Veolia AMI has presented plans to address these issues and to demonstrate that the proposed project will, upon implementation of the specific measures detailed below:
- be consistent with Veolia Environnement’s corporate environmental protection and social responsibility commitments; and
- comply with applicable host country laws and regulations and World Bank requirements. Detail on each issue is provided below.
- Environmental Management Systems
As one of Veolia Environnement’s business units, Veolia AMI is implementing the Environmental Management System (EMS) developed by the parent company in order to better assess and reduce the impacts of its activities on the environment and to allow it to successfully manage and enhance environmental and social performance. The Company relies on the support of the parent’s Environmental Department for environmental assessment and management resources, as well as Veolia Environnement’s Health Department for environmental health studies and training of employees. In one of its Morocco-based operations, an epidemiological study of the public health benefits due to the distribution of drinking water and rehabilitation of the wastewater collection system supported the investment plan. Another example is the use of the Hazard Analysis Critical Control Points (HACCP) method to identify potential hazards in water supply systems and devise solutions to control them.
Veolia AMI recently established its own environment organizational structure, including an assigned responsible individual who is part of the environmental managers’ corporate network. To ensure compliance with all regulatory standards and mitigation of environmental and public health risks, stringent risk prevention procedures have been put in place. These include periodic corporate-led environmental and health audits of Veolia AMI operations. Where areas of concern or non-compliance are identified as a result of these audits, action plans with specific mitigation and performance improvement measures are developed and implemented. For operations in which the Company does not have a controlling interest or are not in charge of capital investments, they provide information to their clients so that the necessary measures can be taken.
Veolia AMI will adopt IFC environmental and social safeguard policies as part of the EMS it is implementing for each of its operations. In addition, the Company will incorporate formal procedures for environmental and social screening of investment opportunities and new projects into its business strategy, commercial planning, and project bidding processes.
- Potable Water Production and Distribution
Veolia AMI’s potable water operations typically involve the production and/or distribution of drinking water. Although the responsibility of managing raw water resources ultimately lies with the respective government authorities with whom the Company has agreements, Veolia AMI takes an aggressive approach to reducing water losses in the distribution systems it operates, thereby preserving water resources. In Morocco for example, the volume of water saved in making improvements between 2002 and 2004 represents the amount consumed by 200,000 people. Managing demand more effectively is another method of saving water. This involves providing information to consumers, installing individual meters, and introducing pricing policies designed to reduce wasteful use.
The quality of the water Veolia AMI distributes generally complies with WHO drinking water standards, and in many cases EU standards. In operations where raw water treatment is required (such as Gabon), the Company employs conventional processes (flocculation, sedimentation, and filtration, and disinfection) at its water treatment facilities and produces good quality water. At treatment plants and throughout distribution systems, detailed procedures that ensure control over the quality of water are in place. These include ongoing sampling and monitoring of key indicators, as well as strategically located post chlorination units to maintain concentrations of chlorine residual. They are also modernizing and upgrading laboratories and training new staff throughout a number of operations in order to maintain the necessary quality assurance and control.
- Wastewater Management and Public Health
Currently focused primarily in Morocco, wastewater services include the collection, treatment and disposal of wastewaters generated within contracted service areas. Since beginning operations in 2002, Veolia AMI’s sanitation strategy involves improving public health and enhancing water quality in coastal waters through a capital-intensive clean-up program.
Most of the sewage generated within these coastal areas is currently discharged untreated through numerous outfalls directly to coastal beaches or the mouths of the local rivers. These existing conditions have resulted in widespread pollution of the ocean and estuarine waters surrounding these areas with concomitant risks to the public health and hygiene of residents and visitors. The clean-up programs involve the elimination of these raw sewage discharges and the restoration of water quality through the phased construction of interceptor sewer and pumping station systems followed by a series of wastewater treatment plants and offshore, submerged ocean outfalls. Detailed feasibility studies and environmental assessments have been used to identify cost-effective combinations of sewage collection, treatment, and ocean discharge infrastructure that best meets these water quality objectives. In general, treatment facilities are designed to achieve pollution removal efficiencies of greater than 80% and the elimination of pathogenic organisms. Based on extensive water quality modeling, the Company is designing and constructing lengthy, submerged ocean outfalls in some areas to take advantage of the assimilative capacity of off-shore currents far from the shoreline.
Over the next few years Veolia AMI plans to build seven wastewater treatment facilities and five offshore ocean outfalls. The first plant opened in the Rabat operating area, and effectively treats wastewater for 40,000 inhabitants to levels that comply with Moroccan requirements and World Bank Group policies and guidelines. Sludge generated by the Rabat plant is used as a soil conditioner and disposed by spreading on non-food chain crop land in the area.
- Electricity Generation and Distribution
Electricity distribution (in Morocco) and, in the case of Gabon, power generation and distribution are offered in combination with water and sanitation services where government contracting authorities have determined this is in their best economic interests.
Although the majority of electricity generation in Gabon is from existing, government-established hydropower facilities located throughout the country, Veolia AMI operates some supplemental, existing engine-driven thermal power generation plants that use liquid petroleum fuels, some with high sulfur levels characteristic of the crude oil produced in the region.
Going forward, the Company will determine the air emission levels for particulate matter, nitrogen oxides, and sulfur oxides from these facilities, and establish ongoing air emission monitoring programs. Concurrently and in the interests of promoting cleaner burning fuels, they will investigate the feasibility of switching fuels to natural gas at these plants. Not only will this lower carbon emissions, but it will also reduce loadings of sulfur dioxides that likely are being generated by burning oil. Veolia AMI will also measure ambient noise levels at the boundaries of the plants where permanent residential communities exist. Where noise levels need to be reduced, they will consider implementing noise reduction actions, such as enclosing noise sources or building noise barriers.
Transformers and other equipment containing PCBs used in the electrical transmission and distribution networks that Veolia AMI operates are being progressively replaced. Veolia AMI collects contaminated equipment and related materials and transports it to France where it is disposed of consistent with the Stockholm Convention on persistent organic pollutants.
- Fuels/Hazardous Materials Management and Emergency Response
The principal hazardous materials handled in Veolia AMI’s operations are petroleum fuels used for power generation and chlorine for water disinfection. Petroleum fuel is stored in above ground storage tanks at power generation facilities for the Gabon operations. Chlorine is stored in various forms throughout the various water and wastewater service operations of the Company.
Fuel storage features appropriate environmental protection systems – secondary containment, prevention of leaks, spills and overflows, and safety and fire prevention, loading area spill retention -- to prevent release to the environment of any oil that might be leaked or spilled. Contained stormwaters contaminated with oil are treated.
Veolia AMI, in coordination with government authorities, has developed emergency response plans and procedures, which include provisions for responding to fuel spills, fires, and explosions. Appropriate emergency equipment is provided, including fire fighting equipment, spill clean-up equipment, and personnel are trained in how to properly respond.
Veolia AMI is currently cleaning up some historical oil contamination caused by a power generation plant it inherited in the Gabon operation. Over the years leading up to the Company’s assuming control of the operation, spillage and leakage of fuel oil stored at one of the plants contributed to contamination of a nearby lake. Notwithstanding, they are undertaking remediation of the contaminated areas consistent with Veolia Environnement’s corporate commitment to improve environmental performance.
The Company stores and uses significant amounts of chlorine in water production and distribution, and operates its facilities to minimize the impact of potential release of this hazardous chemical. For chlorine and other water treatment chemicals used within these operations, the protection systems and emergency response procedures are adequate and in line with normal industry practice.
- Employee Health and Safety
Veolia AMI has robust employee health and safety program which aims to provide all employees with safe working conditions and to reduce the frequency and seriousness of work-related accidents. Each operation has its own Safety Division, and safety audits are carried out regularly with the technical support of the corporate Health and Safety Department. Safety committees have also been set up at each operation. Activities include: the continual identification and assessment of workplace risks; the safety aspects of decision-making processes; the wearing of personal protective equipment; employee training, communication, and awareness building; and promotion of employer-employee dialogue and consultation on safety topics. In Morocco, the frequency and severity of accidents and incidents have fallen significantly since Veolia AMI assumed control of operations in 2002.
Among its employees in Gabon, the Company has introduced a campaign for preventing, testing, and treating AIDS. The HIV/AIDS policy of Veolia AMI is aimed at reducing the impact of the disease on the Company’s staff and supporting the government’s efforts against AIDS. Resources assigned include a permanent medical team, and 50 staff members.
- Low-Income Access to Water and Sanitation Services
Veolia AMI has provided access to water and sanitation to more than 192,000 inhabitants of poor neighborhoods throughout the Africa region since 2002. By charging lower prices -- not only differential tariffs for consumption, but also for connection to these services -- the Company has made these services affordable for the most disadvantaged sections of the community. High rates of payment in these areas are evidence that the price of delivered water is affordable and geared to the local population’s ability to pay. In addition, special financing mechanisms to cover the initial cost of connection have been devised to enable low-income users to take advantage of these affordable prices. Where individual connections are not possible, Veolia AMI has set up customized collective water and electricity connections in unstructured settlements and shanty towns, or installed elevated community water taps in enclosed areas without roads. It has also taken steps to obtain assistance from national and international funding sources to provide additional connections to other low-income groups.
