operator of a facility or a
transporter to show that he is in compliance with the provisions of this act.
Section 193 of the code states that any person or institution that voluntary corrupts or foils water for
public springs or reservoir, rendering it less fit for its ordinary use is equally of an offence.
Section 192 of the same act states that a person who makes or vitiates the same atmosphere in any
space to make it noxious of health of a person/institution in dwellings or projects in the
neighbourhood or those passing along public way commits an offence
This is an act of parliament that provides for the planning within the county. The act highlights the
objectives of the county planning, which in essence provides room for the facilitation of
development of a well-balanced system of settlements and ensures productive use of scarce land,
water and other resources for economic, social, ecological and other functions across the county. The
act also provides for the establishment of the county planning unit which is responsible for the
The provided spatial plan addresses the spatial construction or reconstruction within the county and
strategic guidance for a land use management systems in the county taking into account any
guidelines for a land use management. The act also contains strategic assessment of the
environmental impact of the spatial development framework. The spatial plan indicates where public
and private land development and infrastructure investment should take place.
The act provides for city and municipal plans which are instruments for development and
development controls within a city or municipality. The plans highlight the locations of various
types of infrastructure, functions of land use and building plans in addition to development controls.
As a result, city or municipal land use and building plans shall be the regulatory instruments for
guiding and facilitating development within the city.
The act provides for the basis of the preparation of the environmental management plans for the city.
It also has a provision to nurture and promote development of informal commercial activities in an
orderly and sustainable manner as much as it provides the basis for development control.
The city development plan shall bind, guide and inform all planning development and decisions and
ensure comprehensive inclusion of all functions. A county government shall initiate an urban
planning process for every settlement plan in accordance with the Third Schedule in the act. The
integrated urban area or city development plan shall reflect an assessment of the existing level of
development in the city or urban area, including an identification of communities which do not have
access to basic services.
The Act requires all employers to register their workplaces by making an application to the Director
of Occupational Health and Safety Services before they start any operations. The Act also sets
minimum standards that are to be maintained in such workplaces to safeguard health, safety and
welfare of workers. These are all aimed at elimination of hazardous wastes from workplaces. The act
also requires that all workplaces to display the abstract of the act for all workers to read and remind
themselves on how to protect themselves from hazard.
The act and its subsidiary legislation makes provision for health, safety and welfare persons
employed in factories and other places of work such as in building construction and project
operations are defined. The act prohibits emissions of dust, fumes or impurities into the atmosphere
without proper treatment to prevent pollution or other ill effects to life and property. These
The act also requires that no discharges should be made into the environment from factories and
workplaces without proper treatment that requires them harmless to the environment.
The act also has specific measures that need to be taken to protect health, safety and welfare of
workers and environmental conservation. The same act also requires all operation that fall under it to
apply for registration as such to the Directorate of Occupational Health and Safety Services.
The rule states that any employer/proponent/occupier who employs more than twenty persons must
establish a committee to address health, safety and welfare of workers. The employer must also
cause to be carried out a health and safety audit of all its operations in an annual basis by a registered
health and safety advisor who should forward such a report to the Directorate of Occupational
Health and Safety Services.
These have details on first aid requirements in terms of facilities and capacity building among
residential workers.
These regulate the handling, transportation and use of certain listed chemicals which may have negative
effects on the body when one is expected. The rules places the duty on all employers to It shall be the
duty of every employer to prevent his employees from being exposed to hazardous substance. Where it is
not reasonably practical to prevent the exposure, it shall be the duty of every employer to control the
exposure of employees from hazardous substances by:
(a) limiting the amount of hazardous substances used which may contaminate the working
environment;
(b) limiting the number of employees who will be exposed or may be exposed;
(d) limiting the period during which an employee will be exposed or may be
exposed;
(ii) installation of local extraction ventilation systems to processes, equipment and tools
for the control of emission of an air borne hazardous substances;
(f) introducing appropriate work procedures which an employee must follow where
materials are used or processes are carried out which could give rise to exposure of an
employee and that procedures shall include written instructions to ensure:
ii) that process machinery, installations, equipment, tools and local extraction
and general ventilation systems are safely used and maintained;
These rules have set minimum and maximum exposure limits beyond which workers and members
of the public should not be exposed to noise without adequate means of protection. The rules also
have exposure limits for exposure out of workplaces. The rules have several recommendations on a
comprehensive noise control program for workplaces that includes a requirement for medical
examination of workers who are exposed to noise. The rules have also set the minimum noise levels
that should emanate from a facility to public/neighbouring areas by day or by night.
The rules guides health and safety matters in all building/construction and civil engineering works
These rules states clearly that it is the duty of the proponent to ensure health, safety and welfare of
all workers are and authorized visitors to the site before commencement of operations, the proponent
should notify the Director of Occupational Health and Safety Services of the intention so that from
then on, the director advises and follows up on the necessary conditions to safeguard the health,
safety and welfare of workers on site.
Waste plastic and tyre recycling plant Page 32
The rules also states that qualified and experienced persons must be appointed to act as safety
supervisors by the proponent. These should supervise the enforcement of the standards to achieve
the objectives mentioned above.
The rules have specific sections on excavation, transport, demolition, formwork and scaffolds, lifting
and lifting equipment and other safety measures.
As mentioned above, there are limited surface water sources in the area, whereas, the area boasts of
two rivers: Chania and Thika Rivers to the far north of the site. Thika town is located on a gentle
plain before the ascent into the central highlands. Small valleys are on the western and northern
edges following the Chania and Thika Rivers that have waterfalls and meet on the northwestern edge
of Thika.Thika Town is also home to Kenya's magical and breathtaking Fourteen Falls which is
located 65 kilometres North East of Nairobi off the Thika-Garissa Road. The Fourteen Falls consist
of 14 distinct waterfalls on the broad section of the famous Athi River
The area is within larger Kiambu County. The study would like to connect the relationship of the
geology and what its impact has been on the water quality. Some of the rock chemistry influences
the quality and amount of groundwater potential in the area. The local geology lies in the larger
Aberdean watershed the catchment area being fed by rivers from the Aberdare ranges. It‟s
characterized by the following rocks: Recent to Quaternary; Alluvium and soils, and tuffs, Tertiary:
Likipian Trachytes and Simbara Series Basalts and Kapiti phonolites, the basement system takes the
bottomless layers. The short study has shown that the geology of the area has contributed to good
quality water mainly because of the basaltic origin that is free from fumaroles and hydrothermal
active fluids.
4.2.3 Biodiversity
The site is located within a lowly developed industrial zone and the surroundings are still
characterized with natural vegetation comprising of withered grass species (Themeda thriandra,
Cynodon dactylon and Cenchrus ciliarias), Shrubs like mainly Balanities aegyptica and some
poisonous weeds including Solanum incunum. However, vegetative cover within the site has had
influence from human influence through clearance to pave way for construction activities. The east
side of the site is a dumpsite for Thika Municipality that also served Kiambu County.
The 2009 Population and Housing Census indicate that the county had an urban population of
936,411 in 2009 and in 2012 was projected to be 1,018,773. Urban population is expected to reach
1,108,380 in 2015 and 1,172,453 by the end of 2017. The county urban population distribution per
urban centres is as illustrated in table 4 below which shows that Ruiru and Kikuyu towns have the
highest number of people living in urban areas, followed by Thika and Karuri towns respectively.
This high population in urban centre can be attributed to the proximity of the county to Nairobi as
most of the people work in Nairobi and reside in the county. In addition, industrial development in
some districts like Thika West and Ruiru attract more labour force. In these areas, urban planning
should be effectively undertaken to avoid strain on the physical amenities from growth of informal
settlements. In addition, community policing should be enhanced to reduce insecurity. Also, more
infrastructural facilities like transport network, housing, schools and health centres should be built.
The population distribution by urban centres is shown below.
Kiambu County
Gatundu South 114,180 593 124, 223 645 135,149 702 142,962 742
Gatundu North 100,611 352 109,460 383 119,088 417 125,972 441
Thika Town 165,342 760 179,885 827 195,706 900 207,020 952
North: The northern side of the site is partly a fenced plot with rental residential
housing units further two hundred meters or so away.
South: the southern section is an open field with residential flats at approximately
eight hundred meters.
East: the eastern part of the site is an open dumpsite commonly called Kang‟oki
dumpsite which serves the wider Kiambu county especially Thika and Ruiru
towns.
Covering an area of 2,543.42 square kilometers, it is also considered one of the wealthiest counties
in Kenya. It is a leading innovative commercial hub that shares its borders with five other counties;
Nakuru and Kajiado to the West, Murang'a and Nyandarua to the North and Nairobi to the South.
Agriculture is the predominant economic activity in the county and contributes 17.4 per cent of the
county„s population income. It is the leading sub sector in terms of employment, food security,
income earnings and overall contribution to the socio-economic well being of the people. Majority
of the people in the county depend on the sub sector for their livelihood, with 304,449 directly or
indirectly employed in the sector. Coffee and tea are the main cash crops in the county. The main
food crops grown in the county are maize, beans, pineapples and irish potatoes. These are mainly
grown in small scale in the upper highlands of Limuru, Kikuyu, Gatundu North and South
Constituencies.
Lying about 40 kilometers from Nairobi, Thika town is popular for the pineapple plantations and the
heavy industrial activity. Several industries including the Broadways Bakery, Bidco Oil Refineries,
CMC motor vehicle assembly line and Thika Coffee Mills are based here. The town has witnessed
rapid growth due to the explosive real estate boom in the county.
The consultants interviewed some of the immediate neighbours of the proposed project site with a
view of seeking their comments on the potential negative environmental impacts of the proposed
project to the neighbourhood. This was done by the use of questionnaires (attached), to find out
views from the neighbours towards the project. All of the interviewed persons are tenants in the area
who migrated due to employment opportunities within Thika town.
The consultation process included to a large extent public consultation through structured interviews
with interested and affected parties. Non-structured interviews were administered to all the Non-
interested and affected parties.
(2) Whether the proposed project will have negative impacts on the following:
Local residents
Natural ecology of the area
Recreational and leisure facilities
Public health and safety
Water resources and quality
Soils
Road transport
As part of the EIS process for the pyrolysis plant several key stakeholders were engaged to inform
both the study and the project. These stakeholders were consulted based on their institutional
mandates which govern the project and its activities, and members of the general public who are
neighbours to the project. The stakeholders were engaged through Public Participation Questionnaire
(appended at the end of this report). The three main purposes of this exercise were to:
The comments stakeholders raised were collated and analyzed to see which issues are of concern and
should be addressed through this report. The following subsections list these stakeholders and the
comments they raised, whilst referencing to the impact assessment section and the proposed
mitigation measures to elaborate how they contributed to the formulation of the EMP of this report.
Waste plastic and tyre recycling plant Page 42
This was done in respect to the fact that public concern is fundamental to the delineation and
management of the project‟s significant risks.
All the concerns raised by the area residents are already tackled within the report and in the
environmental management plant for the proposed project
5.1 Introduction
The proposed plant will be handling waste tyres and plastics into diesel oil. It is, therefore expected
that there are potential emission of various gases mainly of carbon and hydrogen compounds with
carbon black as the main solid waste from the process. The exhaust gases from the pyrolysis reactors
are also a cause of concern of potential air quality impacts from the Project. The exhaust gases are
mainly hydrocarbons. Harmful substances will be collected by the waste gas cleaning system before
emitting out to the atmosphere. This scenario implies potential linkages with the surrounding
environment and ecological setting that require to be addressed during the construction and upon
commissioning. The following sections outline these linkages as well as proposed corrective
measures.
(i) Mopping up of hazardous and toxic materials from the motor vehicle industry which
churns a most of the waste tyres,
(ii) The plant will open up a chain of employment to suppliers and those who will be
employed directly in the plant,
(iii) The facility will thereby provide an avenue of energy circulation in the environment.
The proposed pyrolysis plant consists of furnace systems. The main reactor operates at the
temperature range of 350oC to 450oC. Waste gases of the main reactor are mainly made up of (CH4 +
C2H4 + C2H6 + C3H6 + C3H8 + C4H8 + C4H10), depending on the composition of waste plastics and
tyres input fed into the main reactor. After pyrolysis in the main reactor, a catalyst and a second
combustion chamber is used to handle and treat the waste gases under designated temperature and
pressure. The waste gases are fully burned in the second chamber, whereby the temperature is
controlled at 850-1000°C. This is to thermally decompose the potentially aromatic substances as
well as odour and gaseous dioxins. The heat generated then re-enters the main reactor, contributing
to the heating of the main reactor which is required to maintain designated temperature. This heat
reclamation is environmentally beneficial and reduces the cost of fuel used by the system.
The by-products from the system are mainly waste gases and ash. A waste gas cleaning system will
be installed for each pyrolysis plant system to reduce the emission of waste gases. This waste gas
cleaning system consists of a cyclone, a dosing device for the additive to bind the pollutants, a
reactor with a ball rotor to improve the efficiency of the additive, and a bag filter to separate dust
from the waste gases. The waste gases are finally exhausted from the 20-metre high chimney
installed for each of the pyrolysis furnace system. A Continuous Emission Monitoring System
(CEMS) will also be installed to continuously monitor the emission concentrations of waste gases.
Ash generated from the main reactor is mainly dry black carbon charcoal. The ash settles at the
bottom of the reactor, where it is discharged out of the reactor via an automated screw pump, and
brought to the ash bin. The ash collected in the ash bin will be disposed of every morning
In terms of the usage of water, a cooling water system will be developed for the pyrolysis plant
system. The cooling water for the waste gas-oil separator is a closed circuit system. The cooling
water would not contact with the waste gases. Hence, the cooling water will be re-used continuously
and only discharged to a sedimentation tank every 3 months.
Each of the pyrolysis furnace system has a temporary storage tank of capacity of 1,000 Litres for
storing the useful fuel oil extracted from the pyrolysis process. The useful fuel oil products will be
collected at frequent times.
Construction Phase
Air Quality
Dust emission may arise from the construction/installation of the pyrolysis plant. Construction works
would include site formation, piling and foundation work, and concreting work. There is no
extensive site formation works and the scale of construction site is limited. With the implementation
of dust suppression measures stipulated under the Air Pollution Control (Construction Dust)
Regulation and adoption of good site practice, no adverse construction dust impact would be
expected.
Exhaust emissions may also arise from the operation of diesel-powered construction equipment.
However, considering the small scale of the Project and limited area of the construction works, the
number of diesel-powered plants would be less. Hence, no adverse air quality impact would be
expected from the construction equipment.
Noise
The potential source of noise impact during the construction phase would mainly be the use of
powered mechanical equipment (PME) for various construction activities. Considering the small
scale of the Project, the number of PME would be limited; also the nearest noise sensitive receivers
are the residents more than 200m away from the Project Site. Adverse noise impact during
construction phase of the Project would not be expected.
Water Quality
The Project is to be built on a paved ground with adequate drainage connection to the site which is
currently in use. With the limited area of excavation works at the Project site, no adverse water
quality impact would be expected from the surface run-off. Domestic sewage would be generated
Waste Management
No major earthworks will be required for the Project site, as the site has already been formed at the
rented land of the Project Proponent which is currently in use. General refuse, including food waste
from the workforce on site and the packaging from the construction materials will be generated.
Chemical waste, like the batteries and lubricating oils from the maintenance of construction
equipment and installation of the pyrolysis plant system will also be generated. However, the
quantities of the general refuse and chemical waste generated would not be significant during the
construction phase of the Project and no adverse impact would be expected.
Land Contamination
The Project site surrounding is currently being used as a dumpsite (for example plastic bottles and
plastic bags) and other waste is evident in the area. Given the general nature of waste recycling
facility, there could be potential land contamination issues within the Project site.
Ecology
The Project site is adjacent to a dumpsite which may not attract other development needs. Therefore, no
ecological value is found at the site. Since the proposed plant will be constructed within the built ground, no
potential ecological impacts would be expected.
Particulate Matter There will be minimal production of particulate matter during the installation
which is mainly installation works for the machinery. This is because; the intended installation will
be done in and open shade meaning no construction need for housing of the plant. The construction
of the go-downs was commenced after appropriate approvals were obtained from the Kiambu
County Council and NEMA from the same county.
(i) Aesthetic and visual problems, though there are no notable settlements within the vicinity
of the site,
(ii) Potential risks of health (mainly bronchial infections) though there are no notable
inhabitants in the immediate neighbourhood,
(iii) Deposition of dust on vegetation hampering development of the same,
(iv) Air pollution aspects including contribution towards climate change.
Biodiversity
There will be no loss of bio diversity since the installation site has been approved for development
and the proponent will be a tenant.
Social Impacts
There are no displacements or direct interference with any social groups within and around the site
since no settlements were found at the time of this assessment. Anticipated social impacts would be
related to gaseous emissions, generation of dust and noise but there are no inhabitants in the
immediate neighbourhood of the site.
5.2.3 OPERATIONS
Air Quality
Potential air quality impacts may arise from the combustion of fuels to supply the required heat
energy for main reactors of the pyrolysis furnace system. Major air pollutants emitted from the
exhausts of fuel combustion will include nitrogen oxides, sulphur dioxide and particulates.
The exhaust gases from the pyrolysis reactors are also a cause of concern of potential air quality
impacts from the Project. The exhaust gases are mainly hydrocarbons. Harmful substances will be
collected by the waste gas cleaning system before emitting out to the atmosphere.
Since each pyrolysis furnace system is connected to a storage tank, fugitive emission of volatile
organic carbons may arise from the storage tanks, pumps and valves connected to the tanks.
Odour emission is also a potential issue due to the shredding of the waste plastics within the Project
site.
Potential noise sources from the Project include shredding of waste plastics and tyres, valves and
pumps of the pyrolysis furnace system. noise impact due to the Project will be insignificant.
Water Quality
Water in the cooling water system of the pyrolysis plant will be reused. Also, the Project site has
already will have a septic tank to hold effluent waste, and no adverse water quality impact would be
expected during the operation of the Project.
Waste Management
From the process, ash which is mostly dry black carbon charcoal, would be generated during the
operation phase of the Project. The ash will be collected from the pyrolysis furnace system daily for
potential reuse and recovery. Chemical waste such as the spent lubricating oil, paint and oil filters
from equipment maintenance will be properly collected and disposed of in accordance with Waste
Disposal. Considering the small quantities of equipment on site, the amount of chemical wastes that
would be generated is small.
General refuse is expected to arise from the workforce during the operation of the Project. However,
since the Project is not expected to generate a large amount of general refuse and the site has already
been in use with proper waste management, adverse impact from general refuse is not expected.
Land Contamination
Land contamination (if any) within the Project site will be identified and possible remediation
options will be addressed in the environmental management plan. As any not entirely contaminated
soil / groundwater will be properly assessed and remediated, no land contamination issues are
expected during the operation of the Project.
Ecology
The project site is located at the existing active dumpsite, No ecological value is found on this land
lot and the surrounding area and potential ecological impacts would not be expected from the
operation of the Project.
The highest structure for the Project is the chimney for each of the pyrolysis furnace system, which
is 20 metres high in the preliminary design. Structure of maximum height of 35 metres will be
allowed whenever necessary depending of the prevailing wind streng. Also, with due consideration
of the landscape and visual impacts, no adverse landscape and visual impact would be expected from
the Project.
Waste plastic and tyre recycling plant Page 49
Hazard to Life
Potential hazard to life issue may arise from the four temporary fuel oil storage tanks which are used
to store the useful fuel oil products for each of the pyrolysis furnace system. However, considering
the small storage capacity for each storage tank and the regular collection of the fuel oil products 3
times daily, no adverse hazard to life impact arising from the Project is expected. On the other hand,
pyrolysis gas is generated as an intermediate product in the production process. Pyrolysis gas is a
flammable substance. Accidental release would lead to fire or explosion hazard. The potential risk to
the surrounding population will need to be addressed. Potential cumulative hazard to life issue from
the bio-diesel plant as well as escalation impact of the pyrolysis plant would need to be assessed
should the operation of the Project site affect those neighbouring plant processing and storage
facilities and vice versa.
The health of the plant workers varies from one section to another as outlined below;
(i) Health risks are found in the management of the waste holding areas, the transfer routes
and preparation procedures. The risks including exposing the workers to a wide open
burning of fuel and raw material in case of fire breakout. The neighbourhood could also
be affected through wind or surface runoff transferring contaminants and other emissions
(ii) Combustion areas are the most critical section in respect of health and safety due to
amount of heat required in the process.
(iii) Heat is also a serious impact to the employees operating the plant since they are likely to
be open. The general ambient heat around the entire premises is also likely to be
relatively high extending the risk to more workers,
(iv) Personal accidents and risks of getting injured by falling objects to the workers and
visitors while moving around the premises cannot be ignored.
(v) There are risks of fire outbreaks from kilns, oil storage areas posing potential danger to
not only the site, but also the neighbouring land users,
The plant is designed for a lifespan of between 50 – 100 years subject to effective maintenance.
During this period, it is possible that necessary retrofications will be carried out on the equipment,
plant layout could be reviewed and processes could be changed while major structural changes and
expansions might be found necessary. At the end of the plant life, a scheduled plant will be
necessary to remove the site component, a process referred to as decommissioning.
(i) Removal of any major section of the plant will require a decommissioning process to
ensure safe removal, movement, transfer, reuse or disposal. Such actions will be
required for furnaces.
(ii) Any desired expansion of the plant, installation of an major component or notable
changes to the plant component will require an environmental impact assessment study
carried for review and approval by NEMA,
(iii) For total removal of the plant, prior notice will be given to NEMA at least one year
before,
(iv) A comprehensive decommissioning audit report of the entire plant will be mandatory at
the ultimate removal at the end of the plan life.
Corporate Initiatives
While planning the site management, it will be necessary to consider the following basic aspects on
environmental conservation;
(i) The health and safety of the workers, the neighbouring communities and on-site
installations should of key importance and necessary mechanisms should be provided at
all times during the project cycle,
(ii) Emissions into the environment have undesirable off-site effects on public health,
particularly those in the windward direction. In this regard it will be necessary to plan for
a monitoring mechanism and maintenance of records on air quality profiles as part of the
corporate capacity building plan,
Site Operations
Appropriate financial and human resources will require to be provided for continuous improvement
of the environmental performance at the premises and the surroundings. In this regard performance
evaluations, reviews of management practices and assessment of material consumption and capacity
of the workers are among the operational aspects that will require constant attention.
Infrastructural Maintenance
Management of environment at the active site cannot be complete until an effective monitoring and
maintenance schedule is established. This includes a continuous performance improvement,
integration of environmental issues in hygiene and sanitation, provision of basic “green” facilities
(safe in-house movement and performance evaluation from customers) are some of the continuous
improvement tools that may be applied. Others important tools include;
(i) Carrying out regular operation performance appraisals,
(ii) Follow scheduled maintenance of equipment and facilities,
(iii) Documentation and record-keeping on resource utilization and conservation,
(iv) Observing good house-keeping at all times with specific focus on waste management,
(v) Regular review of site planning,
(vi) Contractual documents with customers and goods/service suppliers to reflective
environmental responsibility,
(vii) Undertake scheduled monitoring and statutory annual environmental auditing.
Capacity Building
The environmental issues identified in this report require that Environmental and Combustion
Consultant Limited establish appropriate technical and physical capacity to ensure sustainability and
continuous improvement in environmental management. Capacity is required in;
(iv) Awareness and skills in environmental management for the operators, supervisors,
support staff, customers and material suppliers,
(v) A qualified environmental officer to oversee all matters related to management and
conservation aspects who would also take charge of health and safety issues including
basic training on specific skills and technical understanding on environmental, health
and safety to all workers, a general awareness to the customers, contractors and
suppliers.
The following are basic aspects for inclusion in the site design and the wastewater handled in
accordance with waste regulations Legal Notice No. 120 of September 2006;
(i) Construct a concrete slab for holding of the scrap metals coming from the tyres.
(ii) Surface runoff and spills from the plant and any other oil storage areas should be
collected and channeled into an oil interception chamber for easy management from
environmental contamination.
(iii) Maintain appropriate records on wastewater quality for compliance evaluation and
comparison with the gazetted standards on a continuous basis,
(iv) Isolate domestic wastewater from process wastewater for containment in septic tanks
and regular exhaustion,
(v) Oil storage areas should be provided with slabs with surrounding bunds to contain any
spilt oils. Runoff from the oil storage areas.
Handling of solid wastes at the site will require the following components and handled in
compliance with the waste regulations Legal Notice No. 121 of September 2006;
(i) The waste slab should be provided with compartments for segregation of various
categories of waste classified on source and physical nature that should also be handled
separately,
(ii) Provide solid waste holding bins at strategic locations around the premises and install
transfer stations and modalities of waste removal to approved dumping grounds.
(iii) Other solid waste from the facility should be handles as highlighted in the waste
management regulation.
Aerial Emissions
Gaseous and particulate matter is perhaps the most critical environmental aspect associated with the
proposed operations. The following measures should be considered to reduce the elated impacts;
(i) The kilns should be designed with provisions of flue gas trapping, smoke interception
and stacks fitted with scrubbers (for gases) and filters for particulate matter removal,
Attention should also be on the health and safety of the workers, visitors, customers and
neighbouring community such as to include;
(i) All moving machine parts and high temperature areas should be fitted with guard rails
and restrict access,
(ii) Provide all employees with personal protective gear and enforce application at all times
within the place work,
(iii) Workers operating within the high temperature zones should not exceed 2hrs
continuous presence or/as may be directed by the Occupational Health and Safety
Experts,
(iv) Segregate scrap materials on sources basis and devise safe modes of handling each
category especially those that have been removed from the tyres.
(v) Training and induction of all employees and visitors on site to enhance safety.
Construction Environmental Air pollution from - dust, Maintain construction site dump at all times,
Pollution – Noise Emissions from construction equipment and Ensure that all civil works are carried out during
and dust material deliver trucks, normal working hours (8:00 am – 5:00 pm)
Public nuisance from construction equipment. Construction equipment maintained a good working
generation
Noise from construction activities order at all times,
Fence up the construction site to keep off intruders.
Ensure that all noise is kept to prescribed exposure
limits.
Solid waste Approximately 14kg/day of domestic waste Construction waste will be used to backfill and to
generation Around 1,000 kg/gay construction waste will be help develop access road to the site
generated Remaining waste will be sent to landfill
Domestic waste will be segregated for composting
Drainage Change in storm water regime around the site, Consider surface contours and channel storm water
Soil erosion creating siltation of natural drains appropriately,
during rains, Link the site drainage with natural drainage pattern
Discharge of wastewater from the site into dry in the area.
drainage system with risks of environmental
pollution downstream.
Social Issues Noise Levels:
High noise levels from construction machinery Construction to take place only during the day,
and materials‟ delivery trucks, Maintain machinery in good working order.
Health and Safety:
Bronchial infections from dusts and other Keep dry construction materials dump at all times,
emissions, Keep emissions from sources the lowest possible
Water sources contamination, limits,
Waste plastic and tyre recycling plant Page 55
Development Environmental Anticipated Impacts Recommendations Mitigation Measures
Stage Aspects
Risks to health and safety of the construction Provide personal protective gear to the workers ad
workers, e.g. HIV/AIDS. ensure application at all times,
Fence up the construction site to keep off intruders,
Install warning signage around the construction site
Cultural Values:
Social interaction of construction workers with Sensitize workers and local communities on moral
local communities, values and cultural integration.
Moral effects (e.g. rise in prostitution, crime,
etc.)
Operation Waste Water
Aspects Surface water contamination, Ensure acceptable solid waste collection systems
Land and soil degradation from sources, storage arrangement and transfer,
Pollution from disposal of scrap oil, leachate and Develop appropriate documentation and waste
wastewater, manifest for hazardous waste movement,
Pollution from off-site solid waste dumping, Install oil interceptors and grit traps along all the
affected drainage system,
Slab the hazardous wastes holding yard and install
trapping arrangement for leachate and surface runoff
there from.
Flue gas emission No harmful emissions (dioxins and furans) Emissions will be in accordance with standards, with
produced <100μg/m3 PM10
90% PM removal with wet scrubber
Noise Levels Noise generation from factory is expected to be Plant will operate 12 hours per day.
58 dBA and 45 dBA at a distance of 500m and Noise generated will be with respect to industrial
100m respectively noise exposure limits
Biological No signs of significant wild life in the area, Ensure solid refuse handlers dispose into approved
Diversity Removal of grass cover, arid trees and shrubs, grounds to avoid biodiversity degradation,
Related microorganisms associated with the Plant trees on the open spaces continuously,
scarce vegetation removed. Externalize initiative for ecological conservation.
No directly negative impact to income generation on Enhance employment opportunities for the local
the area. Positively affecting the local social and community,
economy Provide leadership on opportunity for collaboration
with waste recyclers,
Ensure sustainability through cost savings from waste
minimization at sources and recycling options,
Expand the scrap metal market and create more
opportunities.
Social and Cultural Issues:
Social nuisance from pollution to physical Maintain efficiency in the emission reduction point
environment such as land and air by emissions sources and minimize external effects,
from the site, Establish a public relation strategy with the
Social complaints and concerns on health and neighbourhood for enhanced co-existence,
safety, Undertake statutory annual environmental audit for
Cultural intrusion from employee intrusion, continuous improvement on social issues.
Conflict on land use, Enhance monitoring system on social concerns,
Conflicts at off-site solid waste dumping areas, Invest in social responsibility initiatives,
Comply with labour laws and related regulations.
Health and safety:
Risk to workers‟ health from aerial emissions Provide all workers with the necessary personal
originating from the site operations, protective equipment and ensure application at all
Risks to life through outbreak of fires, times,
Health problems from excessive heat, Enhance good hygiene practices to reduce exposure
Risks of fire to the site property and that of the of the employees and customers to infections,
neighbours, Provide suitable signage for fire escapes and
Risks from internal movements of workers and convenience directions,
customers, Develop a disaster management manual on a wide
Slippery surfaces, e.g. store rooms, range of health, safety and security issues, among
(ii) Control of soil erosion and siltation of springs downstream as public sources of
water,
(vi) Realization of cordial relations among various community, economic, social and
cultural groups as well as between the local community and the contractor,
(vii) Enhancing equity and maximizing social and economic benefits for the local
community through income generation from employment,
(i) The contractor and other players in the construction activities be prevailed upon to
implement this EMP,
(ii) The development should appreciate the interests of the neighbouring communities
at all stages of the project,
(iii) Maintenance of the natural beauty of the countryside around the site area such as
to include green belts and other beatification initiatives,
(v) A site specific environmental, health and safety plan is established soon after
commissioned.
Health Issues
Ensure that the plant operates efficiently so as to avoid any direct burning of the raw materials
which might cause pollution to the environment through complete combustion. Control emissions
from the machineries as well as dusty conditions throughout the construction cycle and check
operation points upon commissioning. The proponent should also ensure that workers are
protected from any other hazard which might pose risk to health. In addition, occupier will
ensure that risk assessment is conducted for the plant and remedial action put in place.
(i) Ja-Recycling will be responsible for all coordination activities and liaisons,
particularly in regard to issues of environment, social and safety issues,
(ii) The Project Manager is the Contactor‟s link with the Ja-Recycling on matters of
environmental and social nature and is responsible of implementing the
environmental management plan established under this report,
Construction Environmental Ensure contractor undertaking on Ja-Recycling and Sustainable Complaints from
Pollution environmental considerations, Contractor construction neigbourhood,
Integrate public safety in the Initiate action No direct cost Residents complaint
construction process,
with construction involved
Waste Maintain Isolation of surface storm Ja Recycling Streamlined Waste categories and
Management water drains from those carrying waste flow separation,
oil/grease residuals, paths.
Mode of transfer
Enhance water recycling for
conservation purposes (Whenever
applicable), Final destinations.
Install gadgets to intercept the Initial installation To be The measured air quality
particulate matter as well as aspects must meet the set
are design determined
controlling gaseous emissions. standards in the Air Quality
controlled during
operation Regulation
Vegetation cover Introduction of vegetation (trees, shrubs Ja-Recycling Greening the Number of trees planted.
and grass) on open spaces within and compound and
around the site. Indigenous species Upon
Social Aspects Draw of-site contracts to enhance Ja-Recycling Social Health problems and
socially acceptable procedures, acceptability degradation of environmental
and co- resources,
existence.
Involve more independent interested Upon The public opinion,
parties (waste collectors) in commissioning
establishing options for waste then continuous Satisfaction to the relevant
recycling, authority.
Health and Safety Constitute health and safety Ja-Recycling Quick and The security and safety of
committee, effective the neighbouring premises,
response to
Safety cases over a period of
emergencies. time,
Maintain safety reticulation (e.g. fire
detection and fighting equipment), Response period on safety
Annual budget and medical aspects.
of KShs.
Train on HS issues and provide PPEs Immediately 250,000
and enforce applications,
Undertake a annual hearing survey of Upon KShs. 300,000 External receptors as defined
all the workers, commissioning for equipment under the EMCA regulations on
Train, provide ear muffs/corks and and continuous. and noise and vibrations (2009)
enforce application, professional
guidance
Compliance Develop an environmental policy, Ja-Recycling An all time A facility to ensure compliance
Aspects Continuous compliance with laid down guidelines at all
Establish a legal register on critical
times
relevant environmental laws,
Institution Adapt environmental aspects in Ja-Recycling Coordinated To ensure that all actions on
Framework administrative framework, Continuous environmental environment are integrated in
management the future corporate business
Review the contracting arrangement
at all levels of the operations, plans
environmental management.
Collaboration Collaborate with other players on Ja-Recycling Sustained Kenya Institute of Waste
environmental protection, waste capacity Management is recommended
Decommissioni Composite Notify NEMA and other authorities Ja-Recycling, Rehabilitated Air quality and soil status in the
ng impacts on intension to stop operations at NEMA, Kiambu site area.
least 1 year in advance, county, ERC and
environmental
Carry out a decommissioning audit expert. Social and economic
and submit report to NEMA for implications in the area
review six months in advance,
7.1 Conclusion
From the foregoing, it is concluded that the proposed pyrolysis plant is in appropriate location in
as far as land use and interactions with human social and economic setting is concerned. There
are minimal habitations in the neighbourhood, no significant sensitive environmental features are
found within the vicinity and the area is not fully zoned for waste handling (damping site) giving
an opportunity to isolate the location for this purpose in future. The proposed development has
been approved by Kiambu County Council subject to compliance with all regulations while land
transfers to the ownership of the proponent have been accomplished. However, there are certain
social concerns that touch on general environmental pollution, groundwater contamination,
health of the workers, attraction of human settlements in future and soil contamination. For this
reason, appropriate preventive measures have been developed in this report. The measures, if
integrated in the site design and operations and maintained throughout the site lifespan, will
ensure environmental and social sustainability of the factory.
7.2 Recommendation
It is recommended that the plant be licensed to proceed subject to full implementation of the
environmental management plan in addition to observing the mitigation measures established for
every impact identified. Among the specific recommendations include,
(i) Ensure waste and wastewater management regulations are complied with through
provision of appropriate facilities including wastewater treatment facility, solid
waste collection bins and transfer arrangements. Hazardous waste holding units
should be isolated from the external environment at all times,
(ii) Aerial emissions be controlled through appropriate extraction fans in the operation
areas into bag houses, electrostatic precipitators and installed scrubbers in the stacks
to ensure no hazardous residuals finds their way back in to the natural environment,
(iii) Safety measures for the workers and the neighbouring community shall be
integrated in the entire project cycle,
(iv) Compliance with the existing laws and regulations shall be upheld at all times,
(v) The above environmental management plan shall be adopted and applied as the
basis for addressing environmental and social aspects throughout the project cycle
with necessary amendments as may found appropriate. In this connection, it will be
the guiding tool for future audits and monitoring exercises.
69
REFERENCES
(1) Kenya gazette supplement Acts 2000, Environmental Management and Coordination Act
Number 8 of 1999. Government printer, Nairobi
(2) Kenya gazette supplement Acts Building Code 2000 by government printer, Nairobi
(3) Kenya gazette supplement Acts Land Planning Act (Cap. 303) government printer,
Nairobi
(4) Kenya gazette supplement Acts Local Authority Act (Cap. 265) government printer,
Nairobi
(5) Kenya gazette supplement Acts Penal Code Act (Cap.63) government printer, Nairobi
(6) Kenya gazette supplement Acts Physical Planning Act, 1999 government printer, Nairobi
(7) Kenya gazette supplement Acts Public Health Act (Cap. 242) government printer,
Nairobi
(8) Kenya gazette supplement number 56. Environmental Impact Assessment and Audit
Regulations 2003. Government printer, Nairobi
70