waste management in ghana

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Annex F

Waste Report


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CONTENTS

F1 INTRODUCTION 1F1.1 INTRODUCTION 1F1.2 STRUCTURE OFREPORT 1F2 OVERVIEW OF WASTE MANAGEMENT IN GHANA 2F2.1 LEGISLATION ANDREGULATORYREQUIREMENTS 2F2.2 INTERNATIONALAGREEMENTS AND CONVENTIONS 4F2.3 WASTEMANAGEMENTINFRASTRUCTURE 6F2.4 RECYCLINGFACILITIES 8F2.5 WASTE TREATMENT ANDPROCESSING 8F2.6 EXPERIENCE AND CAPABILITIES OFWASTEMANAGEMENTCONTRACTORS 9F2.7 INTERNATIONAL SUPPORTINITIATIVES 9F3 TULLOW GHANA WASTE MANAGEMENT NEEDS 11F3.1 WASTEMANAGEMENTPRINCIPLES 11F3.2 INTRODUCTION TO WASTEMANAGEMENTNEEDS 12F3.3 FACILITIESREQUIRED TOMEETWASTEMANAGEMENTNEEDS 13F4 WASTE MANAGEMENT OPTIONS AND TULLOW STRATEGY 16F4.1 SHORTTERM 16F4.2 MEDIUM ANDLONG TERM 17


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ENVIRONMENTAL RESOURCES MANAGEMENT TULLOW GHANA LIMITED

F-1

F1 INTRODUCTION

F1.1 INTRODUCTIONTullow Ghana Limited (Tullow) acting on behalf of the Joint Venture partners,

in the course of development and operation of the Jubilee Field will generate avariety 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 anddescribes 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 OFREPORTThis report contains the following Sections:

Section F2: Overview of Waste Management in Ghana

Section F3: Tullows Waste Management Needs

Section F4: Options and Strategy for Waste Management


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F2 OVERVIEW OF WASTE MANAGEMENT IN GHANA

F2.1 LEGISLATION ANDREGULATORYREQUIREMENTSF2.1.1 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 maintool 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 andprocedures 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 andfinal 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 ManagementThe 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 bereleased into the environment; and

the collection, storage, recovery, recycling or disposal of substanceswhich 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 thePreparation 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 by2020 (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 SystemsThere 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:

solid wastes; liquid wastes; gaseous wastes; and toxic, radioactive and other special wastes.

F2.1.4 Permitting RequirementsThe EPA is responsible for the environmental and operational permitting of

waste management facilities; this includes treatment and final disposal

facilities.

F2.2 INTERNATIONALAGREEMENTS AND CONVENTIONSF2.2.1 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 ConventionGhana 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 disposingof the waste in an environmentally sound manner; and

(b) the receiving state has appropriate, environmentally sound facilities, andagrees 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 inGhana, 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 ConventionGhana 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 ImplicationsTullow 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 portvisited (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 inTullows 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 DIvoire. 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 WASTEMANAGEMENTINFRASTRUCTUREF2.3.1 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 ManagementWaste 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 Sekondi-

Takoradi (with 10 cells and enough capacity for approximately 15 years ofwaste 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 3fill 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 ManagementThere 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 FacilitiesThere 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 stations 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


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Refuse and sewage wastes are dealt with via the Metropolitan Assemblys

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 RECYCLINGFACILITIESBasic 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 ANDPROCESSINGThere 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 OFWASTEMANAGEMENTCONTRACTORSWaste 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 discussionswith 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 Ghanas

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 phaseelement replacing the facility they currently use within the Takoradi PowerStation).

A further tank cleaning waste reception facility for other, principallyinorganic waste, transportation tanks (waste would come from Zeals ownmobile tank cleaning operations) is planned but has yet to be constructed.

Chemical treatment system (details not finalised but probablyincorporating acid/alkali neutralisation and metal hydroxideprecipitation).

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 SUPPORTINITIATIVESIn 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 WASTEMANAGEMENTPRINCIPLESThere are a number of key principles which should be considered when

determining waste management requirements and these are developed in thefollowing sections.

F3.1.1 The Waste Management HierarchyThe 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 PrincipleA 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 OptionThis 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 bedeemed to be the best technology option it currently necessitates export which

is the least desirable option under the proximity principle.

F3.2 INTRODUCTION TO WASTEMANAGEMENTNEEDSA 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 environmentallyacceptable facilities for the management of:

general solid wastes, including recyclables (domestic-type, bio-degradablenon-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 FACILITIESREQUIRED TOMEETWASTEMANAGEMENTNEEDSF3.3.1 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 ReuseIn 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 sophisticatedrecovery/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 WastesBPEO for disposal of general solid wastes (ie municipal type wastes) would be

sanitary landfill or incineration. High density aerobic (HDA) landfill as

defined in Ghanas 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 Bankfunded 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 WastesBPEO 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 (seeprevious discussion about use as fuel for heating or as wood preservativeand discussion in the next sub-section).

F3.3.5 Solid Wastes Contaminated With Oil or Other Organic CompoundsBPEO for such wastes would be high temperature incineration for heavilycontaminated 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 Zeals 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 pendingexport 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 WastesSmall 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 SHORTTERMGhana currently has a BPEO solution for MARPOL Annex I wastes in

Takoradi however there are few options for the management of most othertypes 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 formedical 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 andrecycling markets in Ghana, periodically auditing the activities of therecovery and recycling contractors to ensure that these wastes aremanaged in an environmentally sound manner.

Use the current STMA service for disposal of general solid domestic-typewastes ensuring that, as far as practicable, hazardous wastes and otherwastes unsuitable for landfill are segregated from this waste stream.

Investigate the use of the oily waste processing facility at the TakoradiPower Station, and if used then implement a periodic audit to ensure thatresidual materials are managed in an acceptable manner.

Segregate and store industrial and hazardous waste that are unsuitable forlandfill 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 fromGhana.

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 ANDLONG TERMAs 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 withsuitable 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 developfacilities 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 ofimproved 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 ahazardous waste cell in the design of the Takoradi Sanitary Landfillproject, the design of which is currently being reviewed by a localcompany 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.

waste management in ghana

Documents