The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific measures agreed, comply with applicable host country laws and regulations and World Bank/IFC requirements. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow.
Over the last 2 years MSC has completed a variety of independent and in-house environmental, health and safety studies. The project has a strong development impact. MSC has historically maintained excellent relationships with the local community (mostly Maasai) and has initiated and supported a variety of community development programs related to education, health, water supply, training, micro-business support and employment. In the last year MSC has moved to formalize their community involvement and have developed a Local Community Involvement Plan, hired a Community Liaison Officer, and developed an official corporate Community Policy (November 2000). The studies completed include: Environmental Improvement Program, Magadi Soda (July 2002); Management and Disposal of Waste, Magadi Soda (July 2002); Local Community Involvement, Magadi Soda (February 2001); Plant Design Report-Environmental Impacts, Kvaerner (September 2001); and, EIA Pure Ash project, Norconsult (October 2000). Currently an independent Environmental Audit, being conducted by Norcon (Kenya), is underway. This Audit is being completed to meet local environmental requirements. IFC has agreed with MSC that upon completion of this Audit, in which it is not anticipated that any critical issues will arise due to results of previous studies, a revised Environmental Action Plan, which covers and incorporates all issues and reports listed above, will be drafted. This document will serve as a consolidated stand-alone reference for all environmental and social mitigation related to MSC operations and submission of an EAP acceptable to IFC will be a requirement in the project Investment Agreement between MSC and IFC. What follows is a summary of how these key issues are/will be addressed by MSC, and how all issues will be covered in the integrated EAP. Magadi also aims to develop an Environmental Management System (EMS), and the EAP will provide the framework for this.
Liquid and Solid Waste Disposal
Key waste generated is as follows:
Operations - waste oil from all operations, (e.g., workshop, storage areas, rail yard workshops, and the plant) is collected and sent to recycling plants. The company has a policy against waste oil being sold to individuals. Any heavy fuel oil that escapes/leaks is collected in bunds and returned to the tanks for burning in the calciner. All packaging, scraps, refractory brickwork from calciners, timber is collected and sent to the landfill. Liquor used as the medium to pump the trona from the dredges to the plant is pumped back to the lake and comprises the only significant solid/liquid waste from the plant. In some cases BOD discharges to the lake from the plant domestic septic tanks have been over limits. However given the chemical properties of the lake impacts are minimal. MSC is also in the process of eliminating asbestos from old facilities and equipment, an Asbestos Disposal Plan will also form part of the EAP. The key liquid/solid waste that will arise from the new operation is sodium fluoride tailings. To improve the purity of the soda ash, fluoride must be removed. This fluoride will be returned to the paddock (area where the dredges operate) to settle below the alkaline liquor on the trona surface. Over time, the paddock area will seal with regenerated trona and the fluoride will be locked in the lake. Given the chemical properties of the lake this is not anticipated to have any negative impacts nor affect the regeneration of trona.
Town - domestic solid waste is sent to the landfill for burial or burning. Magadi is instituting a waste separation and recycling program and will sell/give away paper, plastic and metal waste. The landfill requires upgrading so that waste can be properly buried. This is an action item in the current EAP. All liquid waste and sewage passes through a septic tank to a soakaway. No negative impacts on groundwater is anticipated due to the geology and general absence of groundwater. Septic tanks are emptied biannually and sludge is disposed of at a designated site within the town landfill.
Hospital - the town hospital, which is owned and operated by Magadi, has an incinerator which is used to destroy all sharps, used sample bottles, expired drugs and drug containers, and other contaminated waste (such as used dressings, etc.) This incinerator is operated by the Head Nurse. Ash from the incinerator is then transported to the landfill. Liquid effluents pass through septic tanks and are handled as per town procedures.
Air and Dust Emissions
The main sources of emissions and dust from current and proposed operations are listed below and mitigation is as noted:
Flash Calciner Precipitator
Fluid Bed Dryer Baghouse
Boiler Wet Scrubber
Conveyor Baghouse
The Kvaerner and Norconsult studies and designs have been carried out to ensure compliance with IFC guidelines. Annual reporting indicates that all emissions comply except dust emissions from the existing grinding and screening plant stack and the calciner. MSC have indicated that they will upgrade the grinding and screening plant dust collection to a double deck system which should reduce emissions below required levels. However, the existing calciner stack requires an upgrade for dust control. Given that Magadi is very remote and given that whole Rift Valley is naturally extremely dry and dusty, incremental impacts from calciner stack dust are very small, however they will be addressed as part of the current Audit and will also be covered in the EAP. The stack will likely require a precipitator to control particulates. The only other major source of air or dust emissions is the shed at Mombasa which is discussed under the Port section below.
Power Supply and Efficiency/Renewable Options
The main supply source to the town and the plant is the national grid. Given that the grid is unreliable and interruptions and fluctuations are common, MSC operate their own dedicated heavy fuel oil fired plant and a series of back-up generators. Stack emissions tests provided through MSC annual reporting to IFC indicate that these units are well within World Bank/IFC guidelines. In addition MSC have ensured proper fuel handling procedures and installation of secondary containment on all fuel and oil storage tanks. The Pure Ash Plant will be a computer controlled, state of the art facility. Due to the heavy electronic it will require a steady, uninterrupted power supply. Accordingly MSC aims to install a dedicated 1.75 MW co-generation plant. Design details for this plant are not yet available, however IFC will review plant design and mitigation prior to installation. IFC has also discussed energy efficiency and renewable energy options with MSC. MSC will be using a steam turbine generator in conjunction with the steam boiler for heat recovery, transfer and power generation. IFC has also proposed MSC look into the possibility of supplementing grid and thermal sources with wind energy. Preliminary discussions indicate that the power need and capital cost may be too high, however IFC and MSC are still looking into the options.
Water Supply
The Magadi area is extremely water scarce and the only supply is via a 30 km pipeline emanating from the Ngurumani Hills. This pipeline gravity feeds the town and neighboring communities along the way. This supply has no negative impact on other users, in fact, it is the main source for all users, and has been in place for many years. All communities along the pipeline have access to this water and, as mentioned below, their involvement in pipeline maintenance is supported by MSC. In addition, MSC aims to draw water from the springs for use in the crystallization section of the new plant. Monitoring to ensure extraction rates are sustainable will form part of the EAP.
Employee Health and Safety
Occupation safety is closely followed by management and accident records and work targets are posted on company notice boards and regularly analyzed. The company has a written Safety Policy and periodically conducts third party reviews to assess safety measures and provides safety training. All staff are provided with, and based on IFC site visits, are diligent about using, personal protection equipment (including: gloves, boots, dust masks, eye protection, and coveralls). All machine workers and employees working in areas with moving machinery are provided with specific training. Designated staff in all departments receive first aid training and a fire station is maintained in the town. An area that could be improved is man over board precautions on the dredges and IFC has discussed this with MSC, who are amenable to upgrading existing procedures and safety equipment.
The town hospital, which is owned and operated by Magadi, provides a fairly comprehensive medical services. There is an X-ray machine and an operating theater. The hospital sees about 1000-1500 outpatients per month, including staff and locals. The main treatment is malaria, followed by cholera and TB. Treatment is free for staff, as well as for locals during drought times (otherwise 30%). MSC, though they have the capability (and screen all blood donations), do not as a routine diagnose HIV/AIDS and do not currently have a specific HIV/AIDS policy. However, IFC has provided the company with guidance materials on HIV/AIDS and will discuss with MSC the feasibility of developing proactive programs.
Natural habitats
Given that Lake Magadi is alkaline (only halophilic, salt-tolerant, microbes survive), that the surrounding landscape is extremely dry and barren, and that Magadi takes no resources from the area (except the trona from the lake surface), impacts on the physical environment are minimal. Small lagoons which border the lake are spring fed and are not impacted by operations. In over 90 years of excavation of the trona, less than 10% of the lake has been touched and given that trona naturally regenerates through a process of geothermal heat causing leaching of chemicals from the underground rock strata which then rises and crystallizes as trona, one can characterize the trona as a renewable resource. In addition springs and lagoons that border the lake are not interfered with by Magadi; in fact MSC has welcomed and supported the work of biologists and archaeologists who visit the area to study some of the unique species of fish which live in hot springs. There is wildlife in the area, mainly birds, plains game (antelope, zebra etc.), and various predators. However impacts on these populations is minimal as the footprint of the town and plant is small compared to the vast open areas all around the lake. As with all savannah and plains areas in East Africa wildlife engage in seasonal migration and this movement is in no way restricted by operations. In fact given periods of extreme and extended drought, water supply that Magadi provides to local communities and their herds is also used by wildlife; thus in some ways the project is also a benefit to wildlife at times as the area is very water scarce. Bird counts conducted by the National Museums of Kenya (NMK) between 1991 and 1999 indicate that species and counts are relatively stable and counts have in fact increased in the last 5 years. Flamingos, which predominate are highly mobile, moving up and down the Rift Valley between soda and freshwater lakes and there numbers change year to year, though they are still stable over 10 years. MSC is committed to long term monitoring of impacts on wildlife and birds and the lake ecology. Based on coordination with IFC and Kenyan government authorities, MSC will remain open to changing operations management to mitigate potential negative impacts on natural habitats.
Rail and Port Operations
MSC operates about a 140km stretch of railway line (Magadi Rail) and associated rolling stock and depots, from Magadi to Konza. From Konza to the port all operations are by Kenya Railways. The dedicated line to Konza was built over 70 years ago and it''s operation does not displace or negatively humans or wildlife. In fact, as mentioned, the railway serves as a mode of communication, free transport, and water supply to local communities. Magadi Rail is perhaps the most efficient part of the national network and it possesses state-of-the-art satellite communication technology enabling headquarters to stay in touch with engine drivers and all stations. Staff who manage the railway are highly qualified professionals, some of whom used to work for Kenya Railways. Major issues associated with the railway are related to waste handling and fuel storage. These are discussed above. As with general plant safety, Magadi Rail has an excellent safety record and has had no major accidents or derailments to date.
Port operations are fairly straightforward. The trains pull up straight to the shed at the port from where ash is unloaded from hoppers to the shed and then it is transferred by conveyor to the dockside on to ships. Historically MSC has a problem in controlling dust levels at these points and has had plans now for several years to install dust collector units and noise attenuation at the conveyor load points in the shed and a ship loader with dust control equipment (i.e., Cleveland Cascade Chute). IFC has been aware of this issue and has discussed it with MSC. The situation is that all structures, services and equipment (e.g., dust control equipment) at the shed are owned and provided by the Kenya Port Authority (KPA). Thus, it is up to KPA to upgrade dust control measures, however, they lack the funds. MSC has thus proposed to fund replacement of this equipment in exchange for Government support/incentives. Until an agreement is reached there is little MSC can do. Otherwise, operations at the port are well managed. Power, water and domestic waste services are provided by KPA to local standards.
Community Development, Support and Consultation
Magadi Soda has long been a "good corporate neighbor" to its surrounding communities. There are few negative social impacts on local communities (i.e., there is no involuntary resettlement related to this project nor is there restriction of access to land or other natural resources). As such, MSC supports a variety of positive community activities and has established a committee through which they regularly consult with the Group Elders who represent the 4 Group Ranches of the area. The local Chiefs and Councillors are provided with free accommodation at Magadi so that MSC can be in regular touch with them. MSC also provides free office space and housing to two NGOs, Intermediate Technology Development Group (ITDG) and the Semi-Arid Rural Development Program (SARDEP). Both of these NGOs are bilaterally funded (Danish and Dutch respectively) and are engaged with the Group Ranches in developing a variety of socio-economic focused projects (e.g., handicrafts, water management, education, housing construction, women''s groups, micro enterprise).
The following list highlights some of the key initiatives MSC supports within the community: famine relief food; twice weekly train water supply; permanent town water supply; hospital open to all comers (70% subsidized); immunization campaign; eye clinics; repair to community posho (grain) mill; free passenger coach on train; free housing and services to Rotary Doctors who run clinics in the Group Ranches; scholarships for local children at Magadi School and other schools in Kenya; support two local students to attend university overseas; adult literacy classes; printer/copier to the school; and construction materials for school construction in the Group Ranches.
Magadi recognizes that there is need for consultation with a wider cross-section of the community and a need to build and strengthen mutual trust. Thus, Magadi Soda has decided to employ a Community Relations Officer to bring focus to the community work and add resources to the Human Relations Department. This will also ensure that culturally appropriate consultation with local communities is systematic and on-going. The Community Relations Officer will build on the work already started and seek to manage the issues which no doubt arise when the Pure Ash project gets underway.
One of the major problem continues to be the availability of skilled human resources to manage and implement projects. There is a perceived need for community leaders to understand the role they have to play in making sure the initiatives started within the town/project/Group Ranches are successfully completed, and this will be a prime focus of the MSC Community Relations Officer. Community leaders also need to be cognizant of the fact that there is not unlimited resources. IFC will seek to work with Magadi to prioritize community needs and formalize a community development plan over time. Along with the activities of the Community Relations Officer, a community development plan that identifies community needs, sets targets, and communicates outcomes will help in managing community expectations.
Supply Chain Development
The company has placed a strong emphasis on assisting in the creation of economic opportunities for the local community (mainly Maasai) and other members of the Magadi community (e.g., employees'' spouses). They have done this by initiating dialogue with the Maasai on training needs so that the Maasai may secure contracts to provide services to the company (e.g., road maintenance, water pipeline maintenance, salt production etc.). A contract to maintain roads within Magadi had previously been given to a group of Maasai. There are also around 100 shops/stalls which Magadi leases to entrepreneurs. These stalls sells such things as books, shoes, bicycle parts/repair, fruit, general retail items (soap, etc.). Of the 20 shops/stalls, 40 percent are leased to locals (Maasai), 30 percent to employees/spouses, and 30 percent to others. Maasai have also been given contracts to clean Magadi offices and the town. In addition, they are given preference for all plant related unskilled jobs (e.g., conveyor cleaning). Often what is lacking though is a sustained commitment to follow through on contracts undertaken by the local community and an ability to efficiently manage income earned from contracts. These are areas where MSC would like to focus training on and their Community Relations Officer is engaged with the Group Elders who represent the 4 Group Ranches in the Magadi area. MSC have also held preliminary discussions with the IFC-managed Africa project Development Facility (APDF) about ways Magadi can catalyze micro-enterprise opportunities amongst the Maasai. Another example of supply chain development is the town petrol station which Magadi has given to a cooperative to manage. These various initiatives and existing programs serve to illustrate that MSC is a company that is proactive in the area of social and local economic development and that they are now moving a further step ahead to formalize and clearly define their community support making.
Local Disclosure
This ERS will be made available locally at the Magadi District Officer''s Office and the company offices. Availability of the document at these sites will be advertised on a public bulletin board at Magadi Municipal Offices and company offices. In addition, the company''s Community Liaison Officer will make oral presentations to the local Maasai community and townspeople as necessary.
