World Bank Document

Public Disclosure Authorized Public Disclosure Authorized

Kakira Sugar Works Cogeneration Expansion Environmental Assessment Public Disclosure Authorized Document No. 0385240100-REP-VO001-02

Third Party Disclaimer This document has been prepared in response to a specific request for service from the client to whom it is addressed. The content of this document is not intended for the use of, nor is it intended to be relied upon, by any person, firm, or corporation, other than the client of Wardrop Engineering Inc. to whom it is addressed. Wardrop Engineering Inc. denies any liability whatsoever to other parties, who may obtain access to this document for damages or injury suffered by such third parties arising from use of this document by them, vithout the express prior written authority of Wardrop Engineering Inc. and its client who has commissioned this document Public Disclosure Authorized Confidential This document is for the confidential use of the addressee only. Any retention, reproduction, distribution or disclosure to parties other than the addressee is prohibited without the express written authorization of Wardrop Engineering Inc. Report to:

THE MADHVANI GROUP

KAKIRA SUGAR WORKS COGENERATION EXPANSION ENVIRONMENTAL ASSESSMENT

APRIL 2004

Prepared by Date Knstina Farrner, M.Sc., P.Ag.

Reviewed by Date Wayne Slack, P.Eng.

Authorized by Date Peter Komelson, M.Sc. VWWROP

6725 Airport Road, 6th Floor, Mississauga, Ontario L4V 1V2 Phone: 905-673-3788 Fax: 905-673-8007 E-mail: [email protected]

0385240100-REP-VOOOI-02 REV. ISSUE DATE PREPARED BY REVIEWED BY APPROVED BY DESCRIPTION OF REVISION NO AND DATE AND DATE AND DATE

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EXECUTIVE SUMMARY

The proposed co-generation expansion project at Kakira Sugar Works (1985) Limited (KSW) is an exciting project that is utilising a waste material to produce electricity for Uganda. Even though the amount of bagasse combustion will be no different with or with out the project, the benefits are the production of electricity and the reduction of diesel fuel currently used for loading and transporting the 113,000 tonnes of surplus bagasse'to the fields for disposal (buming).

Introduction

The Kakira Sugar Works (1985) Limited (KSW) is located 16 kilometres east of the town of Jinja in central Uganda. Currently, the enterprise is crushing sugar cane at the rate of over 3000 tonnes of cane crushing per day (TCD) and employs over 6,000 workers throughout its operations. KSW plans to expand this capacity by to a rate of 5000 TCD, a goal that will involve upgrading of the plant capacity. To achieve the expanded production target, expansion of the sugar factory with modifications to some processes will be required. Engineering feasibility studies and plans have been prepared for this project. KSW prepared and submitted an Environmental Impact Assessment (EIA) for the overall expansion program to the Govemment of Uganda National Environmental Management Agency (NEMA). Approval for the project was received in November 1998.

Kakira currently employs a cogeneration facility utilizing the solid cane waste, known as bagasse, to generate electricity for the facility. Due to a need for additional electricity generation capacity in the grid network, KSW submitted a proposal to the Govemment of Uganda offering to expand its cogeneration facility beyond its own needs and supply electricity to the national grid network. KSW proposes to supply up to 7 MW of electricity to Uganda Electricity Transmission Company Limited (UETCL) for six hours per day during the peak period from 1800 hours to 2400 hours.

KSW has developed a phased expansion program for the expansion of the factory and the cogeneration facilities. The current phase comprises a plan to expand production to 4000 TCD and install a new cogeneration facility of 14-15 MW. The proposed project includes installation of additional boilers, turbo-generator, related piping, cabling, electrical equipment, instrumentation and control systems, and additional bagasse handling equipment. A new electrical sub-station at Kakira and a new 33 kV distribution line from Kakira to UEDCL's Jinja Industrial Sub-station at Mailombili will be constructed and allocation to UEDCL.

KSW has requested financial support of the cogeneration portion of the project through the Energy for Rural Transformation (ERT) program. WARDROP

Environmental Assessment

Completion of an environmental assessment, in accordance with World Bank policy, is a requirement under the ERT. As such, this Environmental Assessment report focuses on the KSW new cogeneration facility and the relevant aspects of the related investments including the electrical substation. An assessment of the new distmbution line will be completed following determination of the route.

Information on the project was obtained from KSW, consultants, published literature, previous environmental reports, and literature and internet searches. Discipline specialists were contacted to help describe the project and the environment.

Potential Environmental Effects

Potential environmental effects of the proposed cogeneration project were identified using scoping methods, interaction matrix techniques, and professional judgement. Mitigation measures were identified to eliminate, reduce and control environmental effects determined to be adverse. Follow-up was proposed to vepify the accuracy of the assessment and determine the effectiveness of mitigation measures. The significance of the residual environmental effects remaining after mitigation were then evaluated.

Potential environmental effects of the proposed project were determined to be:

* Increased noise * Increased emissions * Increased dust * Reduced soil quality (spills and disposal) * Decreased groundwater quality (spills) * Decreased surface water quality (discharges) * Adverse effects on mammals and birds (waste disposal and storage) * Attraction of nuisance species (waste disposal) * Changes in employment opportunities * Reduced human health (noise, drinking water quality, air emissions)

Summary information on potential environmental effects is provided in Table ES-1, attached.

Environmental and Social Management Plan

A number of mitigation measures and follow-up requirement are identified in this environmental assessment report. Some of the main measures include:

x Controlling the timing of noise generation to least disruptive periods, as practicable, and monitoring noise levels as required. Hearing protection will be provided to employees working in high noise areas. Corrective actions will be taken on an as- required basis. X To minimize air emissions from vehicle and equipment use, Kakira will ensure that vehicles and equipment are inspected and maintained on a regular basis and that

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they will not be left idling when not in use. No ozone depleting substances will be used or generated from equipment during construction.

. The boilers will be equipped with a full wet scrubber to reduce the amount of ash released into the environment. x Kakira will develop a spill prevention plan, prepare and implement chemical handling and storage procedures and train employees about their use. A Concrete berms will be constructed around areas where liquids are stored to contain any spillage X Spill kits will be maintained in all fuel and chemical storage areas for quick access if needed Work will be monitored during construction to ensure there are no releases of deleterious substances. x Refuelling and maintenance of equipment will be conducted in designated locations only. Workers handling chemicals will be provided training in chemical safety and adequate personal protective equipment. x All water and dirt from transformers produced during maintenance activities will be collected and treated as hazardous waste.

. A waste disposal site will be properly sited and designed. x A spill prevention plan will be developed. x Spill containment supplies will be kept on-site in case of fuel leak. x Storage of fuels and other hazardous materials will be conducted in designated locations only. x Kakira's overall expansion plan includes a wastewater treatment system including: w Oil, grease and grit separation A primary settling and flow equalisation pond An anaerobic pond An aerobic pond

' Kakira will commit to reducing water use to minimize the wastewater generated. X Obtain permit from NEMA to operate waste disposal site X Proper siting and formal design will allow for vermin breeding control x Dispose of waste at a licensed off-site facility X Create additional jobs in other locations within the factory for displaced workers

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Table ES-1

Environmental Effects Summary for the Proposed Kakira Sugar Works Cogeneration Expansion

Environmental Component Potential Project Effects Residual

______E ffects Adverse? Positive Can Be Mit gated? Signi icant? Yes No Yes No Inknowr Yes No Air Quality, Climate, Meteorology '4 4 4

Topography and Bedrock 4

Soil Quality J '4 '4

Groundwater '4 4

Surface Water '4 ' '

Mammals and Birds ' '4 '4

Vegetation ' 4

Fish and Aquatic Invertebrates 4

Sensitive Habitats 4

Nuisance Species, vectors, '44 dangerous

Commercially important species

Land/resource use 4 4 '

Planned Development Activities

Community Structure '4

Employment ' '

Dist. of Income, Goods, Services 4

Recreation 4

Health and Safety '4 ''

Cultural Properties '

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ACKNOWLEDGEMENTS

Wardrop acknowledges, with appreciation, the contribution of the following individuals consulted during the course of this assessment, particularly:

* Mr. Richard Orr, General Manager, Kakira Sugar Works (1985) Limited. * Mr. Farhan Nakhooda, Projects Director, Kakira Sugar Works (1985) Limited. * Mr. Kiran Kamat, Project Coordinator, Kakira Sugar Works (1985) Limited. * Mr. Geoffrey Wabomba, Safety Health and Environment Superintendent, Kakira Sugar Works (1985) Limited. * Mr. Francis Kirudde, Safety Supervisor, Kakira Sugar Works (1985) Limited. * Mr. F.C.K Odongo, Administration Manger, Kakira Sugar Works (1985) Limited. * Mr. Max Polzin, Works Manger, Kakira Sugar Works (1985) Limited. * Mr. K.G.K. Raju, Agricultural Manager, Kakira Sugar Works (1985) Limited. * Mr. V.G. Modi, Corporate Financial Controller, Kakira Sugar Works (1985) Limited. * Mr. B.L. Lamba, Engineering Manager, Kakira Sugar Works (1985) Limited. * Mr. Peter Ongula, Chemist, Kakira Sugar Works (1985) Limited. * Mr. Robert Kwok, John H. Payne, Inc.

STUDY TEAM

The following key personnel were directly involved in the preparation of this report:

Mr. Peter Komelson, P.Eng. - Project Manager Mr. Wayne Slack, P.Eng. - Project Director Ms. Kristina Farmer, M.Sc., P.Ag. - Lead Assessor Dr. Patrick Mwesigye, Ph.D. - Assessor Ms. Jennifer Van de Vooren, M.N.R.M. - Assessor Ms. Sarah Wakelin, M.Sc. - Assessor Mr. Ed Wolowich, M.Sc., P.Eng. -Advisor

This Wardrop report has been prepared for The Madhvani Group and its use is governed by the following Third Party Disclaimer.

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DISCLAIMER

This document has been prepared in response to a specific request from the client to whom it is addressed. The contents of this document are not intended for use of, nor is it intended to be relied upon, by any person, firm, or corporation other than that client of Wardrop Engineering Inc. to whom it is addressed. Wardrop Engineering Inc. denies any liability whatsoever to other parties who may obtain access to this document, or for damages or injury suffered by such third parties arising from the use of this document by them, without the express prior written authorization of Wardrop Engineering Inc. and its client who has commissioned this document.

LIMITATIONS

The scope of this report is limited to the matters expressly covered and is intended solely for the client to whom it is addressed. Wardrop makes no warranties, expressed or implied, including without limitation, as to the marketability of the site, or fitness for a particular use. The assessment was conducted using standard engineering and scientific judgement, principles and practices, within a practical scope and budget. It is partially based on the observations of the assessor during the time of the site visit, in conjunction with archival information obtained from a number of sources which is assumed to be correct. Except as provided, Wardrop has made no independent investigations to verify the accuracy or completeness of the information obtained from secondary sources or personal interviews. Generally, the findings, conclusions and recommendations are based on a limited amount of data interpolated between sampling points and the actual conditions on the property may vary from that described above. Any findings regarding site conditions different from those described above upon which this report is based, will consequently change Wardrop's conclusions and recommendations.

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TABLE OF CONTENTS

1.0 INTRODUCTION . . . I 1.1 BACKGROUND ...... 1 1.2 ASSESSMENT METHODS ...... 2 1.2.1 REVIEW OF EXISTING INFORMATION ...... 2 1.2.2 SCOPE ...... 2 1.2.3 PROJECT COMPONENTS, PHASES AND ACTIVITIES ...... 2 1.2.4 ENVIRONMENTAL COMPONENTS ...... 3 1.2.5 IDENTIFICATION OF ENVIRONMENTAL EFFECTS ...... 3 1.2.6 RESIDUAL EFFECTS ...... 4 1.2.7 SIGNIFICANCE OF RESIDUAL EFFECTS ...... 6 2.0 POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 7 2.1 ADMINISTRATIVE FRAMEWORK ...... 7 2.1.1 NATIONAL ENVIRONMENT MANAGEMENT AUTHORITY ...... 7 2.1.2 DIRECTORATE OF WATER DEVELOPMENT (DWD) ...... 7...... 7 2.1.3 UGANDA WILDLIFE AUTHORITY ...... 8 2.1.4 ELECTRICITY REGULATORY AUTHORITY ...... 8 2.1.5 WORLD BANK ...... 8 2.2 PROGRAMS, REGULATIONS AND GUIDELINES ...... 8 2.2.1 ENERGY FOR RURAL TRANSFORMATION (ERT) PROGRAM (2001) ...... 8 2.2.2 THE NATIONAL ENVIRONMENT STATUTE (1995) ...... 9 2.2.3 THE PUBLIC HEALTHACT (1964) ...... 10 2.2.4 THE FACTORIES ACT (1964) ...... 11 2.2.5 BEST MANAGEMENT PRACTICES ...... 11 2.2.6 NEMA PROPOSED STANDARDS ...... 11 3.0 DESCRIPTION OF THE PROPOSED PROJECT ...... 12 3.1 LOCATION ...... 12 3.2 CURRENT OPERATIONS ...... 12 3.2.1 SUGAR CANE PROCESSING ...... 13 3.2.2 STEAM GENERATION ...... 19 3.3 PROPOSED EXPANSION ...... 23 3.3.1 FACTORY ...... 23 3.3.2 CO-GENERATION ...... 25 3.4 PROJECT ACTIVITIES - PRECONSTRUCTION, CONSTRUCTION, O&M ...... 28 3.4.1 PRECONSTRUCTION PHASE ...... 28 3.4.2 CONSTRUCTION PHASE ...... 29 3.4.3 OPERATION AND MAINTENANCE ...... 30 3.5 SCHEDULE ...... 30 3.6 STAFFING AND SUPPORT FACILITIES ...... 30 3.7 OFF-SITE INVESTMENTS ...... 30 3.8 LIFE-SPAN AND EXPECTED FUTURE GROWTH ...... 30 4.0 BASELINE DATA ...... 32 4.1 ENVIRONMENTAL OVERVIEW ...... 32

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4.1.1 SITE DESCRIPTION ...... 32 4.1.2 LAND USE ...... 32 4.2 PHYSICAL ENVIRONMENT ...... 32 4.2.1 LOCATION / SETTING ...... 32 4.2.2 DRAINAGE ...... 32 4.3 BIOPHYSICAL ENVIRONMENT ...... 33 4.3.1 CLIMATE ...... 33 4.3.2 AIR QUALITY ...... 33 4.3.3 NOISE ...... 36 4.3.4 BEDROCK AND SURFICIAL GEOLOGY ...... 37 4.3.5 SOILS ...... 38 4.3.6 HYDROGEOLOGY ...... 38 4.3.7 HYDROLOGY ...... 38 4.4 BIOLOGICAL ENVIRONMENT ...... 39 4.4.1 TERRESTRIAL HABITAT ...... 39 4.4.2 TERRESTRIAL BIOTA ...... 41 4.5 SOCIO-CULTURAL ENVIRONMENT ...... 42 4.5.1 LANDAND RESOURCE USE ...... 42 4.5.2 DEMOGRAPHIC CHARACTERISTICS OF THE AREA ...... 42 4.5.3 ECONOMIC CONDITION ...... 42 4.5.4 INFRASTRUCTURE ...... 42 5.0 SIGNIFICANT ENVIRONMENTAL AND SOCIAL IMPACTS ...... 43 5.1 BIOPHYSICAL EFFECTS ...... 43 5.1.1 AIR QUALITY, CLIMATE AND METEOROLOGY ...... 43 5.1.2 SOIL QUALITY ...... 68 5.1.3 GROUNDWATER ...... 72 5.1.4 SURFACE WATER ...... 73 5.1.5 MAMMALS AND BIRDS ...... 76 5.1.6 VEGETATION ...... 77 5.2 SOCIAL EFFECTS ...... 77 5.2.1 POPULATION DEMOGRAPHICS ...... 77 5.2.2 LAND / RESOURCE USE ...... 78 5.2.3 EMPLOYMENT ...... 78 5.2.4 PUBLIC HEALTH AND SAFETY ...... 79 5.3 POSITIVE EFFECTS ...... 82 6.0 ANALYSIS OF ALTERNATIVES . . . 83 6.1 STATUS QUO .. 83 6.2 EXISTING ENVIRONMENTAL CONDITION .83 6.3 CONCLUSION .. 84 7.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN . . .85 7.1 MITIGATION MEASURES .. 85 7.2 INSTITUTIONAL STRENGTHENING AND TRAINING .. 85 7.3 MONITORING .. 92 8.0 TECHNICAL REFERENCES . . . 93 1ARDROP

LIST OF APPENDICES

Appendix A Terms of Reference for the Environmental Assessment Appendix B Air Emissions Appendix C Kakira Sugar Works (1985) Ltd. Permits Appendix D List of Environmental and Social Assessment Preparers Appendix E Comments from World Bank and Corresponding Response Appendix F Minutes of Public Consultation Meeting

LIST OF TABLES

Table 1 Residual Effects Evaluation Criteria Used to Assess Significance Table 2 Factors Used to Assess High Significance of Residual Effects Table 3 Non-Hazardous Solid Wastes Generated at Kakira Table 4 Air Emission Sources at Kakira Table 5 Boiler Emissions Source Summary Table 6 Bi-monthly Noise Monitoring Results Table 7 Drinking Water Quality Results Table 8 Project Interaction Matrix Table 9 Environmental Effects Summary Table 10 Residual Effects Assessment for Significance Table 11 a Noise Emission Levels from Various Construction Vehicles and Equipment Table 11 b Values Used in Calculating Combined Noise Levels Table 11 c Cumulative Noise Emissions for All Construction Vehicles and Equipment Table 1ld Estimated Noise Emission from Expanded Cogeneration Table 12a Estimated Project Fuel Consumption During Construction Table 12b Estimated Fossil Fuel Emissions During Construction Activities Table 12c Anticipated Greenhouse Gas Production During Construction Table 13 Mitigation Action Plan Table 14 Environmental Monitoring Plan

LIST OF FIGURES

Figure 1 Location of Kakira Sugar Works Estate Figure 2 General Site Plan - Kakira Sugar Works Figure 3 Generic Flow Diagram of Sugar Processing Figure 4 Detailed Flow Diagram of Sugar Processing Figure 5 Existing Power Generation Layout Figure 6 Schematic Flow Diagram of the Cogeneration Process Figure 7 Proposed New Power Generation Arrangement Figure 8 Kakira Sugar Works Land Cover Map

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ABBREVIATIONS

ACGIH American Conference of Govemmental Industrial Hygienists ASHRAE American Society of Heating, Refrigerating and Air- conditioning Engineers AST Aboveground Storage Tanks BMP(s) Best Management Practices BOD Biochemical Oxygen Demand COD Chemical Oxygen Demand DO Dissolved Oxygen DWD Directorate of Water Development EC Electrical Conductivity EIA Environmental Impact Assessment EF Emission Factor EHS Environment, Health and Safety EMS Environmental Management Systems ERT Energy for Rural Transformation GoU Government of Uganda IAQ Indoor Air Quality KSW Kakira Sugar Works MVA Megavolt Amps MW Mega Watt NEMA National Environmental Management Authority (Government of Uganda) NES National Environment Statute ODS Ozone Depleting Substances OSHA Occupational Safety and Health Administration PCBs Polychlornated Biphenyls PPE Personal Protective Equipment SHE Safety, Health and Environment TCD Tons of Cane Crushing per Day TDS Total Dissolved Solids TKN Total Kjeldahl Nitrogen TOCs Total Organic Carbons ToR Terms of Reference TSS Total Suspended Solids TWA Time Weighted Average UST Underground Storage Tanks UEDCL Uganda Electricity Distribution Company Limited UETCL Uganda Electricity Transmission Company Limited USEPA United States Environmental Protection Agency VOCs Volatile Organic Carbons WDG Waste Disposal Ground WIRDROP

1.0 INTRODUCTION

1.1 BACKGROUND

The Kakira Sugar Works (1985) Limited (KSW) property covers over 9000 hectares of land and is located 16 kilometres east of the town of Jinja in central Uganda. Currently, the enterprise is crushing sugar cane at the rate of over 3000 tonnes of cane crushing per day (TCD) and employs over 6,000 workers (including contract employees) throughout its operations. KSW plans to expand this capacity to a rate of 5000 TCD, a goal that will involve upgrading of the plant capacity.

KSW originally proposed to provide the Ministry of Energy of the Govemment of Uganda with 18 MW of electricity to the grid on a 24-hour per day basis. However, demand forecasts prepared by the Uganda Electricity Board / Uganda Electricity Transmission Company Limited (UETCL) indicated that this quantum of electricity would be greater than what could be sold. KSW therefore reduced its cogeneration project to supply up to 7 MW of electricity to UETCL for six hours per day during the peak period from 1800 hours to 2400 hours.

To achieve the expanded production target, expansion of the sugar factory with modifications to some processes will be required. Engineering feasibility studies and plans have been prepared for this project. KSW prepared and submitted an Environmental Impact Assessment (EIA) for the overall expansion program to the Govemment of Uganda National Environmental Management Agency (NEMA). Approval for the project was received in November 1998.

KSW has requested financial support of the cogeneration portion of the project through the Energy for Rural Transformation (ERT) program. Completion of an environmental assessment, in accordance with World Bank policy, is a requirement under the ERT. As such, this Environmental Assessment report focuses,on the KSW new cogeneration

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facility and the relevant aspects of the related investments including the electrical substation. An assessment of the new distribution line will be completed following determination of the route.

1.2 ASSESSMENT METHODS

Background information was acquired from a wide range of sources, including Ugandan government internet sites, consultant reports, documentation by public-interest groups, and publications of Ugandan legislation and policies.

1.2.1 REVIEW OF EXISTING INFORMATION The consultant team obtained and reviewed information on the proposed project, KSW property descriptions and use, and the surrounding environment. Information sources included KSW documents, photographs, NEMA data, engineering drawings, and geological, hydrogeological and hydrological data. Information deficiencies were identified during this process. Information requests were presented to KSW.

1.2.2 SCOPE

The scope of the assessment includes a determination of the environmental effects to be addressed and the effects to be considered in making decisions regarding the project. The scope of this environmental assessment was determined by the World Bank and was described in the Terms of Reference for the Environmental Assessment of the proposed project, which is provided in Appendix A.

Appendix E provides comments received from the World Bank on the draft report and the clients' and consultants' respective response to these comments. Appendix F provides the minutes of the Public Consultation Meeting held at the suggestion of the World Bank.

1.2.3 PROJECT COMPONENTS, PHASES AND ACTIVITIES Project components were identified by the consultant team from an examinabon of project documentation and through consultations with the consultant engineers and representatives from KSW. Three components were identified for the project:

1) Factory Expansion 2) Cogeneration Expansion 3) Substation Construction

An additional component, comprising the construction of the 33 KV distribution line, will be assessed at a future date when the project is more developed. No construction on the transmission line will occur until the environmental assessment, including a resettlement plan, if required, has been cleared and disclosed by the World Bank. Two project phases were identified:

1. Construction

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2. Operation and maintenance

Project activities for each of the above project components were identified by the consultant team through an examination of project documentation and through consultations with the consultant engineers. A detailed project description, including the components and activities, is presented in Section 3.

1.2.4 ENVIRONMENTAL COMPONENTS Environmental components were identified by the consultant team after examining reference documents, conducting a site visit, discussing environmental conditions with KSW, and contacting relevant environmental authorities.

BIOPHYSICAL ENVIRONMENT Components of the biophysical environment described include:

A air quality x noise x bedrock and surficial geology x soils

x hydrogeology x hydrology X terrestnal biota and habitat

A aquatic biota and habitat

SOCIO-ECONOMIc ENVIRONMENT The description of the socio-economic environment includes information on the function and structure of the socio-economic environment in the study area, demographics, infrastructure, and existing and planned land uses.

1.2.5 IDENTIFICATION OF ENVIRONMENTAL EFFECTS Environmental effects were identified for the project using a combination of methods including:

x Expert consultation x A multidisciplinary team brainstorming process x Interaction matrices

An environmental effect is any change that the project may cause in the environment. The World Bank defines environment as 'the natural and social conditions surrounding all...mankind, and including future generations". For the purpose of this environmental assessment, the term "environmental effect' includes any change that the project may cause to the environment, including any effect of such change on:

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x Biophysical conditions

k Health and socioeconomic conditions (resulting directly from environmental effects)

X Sustainable use of resources x Current use of lands and resources for traditional purposes.

The multidisciplinary consultant team's professional judgement was used to complete a project activity / environmental component interaction matrix. The team comprised experts in environmental science, biology, soil science, hydrogeology, and environmental engineering.

Potential interactions between project activities and environmental components were indicated on an interaction matrix for the subject site. Interactions were denoted with open and closed circles. Open circles were used to denote interactions that would not result in a change from baseline conditions; consequently, these interactions were not discussed further. Closed circles were used to identify interactions that could lead to a direct adverse environmental effect and/or indirect social effect requiring mitigation. Negative or adverse direct environmental effects and indirect social effects are discussed in Section 5.

1.2.6 RESIDUAL EFFECTS Residual effects, or the effects remaining after the implementation of mitigation, were evaluated using a number of criteria relating to both biophysical and socioeconomic components. Criteria used include:

x Magnitude of effect x Frequency of occurrence

X Duration X ProbabilityAikelihood x Reversibility

k Geographic extent

These criteria are briefly described below and in Table 1.

MAGNITUDE OF EFFECT Magnitude is an estimation of the extent of change to the environment caused by the project, based on predicted deviations from baseline conditions. For this project, magnitude was categorized as:

* Low (L) - a measurable change from background conditions but no lasting effect(s) on the environment.

* Medium (M) - a measurable change from background conditions with localized and/or short-term effect(s) on the environment.

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Residual Effects Evaluation Criteria Used to Assess Significance

1Magnitude of Effect 2Frequency of Occurrence 3Duration 4Probability / Likelihood 5Reversibiflty 6Geographic Extent Low (L): Low (L): Short-term/Low (L): Low (L): Likely/Low (L): Low (L): • measurable change from . Infrequent; occurs once a . Environmental effects are . <20% probability of . Effect is expected to * Effects occurs within background year. expected to last < 1 month occurrence be reversible the project study area * no lasting effect on environmental condition Medium (M): Medium (M): Long-term/Medium (M): Medium (M): Unlikely/High (H): Medium (M): * measurable change from . Occurs intermittently . Environmental effects are . 20 - 70% probability of * Effect is not expected * Effect occurs within background throughout a year. expected to last 1 month to occurrence to be reversible the local study area * localized and short-term 18 months High (H): High (H): Far Future/High (H): High (H): Insufficient Data (n/a): High (H): * measurable change from . Frequent; occurs daily. . Environmental effects are . >70% probability of * Evaluation of effect is * Effect occurs beyond background expected to last > 18 months occurrence not applicable due to the local study area * widespread and long-term insufficient data. References: CEAA 1999.

Notes: 'Magnitude of Effect - measure of the degree of change in a measurement or analysis endpoint. 2Frequency of Occurrence - how often the effect occurs within a given tme period. 3Duration - length of time over which an environmental effect spans. 4Probability - that the event is likely to occur anywhere in the study area. IReversibility - indicator of the potential for natural recovery of the endpoint from the effect. 6 Geographic Extent - area affected by the project.

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High (H) - a measurable change from background conditions with widespread and long-term effect(s) on the environment.

FREQUENCY OF OCCURRENCE Frequency relates to the number of times a project activity and/or an environmental effect will occur. An infrequent event, occurring once per year, was defined as having low (L) frequency. An event having a medium (M) frequency corresponds to an effect that occurs intermittently throughout the year. The term high (H) frequency was applied to any event occurring on a daily basis.

DURATION Duration is the length of time that potential effects or activities could last. The duration of effect(s) may or may not be related to the durafion of a particular activity. Environmental effects and/or activities expected to last less than one month were considered short-term, or of low (L) duration. Environmental effects and/or activities expected to last between one to 18 months were considered medium-term, with medium (M) duration. Any effects or activities expected to last beyond 18 months were considered a long-term, or of long (H) duration for the purposes of this assessment.

PROBABILITY! LIKELIHOOD Probability is the chance or likelihood that an effect will occur in the environment. Probabilities were assigned as follows:

Low (L) <20% probability x Medium (M) 20% to 70% probability x High (H) >70% probability

The above values were selected based upon professional judgement.

REVERSIBILITY

An effect is considered reversible if, through natural or human processes, the environment returns to the original conditions present before exposure to the effect. Reversible effects were designated as (L). If the environment cannot recover naturally, the effect is considered irreversible and designated as (H).

GEOGRAPHIC EXTENT Geographic extent describes the area over which the environment is subject to potential effects. Defining spatial boundaries establishes a frame of reference for identifying and evaluating environmental effects. Geographic areas examined for this project include the Project Study Area and Local Study Area. The geographic extent over which the residual effect may have an influence was classified as low (L) if the effect remained within the Project Study Area, medium (M) if the effect influenced the Local Study Area, and high (H) if the effect influenced an area beyond the Local Study Area.

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1.2.7 SIGNIFICANCE OF RESIDUAL EFFECTS The residual environmental effects of each project component (construction, operation, and maintenance) were assigned an overall significance rating based on their predicted influence on the terrestrial, aquatic, atmospheric, and socioeconomic environments.

In assessing the significance of effects, the most important criterion was magnitude and the application of other criteria was dependent on the rating for magnitude.

The following criteria were used to determine if the significance of the residual effects was high:

Table 2

Factors Used to Assess High Significance of Residual Effects If Magnitude of Effect Then the Requirements for the Residual Ratina is: Effect to be of High Significance are: H One additional criterion rated 'H" and two other criteria that are rated either 'H" or 'M" M Two additional criteria rated "H" and two other criteria that rated either 'H" or 'M" L Four additional criteria rated "H"

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2.0 POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

The following sections provide a summary of the pertinent intemational, national, regional and local regulations and standards under which KSW must follow.

2.1 ADMINISTRATIVE FRAMEWORK

2.1.1 NATIONAL ENVIRONMENT MANAGEMENT AUTHORITY Following the enactment of the National Environment Statute (NES) 1995, the National Environment Management Authority (NEMA) was created and charged with the responsibility to oversee, coordinate and supervise environmental management in Uganda. NEMA's overall goal is to promote sound environmental management and prudent use of natural resources in Uganda.

Since its formation in 1995, NEMA has put a strong emphasis on developing environmental policies, laws and guidelines as evidenced by the large number of environmental regulations that have been enacted over the last few years. Safeguard policy issues are addressed through these regulations, including environmental impact assessment (EIA) regulations. NEMA is responsible for EIA review and monitoring of the implementation of environmental mitigation measures.

2.1.2 DIRECTORATE OF WATER DEVELOPMENT (DWD) The right to investigate, control, protect and manage water in Uganda for any use, is vested in the Govemment and exercised by the Director of DWD in accordance with the provisions in the Water Statute (1995). DWD is the Secretariat for the Water Policy Committee. The duties and roles of DWD include, among others, carrying out inventory of water resources and preparation, update and revision of water action plans, revision, variation and cancellation of water and wastewater discharge permits. These permits are approved in collaboration with major stakeholders such as NEMA.

Regulations under the Water Statute include: a The Water (Waste Discharge) Regulations, 1998 a The Water Resources Regulations, 1998 a The Sewerage Regulations, 1999 a The Water Supply Regulations, 1999

The statute provides for the management of water in Uganda and is under the mandate of DWD in the Ministry of Water, Lands and Environment. Section 31, subsection (1) of the Water Statute deals with prohibition of pollution to water and stipulates that a person commits an offence who, unless authorised under this Statute, causes or allows waste to

The Madhvani Group 7 0385240100-REP-VOOOI-02 Kakira Sugar Works Cogeneration Expansion Environmental/Assessment WRDROP

come into contact with any water; waste to be discharged directly or indirectly into water; or water to be polluted.

Under section 107, the Water (Waste Discharge) Regulations (1998); the Water Supply Regulations (1999) and the Sewerage Regulations (1999) have been put in place to operationalise the Statute and are aimed at minimising pollution of public waters by developers and other users. These regulations give procedures for obtaining water abstraction and effluent discharge permits from DWD.

2.1.3 UGANDA WILDLIFE AUTHORITY The Uganda Wildlife Authority (UWA) was established under the Uganda Wildlife Statute (1996). The main function of the UWA is to ensure sustainable management of wildlife in conservation areas by coordinating, monitoring and supervising wildlife management issues; however, UWA can manage wildlife (wild plant and wild animals native to Uganda) in both protected and unprotected areas.

2.1.4 ELECTRICITY REGULATORY AUTHORITY Under the Electricity Act (1999), the Electricity Regulatory Authority is responsible for issuing license for the generation, transmission, distribution and/or sale of electricity.

2.1.5 WORLD BANK Environmental Assessment is used in the World Bank to examine the potential environmental risks and benefits associated with projects proposed for Bank financing. The Bank's environmental assessment policy and procedures are described in OP/BP (Operational Policy/Bank Procedures) 4.01. Environmental Assessment is one of the 10 environmental and social Safeguard Policies of the World Bank. The Environmental and Social Management Framework, which also includes a resettlement policy framework, will be referred to especially when resettlement issues are to be assessed during consultations for the transmission line. The World Bank's Policy on involuntary resettlement will be triggered and the policy will be used as guidance to prepare resettlement/compensation plan as needed during the assessment of the transmission line.

2.2 PROGRAMS, REGULATIONS AND GUIDELINES

2.2.1 ENERGY FOR RURAL TRANSFORMATION (ERT) PROGRAM (2001) This is a Govemment of Uganda program aimed to bring electricity to currently unserved rural areas. The goal is to facilitate economic transformation of the rural economy via provision of energy services. The project is focused on the private sector as the primary service provider. The World Bank provides funding assistance for implementation of the ERT program.

All ERT projects must comply with the applicable environmental and social safeguard policies of the Government of Uganda and the World Bank, including Environmental

The Madhvani Group 8 0385240100-REP-VOOOI-02 Kakira Sugar Works Cogeneration Expansion EnvironmentalAssessment ARDROP

Impact Assessment. NEMA is responsible for the review of the EIA and the monitoring of the implementation of environmental mitigation measures.

For ERT projects, the WB Environmental Assessment categories apply. Most ERT projects are classified under Category B.

2.2.2 THE NATIONAL ENVIRONMENT STATUTE (1995) Following the enactment of the National Environment Statute (NES) 1995, the National Environment Management Authority (NEMA) was created and charged with the responsibility to oversee, coordinate and supervise environmental management in Uganda.

The NES details environmental planning issues; environmental regulation; environmental management; control of pollution; environmental restoration orders and environmental easements; records, inspection and analysis; information, education and public awareness; and financial provisions. Inaddition, offences, judicial proceedings, intemational obligation and miscellaneous provisions are included. Regulations and guidelines have been or are in the process of being developed.

A Environmental Regulation (Part V) - including environmental impact assessment, auditing and monitoring.

( Environmental Impact Assessment Regulations, 1998 - a developer is responsible for conducting an environmental assessment of any project that may have, will likely have, or will have an impact on the environment (NES 20(1) (3 a, b, c)). The objective of the assessment is to determine the possible environmental impacts of a proposed project and measures to mitigate their effects. Terms of reference, including study format and contents, methodology, public participation and any other relevant matters, are developed by the proponent in consultation with NEMA and any other agencies involved. NEMA and the lead agency review the assessment report. The public also has an opportunity to comment on the report. The Executive Director of NEMA makes a decision regarding the assessment based on the validity of the predictions made, public comments, an analysis of the economic and social impacts of the project, and any other important factors (Part VI Section 24(1). A post-assessment audit of the project must be completed within 36 months of the project.

Environmental Audit Guidelines (1999) - According to the National Environment Statute 1995 (Section 23), NEMA shall, in conjunction with the lead agency, be responsible for carrying out an environmental audit of the activities that are likely to have significant effect on the environment. These guidelines outline requirements, procedures and methods for carrying out an environmental audit in Uganda. Environmental Audit Regulations are in advanced stages of preparation.

A Establishment of environmental standards (Part VI) - Standards for air quality, water quality, discharge of effluent into water, control of noise and soil quality. The standards for discharge of effluents into water or on land and minimum standards for

The Madhvani Group 9 0385240100-REP-VOOOI-02 Kakira Sugar Works Cogeneration Expansion EnvironmentalAssessment VAROP

management of soil quality have already been developed. The National Environment (Standards for Discharge of Effluent into Water or on Land) Regulations (1999), Minimum Standards for Management of Soil Quality Regulations (2001) and The National Environment (Noise Standards and Control) Regulations, 2003 are in place. Environmental standards on air quality are still in draft form.

Other regulations that have been developed under Section 108 of the NES include the National Environment (Wetlands, River banks and Lake Shores Management) Regulations (2000), National Environment (Waste Management) Regulations (1999) and Management of Ozone Depleting Substances and Products Regulations (2001).

x. Regulation 4 of the National Environment (Waste Management) Regulations (1999) describes the sorting and disposal of domestic waste and provides that the generator of domestic waste may, without a licence issued under these regulations, dispose of non-hazardous waste in an environmentally sound manner in accordance with by-laws made by a competent local authority.

x The National Environment (Waste Management) Regulations (1999) also directly mentions the application of cleaner production as a means to minimise production of wastes. Regulation 5 (1) states that: A person who owns or controls a facility or premises which generate waste shall minimise the waste generated by adopting the following cleaner production methods:

Improvement of production processes through: - Conserving raw materials and energy; - Eliminating the use of toxic raw materials; - Reducing toxic emissions and wastes

Monitoring the product cycle from beginning to end by: - Identifying and eliminating potential negative impacts of the product; - Enabling the recovery and reuse of the product where possible; - Reclamation and recycling;

Incorporating environmental concems in the design and disposal of a product.

The Executive Director of NEMA may give directions in writing to any person or class of persons to apply specifically stated methods of cleaner production. This is to achieve the goals of cleaner production stated in the directive.

2.2.3 THE PUBLIC HEALTH ACT (1964 ) Section 7 of the Act provides local authorities with administrative powers to take all lawful, necessary and reasonable practicable measures for preventing the occurrence of, or for dealing with any outbreak or prevalence of, any infectious communicable or preventable disease to safeguard and promote the public health and to exercise the powers and perform the duties in respect of public health conferred or imposed by this act or any other law.

The Madhvani Group 10 0385240100-REP-VOOOI-02 Kakira Sugar Works Cogeneration Expansion Environmental Assessment .RDROP

Section 105 of the Public Health Act (1964) imposes a duty on the local authority to take measures to prevent any pollution dangerous to the health of any water supply that the public has a right to use for drinking or domestic purposes.

The Act details the siting of waste disposal facilities such as solid waste skips in relation to settlements and food points.

2.2.4 THE FACTORIES ACT (1964) This act makes provisions for the health, safety and welfare of persons employed in factories and other places. Items included under this act include housekeeping, overcrowding, provisions for adequate ventilation and lighting, and general safety items pertaining to work in confined spaces and fire safety. Workers must have sufficient training for their specific job and have supervision by a knowledgeable and experienced person. In addition, workers must have and be trained in the proper us of personal protective equipment, as required.

2.2.5 BEST MANAGEMENT PRACTICES Best management practices (BMPs) are generally accepted industry practices or standards for environmental management and occupational health and safety. In the absence of Ugandan legislation, BMPs provide quantitative or qualitative standards against which to compare current performance. The standards used during this assessment include:

x Cane Sugar Agricultural Operations, Occupational Safety and Health Guidelines, World Bank, 1984 x Cane Sugar: Mill and Refinery Operations, Occupational Safety and Health Guidelines, World Bank, 1984 x Sugar Manufacturing, World Bank, 1993 x Guidelines for Drinking-Water Quality, Volume 1, Recommendations, World Health Organization, 1984 a Pollution Prevention and Abatement Handbook, Part IlIl, World Bank, 1998 x National Ambient Air Quality Standards, US EPA x Occupation Safety and Health Administration (OSHA) - Indoor Air Quality Guidelines. x American Conference of Govemmental Industrial Hygienists (ACGIH) - Indoor Air Quality Guidelines, American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) - Indoor Air Quality Guidelines.

2.2.6 NEMA PROPOSED STANDARDS x Proposed Environmental Air Quality Standards and Guidelines for Uganda, 4th Draft, NEMA, February 2002 x Proposed National Environment (Noise Standards and Control) Regulations, 2001 x Proposed Hazardous Chemicals Regulations (pending) x Oil Spillers Liability Regulations (pending)

The Madhvani Group 11 0385240100-REP-VO001-02 Kakira Sugar Works Cogeneration Expansion Environmental Assessment WARDROP

3.0 DESCRIPTION OF THE PROPOSED PROJECT

3.1 LOCATION

Kakira Sugar Works is located 16 km east of the town of Jinja and 100 km east of Kampala in central Uganda, with the shore of Lake Victoria at its southem edge (Figure 1).

The enterprise was originally established in 1927 by the Madhvani family. At the time of establishment, the facility's crushing capacity was 150 tonnes of sugar cane per day. By 1972, the enterprise was crushing approximately 3000 tonnes of sugar cane per day and producing 85 000 tonnes of sugar per year. Between 1972 and 1985, the factory was closed and operations ceased due to the political turmoil in Uganda at that time. In March 1985, a new company, Kakira Sugar Works (1985) Limited, also owned by the Madhvani family, was incorporated and an expanded and modernized facility resumed operation.

3.2 CURRENT OPERATIONS

A general site plan of the Kakira sugar factory is provided as Figure 2. Flow diagrams of the sugar manufacturing process are presented in Figures 3 (generic) and 4 (detailed).

Wastes generated by the process during the 2002 - 2003 season are listed in Table 3, below.

Table 3

Non-Hazardous Solid Wastes Generated at Kakira

Waste Description Disposal Method Quantity generated (annual basis) Bagasse Used to fuel cogenerabon units producing 350 000 tonnes produced* steam and electricity (38.89% of cane crushed)

Excess is disposed by buming in open Approximately 113 000 tonnes fields. (150 loads x 3 MT = 450 MT/day) of excess bagasse are transported to the fields every day.

Bagacillo Recycled to vacuum filters 5800 tonnes

Filter cake Applied as fertilizer to the cane fields 34 000 tonnes*

L ______(3.77% of cane crushed)

The Madhvani Group 12 0385240100-REP-VOOOI-02 Kakra Sugar Works Cogeneration Expansion Environmental Assessment VARDROP

Boiler ash Stockpiled. Some used for erosion control. 2700 tonnes* (0.3% of cane crushed) Factory paper waste Transported using tipper lorry, bumt and 72 tonnes** covered with murram soil (twice a week). Chemical packaging Transported using tractor-trailer to open 40,100 paper bagst (paper and plastic bags) dumping at quarry site (twice a week). 39,000 plastic bags"* Molasses (by-product) Stored in aboveground tank and sold to 31 000 tonnes* private customers. (3.46% of cane crushed) Metal scrap Recycled to foundry or steel mill. Foundry Not available melts down the scrap to make machine parts. Clarifier sludge Dumped on ground occasionally near Not available cooling ponds when bagasse is in short supply. Clarifier cleaned every 2 weeks. Slag Dumped on ground near foundry Minor amounts *Ref Kakira Final Manufacturing Report (1993-2000) and communicatons with F. Nakhooda. Estimate based on 900 000 tonnes of cane crushed per year, or over 3000 tonnes cane crushed per day (TCD), and 250 production days. Estimated based on lT of waste, twice a week for 36 production weeks. Provided by Kakira in fax dated May 16th, 2002. Packaging quanuties based on quantty consumed.

The following is a brief descnption of the sugar manufacturing process.

3.2. 1 SUGAR CANE PROCESSING

GROWING AND HANDLING Sugar cane, the raw material for the process, is cultivated and grown on extensive cane fields on Kakira property. Harvesting is done by hand with machetes or by mechanical cutters. At present, Kakira estates produces about 470 000 tonnes of cane per year, while outgrowers contribute 430 000 tonnes of cane per year, for a total of 900 000 tonnes of cane per year, or over 3000 TCD. There are currently approximately 3,600 outgrowers registered with Kakira, cultivating around 9000 hectares of sugar cane. Kakira has received approval from NEMA to proceed with an outgrowers development program to increase the number of outgrowers from 3,600 to 4,200, cultivating about 12 000 hectares of soil.

The cane from the fields is transported by truck or tractor and trailer to the cane yard adjacent to the sugar-processing factory. The cane is weighed and unloaded from the vehicles by grab unloaders, manually offloading or dumping. Cane loaded onto the ground is stacked and then transferred to the main cane carrier by a Cameco unloader for processing as required.

The raw sugar cane from the cane yard is conveyed to the milling station on the main carrier. Before milling, the cane is first evened in the kicker, cut down to smaller pieces by a series of rotating cutting knives, and then chopped further in the fibrizer, which shreds the cane and exposes the sugar containing cells. Kakira does not prewash the raw cane prior to juice extraction.

The Madhvani Group 13 0385240100-REP-VO001-02 Kakira Sugar Works Cogeneration Expansion Environmental Assessment R:\CLIENTS A - Z\THE MADHVANIGROUP - 8524\03852401.00 - ENViRONMENTAL ASSESSMENT\CAD\KAKIRA\0385240100-0WG-VO002-0OA.0WG 03.07.29 15:05

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HP STEAM I _ MOLASSES

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SUGAR POWER TO GRID FOR SALE TO THIRD PARTIES

NOTE: ADAPTED FROM THE MADHVANI GROUP, 2002

OWC DESCRIPTION FIGURE 4: SCHEMATIC FLOW DIAGRAM OF NO. DESCRIPTION DATE ey REVISIONS/ISSUE R OP IW%Engineering Inc. THE COGENERATION PROCESS THE MADHVANI GROUP DESIGNED BY: KF |DRAWN BY: VG |DWG NO. CLIENT CHECKED BY: DATE: 03.05.02 | 0385240100-DWG-VOOO1-00 ADROP

MILLING At the milling station, the cane passes through a series of rollers that crush the cane and extract the juice. Maceration or imbibition water (equal to 20-40% of the cane weight passing through the mill) is added to the crushed cane prior to the final crushing mill to assist in extracting the cane juice. The juice flows through the machinery to a metal trough below the floor and is pumped to a receiving tank. The bagasse (waste sugar cane material) is conveyed to the boiler furnaces for buming.

The objective is to optimize the milling operation via maximum cane preparation, maximum juice drainage, good mill setting and continuous even grinding rate.

CLARIFYING From the receiving tank, batches of cane juice are pumped to the primary juice heater where it is heated to about 65 to 70°C. The heated cane juice is then pumped to a reaction tank where a lime solution is added to prevent sucrose inversion by increasing the pH from 5.2 to 7.8. The lime solution is formed by adding powdered lime (calcium oxide) and water in the lime slaker.

From the reaction tank, the cane juices are heated in the secondary heaters to 100 tol 050C and are then pumped to a clarifier where the solids are allowed to settle out. The clarifier mud is collected and transported to the filters, where bagacillo (fine bagasse particles) are used as a filter medium to extract the remaining filtrate from the clarifier mud. The clarifier is cleaned out every two weeks. The remaining sludge is spread on the ground adjacent to the water treatment plant. The filter cake (dried clarifier mud) from the filters is transported to the sugar cane fields for use as a soil amendment and the filtrate is recycled back into the cane juice process. A total of 24 000 tonnes (3.77% of cane crushed) of filter cake is produced.

EVAPORA TING The clear juice from the clarifier is pumped to multiple effect evaporators where it is concentrated from about 85% water to 30-40% water. The concentrated juice is now called syrup and is pumped to the sulphitor where sulphur dioxide (SO2) gas is bubbled through the syrup. The SO2 gas, created in the sulphur burner by igniting powdered sulphur, serves three purposes:

A it acts as a disinfectant x reduces the viscosity of the slurry x bleaches the syrup

Syrup from the evaporators is treated with sulphur dioxide (SO2) gas for bleaching purposes. The SO2 is generated in a reaction vessel and bubbled through the syrup in the "sulphitor" reaction tank, reducing the pH of the syrup from 6.8 to 5.5. Excess sulphur dioxide is discharged from a tank vent to the roof. Approximately 0.3 kg of sulphur is consumed per tonne of crushed cane. On a 2500 metric tonnes of cane crushed per day (TCD) basis, approximately 750 kg of sulphur is used per day. The exhausted gas discharged from the reaction vessel is estimated to have a maximum SO2 gas concentration of 0.2% of the gas used (Kakira, 2000). Therefore, the SO2 gas

The Madhvani Group 18 0385240100-REP-VOOOI-02 Kakira Sugar Works Cogeneration Expansion Environmental Assessment VARDROP

discharged from the sulphitor vessel will be a maximum of 1.5 kg/day. There is no pollution control equipment on the sulphitor vessel.

CRYSTALLIZING After bleaching, the syrup is taken to the vacuum pans for crystallization. Molasses is then separated from the sugar in the centrifuges. The sugar is discharged to a conveyor that takes it to a dryer where the sugar is dehumidified to give dry sugar, weighed in 50- kg bags, and shipped out for sale or stocked.

The molasses is piped to a 3000 m3 outdoor aboveground storage tank adjacent to the factory and is sold directly to private customers. The molasses is dispensed from the tank to drums in the back of customers' trucks, via an overhead hose. Molasses, though not hazardous to handle or to ingest, is a very viscous material and has a high biological oxygen demand (BOD). If discharged to the environment in any significant quantity, it may have considerable environmental impact on wildlife and aquatic life. The molasses tank is of single-walled, stainless steel construction and was observed to be in fair condition (Wardrop, 2002). There is no secondary containment. To keep the molasses cool, and to prevent fermentation, water is continually sprayed on the exterior of the tank. The water spray drains to a gutter that runs along side of the tank and eventually discharges to the ground, reportedly somewhere in the bush.

3.2.2 STEAM GENERATION

BAGASSE-FIRED BOILERS KSW bums bagasse to generate steam to drive factory turbo-generators, mill turbines and turbo-pumps, and for use in sugar processing in the Boiling House. Bagasse quality (moisture and ash content) is important for boiler efficiency. Bagasse moisture in the range of 45-48% is desirable for efficient burning. It is necessary to have a continuous flow of bagasse to the boiler fumaces; therefore, bagasse storage and reclaim systems that can respond to accommodate variations in plant operations are essential.

A total of 350 000 tonnes of bagasse (38.89% of cane crushed) are produced on an annual basis. Of this, approximately 237 000 tonnes are bumed in the boilers. The remaining 113 000 tonnes (150 loads x 3 MT = 450 MT/day) of excess bagasse are transported to the cane fields for disposal.

Operation Bagasse is currently used to fuel four boilers (identified as Boiler Nos. 1 - 4) in the Kakira factory (Figure 5). Bagasse is transferred from the mill tandems to the boilers on bagasse carriers. The bagasse is gravity-fed through chutes to the boilers where it piles onto a refractory hearth. Primary and overfire combustion air flows through ports in the fumace walls; buming begins on the surface pile. Fuel oil or firewood is used for boiler start-up, or as alternative emergency sources of energy.

Boilers No. 2 and 3, installed in 1954, are the oldest boilers at KSW. Boiler No.1 (Babcock & Wilson) was installed in 1969 and Boiler No. 4 was installed in 1971. The boiler operating parameters and steam output (in tonnes per hour) are as follows:

The Madhvani Group 19 0385240100-REP-VO001-02 Kakira Sugar Works Cogeneration Expansion Environmental Assessment WJADROP

Boiler No. 1: 30 T/h Boiler No. 2: 15 T/h Boiler No. 3: 15 T/h Boiler No. 4: 30 T/h Total Current Steam Capacity 90 T/h

The steam requirement at the current operating level (3000 TCD) is 75 T/h, which is supplied by operating boilers 1 and 4 with extra steam from boilers 2 and/or 3, as required. The flue gas from the boilers is vented to the outdoors via three tall stacks. The boilers are not equipped with any pollution control equipment. Fumace ash is manually removed from the boilers and trucked to a disposal area or used in the field as a soil amendment (John Payne, 1998).

Maintenance All of the boilers have undergone various upgrades over the years. The boilers are inspected for safe operation every 12 to 14 months as per the Uganda Factory Act (1964).

COGENERA TION A schematic flow diagram of the cogeneration process is provided again as Figure 6.

Boilers for cogeneration range from 20 bar to 80 bar pressure. The ratio of power to steam generation increases with increasing pressure.

High-pressure steam is partly used to drive the Steam Turbine Drives in the sugar mill. The balance of the high-pressure steam is fed to the turbo-generators where the steam energy is converted to electrical energy. This electricity is used to drive equipment in the factory, foundry, workshop, offices and residential areas. The exhaust low-pressure steam from the turbine is then used in the sugar manufacturing process.

KSW currently has two turbogenerators:

1. Franco Tossi 3 MW rated capacity, 2.7 MW achievable output 2. Blohm and Voss 1.5 MW rated capacity, 1.2 MW achievable output

KSW also has five diesel generator sets with a combined capacity of 2500 KVA. Currently, KSW's intemal power generation is only used for intemal needs (sugar factory and some ancillary units). KSW purchases electricity form UEDCL to provide electricity for its infrastructure (housing, street lighting, sweets factory and irrigation).

The Madhvani Group 20 0385240100-REP-VO001-02 Kakira Sugar Works Cogeneration Expansion Environmental Assessmnent R:\CLIENTS A - Z\THE MADHVANI GROUP - 8524\03852401.00 - ENVIRONMENTAL ASSESSMENT\CAD\KAKIRA\0385240100-DWG-V0006-OOA.DWG 03.07.29 15:00

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NOTE: ADAPTED FROM THE MADHVANI GROUP, 2002

DWG DESCRIPTION FIGURE 6: SCHEMATIC FLOW DIAGRAM NO. DESCRIPTION DATE BY REVISIONS/ISSUE OP E n g i n e e r i n g I n c. OF THE COGENERATION PROCESS THE MADHVANI GROUP DESIGNED BY: KF |DRAWN BY: VG |DWG NO. CUENT CHECKED BY: |DATE: 03.05 .02 0385240100-DWG-VO001-00 VARDROP

3.3 PROPOSED EXPANSION

Once KSW increases cogeneration, they will provide electricity for their own infrastructure that is estimated to be in the order of 1.5 MW. This includes electric power for pumping water for the factory and housing. The expanded sugar factory and new cogeneration plant will consume another 4.4 MW. During off-peak hours, the total future KSW in-house power consumption, including irrigation, is estimated to be 8.6 MW. During peak hours, when there will be no irrigation, the estimated power requirements are 12 to 13 MW total, with 6 to 7 MW exported to UETCL (KSW, 2002).

3.3.1 FACTORY To facilitate an increase in production to 4000 TCD, a number of modifications and upgrades are required within the factory at each processing stage.

PROCESSING x A new Cameco unloader will be used to unload cane directly onto the feeder table. This process will be located between the mill yard and the machine shop. The overhead crane will be extended and possibly elevated so that the crane can discharge cane onto the feeder table. A new cane feeder table (7 m x 12 m) will be installed to transfer cane to the main cane carrier. At night, the Cameco stacker will feed stored cane directly to the main cane conveyor.

A A new shredder will be installed at the same location as the existing Unigrator. The prepared cane will drop onto a belt conveyor that will transport the prepared cane to mill No. 1. A magnet will be mounted over the belt conveyor to remove any metal that has passed through the shredder. This will protect the mill rolls from excessive tooth breakages.

MILLING x The rake-type inter-carrier will allow maceration to be applied to its maximum efficiency. A chute can be mounted on mill No. 2 to improve mill throughput. An increase in extraction is expected.

x To increase milling capacity, strained and unstrained juice pumps, water imbibition pumps and a strainer for secondary juice will be installed.

A A second milling tandem will be added in parallel with the existing milling train to accommodate the planned increase in cane throughput. The second milling tandem will be electrically or steam driven to improve the energy efficiency for the cogeneration project.

CLARIFYING x Additional juice pumps for treated and clear juice, juice screens, rotary vacuum filter, vacuum pumps and milk of lime pumps will be installed to increase the capacity of the juice treatment and clarification.

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x The heating surfaces of the juice heaters as well as the clear juice heater will be increased to increase the capacity.

x A new load cell type 250 tonne/hour juice weighing scale has been installed and was operated during the 2002/2003 crop season. This scale replaces the former 150 tonne/hour scale, increasing the volume of juice weighed and improving the reliability for chemical control.

x A filtrate clarifier (designed locally) has been installed and was operated during the 2002/2003 crop season. This will reduce the load on the existing tray clarifier. A new trayless clarifier of SRI type has been installed and commissioned in January 2003. This new clarifier will be used in lieu of the old tray type clarifier to improve juice quality and to reduce sucrose losses through inversion. The new trayless clarifier will have a retention time of approximately 30 minutes compared to over 2 hours for the old clarifier. The old clarifier will be left in place and be a standby unit for emergency.

A rotary vacuum filter will be added to take care of the increase in mud loading from the increased grinding rate. The mud flow from the mud mixer to the filters will be automatically controlled by monitoring the mud level in the filter mud trough.

EVAPORA TING

X The evaporator station will be converted from quadruple to quintuple effect, and will be automated to ensure steam efficiencies are increased and steam economy is achieved.

CRYSTALLIZING X A new 100 Vhr sulphur bumer was installed for the 2002/2003 crop season. This new unit will improve the sulphitation process, thus resulting in a reduction in sulfur consumption and S02 emissions.

x A syrup floatation clarifier was installed to reduce the turbidity of the syrup. The removal of suspended solids will reduce the syrup viscosity that in tum will improve the pan boiling process.

x To increase plant capacity, low grade Vacuum Pan #8 has been installed and commissioned during the 2002/2003 crop season. Pan Nos. 1 and 2 have also been modified to improve the heating surface volume ratio to improve pan boiling speed.

x The existing cooling water pond will be extended to accommodate the additional water to be processed as a result of the additional vacuum pans. An estimated 20% increase in water volume is expected, although this is all recirculated.

x Belt conveyors will be installed to allow for automation of the bagging and final conveying operations. This will improve the accuracy and control of the system.

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3.3.2 CO-GENERATION The proposed new power generation arrangement is provided as Figure 7.

A continuous flow of bagasse feed to the boilers must be established. To ensure maximum boiler load and to off-set periods of factory stoppages due to mechanical breakdown and reduced cane supply, it is important to have a good bagasse storage and reclaim system. KSW therefore proposes to install additional bagasse handling equipment including new belt type drives for bagasse carriers 1, 2 and 4. Bagasse conveyors for the new boiler facility and the new bagasse house will be belt type. The drag slat type recycled bagasse and feed conveyors to the existing boilers and existing bagasse reclaim house will be retained.

KSW proposes to construct a bagasse storage/reclaim house with a one-day storage capacity. Any excess bagasse beyond the one-day storage quantum would be transferred to an outside storage yard (approximately 1000 T) and retrieved when required.

With the expansion to 4000 TCD, the factory's steam requirement would increase to 95 T/h. An additional 50 T/h steam is required for the cogeneration plant. The total steam requirement is 145 T/h. To produce the additional steam generation capacity the following activities are proposed:

x Refurbish Boilers 2 and 3 to increase steam generation from 15 T/h to 19 T/h l Install two low-pressure Breda boilers (50 T/h at 20 bar) currently available at Kakira.

Proposed steam capacity:

Boiler No. 1 30 T/h Boiler No. 2 19 T/h Boiler No. 3 19 T/h Boiler No. 4 30 T/h Breda Boiler No. 1 50 T/h Breda Boiler No. 2 50 T/h Total Steam Capacity 198 T/h

KSW proposes to add a new 14-15 MW Extraction-condensing turbo-generator. With this type of turbine, only the quantity of steam required for the process is extracted at 1 bar. The balance of the steam continues to flow through the turbine to generate more electric power. The exhaust steam is transferred to the condenser unit from the turbine and the condensed water obtained from this steam is recycled as boiler feed-water. This equipment would have a marginal extra capacity to produce additional power if greater demand occurs and adequate bagasse is available.

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NO. DESCRIPITON IDATE IBy IPO FIGURE 7: PROPOSED NEW EAD kC' ANT REOVISIONS SSUE D ATE Engineering Inc. POWER GENERATION ARRANGEMENT THE MADHVANI GROUP DESIGNED BY KF DRAWN BY VG IDWG NO UARDROP

The new cogeneration plant will operate in two modes during the 305-day crushing season (mid-June to mid-April):

x Off-peak Hours (18 hours per day) 0 210 days, 8.6 MW required for infrastructure, factory, cogeneration plant and irrigation w 95 days, 5.9 MW required for infrastructure, factory, and the cogeneration plant, without irrigation

X Peak Hours (6 hours per day) Boiler steam output will be increased to generate 12 to 13 MW, 6 to 7 MW of electric power to be sold to UETCL.

During the off-season, stored excess bagasse will be used to generate 2.5 MW of power for intemal use only.

Installations of piping, cabling, electrical equipment, instrumentation and control systems are necessary civil works. The entire operation of the factory as well as the turbine and condenser system will be operated through an integrated Distributed Control System from a central control room.

The proposed cogeneration plant will consist of two Breda boilers in addition to the four existing boilers. The Breda boilers are equipped with a dry ash collection system. The remaining fly ash will be scrubbed through a full wet scrubber. The fly ash will be sent to a clarifier where grit will be separated and mixed with the filter cake for disposal to the cane field. The water from the clarifier will be sent to a retention pond and then eventually overflow to the Kiko stream.

ELECTRICAL SUB-STATION AT KAKIRA KSW will construct a new 10 MVA electrical substation at Kakira. The substation will be constructed with one 10 MVA 33 kV transformer. The new substation will require a fenced area of approximately 900 m2 (30 m x 30 m). The substation will be located adjacent to the foundry and, as a result, its construction and operations will not affect any vegetation, animal habitat or human settlements. The details of the electrical installations required will be determined after detailed design of the project, but will likely include synchronization to the grid scheme, grounding and grid isolation. A small concrete building will be required to house the metering instruments. Typically this will be locked and only be opened by the Utility company to obtain the monthly meter reading.

33Kv DISTRIBUTION LINE KSW will install a new distribution line to connect the new Kakira sub-station to the Uganda Electricity Distribution Company Limited (UEDCL) Jinja Industrial Substation at Mailombili. This line comprises:

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x An overhead uninsulated All-Aluminum Alloy Conductor (AAAC) line from Kakira to Wairaka / Bugembe. The total length of this line is approximately 10 km, and it is proposed to be constructed on land owned by KSW.

x An underground 3-core XLP insulated cable laid on the existing 10 m wide UEDCL Right of Way (ROW) from Wairaka to Mailombili. The total length of this portion of the distribution line is approximately 4 km.

Given the risk of theft of non-electrified cables, KSW will start constructing the proposed line only 3-6 months prior to commissioning of the new cogeneration plant that is scheduled for June 2005. It would hence be appropriate to carry out the New Distribution Line route shortly before the construction of the line to ensure that the most current situation on the ground is assessed.

An environmental assessment of the transmission line will be conducted at a later date. No construction on the transmission line will occur until the assessment, including a resettlement plan, if required, has been cleared and disclosed by the World Bank.

3.4 PROJECT ACTIVITIES - PRECONSTRUCTION, CONSTRUCTION, O&M

3.4.1 PRECONSTRUCTION PHASE Activities that occur under the current factory operations include:

Sugar Processing Cogeneration * Transporting cane to factory * Conveying bagasse to boilers * Transferring cane to cane carrier * Boiler start-up (fuel oil or wood) * Preparing / shredding cane 0 Burning bagasse / generating steam * Milling cane * Venting flue gas outdoors (stacks) * Clarifying cane juice (heat, liming, filtering * Removing fumace ash (manually) mud) * Maintaining boilers * Removing mud * Using high pressure steam to drive * Evaporating juice Steam Turbine Drives in mill * Sulphitating Syrup * Using high pressure steam to generate * Crystallizing in vacuum pans power in turbo-generators * Separating molasses * Using low pressure exhaust steam from * Generating waste water turbine in sugar process * Generating air emissions * Using diesel generators

* Generating wastewater * Generating air emissions * Pumping water

Additional activities that will occur during the preconstruction phase of the project include the following:

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x Design x Construction documentation x Contract administration Permits Tendering x Surveying site Inventorying

3.4.2 CONSTRUCTION PHASE The construction phase comprises general activities, the factory expansion, cogeneration expansion, power line and substation. Activities for each of these components are listed below.

GENERAL CONSTRUCTION ACTIVITIES x Designing x Surveying site x Inventorying x Mobilizing / demobilizing x Fencing x Removing hazardous materials x Drilling / digging . Driving piles x Excavating soil x Trenching/servicing x Backfilling soil x Pouring concrete x Using heavy equipment and vehicles x Loading and unloading materials x Separating building materials x Hauling building materials x Stockpiling materials x Storing fuel and hazardous materials x Removing equipment x Installing new equipment x Finishing interior/exterior

FACTORY EXPANSION x Installing equipment for sugar processing (pumps, conveyors, etc.) x Emitting gasses x Releasing effluents x Disposing solid waste

COGENERA TION

x Construct new bagasse storage house x Refurbish existing boilers x Install Breda boilers x Installing extraction-condensing turbo-generator x Installing wet scrubber x Emitting gasses x Disposing solid waste

SUBSTATION x Installing piping and cabling x Installing electrical equipment, instrumentation and control systems x Installing 10 MVA transformer

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3.4.3 OPERATION AND MAINTENANCE

x Cleaning/maintaining buildings . Releasing effluents lx Emitting gasses x Buming bagasse lx Operating turbogenerators x Operating mill turbines x Operating turbo-pumps x Feeding bagasse to boilers l Storing bagasse x Reclaiming bagasse l Extracting high pressure steam for power generation

3.5 SCHEDULE

KSW proposes to complete and commission the project by June 2005. KSW estimates that 1.07 million tonnes of cane will be available in 2004-2005, which equates to enough bagasse to generate at least 5 MW during peak hours. In 2005-2006, 1.12 million tonnes of cane will be available, which will provide enough bagasse to generate at least 6 MW during peak hours.

The final schedule will be determined upon completion of detailed project design.

3.6 STAFFING AND SUPPORT FACILITIES

The facility will require an additional 60 people for the operations. However, following restructuring and automation of some of the processes after the expansion of the sugar factory, these staff will be relocated to the cogeneration facility from other factory processes. Therefore, it is unlikely that the project will result in employing more people.

3.7 OFF-SITE INVESTMENTS

No additional off-site investments will be required as a result of this project.

3.8 LIFE-SPAN AND EXPECTED FUTURE GROWTH

At present, KSW is not planning to export more than the 6 to 7 MW of power currently proposed. However, the system as proposed would accommodate an increase in generation of up to 9 to 10 MW without significant additional capital investment.

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Legend . District Boundary --- County Boundary Sub-County Boundary Parish Boundary All Weather Road, Bound Surface -All Weather Road, Loose Surface Dry Weather Road -+-i-4Railway Line Motorable Tracks

- Main, Permanent River Small, Permanent River Contours Broadleaved Tree Plantation or Woodlot Coniferous Plantation w Tropical High Forest (Fully Stocked) Tropical High Forest (Degraded / Encroached) Woodland Bushland Grassland Wetland Small-Scale (Non-Uniform) Farmland Uniform or Large-Scale Farmland The Madhvani Group Built-Up Area K8Uonetess Map Description OpenWater ~~~~~~~~~~~KakiraSugar Works Impediments ca) ~~~~Land Cover Map (e.g. Bare Rock, Barren Soil) asSt Figure 8 AUTHOR JiL |Pmwct#038524401-Map Number ARDROP

4.0 BASELINE DATA

4.1 ENVIRONMENTAL OVERVIEW

4.1. 1 SITE DESCRIPTION The Kakira property covers about 22,500 acres (9000 hectares) of land, 19,000 acres of which are used for sugar cane cultivation. The remainder of the property is occupied by manufacturing operations, namely a sugar processing and packaging factory, a sweets factory and a soap and oil factory. Supporting infrastructure including administrative buildings, an airstrip, living quarters, schools, hospital, stores and a 500 km road network, is also present.

4.1.2 LAND USE Kakira Sugar Works neighbours with Polota Trading centre to the west, and with Lake Victoria to the south (Figure 8). To the north it is adjacent to Butamira Forest reserve and traversed by River Chico and to the east is Magamaga trading centre, Magamaga - barracks and hill ranges. The terrain of the area is generally flat with undulating hilltops that are generally spread all over the entire plantation estate.

4.2 PHYSICAL ENVIRONMENT

4.2.1 LOCATION / SETTING Lake Victoria borders the property to the south, and agricultural land to the north, east and west. The community of Polota, Mwiri Hill, and a swamp area known as Mutai forest swamp, are also located to the west.

The surface topography in the Kakira area comprises relatively flat terrain with hilly areas surrounding the property boundary. The estate is on a generally undulating plain. Slopes are between 2 to 12% with the steepest land on the midslopes. The general surface slopes from 1200 m in the south near Lake Victoria to 1150 m in the north. Small prominent hills with slopes up to 30% are interspersed on the plain. The relative relief of the plain is 40 to 60 m.

4.2.2 DRAINAGE The factory is located on a slope with the cane yard at the highest elevation and the process and boiler areas on the lowest end of the site. There are two principal drains at the site. The first drain is a storm water and factory drain located on west side of the sugar store, the process house outflow joins this. The second drain services the cane yard area and powerhouse. The two systems combine into a single drain just below the

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spray pond and join Mugala Stream, a natural water drainage system. Currently, all wastewater is discharged untreated into the Kiko River via the Mugala Stream.

4.3 BIOPHYSICAL ENVIRONMENT

4.3.1 CLIMATE The climate in the region is described as tropical. Altitude (1157 m) and Lake Victora moderate temperatures, with an annual average maximum of 280C and a minimum of 18°C. The Jinja District has two dry seasons (December to March and June to August) and two rainy seasons (March to May and September to December).

4.3.2 AIR QUALITY As part of an atmospheric sampling program to determine temporal and spatial trends of pesticides in air and precipitation in the Northem Lake Victoria watershed, a sampling site was established at Kakira in November 1999. Results collected from November 1999 to March 2000 reveal the presence of chlorinated compounds such as DDT and its insecticidally active isomers, Dieldrin, lindane (g-HCH), chlordane, and heptachlor. Preliminary analyses of the data indicate that the presence of these compounds are likely due to regional depositions rather than local use. Analysis to determine the presence of other compounds is underway. (http://Www.lvemp.org/L Publications/Uaanda/newsletter"/o2Oiun%202002.htm).

KSW does not use any insecticides for cane cultivation. Air emission sources and pollutants generated by Kakira operations are summarized in Table 4.

Table 4

Air Emission Sources at Kakira Source Pollutants

Bagasse-fired boilers Particulate, C02, NO, Wood-fired boilers (start-up only) Particulate, CO, CO2, NO., SO., organics Back-up diesel generators Diesel exhaust: Particulate, CO, C02, NO, SOX, organics, metals (trace) Welding Metals (e.g. cadmium, cobalt, copper, chromium, manganese, nickel, lead, zinc), particulate, NO,, CO Cane buming Particulate, NO, CO, C02 Bagasse buming Particulate, NO,, C02 Foundry furmaces (waste oil- Exhaust: Particulate, CO, C02, NO., SO., organics fired/diesel) Sulphitor (tank vent) Sulphur dioxide Sugar dryer Particulate Tippers and Lorries driving on Particulate (from road dust and uncovered loads of unpaved roads bagasse or ash) Storage piles and outdoor conveyor Particulate (bagasse and ash) belts

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BOILER EMISSION RATE ESTIMATES The most significant pollutant emitted by bagasse-fired boilers is particulate matter, caused by the turbulent movement of combustion gases with respect to the burning bagasse and resultant ash.

Under normal operating conditions, the significant product of combustion of the bagasse is carbon dioxide (CO2), with lesser amounts of nitrogen oxides (NO,) and negligible quantities of polycyclic organic matter. Emissions of sulfur dioxide (SO2) from the boilers are also considered negligible, owing to the characteristically low levels of sulfur associated with bagasse.

Pollutant emission rates from the boilers under future operating conditions, where the bagasse feed rate will be increased by 100%, are summarized in Table 5. The emission rates were calculated based on emission factors from the US EPA Publication AP-42, 5th Edition, Volume 1 Chapter 1.8 Bagasse Combustion in Sugar Mills (US EPA, 1996) (Appendix B). The emission rates that have been calculated assume normal boiler operabon and a bagasse moisture content of approximately 50% by weight.

Table 5

Boiler Emissions Source Summary - Future Operation*** Emission Pollutant CAS No. Emission Emission Factor Source Rate (g/s)* Quality Rating" Boiler No. 1 C0 2 124-38-9 6,933 A NO, 10102-44-0 5.3 C Particulates N/A 139 C Boiler Nos. 2 & 3 C02 124-38-9 7,800 A NO, 10102-44-0 6 C Particulates N/A 156 C Boiler No. 4 C02 124-38-9 6,933 A NO. 10102-44-0 5.3 C Particulates N/A 139 C 'See Appendix B for sample calculation of emission rates ** Ref: US EPA AP-42 Table 1.8-1 **Assumes the bagasse feed rate increases by 100%.

There are no Ugandan emission standards to which to compare the above estimated rates. Note that the boilers use old technology and as such the existing combustion conditions may result in significant emissions of carbon monoxide (CO), unbumed organics (VOCs) and total organic compounds (TOCs). These have not been estimated because emission factors for these parameters are not available.

A screening level assessment of air emissions from the three bagasse boiler stacks was conducted using the US EPA SCREEN3 model. The model input parameters, sample calculations and dispersion modelling results are provided in Appendix B.

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The SCREEN3 model results are given as ground level concentrations using a 1-hour averaging time. The 1-hour concentrations were converted to 8-hour and 24-hour averaging times by multiplying US EPA factors. The modelling results expressed in terms of 1 hour, 8 hour and 24-hour averaging times are summarised in Appendix B. The 24-hour ground level pollutant concentrations are presented as a function of distance from the source in Appendix B.

Carbon Dioxide The dispersion modelling results indicate that the 24-hour maximum concentrations of carbon dioxide, nitrous oxides and nitrogen dioxide, when the operations are increased by 100%, are 130 000 ptg/M 3, 100 pg/M3 and 70 pg/M3 respectively. This would occur at 183 m from the source.

Carbon dioxide emissions contribute to the global warming effect. Uganda has not committed to any intemational protocols for greenhouse gas reductions (e.g. Kyoto protocol).

Nitrogen Oxides The dispersion modelling results indicate that the 24-hour maximum concentrations of nitrous oxides and nitrogen dioxide will be 100 p,g/M 3 and 70 pg/M3 respectively, occurring 183 m from the source, when facility operations are increased by 100%.

Nitrous oxides and nitrogen dioxides are precursors of acid rain, which affects forests and vegetation. Our results indicate acceptable levels of these pollutants compared to Uganda and international guidelines.

Other sources of carbon dioxide and nitrous oxides (including nitrogen dioxide), not included in the above, are: diesel generators, foundry fumaces, cane and bagasse buming in the fields, and wood firing of the boilers during start up.

Boiler Particulate Emissions The dispersion modelling results indicate that the 24-hour maximum concentrations of particulates would be 2,600 1pg/M 3, occurring 183 m from the source.

Comparing the particulate results to the 24-hour ambient standard of 300 pg/M3 published in the Proposed Environmental Air Quality Standards for Uganda (February 2002), we find that particulate concentrations may exceed this value for up to 10 km from the stack base. As shown in Appendix B, these concentrations also exceed other intemational standards (e.g. US NAAQS 100 pg/M 3; Equador 80 pLg/M 3).

Pollutant concentrations decrease as one moves away from the source. At the closest Kakira property line (650 m from the source), 24-hour ground level concentrations of particulate are 870 pg/M 3. Thus Kakira employees and the public, or anyone who lives within a 10 km radius of the factory may experience health effects from particulates from the boilers. Please note that these concentrations are based on conservative assumptions and literature values and represent a 'worst-case" scenario. The actual

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concentrations may be much lower. As evidence to this, the Kakira hospital has not received any related health complaints in the past.

Those communities further away may not experience health effects. It is noted that communities such as the one on top of Mwiri hill (157 m above the factory level), may experience concentrations almost double those at ground level, due to the impact of the hill on plume behaviour.

Although the SCREEN3 model incorporates many conservative assumptions, these are estimated results employing emission factors that assume normal boiler operation. These results do not account for operational upsets as may occur at Kakira given that the boilers use older technology.

There are a number of combustion sources that emit particulate matter at Kakira that have not been estimated quantitatively. These include the diesel generators, foundry fumaces, and emissions during boiler start-up using wood. Their sources are considered minor, in comparison to boiler emissions.

Fugitive Dust There are a number of significant sources of fugitive dust emissions from Kakira. These include other fugitive sources such as trucks driving on unpaved roads, outdoor conveyors or chutes, or from holes in galvanized pipes that convey bagasse or bagacillo, and storage piles.

Sulphur Dioxide

Syrup from the evaporators is treated with sulphur dioxide (SO2 ) gas for bleaching purposes. The S02 is generated in a reaction vessel and bubbled through the syrup in the 'sulphitor" reaction tank, reducing the pH of the syrup from 6.8 to 5.5. Excess sulphur dioxide is discharged from a tank vent to the roof. Approximately 0.3 kg of sulphur is consumed per tonne of crushed cane. On a 2500 TCD basis, approximately 750 kg of sulphur is used per day. The exhausted gas discharged from the reaction vessel is estimated to have a maximum SO2 gas concentration of 0.2% of the gas used. Therefore the SO2 gas discharged from the sulphitor vessel will be a maximum of 1.5 kg/day. There is no pollution control equipment on the sulphitor vessel.

Combustion sources such as diesel generators and wood fired boilers (start-up) will emit additional amounts of sulphur dioxide.

4.3.3 NOISE KSW has been monitoring noise levels within and around the sugar factory including the existing cogeneration system. Results obtained from the monitoring exercise on a bimonthly basis from December 2002 to February 2003 by the SHE division of KSW are indicated in Table 6. Except for a few locations like the electrical workshop, the offices and laboratories, the noise levels are higher than the World Bank noise standards for cane mills.

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Table 6

Bi-monthly Noise Monitoring Results

Section Noise Levels (dBA) Current World Uganda Bank Standard Standard (dBA) for Cane Mills December January February 2002 2003 2003 Lab/Offices 66 63 67 66 65 65 85 70 Mill 86 88 87 87 85 88 85 70 Evaporator 80 82 82 84 86 85 85 70 Clarification 83 80 81 83 83 84 85 70 Pan floor 83 81 81 82 83 82 85 70 Centrifugal 81 84 84 84 85 88 85 70 Bagging 76 79 77 77 75 73 85 70 Power house 77 77 78 78 76 77 85 70 control room I Turbo generator 92 94 94 91 89 87 85 70 area Diesel generator 98 98 98 100 83 80 85 70 room Boiler area 86 89 91 89 90 91 85 70 Mechanical 77 82 78 80 80 77 85 70 workshop Electrical 66 70 69 72 70 70 85 70 workshop I_I Foundry 70 85 87 84 89 84 85 70 Factory 63 60 80 82 62 62 75 70 compound (front) Factory 80 78 78 79 85 84 75 70 compound (rear) I I I Notes: Vaues in Bold Italics exceed the World Bank standard.

The noise monitoring was targeted at areas that receive hissing noise from steam and operations of the cogeneration area. It is expected that noise generated from the new boilers of the proposed project will be lower and in general the project will result in less noise levels from the cogeneration project.

4.3.4 BEDROCK AND SURFICIAL GEOLOGY The Jinja District is underlain by Precambrian bedrock. Kakira falls within the Buganda- Toro system which is characterized by partly granitized and metamorphosed formations comprising Argillite and basal quartzite and amphibolies (NEMA, 1996).

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4.3.5 SOILS The regional stratigraphy of this part of Uganda generally comprises Nitisolic (Ferrisolic) soils comprising primarily porous, red clay. NEMA rates this type of soil as the most fertile and productive soil in Uganda. Based on a borehole log obtained from DWD, these clay soils overly a sand unit that is underlain by a 27 m thick rubble zone (Wardrop, 2003). The bedrock, comprising Phyllite, is encountered at approximately 90 m below grade.

x Valley bottoms - moderately drained and imperfectly drained soils dominated by heavy gleyed or mottled clays, developed on recent alluvial deposits

a Cultivated soils - mainly occurs on rhodic ferralsols

4.3.6 HYDROGEOLOGY The Jinja area is considered to have low groundwater potential because of the fine- grained overburden and the resulting decrease in surface water infiltration. The borehole log obtained from the Kakira area indicates water tables at a depth of 51 m (overburden) and 69 m (bedrock) below grade; however, given the clay soil conditions, perched shallow water tables are suspected.

4.3.7 HYDROLOGY The southem extent of the Kakira property is approximately 500 m north of Fielding Bay of Lake Victoria. Chico (also referred to as Kiko), and Muwala (referred to as Mugala in Kakira's Waste Discharge Permit Application) rivers both flow through the property (Figure 1). Water from Lake Victoria is used for irrigation purposes at Kakira.

CHICO RIVER TRIBUTARY (MUWALA STREAM) The Muwala Stream is used as a source of drinking water. Sampling conducted as part of an environmental audit in 2002 indicates that this stream, except for the bacteriological quality, meets the drinking water standards. Relatively high values of total coliforms (1,700 no./100ml), faecal coliforms (573 no./100ml) and faecal streptococci (2,060 no./ 00ml) imply faecal pollution of this stream. Based on the faecal coliform and faecal streptococci ratio (0.28 < 0.4), the likely source of this pollution is animal wastes and stormwater. In addition, during sampling, a man was observed bathing in the stream, while a woman was washing clothes in the streams' waters. Therefore microbiological contamination may also be caused from these activities. This is a cause for concern in view of the fact that most likely the communities residing adjacent to this stream use these waters for domestic purposes including drinking water.

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Table 7

Drinking Water Quality Results Mugala Drinking water lParameter Stream standards Temperature (0C) 26.2 NS pH 6.86 6.5-8.5 EC 461 NS Apparent colour (Ptco) 54 10 True colour (Ptco) 23 10 Turbidity (FAUs) 14 5 DO (mg/l) 5.1 NS TSS (mg/1) 8 50 TDS (mg/l) 324 < 1,000 Nitrates (mg/I) 2.2 45 Total coliforms 1700 50 (no/1 Oml) Faecal coliforms 573 0 (no/1 OOml) Faecal streptoccoci 2060 NS (no/1 OOml) NS = no standard Values in Bold are in excess of the Uganda Standard Specification for Drinking (Potable) Water, February 1994

4.4 BIOLOGICAL ENVIRONMENT

4.4.1 TERRESTRIAL HABITAT The Kakira estate falls into Albizzia chlorophora, semi-deciduous forest vegetation zone. However, the lands in the vicinity of the Kakira estate were cleared for agricultural production almost a century ago leaving only small remnants of relatively natural woodlands with limited ecological function or value and virtually no linkages with other biological features.

During the August 2000 site visit, several Forest Reserves were inspected, including Butamira, Masiga, Namazingiri, and Namafuma. All have been essentially cleared years ago, and now consist of plantations dominated by eucalyptus and/or pine. All Forest Reserves examined in August have areas that are or have been inter-planted with food crops. While this practice serves a social good, it contributes nothing to the ecological value of the forest features.

AGRICUL TURE The Jinja District has a high potential for agriculture due to favourable soils and weather conditions. The main crops cultivated include maize, beans, groundnuts, coffee,

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bananas, sugar cane, sweet potatoes, vegetables and fruits (NEMA, 1996). Crops are grown on both a subsistence and commercial level.

WOODLANDS A small forested area is located within the Chico division of the Kakira property, while developed woodlands follow the main loose-surfaced all weather roads running north and west from the sugar factory.

Butamira Forest Reserve The Butamira Forest Reserve is located in Buyengo sub-county, Jinja District, and it is situated immediately north of the main KSW estate. It is approximately 14 km2 in size. Prior to 1930, it was a natural forest owned by the Busoga Local Government. In 1930, it was gazetted as a Local Forest Reserve, and in 1949, it was leased by the Govemment to Muljibhai Madhvani & Company Limited (MMCL) for a period of 49 years. The terms of the lease required MMCL to clear the natural forest and to replant the lands with eucalyptus at a rate of 400 acres each year for the first 7 years. The eucalyptus trees were subsequently used as a source of fuel for the KSW sugar factory.

The conditions of the permit include, among other items, the preservation of uncultivated strips of land along the streams and rivers in the Reserve to protect against silting and protection of hilltops against erosion and land degradation.

With the expulsion of the Asian community from Uganda in 1971/1972, along with other properties of the Madhvani Group, a widespread deforestation of the Butamira Area occured. In 1985, when the present management re-possessed the Kakira Sugar Complex (now operated under the name of Kakria Sugar Works (1985) Ltd.), it also took charge of the Butamira Area for rehabilitation and development.

As of a August 2000 site visit by Wardrop, more than 700 ha of the Forest Reserve were "cleared" or "under stump", virtually all of which will be planted with cane before the end of 2003.

The NEMA has also reviewed KSW's development plans and has agreed that growing of sugarcane will not have any negative impact of the local environment. Subsequently, Permit No. 00015 dated July 5, 2002, was issued to KSW for cane cultivation in the Butamira Area. A copy of this permit is provided in Appendix C.

WETLANDS There are virtually no wetlands within the nucleus KSW estate. If any existed before establishment of the sugar-production facility, they have long since been displaced by cane field. As such, wetlands are not an issue on the main KSW lands.

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4.4.2 TERRESTRIAL BIOTA

BIRDS A number of birds are known to occur within the Jinja district (NEMA, 1996). These include:

A White-necked Cormorant x African Darter x Black headed Heron x Hamorkop A Hadada Ibis x African Hobby x Bat Hawk x Eastem Grey plantain eater x Brown Parrot x Pied Kingfisher x Woodland Kingfisher x Striped Kingfisher x Grey headed Kingfisher x Double-toothed Barbet x Little swift

Birds may potentially be affected by the cogeneration project due to potential increases in noise generation and due to power line construction

FISH The district's main water bodies, Lake Victoria and River Nile are habitat for a variety of wildlife, of which fish is major. Lake Victoria supports high diversity of fish species. The non-cichlids alone numbered about 50. Of these about 10 are commercially important. These included Bagrus docmac (Semutundu), Claria gariepinus, Protopterius gethiopicus (Mamba), Labeo victorianus (Ningu), Synodontis afrofischeri (Nkolongo), Barbus alrianalio (Kisinja), Mormyrus kannume (Nzere). These species are important locally.

Other species present in the water bodies of the district include: B. docmac, P. aethiopicus, C. gariepinus, Clarias liocephalus, S. agrofichari, M. kanumme, A. Iestesjacksonii (Nsoga), Garra johnstonii, Gnathonemus victoriae, G. Iongibarbis, Xeno clarias spp., L. victorianus, B. altinalis, S. intermedius, and Afromastace.

SMALL MAMMALS A number of small mammals are known to occur in the Jinja district. These include fruit bats (Megachiroptera), insect eating bats (Microchiroptera), rodents, shrews, Civet cats, bats, ground squirrels (Xerus erythropus), and monkeys (Vervet and Colobus badius).

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ENDANGERED AND PROTECTED SPECIES There are no endangered species within the project area. Wetland and forested areas are considered as protected habitat in Uganda; however, these types of habitats do not fall within the project area.

4.5 SOCIO-CULTURAL ENVIRONMENT

The KSW facility, which directly occupies about 9000 hectares of land, now employs over 6,000 workers. In addition, there are about 3,600 "outgrowers", with individual land holdings ranging from about 2 hectares to several hundred hectares (average of 2.5 hectares), which also supply cane under contract to the KSW mill. All outgrowers are located within a 25 km radius of the plant, which has a present sugar-cane crushing capacity of about 3000 tonnes per day (TCD).

4.5.1 LAND AND RESOURCE USE The land in the area is mainly used for cane cultivation.

4.5.2 DEMOGRAPHIC CHARACTERISTICS OF THE AREA The social organization of the area is based on the kinship system, patrilineal line Women in the area account for an important proportion of the labour force required. Majority of residents belong to the poor peasant category who own small land parcels (one or two acres).

4.5.3 ECONOMIC CONDITION KSW has seen a steady growth of employment since 1985. Currently 6,500 people work within the estate, with 600 in the factory and the rest in agriculture and administration, including personnel, schools, hospitals, financing and security, etc. Infrastructure expenditures include housing, roads, transport, electric supply, water treatment and distribution, communication, hospital, education

Commercialization of the various crops is having a positive impact on residents (cash for crops).

4.5.4 INFRASTRUCTURE

UTILITIES Approximately 85% of the power at the Kakira property is supplied by the on-site cogeneration operations. The Uganda ElectricityDistribution Company Ltd. (UEDCL) supplies the remaining 15%.

KSW has invested capital in infrastructure such as housing for employees, roads, transportation, electricity supply, water treatment, modem communications, and hospital and schools.

The Madhvani Group 42 0385240100-REP-VO001-02 Kakira Sugar Works Cogeneration Expansion EnvironmentalAssessment VARDROP

5.0 SIGNIFICANT ENVIRONMENTAL AND SOCIAL IMPACTS

An interaction matrix identifying and assessing the interactions of project activities with environmental and socioeconomic components is presented in Table 8. Project activities with interactions on environmental components that could lead to potential environment effects were denoted with a closed circle in the matrix.

5.1 BIOPHYSICAL EFFECTS

Descriptions and assessments of the identified potential environmental effects of the proposed project are provided in the following sections. Summaries of the results of the assessment are provided in Table 9. The results of the residual effects assessment are detailed in Table 10.

5.1.1 AIR QUALITY, CLIMATE AND METEOROLOGY

INCREASED NOISE GENERATION DUE TO CONSTRUCTION OF EXPANDED COGENERATION FACILITY Expansion activities are expected to occur over a ten-month period. These activities will increase ambient noise levels, resulting in decreased air quality, or noise pollution. Ambient noise levels surrounding the Kakira site are within the 85-dB guideline value (based on noise monitoring values with the factory compound front and rear). The closest residential housing is located approximately 1000 m from the factory.

A number of types of equipment will be used on-site during expansion activities, including trucks, bulldozers, graders, front-end loaders, pneumatic drills, and dump trucks. Noise levels may increase up to 130 dB due to the use of heavy equipment (NCLHH, 1999). Estimates of typical noise emissions from vehicles and equipment expected to be used during this project are provided in Table 1la.

The World Health Organization has published methodology to estimate cumulative noise levels as sound pressure (dBA) (WHO, 1995). Noise levels as sound pressure, dBA, differs from sound strength measured as decibels (dB), which is a measure of sound amplitude. dBA, takes into account the varying sensitivity of human hearing or sound at different frequencies (Saflex Acoustical Guide, 2000). Sound pressure levels are not additive; the mean square of the pressures are added and then reconverted to sound- pressure-level values. If there are any differences in the sound levels from two sources, the combined level will exceed the higher of the two levels, but always by less than 3 dBA (Table 11 b).

The Madhvani Group 43 0385240100-REP-VOOOI-02 KakIa Sugar Works Cogeneration Expansion Environmental Assessrnent Current operation

Table 8 Environmental Component Interaction Matrix Kakira Sugar Works -Bagasse Cogeneration Expansion

Project Components

Current Operation and Maintenance Activities

Sugarcanefactry * " * * I* I I* I * _ Cogeneration

ECE~

E s'~ ~ ~ ~ ~~~

0 ~~~~ ~ ~ a a e ~~~~~ ~~ Environmental Componeints E 8 e a ~~[o5 0= a.' ~~~~1- Ea 0. E ~ 8= >!~ c A 050 f E ~~ ~ ~ o 0 - o EE. 0

Biophysical Components

Clim6Uate&Mete_oloy _ _ ._.._

Topography .fo B_edrock Soilt- Groundwater Surfaceiwalter-- yegelation - natural - - - Vegetation -agrcultural 0 -- Vegetation -rare or endangered species- mammals Birds Fish_andkAquatic- lnvertebrates Sensitive Habitats (parks,peevs t. -- Commercially important species _0_ Nuisance species, vectors, dangerous____

Soclo-cuftural Components Population Demographics 0 ] -- -- - Land/resource use0 30 Planned Development Activities- Community Structure, Employment0 ____ Distribution of Income. Goods, Services Recreation Public Heal-th-&Sa-fty ~ 0 CulturalProperties Tribal People

Customs, Aspirations. Attitudes - -- …

Legend: Ql denotes interactions wvithno resulting change in baseline conditions * denotes potential adverse effect o denotes potential positive effects

Page 44 -_ -_d 1 PP- _TT T

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l058i 000 0 IWDROP

Table 9 Environmental Effects Analysis Summary Kakira Sugar Works Proposed Cogeneration Expansion Project

Potential Effect Mitigation Measure Residual Effect Follow-up Significant?

Air Quality, Climate and Meteorology

Increased noise during construction and * Control the timing of noise to least Low Daily noise monitoring No operation of expanded cogeneration disruptive periods, as practicable. during construction. facility. * Monitor noise levels as required. Implement further noise restrictions where the noise level exceeds ambient levels of 85 dB by more than 20 dB. * Minimize idling of vehicles and/or equipment. * Maintain noise levels below 85 dBA or provide hearing protection.

Increased emissions (SO2; NO,, CO, * Kakira will ensure that vehicles and Low Daily monitoring of No CO2, and particulates) from combustion equipment are inspected and maintained. construction crew. of fossil fuels during construction. * Vehicles and equipment will not be left idling when not in use. * No ozone depleting substances will be used or generated from equipment during construction.

Increased emissions (SO2, NO,, GO, * Equip boilers with dry-ash collection Moderate Air monitoring No CO2, and particulates) during operation system and full wet scrubber to reduce the of expanded facility amount of ash released into the environment.

The Madhvani Group 46 0385240100-REP-VO001-02 Kakira Sugar Works Cogeneration Expansion Environmental Assessment UMRDROP

Table 9 (cont'd) Environmental Effects Analysis Summary Kakira Sugar Works Proposed Cogeneration Expansion Project

Potential Effect Mitigation Measure Residual Effect Follow-up Significant?

Increased dust generation during cane * Develop a bagasse handling management Low Ensure bagasse No and bagasse handling, processing and plan to manage supply and demand and management system is storage ensure bagasse quality. developed and * Repair leakages in bagasse and bagacillo implemented chutes to reduce dust releases. * Cover trucked materials during transport. * Provide Personal Protective Equipment and training to personnel working directly with dust-generating materials. Soil Quality

Reduced soil quality as a result of * Develop a spill prevention plan. Low Develop and implement No hazardous materials spills (fuels, oils, Prepare and implement chemical handling E nvironmental lubricants, other chemicals) andsPreareadiploemuentceialhnln Management Plan and storage procedures ~~~encompassing chemical * Construct concrete bund around areas storage and handling where liquids are stored to contain any procedures. spillage * Maintain spill kits in all fuel and chemical storage areas * Work will be monitored during construction to ensure there are no releases of deleterious substances. * Refuelling and maintenance of equipment will be conducted in designated locations only. * Workers handling chemicals will be provided training in chemical safety and adequate personal protective equipment.

The Madhvani Group 47 0385240100-REP-VO001-02 Kakira Sugar Works Cogeneration Expansion Environmental Assessment 'ARDROP

Table 9 (cont'd) Environmental Effects Analysis Summary Kakira Sugar Works Proposed Cogeneration Expansion Project

Potential Effect Mitigation Measure Residual Effect Follow-up Significant?

Reduced soil quality due to PCBs * Collect all water and dirt from transformers Low All new transformers will No released. during transformer during maintenance activities and treat as continue to be PCB free maintenance hazardous waste.

Reduced soil quality as a result of solid * Proper siting and design of a waste Low No waste disposal disposal site. * Ensure no hazardous wastes are stored or disposed of at waste disposal ground. . Groundwater

Decreased groundwater quality as a * Develop spill prevention plan. Low * Kakira will conduct No result of hazardous materials spills * Prepare and implement chemical handling regular visual (fuel, oil, lubricant and other chemicals) and storage procedures and train inspections of during construction and operation employees on their use. hazardous m r hazardous materials * Spill containment supplies will be kept on- storage areas, site in case of fuel leak. * Construct concrete bund around areas including aboveground where liquids are stored to contain any tanks. spillage * Work will be monitored during construction to ensure there are no releases of deleterious substances. * Storage of fuels and other hazardous materials will be conducted in designated locations only * Refuelling and maintenance of equipment will be conducted in designated locations only. .

The Madhvani Group 48 03852401 00-REP-VO001 -02 Kakira Sugar Works Cogeneration Expansion Environmental Assessment VARDROP

Table 9 (cont'd) Environmental Effects Analysis Summary Kakira Sugar Works Proposed Cogeneration Expansion Project Potential Effect Mitigation Measure Residual Effect Follow-up Significant? Surface Water

Decreased surface water quality due to * Kakira's overall expansion plan includes a Low Kakira will develop and No increased wastewater discharges wastewater treatment system including implement an * Oil, grease and grit separation environmental monitoring * A primary settling and flow program to monitor equalisation pond surface water quality * Ananaerobic pond leaving the wastewater * anaerobicAn pond system. * An aerobic pond Or * Constructed wetlands * Reduce water use to minimize the wastewater generated. Mammals and Birds

Decreased health of mammals due to a Obtain permit from NEMA to operate Low No interactions with improperly stored and waste disposal site disposed hazardous materials and * Proper siting and formal design will allow sewage for vermin breeding control

Nuisance Species, vectors, dangerous

Attraction of nuisance species, vectors * Obtain permit from NEMA to operate waste Low Kakira will work with No and dangerous species at current on- disposal site NEMA to monitor waste site waste disposal site (old quarry site) * Proper siting and formal design will allow disposal ground. for vermin breeding control

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Table 9 (cont'd) Environmental Effects Analysis Summary Kakira Sugar Works Proposed Cogeneration Expansion Project

Potential Effect Mitigation Measure Residual Effect Follow-up Significant? Land/resource use Disposal of wastewater may negatively * Kakira's overall expansion plan includes a Low Kakira will develop and No affect land use due to decreased water wastewater treatment system including implement an quality a environmental monitoring * Oil, grease and grit separation program to monitor * A primary settling and flow equalisation surface water quality pond leaving the wastewater * An anaerobic pond system. * An aerobic pond Or * Constructed wetlands Reduce water use to minimize the wastewater generated. Employment

Decreased employment opportunities * Create additional jobs in other locations Low No as a result of increased factory within the factory for displaced workers automation

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Table 9 (cont'd) Environmental Effects Analysis Summary Kakira Sugar Works Proposed Cogeneration Expansion Project

Potential Effect Mitigation Measure Residual Effect Follow-up Significant?

Health and Safety

Decreased human health and safety as * Conduct personal monitoring of Low Conduct periodic noise No a result of increased noise. employees in the areas of elevated noise monitoring, including levels to determine the appropriate noise personal monitoring. rating of PPE. This should include those employees who may pass through noisy areas on their way to their workstation. * Provide appropriate PPE to staff working in high-noise areas. * Ensure that workers are trained on proper use of PPE. * Construct and install silencers for steam discharges. Decreased human health due to * Kakira's overall expansion plan includes a Low Kakira will develop and No impacted drinking water wastewater treatment system including implement an * Oil, grease and grit separation environmental monitoring program to monitor * A primary settling and flow surface water quality equalisation pond leaving the wastewater • An anaerobic pond system. * An aerobic pond Or * Constructed wetlands * Reduce water use to minimize the wastewater generated.

Reduced human health as a result of air * Equip boilers with dry-ash collection emissions and dust system and full wet scrubber to reduce the amount of ash released into the environment.

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Table 9 (cont'd) Environmental Effects Analysis Summary Kakira Sugar Works Proposed Cogeneration Expansion Project

Potential Effect Mitigation Measure Residual Effect Follow-up Significant?

Health and Safety

* Develop a bagasse handling management plan to manage supply and demand and ensure bagasse quality. * Repair leakages in bagasse and bagacillo chutes to reduce dust releases. * Cover trucked materials during transport. * Provide Personal Protective Equipment and training to personnel working directly with dust-generating materials.

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Table 10 Residual Effects Assessment for Significance Kakira Sugar Works Environmental Effect Evaluation Criteria Residual Environmental Effect Magnitude Frequencyf | Duration Probability/ Geographic Significant? OccFreqencyef Drto Likelihood Etn Air Quality, Climate, Meteorology Increased Noise - L H M H L L No Construction Increased Noise - L H M H L L No Operation Increased emissions L H M H L L No from combustion of fossil fuels during construction

Increased emissions M H H M L L No during operation of expanded facility

Increased dust L H L M L L No generation during cane and bagasse handling, processing and storage

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Table 10 Residual Effects Assessment for Significance Kakira Sugar Works Residual Environmental Effect Evaluation Criteria Residual Environmental Effect Magnitude Frequency of Duration Probability! Reversibility Geographic Significant? Magnitude Occurrence Likelihood Extent Soil Reduced soil quality as M L H L N/a N/a No a result of hazardous materials spills

Reduced soil quality M L M L L L No due to PCBs released during transformer maintenance Reduced soil quality as M M H L N/a L No a result of solid waste disposal Groundwater

Decreased H L H L N/a M jNo groundwater quality as a result of hazardous

materials spills _ Surface Water Decreased surface L M M L L H No water quality due to increased wastewater

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Table 10 Residual Effects Assessment for Significance Kakira Sugar Works Environmental Effect Evaluation Criteria Residual Environmental Effect Magnitude Frequency of Duration Probability/ Reversibility Geographic Significant? agniue Occurrence urin Likelihood vi ,Extent

discharges _ Mammals and Birds Decreased health due to L L L L L L No interactions with improperly stored and disposed hazardous materials and sewage Nuisance Species Attraction of nuisance L L L L L L No species, vectors and l dangerous species to . I waste disposal site _ Population Demographics Human population Cannot be I I displacement as a result ~~~~~~~assessedpresent at of ROW placement present Land and Resource Use Disposal of waste water L T L L L L H No may negatively affect l l land use due to l l l l

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Table 10 Residual Effects Assessment for Significance Kakira Sugar Works

Environmental Effect Evaluation Criteria Residual Environmental Effect Magnitude Frequencyof Duration Probability/ Reversibility Geographic Significant? O~ccurrence jLikelihood Extent decreased water quality

Employment Decreased employment L L H L L L No due to increased factory automation

Public Safety and Health Increased Noise M H M L L M No

Increased potential Cannot be effects induced from assessed at electromagnetic fields present

Reduced human health L H M M L L No as a result of air emissions and dust

Decreased human L L L L L H No health due to impacted drinking water

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Table 11a

Noise Emission Levels from Various Construction Vehicles and Equipment

Equipment Number Estimated Noise Emission Levels (dBA) Vehicle* 5 80 per vehicle Loader** 2 104 Bulldozer** 2 107 Grader** 1 104 Dump Truck** 5 92 Jack Hammer** 1 130 Pneumatic drill or heavy 1 120 machine** Back hoe** 2 104 *Noise emission level reference distance is 15 metres **Noise emission levels taken at the operator Reference: NCLHH, 1999

Table lb

Values Used in Calculating Combined Noise Levels

Difference (dBA) Additive Noise Value Excess of Stronger Add to the Add to the Stronger to get the Stronger* Combined dBA level 0 3.0 1 2.5 2 2.1 3 1.8 4 1.5 5 1.2 6 1.0 7 0.8 8 0.6 9 0.5 10 0.4 *In order to combine sound pressure levels expressed in dBA, the strongest emitter is used as the initial level. Each noise emitter is compared to the strongest, and the difference in dBA levels between the two, determines the combined level. Reference: World Health Organization, 1995

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Table 11 c

Cumulative Noise Emissions for All Construction Vehicles and Equipment

Equipment Noise Difference Add to Cumulative Noise Emission between Stronger to Emission (dBA) (dBA) Noise get Combined Emitters Level Jack hammer 130 Pneumatic drill, 120 10 0.4 130.4 heavy machine Bulldozers** 110 10.4 negligible 130.4 Back hoes** 107 23.4 negligible 130.4 Loaders** 107 23.4 negligible 130.4 Grader 104 26.4 negligible 130.4 Dump trucks* 99 31.4 negligible 130.4 Vehicles* 87 43.4 negligible 130.4 Ambient (heavy 85 45.4 negligible 130.4 traffic area) *Assuming five vehicles or pieces of equipment operating at the same time **Assuming two pieces of equipment operating at the same time

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Table 1Id

Estimated Noise Emission from Expanded Cogeneration

Section Noise Levels (dBA) Proposed Uganda Standard (dBA) Current Average Estimated Changes Dec.2002 to Feb 2003 Turbo generator 91 941 85 area Boiler area 89 952 85 Notes: Values in Bold exceed the guideline. 1. Based on one turbogenerator at 91 dBA. 2. Based on two boilers at 89 dBA each. 3. Noise emissions will be reduced following installation of silencers for steam discharges and increased instrumentation to control temperature and pressure to reduce noisy steam exhaust through safety alarm valves.

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Potential Consequence The estimated cumulative noise emission levels during construction activities may increase by as much as 45 dBA over ambient levels for heavy traffic areas (Table 11 c). This increase is considered a 'worst case" scenario because it assumes all equipment will be used at the same time. Construction activities are generally limited to within the Kakira compound, where elevated noise levels due to factory operations, traffic, and business operations are common. Because increased noise levels can impact human health, mitigation is required.

Mitigation The following mitigation measures are proposed to decrease noise:

x Noise levels will be monitored during construction and further noise restrictions such as limiting the number of equipment operating simultaneously, where the noise level exceeds ambient levels of 70 dB by more than 20 dB. Equipment and vehicles will not be left idling for longer than 10 minutes at a time. x Provide hearing protection to staff. x Isolation of noise sources x Clear waming signs indicating high level noise areas and emphasis of noise protection equipment in those areas

Consequence of Residual Effect Factory expansion is a short-term activity. Noise emissions will decrease by approximately 10 dBA with mitigation, total noise increases are estimated to be about 120 dBA at the source, or 35 dBA above ambient levels. Daily noise monitoring will allow corrective measures to be applied. The residual effect of noise disturbance during demolition will be of low consequence.

INCREASED NOISE GENERATION DUE TO OPERATION OF EXPANDED COGENERATION FACILITY The expanded cogeneration facility will be in operation indefinitely. Due to the addition of two boilers and one turbogenerators, as well as the associated infrastructure, additional noise will be produced, potentially resulting in decreased air quality, or noise pollution. Ambient noise levels surrounding the Kakira site are approximately 85 dB. The closest residential housing is located 1000 m from the factory.

Potential Consequence Based on the addition of two boilers and one turbogenerator, the cumulative noise emission levels during operation of the expanded cogeneration facility may increase by as much as 10 dBA over current levels in those areas of the factory (Tables 11 d). This increase is considered a "worst case" scenario because it assumes that the new equipment will release the same amount of noise as all of the equipment in use during the 2002/2003 noise monitoring events. Increased noise as a result of infrastructure than the generators and boilers has not been included in this assessment. Because increased noise levels can impact human health, mitigation is required.

The Madhvani Group 60 0385240100-REP-VO001l02 Kakira Sugar Works Cogeneraton Expansion Environmental Assessment WARDROP

Mitigation The following mitigation measures are proposed to decrease noise:

x Noise levels will be monitored semi-monthly. Monitoring events will be conducted during operation of the boilers and turbogenerator. Noise restrictions such as limiting the number of equipment operating simultaneously, where the noise level exceeds ambient levels of 70 dB by more than 20 dB, will be implemented, if possible. x If off-site noise levels are greater than 70 dBA for extended periods of time, Kakira will investigate the Installation of sound baniers such as trees or earth berms to reduce off-site noise levels.

Consequence of Residual Effect Noise monitoring will allow corrective measures to be applied. The residual effect of noise disturbance during operation will be of low consequence.

DECREASED AIR QUALITY FROM FOSSIL FUEL EMISSIONS DURING CONSTRUCTION Gaseous and particulate air emissions released from vehicles and equipment used during construction and operation will increase carbon dioxide (CO2), carbon monoxide (CO), methane (CH4), nitrogen dioxide (NO2), nitric oxide (NO), nitrogen oxides (NO,), sulfur oxides (SO,), VOCs, and ground level ozone levels. Increased fossil fuel emissions may decrease local air quality.

Types of equipment with petroleum-fuelled engines that will likely be used during construction include trucks, front-end loaders, dump trucks and light equipment. For the purposes of this assessment, it is assumed that approximately two pieces of each type of equipment and five vehicles will be used and the bulk of construction will take approximately 1.5 years.

Total estimated emissions for the proposed project were calculated using the relationship between fuel consumption and exhaust gas production. The estimated fuel consumption during construction, as well as the estimated emissions during construction for various types of vehicles and machinery, is provided in Tables 12 a and b, respectively. The use of equipment during construction will increase emission values only slightly from current levels; therefore, construction will not likely result in direct air quality problems or indirect effects on the health of valued environmental components or human health.

Substances that deplete ozone and contribute to global warming and acid rain can be major components of air emissions. Compounds related to global warming (CO2, CH4, and N20) and compounds related to acid rain (NOx and SOx) are anticipated. The total estimated greenhouse gas emissions for the project are summarized in Tables 12 c.

The Madhvani Group 61 0385240100-REP-VO001-02 Kakira Sugar Works Cogenerafion Expansion Environmental Assessment IADROP

Table 12a

Estimated Project Fuel Consumption During Construction

Construction Estimated Fuel Type Estimated No. Total Fuel Total Fuel Equipment Number Consumption Construction Consumption Consumption (L/day) Days (L) (kg) Vehicles 5 Gasoline 150 550 82 500 56 925 Loader 2 Diesel 300 550 165 000 113 850 Dump Truck 2 Diesel 200 550 110 000 75 900 Backhoe 1 Diesel 200 550 110 000 75 900 Light All Gasoline 100 (total) 550 55 000 37 950 Equipment Total 522 500 360 525 Note: Construction Number of Days = (7 days per week) x (78 weeks) = 550 days. Based on worst case scenario using all equipment every day of the estimated 1.5 year construction period. Assume the density of gasoline is 0.69 g/mL; Assume the density of 1-0 fuel (diesel) is 0.81 g/mL. Total annual fuel consumption in Uganda equals 127 million L annually (http://www.wri.orq/wri/ehiAeaddev.html) References: RCO, 1999 ICC,1996

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TABLE 12b Estimated Fossil Fuel Emissions During Construction Activities

Equipment Type C02 CH4 N20 NO, co SO2 kg/year kg/year kg/year kg/year kg/year kg/year Vehicles 143153 41.7 1.252 1252 16 692 31.7 Loader 138 971 9.48 1.137 1516 1895 30.4 Dump Truck 92 648 6.32 0.758 1011 1264 20.2 Backhoe 46 324 3.16 0.379 505 632 10.1 Light Equipment 35 629 10.4 0.312 312 4155 7.88 Total 366 725 71.1 3.83 4596 24 638 100.3 Global Warming Potential 1 21.00 310.000 Insignificant Insignificant N.A. Insignificant Insignificant Total in CO2 Equivalents 366725 1493 1187 Note: All values shown are expressed in kg/year. All calculations were done in accordance with IPCC Guidelines (IPCC, 1996) Annual emissions are based on 90 days of construction activity (year = 90 days) N.A. = Not Applicable Reference: Environment Canada, 1999

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Table 12c

Anticipated Greenhouse Gas Production During Construction

Greenhouse Gas (kt CO2 Emissions (ktlyear) Equivalents) Total Project World Carbon Dioxide 0.367 23 900 000 Methane 0.0015 7 560 000 Nitrous Oxide 0.00119 17 050 000 Total 0.370 485100 009 Percent Project 100 1.14 x 107 May Generate Reference: Environment Canada, 1999

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Potential Consequence It is unlikely that air quality will be affected by fossil fuel emissions generated during project activities. Although carbon monoxide, carbon dioxide, nitrogen oxides, sulphur oxides, methane, VOCs, and ground ozone levels may be slightly affected locally during times of construction using diesel or gas powered equipment, the changes in air quality due to project activities are expected to be minor.

Although the potential emissions produced during construction activities are low, there is a continual effort to decrease worldly emissions; therefore, mitigation is required in the project study area.

Mitigation The following mitigation measures are proposed to reduce emissions from vehicle and equipment use:

x Kakira will ensure that vehicles and equipment are inspected and maintained. A poorly maintained engine and under-inflated tires can increase fuel consumption by up to 10% and 4 to 8%, respectively. l Vehicles and equipment will not be left idling when not in use. x No ozone depleting substances will be used or generated from equipment during construction.

Consequence of Residual Effect Ensuring a high standard of inspection, maintenance, and operational practices is an effective method of controlling excess emissions. This will reduce the magnitude and probability of gaseous and particulate emissions from vehicle and equipment use to an acceptable level. The residual effect of decreased air quality due to fossil fuel emissions was evaluated to be of low consequence in the project study area.

REDUCED AIR QUALITY INCREASED AIR EMISSIONS DURING OPERATION OF EXPANDED COGENERATION FACILITY The air emission sources and pollutants generated by Kakira operations are summarized in Table 4. The most significant pollutant emitted by bagasse-fired boilers is particulate matter, caused by the turbulent movement of combustion gases with respect to the buming bagasse and resultant ash.

Under normal operating conditions, the significant product of combustion of the bagasse is carbon dioxide (CO2), with lesser amounts of nitrogen oxides (NOx) and negligible quantities of polycyclic organic matter. Emissions of sulfur dioxide (SO2) from the boilers are also considered negligible, owing to the characteristically low levels of sulfur associated with bagasse.

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Dispersion modelling results for future conditions (a 100% increase in the bagasse feed rate to the boilers) indicate the following maximum 24-hour concentrations could occur at 183 m from the source:

3 X Carbon Dioxide - 130 000 _g/r- Carbon dioxide emissions contribute to the global warming effect. Uganda has not committed to any intemational protocols for greenhouse gas reductions (e.g. Kyoto protocol).

3 x Nitrous Oxides and Nitrogen Dioxide - 100 pg/M3 and 70 11g/M , respectively- Nitrous oxides and nitrogen dioxides are precursors of acid rain, which affects forests and vegetation. Current concentrations fall within acceptable levels of these pollutants compared to Uganda and intemational guidelines.

X Total Particulate Matter - 2600 pg/M3 - At the closest Kakira property line (650 m from the source), the 24-hour ground level concentration of particulates could reach 870 j1g/M 3, and the concentration does not drop below the Uganda AQS Standard (300mg/m 3) for more than 10 km away from the stack. Thus Kakira employees and members of the public living within a radius of 10 km from the factory may experience health effects from particulate from the boilers. Communities further away will most likely not experience health effects associated with particulate emissions. It should be noted that communities such as the one on top of Mwiri hill (157 m above the factory level), may experience concentrations almost double to those at ground level, due to the impact of the hill on plume behaviour. However, Kakira Hospital has no recorded case or complaints of this effect.

Other emissions include:

X Fugitive Dust Emissions - There are a number of significant sources of fugitive dust emissions from Kakira. These include other fugitive sources such as trucks driving on unpaved roads, outdoor conveyors or chutes, or from holes in galvanized pipes that convey bagasse or bagacillo, and storage piles.

x Sulphur Dioxide - Syrup from the evaporators is treated with sulphur dioxide (SO2) gas for bleaching purposes. The SO2 is generated in a reaction vessel and bubbled through the syrup in the 'sulphitor" reaction tank, reducing the pH of the syrup from 6.8 to 5.5. Excess sulphur dioxide is discharged from a tank vent to the roof. Approximately 0.3 kg of sulphur is consumed per tonne of crushed cane. On a 2500 metric tonnes of cane crushed per day (TCD) basis, approximately 750 kg of sulphur is used per day. The exhausted gas discharged from the reaction vessel is estimated to have a maximum SO2 gas concentration of 0.2% of the gas used. Therefore the S0 2 gas discharged from the sulphitor vessel will be a maximum of 1.5 kg/day. There is no pollution control equipment on the sulphitor vessel. Combustion sources such as diesel generators and wood fired boilers (start -up) will emit additional amounts of sulphur dioxide. Kakira installed a new 100 tVhr sulphur bumer which includes a scrubber during the 2002/2003 crop season. This new unit will improve the sulphitation process, thus resulting in a reduction in sulphur consumption and overall SO2 emissions.

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Under the expanded operations, these concentrations can double, based on a doubling of production and no additional emission controls. Air emissions assessment and dispersion modelling are provided in Appendix B. The maximum pollutant concentrations are found at 183 m from the source.

Potential Consequence With the expanded operations, air quality will be adversely affected as air emissions will approximately double. Mitigation is required to reduce the potential impacts.

Mitigation The following mitigation measures are proposed to decrease emissions during operation of the expanded facility: * The boilers will be equipped with a dry ash collection system and a full wet scrubber to reduce the amount of ash released into the environment. A properly chosen, sized and maintained wet scrubber should remove greater that 90% of the particulate emissions from the bagasse boilers (US EPA, 1996). If this removal is applied to the calculated air dispersion results provided in Appendix B, the maximum 24-hour concentration of particulates that could escape into the surrounding environment would be 260 pLg/M 3. This is less than the maximum Uganda AQS Standard (300 pLg/rn3).

* Install a process control system to eliminate excess SO2.

Consequence of Residual Effect Air emissions are one of the major environmental outputs at Kakira. Emissions are released throughout the sugar manufacturing process and will be released during cogeneration activities. Following implementation of measures to control air emissions, the probability that air emissions will be in excess of guideline values will be reduced. Follow up monitoring may be required to determine actual concentrations of contaminants emitted from the expanded facility. As Kakira has committed to installing pollution control devices and has already changed the sulphitation process resulting in a reduction in sulphur released to the atmosphere, the resultant residual effect after implementation of mitigation was evaluated to be of low significance.

REDUCED AIR QUALITY DUE TO DUST GENERATION DURING BAGASSE HANDLING, STORAGE AND DISPOSAL Disposal and storage of bagasse is an on-going challenge for Kakira. Excess bagasse, or bagasse that is too wet for buming, is stored in a covered storage area near the boilers. Currently, approximately 450 tons of bagasse is transported in uncovered trucks daily to the sugar cane fields for buming. While not a hazardous material, bagasse creates nuisance dust and is thus damaging to the environment. Bagasse buming also creates nuisance conditions for surrounding communities. Stockpiles of damp bagasse create ideal conditions for growth of toxic moulds that can be a health hazard for employees.

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Potential Consequence With the installation of the new Breda boilers and expansion of the bagasse handling area, the excess bagasse problem will be reduced. However, management of the bagasse to ensure a steady supply to the boilers will be critical. Mitigation is required.

Mitigation The following mitigation measures are proposed to decrease dust generation dunng bagasse handling, storage and disposal:

A Kakira will develop a bagasse handling management plan to manage bagasse supply and demand to the boilers and to ensure bagasse quality is maintained during storage. A Repair leakages in bagasse and bagacillo chutes to reduce dust releases. A Cover trucked materials during transport. A Provide Personal Protective Equipment and training to personnel working directly with dust-generating materials.

Consequence of Residual Effect Dust generation during cane and bagasse handling and storage cannot be avoided completely; however, it can be minimized via the implementation of mitigation measures. Where unavoidable, Kakira will supply workers with appropriate personal protective equipment and will train them in its proper use. The residual effect after mitigation was evaluated to be insignificant.

5.1.2 SOIL QUALITY

REDUCED SOIL QUALITY DUE TO HAZARDOUS MATERIALS SPILLS A summary of non-hazardous solid wastes generated at Kakira, and disposal practices, is provided as Table 3. Kakira recycles or reuses a number of waste products.

Wastes that are considered hazardous in Uganda are defined as those that are listed in the fifth schedule of the National Environment (Waste Management) Regulations (1999). Hazardous materials include substances, if released, may pose risks to the environment or to the health and safety of people or wildlife. Hazardous materials used at Kakira include the following:

X Process Chemicals - kept in the main store where housekeeping and storage conditions are considered adequate (Wardrop, 2003). The floor is concrete, preventing surface contamination and most chemicals are kept on pallets, which keeps them dry. w Sulphur ( Lime 0 Caustic soda and washing soda w Talocide (antibacterial spray applied in vicinity of milling equipment) w Phosphoric acid X Seperan/Flocculant

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Sodium hydrosulphite

x Fuels - petroleum storage tanks - Surficial staining was observed in at least two tank locations (standby diesel generator tanks, concrete pad at Chico division headquarters) and discrepancies in dip records have historically been encountered. Kakira were not aware of any spills that have occurred. It is our understanding that none of the tanks are cathodically protected.

2. Other Materials - Other hazardous materials used at Kakira include various types of lubricating oils. Empty waste oil drums are primarily stored outside the main store.

Potential Consequence A hazardous materials spill may occur from inadequate storage, fuelling activities, or as a result of a vehicle accident. Depending on the locabon of the spill, impacts to surface water, groundwater, and/or soil could result.

Mitigation The following mitigation measures are proposed to decrease the potential risk of decreased environmental quality due to spills of hazardous materials:

x Kakira will develop a spill prevention plan.

x Kakira will ensure that chemical containers are labelled and documentation regarding safe handling or first aid measures (i.e. MSDS) are accessible from each storage and use location.

x Kakira will make spill clean-up equipment readily available in chemical storage areas.

x Kakira will ensure that chemical containers are stored in a safe fashion to reduce the potential for containers falling over and spilling.

x Storage of fuels and other hazardous materials will be conducted in designated locations only

x Work will be monitored during construction to ensure there are no releases of deleterious substances.

Refuelling and maintenance of equipment will be conducted in designated locations only

X Workers who handle the chemicals will be provided training in chemical safety and adequate personal protective equipment. Occupational exposure of workers during handling of toxic powdered chemicals such as caustic soda and sulphur, is a particular concem. Emergency showers or eyewash stations in areas where some chemicals are handled will be considered.

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Consequence of Residual Effect Following the implementation of mitigation measures, the nsk of accidental spills of hazardous materials will be reduced. This potential effect will be of low significance.

REDUCED SOIL QUALITY DUE TO PCBs RELEASED DURING TRANSFORMER MAINTENANCE There are thirty-three electrical transformers on the Kakira property. UEDCL owns ten of these and Kakira owns the rest. Kakira will be adding one additional transformer as a result of the cogeneration project.

The transformers currently on the Kakira property were installed between 1959 to 2000. Private contractors complete major repairs on the transformers off-site; however, Kakira completes minor repairs on-site, including periodic filtering of the transformer oil to remove water and dirt. The facility has a portable piece of equipment for pumping the oil from the transformer, separating the oil and dirt and recycling the oil back to the transformer. The typical practice is to discard small quantities of separated water onto the ground.

PCBs are a class of chemicals, some of which are highly toxic and/or bioaccumulative. PCBs although not highly flammable, if ignited, will generate toxic fumes containing dioxins. PCB oils have excellent conductive properties and were therefore used extensively in transformers and other electrical equipment. However, now that its toxicity is well known, the use of the oils has been phased out in many parts of the world.

It is unknown whether the transformer oil contains PCB's. However, NEMA suspects that many transformers in Uganda contain oil laced with PCB's, particularly old transformers. There are no facilities in Uganda to analyse for PCB's. Although it is assumed that the new transformer will be PCB-free, mitigation is required to limit the amount of PCBs potentially being released to the environment during maintenance activities of the existing units. For replacement of transformer oils, KSW will use PCB- free transformer oils.

Potential Consequence The amount of PCBs currently released to the soil environment via discarded water is likely minimal as PCBs have a relatively low water solubility. However, due to the potential toxic effects associated with PCBs, and because an additional transformer will be installed, mitigation is recommended.

Mitigation The following mitigation measures are proposed to decrease the potential risk of decreased environmental quality due to the addition of PCBs to the soil:

A Kakira will collect all water and dirt from transformers during maintenance activities and treat as hazardous waste. These materials will be stored in an approved location for future incineration in Europe. The estimated costs of analysis of PCBs, transport and incineration in Europe are indicated in the following table:

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Estimated costs of handling Transformer PCBs at Kakira Sugar Works

Item Estimated cost Analysis of PCBs $150 per sample Transport to Europe $1500 per tonne Incineration of PCBs $ 3000 per tonne Miscellaneous (permits, handling etc) $ 2000 per shipment

Consequence of Residual Effect After implementation of mitigation measures, this potential effect is deemed to be insignificant.

DECREASED SOIL QUALITY DUE TO ADDITION OF METALS TO SOILS THROUGH FILTER CAKE (MUD) AND FLY ASH SOIL AMENDMENTS There is the potential for metals to be added to agricultural soils through the addition of filter cake and fly ash. A total of 24 000 tonnes (3.77% of cane crushed) of filter cake is produced annually. During a previous environmental investigation, it was determined that the filter cake has an elevated level of copper (Wardrop 2003). It is understood that elevated copper levels are naturally occurring and as such are not a result of the Kakira activities. Therefore, the fly ash and filter cake classify as non-hazardous waste.

Potential Consequence The concentrations of metals within the filter cake and fly ash are within referenced guideline values for agricultural soils. Kakira does not add metals within their process, therefore all of the metals contained in the fly ash are expected to be naturally occurring, likely derived from the soil. Mitigation is not required.

REDUCED SOIL QUALITY AS A RESULT OF SOLID WASTE DISPOSAL Kakira currently of solid waste at an old quarry site on their property. The quantities of waste disposed at this location are minimal currently; however, this is an unlicensed site with no formal design. The potential for environmental effects exists.

Mitigation The following mitigation measures are proposed to decrease the potential risk of decreased environmental quality due to solid waste disposal:

A Kakira will discontinue use of unlicensed waste disposal grounds. Only a site with proper siting, and a formal design (e.g. soil cover, leachate management, ventilation, vermin breeding control, etc.) will be used. x Ensure that no hazardous wastes are stored or disposed of at waste disposal ground.

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Consequence of Residual Effect After implementation of mitigation measures, this potential for adverse effects will be reduced. The residual effect is deemed to be insignificant.

5.1.3 GROUNDWATER

DECREASED GROUNDWATER QUALITY AS A RESULT OF HAZARDOUS MATERIALS SPILLS The Jinja area is considered to have low groundwater potential because of the fine- grained overburden and the resulting decrease in surface water infiltration. Water tables in the Kakira area are found at a depth of 51 m (overburden) and 69 m (bedrock) below grade; however, given the clay soil conditions, perched shallow water tables are suspected.

Potential Consequence Groundwater in the Kakira area may be subject to impact as a result of spills of hazardous materials, including fuels. The magnitude of effect will depend greatly on the type of material released, the area in which the spill occurs, and whether a perched shallow water table exists. Mitigation measures are required.

Mitigation The following mitigation measures are proposed to decrease the potential risk of decreased groundwater quality due to hazardous materials spills:

X Develop a spill prevention plan. k Prepare and implement chemical handling and storage procedures and train employees on their use.

- Kakira will conduct regular visual inspections of hazardous materials storage areas, including aboveground tanks. k Kakira will ensure that chemical containers are labelled and documentation regarding safe handling or first aid measures (i.e. MSDS) are accessible from each storage and use location. x Kakira will make spill clean-up equipment readily available in chemical storage areas. x Kakira will ensure that chemical containers are stored in a safe fashion in a designated storage area to reduce the potential for containers falling over and spilling. x Construct concrete berm around areas where liquids are stored to contain any spillage X Work will be monitored during construction to ensure there are no releases of deleterious substances.

Consequence of Residual Effect Following the implementation of mitigation, the probability of impacts to groundwater will be reduced. This effect was deemed insignificant.

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5.1.4 SURFACE WATER

DECREASED SURFACE WATER QUALITY DUE TO INCREASED WASTEWATER DISCHARGES

There are currently three effluent streams discharged from the factory: mill effluent; filter effluent; and centrifugal effluent. These streams combine and are later joined by minor effluent streams from the canteen and the sweets factory and overflow from the spray ponds. The latter receives cooling and condenser waters from the vacuum pans and evaporators. The wastewater discharge then continues through the sugar plantation fields, is joined by the Muwala Stream, which finally discharges into the Chico River flowing north.

Kakira recently received its waste discharge permit from DWD. In its environmental monitoring programme, Kakira has been sampling individual effluent streams, as well as combined wastewater streams, on a monthly basis and analysing for the following parameters:

l PH x temperature l 5-day Biological Oxygen Demand X Chemical Oxygen Demand (COD) x total suspended solids (TSS) x turbidity k total dissolved solids (TDS) x total phosphorus, nitrate and nitrogen flow

The results of a 2002 wastewater-sampling program of each individual effluent stream have been compared to the conditions of Kakira's recently received waste discharge permit and Uganda's Effluent Discharge Standards (Wardrop, 2002). In general, many of the parameters exceeded the permit conditions at some point in time. Note that this comparison is probably most relevant for the combined factory effluent stream, before it passes through the sugar plantations, because it constitutes the undiluted, combined 'industrial waste" stream stipulated in the permit.

X Factory Effluents - These effluent streams refer to the wastewater streams from the sugar cane factory and include the mill, centrifugal and filter effluents before combining with other water/waste streams. Analytical results of wastewater samples collected are presented in Wardrop 2002. The results show that the temperature, pH, Chemical Oxygen Demand (COD), 5-day Biological Oxygen Demand (BOD5) of samples collected from all three streams exceed the permit conditions.

w Temperature of these streams were in the range of 49.1to 54.6 degrees Celsius compared to specified range of 20 to 3 5 degrees Celsius. The pH of the mill effluent and the centrifugal effluent were 9.4 and 10.5 respectively and exceeded the specified range of 6.0 to 8.0.

i BOD5 and COD of these streams, particularly the centrifugal stream with a BOD5 and COD of 1037 and 3038 mg/l respectively, also significantly exceeded the specified permit conditions of 335 and 1450 for BOD5 and COD respectively.

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Filter and centrifugal effluents also have high Total Suspended Solids (TSS) concentrations (470 and 212 mg/l respectively), which exceed the permit condition of (175 mg/I).

Effluent from the centrifuge station has high true colour {(357 platinum cobalt units) Ptco)}, which is above the standard value of 100 Ptco, while that from the filter and mill was 74 and 52 Ptco respectively.

The results also showed that Filter and Centrfugal effluents had TDS concentrations of 1,324 and 2,156 mg/l respectively, which are above the recommended standard of 1000 mg/I. A review of the TDS results obtained by Kakira shows that the TDS content of these effluents was on average = 200 mg/l for most of the time and hence below the recommended guideline value. The latter was exceeded only once during the sampling period by the centrifugal effluent with a value of 1,890 mg/I.

The nutrient content of these effluents (Total Phosphorus (Total-P) and nitrogen (measured as TKN)) falls within the effluent guideline values. Values for Total Phosphorus of less than 1 mg Total-P/I (Guideline value is 10 mg/I) and TKN of less than 1.5 mg/l were obtained with no TKN detected in the filter effluent. However, analysis of Total-P by Kakira (for the period between 25/07-7/09/2001) shows that the standard value was exceeded by the Mill station effluent (18 mg/I) and the filter station (11.7 mg/I). Observed levels of phosphorus at the filter station may be attributed to addition of phosphoric acid in the clarifier stage, and possibly from phosphate-based fertilizer residue on the cane.

The total sulphates of these effluents were very low (less than 2 mg/I) compared to the guideline value of 500 mgA for effluent discharge.

Results for the oil and grease analysis of selected samples (mill, filter, centrifugal and factory effluent through the plantation) showed low levels (less than 1 mg/I) compared to the guideline value of 10mg/l. The filter effluent had the highest value of 0.780 mg/l while the centrifugal effluent had the lowest of 0.007 mg/I. The low oil and grease concentration in the effluents is likely attributed to good maintenance and housekeeping practices in the factory.

Combined Factory Effluent - Sampling locations were a few metres from the factory premises, further as it flows through the plantation, just before joining the Muwala stream (tributary of the Chico River) and finally its combination with the Chico River. Results show that the combined effluent as it leaves the factory premises has temperature, true colour, TSS, COD and BOD5 values which fall outside the effluent discharge standards. However, this is further confirmed by the historical data (Table 6). We noted the COD and BOD5 of this stream (1,382 and 214 mg/I respectively) do not exceed Kakira's permit conditions.

According to the Environment Superintendent of the factory, their efforts since 2002 (the first year of operation under the permit) towards reducing the pollution strength of the final effluent have involved improvement in housekeeping as well

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as reduction of the amount of wastewater discharged. Note that reduction in wastewater volumes may increase pollutant concentrations.

Samples collected and analysed further downstream generally showed reduced pollution levels, except for BOD5 (223 mgA compared to the initial value of 214 mg/I) just before the effluent joins the Muwala stream.

Chico Composite - The Chico composite has lower values of BOD5 (126 mg/I) and COD (232 mg/l) compared to the combined factory effluent before joining the Muwala stream. This is probably due to dilution by the Muwala stream resulting in an increased flow rate.

Considering the likelihood of communities downstream using the rivers waters for domestic purposes, the Chico composite quality was compared to the Uganda Standard Specification for Drinking Water (February 1994). It was found that the water quality with respect to colour and turbidity does not meet the standard. In addition, this stream has very low dissolved oxygen (DO) levels (<1 mg/I) and may impact on the aquatic life (e.g., many types of fish cannot survive when levels of DO drop below 2-5 mg DO/I).

A metal scan analysis of this wastewater further shows that the iron levels (5.6 mg/I) are above both the effluent discharge and drinking water standards (5 mg/I and 0.3-3.5 mgA respectively). This may be attributed to the Muwala stream, which being a groundwater source (with a high TDS) probably has high levels of this metal. Furthermore, the manganese level of this wastewater (0.59 mg/I) does not fall within the drinking water standards range (0.1-0.5), although it is within the acceptable range for effluent discharge standards (1 mg/I). This again shows that presence of this metal in the Chico composite may be due to the Muwala stream. KSW does not use iron or manganese for its processes, so it is likely that the elevated iron and manganese in the wastewater are naturally occurring.

No lead, copper and nickel were detected in the wastewater stream. Low levels of Al (0.01 mg/l), Zinc (0.23 mg/I), Chromium (0.03 mg/l) was found in this composite stream and all were within the acceptable effluent discharge and drinking water standards. Cadmium was found at a level of 0.01 mgA, which though compliant with the effluent discharge standards, is on the borderline for drinking water standards (0.01 mg/I). This is a concem in view of the use of the river by downstream communities for drinking purposes. The potential source of this metal in the Chico composite is either runoff from the estates fields or sediments in the natural river waters.

With factory expansion, the volume of wastewater generated will increase. With increased efforts to reduce water consumption, concentrations of each parameter will likely also increase.

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Potential Consequence Water quality of the waters receiving effluent from the factory (Muwala Stream and Chico River) could be adversely affected unless mitigation measures are implemented.

Mitigation The following mitigation measures are proposed to decrease the potential risk of decreased water quality due to effluent release:

x Kakira's overall expansion plan includes a wastewater treatment system. A preliminary design has been completed. The proposed wastewater treatment system consists of four components:

Oil, grease and grit separation, using separators installed at or close to the sources of the oil, grease or grit contaminants. A primary settling and flow equalisation pond with a 24 hydraulic retention time (HRT) An anaerobic pond with a 3 day HRT. An 'aerobic' pond with a 24 hour HRT.

It is expected that the discharge from the waste water treatment will be meet the discharge standards given in the Sugar Manufacturing Guideline of the World Bank (PPAH, 1998). This means that strict monitoring of discharge from the treatment will be necessary in order to minimise the impacts of the discharge onto the quality of the water quality of the streams that are used by local communities.

* Reduce water use to minimize the wastewater generated.

Consequence of Residual Effect Following the implementation of mitigation, the quality of the wastewater leaving Kakira will be within guidelines. The potential for effects on surface water quality will be greatly reduced. The residual effect is deemed to be insignificant.

5.1.5 MAMMALS AND BIRDS

DECREASED HEALTH OF MAMMALS AND BIRDS AND INCREASED INTRODUCTION OF NUISANCE SPECIES AND VECTORS AS A RESULT OF WASTE DISPOSAL Waste (including hazardous waste) and wastewater are currently disposed of untreated within the Kakira Estate.

Hazardous wastes that are generated and stored (at least temporarily) on the property include waste oil drums, chemical containers and small quantities of hazardous solid wastes (e.g. sulphur ash) and biomedical wastes. Further, some hazardous wastes such as sulphur ash are disposed of at the old quarry site, which is not appropriate

Kakira currently uses the old quarry for open dumping of waste. The quantities of waste disposed at the quarry are minimal at this time. However, Kakira does not hold a permit

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to operate a disposal site, and the site does not have a formal design (e.g. soil cover, leachate management, ventilation, vermin breeding control) to meet the provisions of NEMA or best management practices.

Potential Consequence There is the potential for birds and animals to come into contact with improperly stored and/or disposed of wastes generated at Kakira. Some of these wastes may be harmful to these organisms. Nuisance species and vectors may also inhabit improperly designed waste dumping areas. Mitigation is required.

Mitigation The following mitigation measures are proposed to decrease of health effects to mammals and birds and to decreased the potential for the introduction of nuisance species and vectors:

. The hazardous waste storage facility should be designed in accordance with best management practices. Best management practices for landfill design and operation are provided in the Solid and Hazardous Waste Management Plan (Wardrop, 2002). Kakira should arrange to obtain an appropriate permit from NEMA for the operation of waste disposal site. Proper siting and formal design of the waste disposal site (e.g. soil cover, leachate management, ventilation, vermin breeding control) should be undertaken in coordination with NEMA to meet the provisions of the regulation and best management practices. Kakira can dispose of its waste at a licensed off-site facility when such a unit is established in the vicinity.

Consequence of Residual Effect Following the implementation of mitigation measures, the residual effect on mammals and birds is deemed to be insignificant.

5.1.6 VEGETATION Any adverse impacts to vegetation will be as a result of the transmission line. As routing has not been confirmed, these potential effects cannot be evaluated.

5.2 SOCIAL EFFECTS

5.2.1 POPULATION DEMOGRAPHICS There is the potential for human population displacement as a result of the placement of the transmission line ROW. As routing has not been confirmed, these potential effects cannot be evaluated.

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5.2.2 LAND / RESOURCE USE

DECREASED DRINKING WATER QUALITY AS A RESULT OF INCREASED WASTE WATER DISCHARGES

Potential Consequence As a result of factory expansion, wastewater discharges will increase. Discharge of untreated effluent is currently a major concem for downstream communities on the Chico River. As these communities likely use the water for domestic purposes including drinking water, the quality of the water will affect the use of this resource. Residents of communities downstream of Kakira use the Water quality of the waters receiving effluent from the factory (Muwala Stream and Chico River) could be adversely affected unless mitigation measures are implemented.

Mitigation The following mitigation measures are proposed to decrease the potential risk of decreased water quality due to effluent release:

x Kakira's overall expansion plan includes a wastewater treatment system. A preliminary design has been completed. The proposed wastewater treatment system consists of four components:

w Oil, grease and grit separation, using separators installed at or close to the sources of the oil, grease or grit contaminants. m A primary settling and flow equalisation pond with a 24 hydraulic retention time (HRT) X An anaerobic pond with a 3 day HRT. ) An "aerobic" pond with a 24 hour HRT.

* Reduce water use to minimize the wastewater generated.

LOSS OF LAND USE DUE TO TRANSMISSION LINE PLACEMENT Depending on the route selected for the transmission line right-of-way, land use may be adversely affected. This is especially true if a new corridor is selected over an existing one. As routing has not been confirmed, these potential effects cannot be evaluated.

5.2.3 EMPLOYMENT

DECREASED EMPLOYMENT OPPORTUNITIES AS A RESULT OF FACTORY EXPANSION Kakira's factory expansion plan includes automation of a number of steps. As a result, there is a potential for decreased employment at the factory.

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Potential Consequence In order to facilitate an increase in production to 4000 TCD, a number of modifications and upgrades are required within the factory at each processing stage. Some of these modifications include increased reliance on mechanized equipment. Details are provided in Section 3.3. As a result, some factory staff will be displaced.

Mitigation Kakira is aware of employment concems as a result of the factory expansion. Kakira will endeavour to transfer and train displaced workers in other areas of the factory, including the cogeneration facility.

Consequence of Residual Effect With the implementation of mitigation, it is anticipated that there will be no reduction in the workforce at Kakira.

5.2.4 PUBLIC HEALTH AND SAFETY

INCREASED NOISE The results from the noise sampling conducted at Kakira as part of the 2002 audit indicate that the workers assigned to many areas in the factory may be exposed to harmful noise levels. These areas include: cane preparation and crushing mill; the pans; the clarifiers; the sugar bagging house; the evaporators; the foundry; the centrifuges; the mechanical shop; the power plant and near the boilers. Noise measurements indicated that workers in these areas might be exposed to noise levels above Uganda's proposed noise standard (85 dB (A)) over an 8-hour shift.

Potential Consequence Based on the addition of two boilers and one turbogenerator, the cumulative noise emission levels during operation of the expanded cogeneration facility may increase by as much as 10 dBA over current levels in those areas of the factory (Tables 11 c and d). This increase is considered a 'worst case" scenario because it assumes that the new equipment will release the same amount of noise as all of the equipment in use during the 2002/2003 noise monitoring events. Increased noise as a result of infrastructure other than the generators and boilers has not been included in this assessment. Because increased noise levels can impact human health, mitigation is required.

Mitigation

The following mitigation measures are proposed to decrease the potential risk to human health and safety as a result of increased noise generation:

x Conduct personal monitoring of employees in the areas of elevated noise levels to determine the appropriate noise rating of PPE. This should include those employees who may pass through noisy areas on their way to their workstation.

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x Provide appropriate PPE to staff working in high-noise areas. x Ensure that workers are trained on proper use of PPE. A Construct and install silencers for steam discharges.

Consequence of Residual Effect Following the implementation of mitigation, the impacts on human health and safety as a result of increased noise is deemed to be insignificant.

INCREASED POTENTIAL EFFECTS INDUCED FROM ELECTROMAGNETIC FIELDS Depending on the route selected for the transmission line right-of-way, people living adjacent to the corridor could be adversely affected by electromagnetic fields (EMF). As routing has not been confirmed, these potential effects cannot be evaluated.

REDUCED HUMAN HEALTH AS A RESULT OF AIR EMISSIONS As discussed in Section 5.1.1, there are a number of air emissions coming from Kakira. These air emissions will likely increase substantially after factory expansion and implementation of cogeneration.

Potential Consequence There is a potential for worker and public health effects from reduced air quality as a result of emissions and dust. Risk to worker health is likely greater than public health, depending on the proximity to the activity. Air pollutants from vehicles and equipment, as well as dust from bagasse handling, may cause distress to workers that come in contact with it. Mitigation is required.

Mitigation The following mitigation measures are proposed to decrease emissions and dust during operation of the expanded facility: * The boilers will be equipped with a dry ash collection system and a full wet scrubber to reduce the amount of ash released into the environment. A properly chosen, sized and maintained wet scrubber should remove greater that 90% of the particulate emissions from the bagasse boilers (US EPA, 1996). If this removal is applied to the calculated air dispersion results provided in Appendix B, the maximum 24-hour concentration of particulates that could escape into the surrounding environment would be 260 j.g/m3. This is less than the maximum Uganda AQS Standard (300 1Lg/m 3). A Kakira will develop a bagasse handling management plan to manage bagasse supply and demand to the boilers and to ensure bagasse quality is maintained during storage. A Repair leakages in bagasse and bagacillo chutes to reduce dust releases. A Cover trucked materials during transport. A Provide Personal Protective Equipment and training to personnel working directly with dust-generating materials.

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Consequence of Residual Effect Air emissions are one of the major environmental outputs at Kakira. Emissions are released throughout the sugar manufacturing process and will be released during cogeneration activities. Following implementation of measures to control air emissions, the probability that air emissions will be in excess of guideline values will likely be reduced. Follow up monitoring may be required to determine actual concentrations of contaminants emitted from the expanded facility. As Kakira has committed to installing pollution control devices and has already changed the sulphitation process resulting in a reduction in S released to the atmosphere, the resultant residual effect after implementation of mitigation was evaluated to be of low significance.

DECREASED HUMAN HEALTH DUE TO IMPACTED DRINKING WATER

Potential Consequence As a result of factory expansion, wastewater discharges will increase. Discharge of untreated effluent is currently a major concem for downstream communities on the Chico River. As these communities likely use the water for domestic purposes including drinking water, the quality of the water will affect the use of this resource. Residents of communities downstream of Kakira use this water source for domestic purposes. Human health could be affected if untreated effluent continues to be discharged into the water system. Mitigation is required.

Mitigation

The following mitigation measures are proposed to decrease the potential risk of decreased water quality due to effluent release:

A Kakira's overall expansion plan includes a wastewater treatment system. A preliminary design has been completed. The proposed wastewater treatment system consists of four components:

* Reduce water use to minimize the wastewater generated.

Consequence of Residual Effect Following the implementation of mitigation, the quality of the wastewater leaving Kakira will be within guidelines. The potential for effects on human health will be greatly reduced. The residual effect is deemed to be insignificant.

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5.3 POSITIVE EFFECTS

Following the implementation of mitigation, the proposed project will lead to many positive effects in both the biophysical and social environments. These include the following:

X Improved Surface Water Quality - Following the construction and implementation of the wastewater treatment system, effluent quality leaving the factory will be improved. As a result, the quality of the receiving streams will also likely improve.

x Reduced Unit Air Emissions - Kakira's project design includes various air emission controls designed to reduce the unit air emissions.

A Reduced Fossil Fuel Requirements for Steam Generation - Buming bagasse, which is a waste product of sugar processing, reduces the requirement for use of fossil fuels to generate steam. This steam is then used for both factory operations as well as for generating electricity. Emissions related to energy consumption for steam generation will decrease.

Storage and Disposal of Excess Bagasse - Disposal and storage of bagasse is an on-going challenge for Kakira. Excess bagasse, or bagasse that is too wet for buming, is stored in a covered storage area near the boilers. Approximately 450 tons of bagasse is transported in uncovered trucks every day to the sugar cane fields for buming. While not a hazardous material, bagasse creates nuisance dust and is thus damaging to the environment. Bagasse buming also creates nuisance conditions for surrounding communities. Stockpiles of damp bagasse create ideal conditions for growth of toxic moulds that can be a health hazard for employees. The expansion of the cogeneration facility will substantially eliminate the excess bagasse problem.

x Reduced Fossil Fuel Requirements for Transport of Bagasse - Currently, approximately 60 litres of fuels is used per day to transport bagasse from the factory to the fields for disposal. The expansion of the cogeneration facility will eliminate this step in the process.

k Improved Air Quality - Buming of bagasse the cogeneration facility rather than in agricultural fields will lead to improved air quality as a result of decreased generation of carbon monoxide due to more efficient combustion and decreased nuisance smoke.

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6.0 ANALYSIS OF ALTERNATIVES

6.1 STATUS QUO

"Altematives to" the project are functionally different ways to meet the project need and achieve the projected purpose. The Status Quo altemative, or the alternative of not constructing the project, is described below.

The Status Quo altemative comprises the current operations at KSW, as described in Section 3 of this report. KSW processes approximately 900,000 tonnes of cane per year, crushing sugarcane at the rate of over 3000 tonnes of cane crushing per day (TCD).

KSW bums bagasse in four fuel boilers to generate steam to drive factory prime movers such as turbo-generators, mill turbines and turbo-pumps, and for use in sugar processing in the Boiling House. The total steam capacity of the plant in 90 T/h. The steam requirement at the current operating level (2500 TCD) is 75 T/h, which is supplied by operating boilers 1 and 4 with extra steam from boilers 2 and/or 3, as required. The flue gas from the boilers is vented to the outdoors via three tall stacks. The boilers are not equipped with any pollution control equipment. Fumace ash is manually removed from the boilers and trucked to a disposal area or used in the field as a soil amendment.

KSW also has five diesel generator sets with a combined capacity of 2,500 KVA. Currently, KSW's intemal power generation is only used for intemal needs (sugar factory and some ancillary units). KSW purchases electricity form UEDCL to provide electricity for its infrastructure (housing, street lighting, sweets factory and irrigation).

6.2 EXISTING ENVIRONMENTAL CONDITION

The environmental interactions between the current operation and the environment are identified in Table 8a. The following environmental parameters are affected by the current operations at KSW:

x Air quality- Fugitive dust and petroleum hydrocarbon emissions are emitted during various phases of the sugar process. Emissions from the boiler stacks, exhaust from the syrup suphitor and fugitive fly ash emissions from burning bagasse all have the potential to impact air quality.

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x Surface Water Quality - Surface water is affected by the release of wastewater to the River Kiko. Water is pumped from Lake Victoria.

x Vegetation - Vegetation is removed for the sugar process. Fumace ash is applied to agricultural soils as a soil amendment.

x Mammals and Birds - Noise generated during the sugar process may adversely affect mammals and birds in the area; however, it is likely that these organisms are accustomed to these operations.

x Fish and Aquatic Invertebrates - Impacts to surface water quality can lead to effects on aquatic organisms. Specifically, the addition of wastewater effluents to natural water bodies and potential deposition of dust and other air emissions on the water may adversely affect these organisms.

x Nuisance Species and Vectors - Nuisance species may be more prevalent as a result of disposal of solid wastes, hazardous wastes and sewage.

The following social components are affected by the current operations at KSW:

x Land and Resource Use - The lands within the KSW Estate comprise mainly sugar cane acreages. There is increasing interest in cultivating sugar cane over other traditional food and cash crops (Bhatt, 1998).

x Public Health and Safety- Public health concems are mainly associated with air quality.

6.3 CONCLUSION

If the KSW Cogeneration Expansion project is not implemented, none of the positive effects listed in Section 5.3 will be achieved. With the implementation of the proposed mitigation measures, the overall significance of this project will be low.

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7.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

An Environmental Management Plan (EMP) is defined as an instrument that details:

a the measures to be taken during the implementation and operation of a project to eliminate or offset adverse environmental impacts, or to reduce them to acceptable levels

a the actions needed to implement these measures (World Bank, OP 4.01).

7.1 MITIGATION MEASURES

Mitigation is defined as the elimination, reduction and control of the adverse effects of a project. Mitigation measures outlined in Section 5 of this report are summarized in Table 13. Descriptions and technical details of the mitigation measures, responsibilities for implementation, schedules, methods, and sources of funds are also detailed.

7.2 INSTITUTIONAL STRENGTHENING AND TRAINING

KSW has been operating a cogeneration facility with relatively old equipment and little or no pollution control. They have introduced an environmental management system. The proposed cogeneration project will include the establishment of modem equipment and the employment of new/improved methods of environmental management to satisfy the requirements identified as mitigation measures in this report. As a result, institutional strengthening and training of human resources at KSW will be required in order to meet this challenge.

The main objective of the Institutional Strengthening is to strengthen the institutional capacity within KSW to implement the mitigation measures in the report and to thereby contribute to social and environmental sustainable development. The proposed mechanism for institutional strengthening and training at KSW includes:

x Training of personnel to handle the equipment for cogeneration project by the contractor who is to install the equipment. a Closer co-ordination among existing activities and the cogeneration project at KSW. a Enhancement of environmental management capacity throughout the company.

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Table 13 MITIGATION PLAN Effect Mitigation Measure 1 Estimated Time Scale2 Cost (Ush)J AIR QUALITY, CLIMATE AND METEOROLOGY

Increased noise during construction and * Control the timing of noise to least disruptive periods whenever operation of expanded cogeneration facility. practical. S

* Monitor noise levels during construction. Implement further noise restrictions S where the noise level exceeds ambient levels of 85 dB by more than 20 dB * Minimize idling of vehicles and/or equipment S * Maintain noise levels below 85 dBA or provide hearing protection S Increased emissions (SO, NOR,, CO, CO, and 2 2 * Kakira will ensure that vehicles and equipment are inspected and particulates) from combustion of fossil fuels maintained. M during construction

* Vehicles and equipment will not be left idling when not in use. S * No ozone depleting substances will be used or generated from equipment during construction S Increased emissions (S02, NO,, CO, CO2, and * Equip boilers with a dry ash collection system and full wet scrubber to 20 - 100 m particulates) during operation of expanded reduce the amount S facility of ash released into the environment.

Increased dust generation during cane and * Develop a bagasse handling management bagasse handling, plan to manage supply and M processing and storage demand and ensure bagasse quality. * Repair leakages in bagasse and bagacillo chutes to reduce dust 5 - releases. 20 m M * Cover trucked materials during transport. 5 m S * Provide Personal Protective Equipment and training to personnel 5 m S working directly with dust-generating materials.

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Table 13 (cont'd) MITIGATION PLAN

Mitigation Measure Estimated Time Scale 2 Cost (Ush)l SOILS

Reduced soil quality as a result of hazardous * Develop and implement a spill prevention plan including implement 20 m M materials spills (fuels, oils, lubricants, other chemical handling and storage procedures chemicals) * Construct concrete bund around areas where liquids are stored to contain any spillage * Maintain spill kits in all fuel and chemical storage areas * Refuelling and maintenance of equipment will be conducted in designated locations only * Workers handling chemicals will be provided training in chemical safety and adequate personal protective equipment. * Work will be monitored during construction to ensure there are no 10 m S releases of deleterious substances. Reduced soil quality due to PCBs released * Collect all water and dirt from transformers during maintenance activities 10 m M during transformer maintenance and treat as hazardous waste.

Reduced soil quality as a result of solid waste * Proper siting and design of a waste disposal site. disposal 50 m M

* Ensure no hazardous wastes are stored or disposed of at waste S L ______disposal ground.

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Table 13 (cont'd) MITIGATION PLAN

Mitigation Measure Estimated Time Scale2 Cost (Ush)' GROUNDWATER

Decreased groundwater quality as a result of * Develop spill prevention plan. 20 m hazardous materials spills (fuel, oil, lubricant M and other chemicals) during construction and * Prepare and implement chemical handling and storage procedures and operation train employees on their use. * Spill containment supplies will be kept on-site in case of fuel leak. * Construct concrete bund around areas where liquids are stored to contain any spillage * Work will be monitored during construction to ensure there are no releases of deleterious substances. * Storage of fuels and other hazardous materials will be conducted in designated locations only * Refuelling and maintenance of equipment will be conducted in designated locations only. SURFACE WATER

Decreased surface water quality due to * Kakira's overall expansion plan includes a wastewater treatment system increased wastewater discharges including 1000 m S * Oil, grease and grit separation * A primary settling and flow equalisation pond * An anaerobic pond * An aerobic pond Or * Constructed Wetlands * Reduce water use to minimize the wastewater generated.

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Table 13 (cont'd) MITIGATION PLAN

Mitigation Measure X Estimated Time Scale2 Cost (Ush)' MAMMALS AND BIRDS

Decreased health of mammals due to * Obtain permit from NEMA to operate waste disposal site 50 m interactions with improperly stored and S disposed hazardous materials and sewage * Proper siting and formal design will allow for vermin breeding control

NUISANCE SPECIES, VECTORS, DANGEROUS

Attraction of nuisance species, vectors and . Obtain permit from NEMA to operate waste disposal site 50 m dangerous species at current on-site waste S disposal site (old quarry site).

* Proper siting and formal design will allow for vermin breeding control LAND/RESOURCE USE

Disposal of wastewater may negatively affect * Kakira's overall expansion plan includes a wastewater treatment system Included above land use due to decreased water quality including S • Oil, grease and grit separation * A primary settling and flow equalisation pond • An anaerobic pond • An aerobic pond Or a Constructed Wetlands * Reduce water use to minimize the wastewater generated. EMPLOYMENT

Decreased employment opportunities as a * Create additional jobs in other locations within the factory for displaced result of increased factory automation workers l

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Table 13 (cont'd) MITIGATION PLAN

Mitigation Measure | Estimated Time Scale2 Cost (Ush)l HEALTH AND SAFETY

Decreased human health and safety as a result * Conduct personal monitoring of employees in the areas of elevated 5-10 m S of increased noise. noise levels to determine the appropriate noise rating of PPE. This should include those employees who may pass through noisy areas on their way to their workstation. * Provide appropriate PPE to staff working in high-noise areas. s

* Ensure that workers are trained on proper use of PPE. s

* Construct and install silencers for steam discharges. S-M

Decreased human health due to impacted * Kakira's overall expansion plan includes a wastewater treatment Included above drinking water system including S * Oil, grease and grit separation • A primary settling and flow equalisation pond • An anaerobic pond • An aerobic pond Or * Constructed Wetlands * Reduce water use to minimize the wastewater generated.

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Table 13 (cont'd) MITIGATION PLAN

Mitigation Measure Estimated Time Scale 2 Cost (Ush)' Reduced human health as a result of air a Equip boilers with dry-ash collection system emissions and and full wet scrubber to dust reduce the amount of ash released into the environment. S * Install a scrubber on the tank vent of the sulphitor to reduce S emissions. * Develop a bagasse handling management plan to manage supply and 10 - 15 m M demand and ensure bagasse quality. * Repair leakages in bagasse and bagacillo chutes to reduce dust 5 - 20 m releases. M * Cover trucked materials during transport. 5 m s * Provide Personal Protective Equipment and training to personnel S working directly with dust-generating materials. Note: 'Estimated order of magnitude costs are in millions (m) of Ugandan Shillings 2 Three implementation time scales have been recommended: S = short (during construction) M = medium (one to three years following construction) L = long (greater than 3 years following construction)

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7.3 MONITORING

An Environmental Monitoring Plan (EMP) has been developed to verify the accuracy of the environmental assessment and to determine the effectiveness of measures taken to mitigate the adverse environmental effects of the project. Specifically, it will provide information on whether the predicted impacts of the project are within the specified limits, and will provide early waming information of any unacceptable environmental conditions. A more comprehensive EMP that will take into consideration the impacts of the transmission line will be made after public consultations and social assessment of the proposed line after a decision has been made by the developer and UEDCL.

Kakira currently has a routine inspection and monitoring program in place for certain aspects of their operations, including noise monitoring. Additional data has been collected for effluent and surface water quality, as well as air quality. The EMP will build upon the program already in place. Records will be kept by the Environmental Lead at Kakira, or designate, and reported to NEMA and/or other authorities, as appropriate.

Table 14: Environmental Monitoring Plan

Location Parameter Frequency of monitoring

Boiler House Noise levels Routinely

Cogeneration Air quality Continuous plant Personal Protective Equipment Continuous

Wastewater Effluent quality Monthly treatment plant

Boiler House Working Continuous environment

Surface Water Water Quality Continuous

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8.0 TECHNICAL REFERENCES

Bhatt, S.G. 1998. Environmental Impact Assessment of Kakira Sugar Works (1985) Limited on Existing Conditions and Future Expansion.

Intergovemmental Panel on Climate Change (IPCC). 1996. Revised 1996 IPCC Guidelines for National Greenhouse Gas Inventories. hftp://www.ipocc- nggip.iaes.or.ip/public/gl/invsl.htm

Intemational Bank for Reconstruction and Development. 1991. Environmental Assessment Sourcebook Volume I: Policies, Procedure, and Cross-Sectoral Issues. World Bank technical paper, ISSN 0253-7494, no. 139.

Intemational Bank for Reconstruction and Development. 1991. Environmental Assessment Sourcebook Volume IlIl: Guidelines for an Environmental Assessment of Energy and Industry Projects. World Bank technical paper, ISSN 0253-7494, no. 139- 140.

John H. Payne. 1998. Kakira Biomass Cogeneration Project No. 97-007B Final Report Volumes 1, 2, 3. Prepared for Kakira Sugar Works by John H. Payne, Inc., Hawaii, U.S.A.

Kakira Sugar Works (1995) Ltd. (KSW). 2000. Kakira Final Manufacturing Report (1993-2000)

Kakira Sugar Works (1995) Ltd. (KSW). 2002. Expansion of the Kakira Sugar Complex. The Madhvani Group.

Multiplan Consulting Engineers. 2000. Factory Based Effluent Treatment Works Preliminary Design Study Report (Final Draft). Prepared for Kakira Sugar Works (1985) Ltd. by Multiplan Consulting Engineers.

National Environment Management Authority (NEMA). 1996. Jinja District Profile. htti://www.nemaua.ora/disrictProfiles/JI NJA.pdf

Noise Centre for the League for the Hard of Hearing (NCLHH). 1999. Noise Levels in our Environment Fact Sheet. http://www.lhh.org/noise/decibel.htm

Saflex Acoustical Guide. 2000. Frequently Asked Questions about Acoustics. httD:/ANww.saflex.com/acoustic/faa.htm

US EPA. 1996. Bagasse Combustion in Sugar Mills. Publication AP-42, 5th Edition, Volume 1 Chapter 1.8.

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Wardrop Engineering Inc. 2002. Environmental Audit Kakira Sugar Works (1985) Limited. Report to the Ministry of Finance, Planning and Economic Development of Uganda for the Privatisation and Utility Sector Reform Project.

World Health Organization (WHO). 1995. Community Noise. http://www.nonoise.ora/librarv/whonoise/whonoise.htm#31

World Bank Policies

* OP. 4.01 Environmental Assessment * OP. 4.09 Pest Management * OP. 4.04 Natural Habitat

World Banks Guidelines ( PPAH. 1998) * Environmental Audits in Industrial projects; * Guidelines for Sugar Manufacturing . General Environmental Guidelines; * Environment Management Systems and ISO 14000.

Relevant IFC Policies, Guideline and Guidance documents (www.ifc.org) * Policy Statement on Forced labor and harmful child labor; * Guidance document on HIV/Aids in the work place (IFC 2001); * General Health and Safety Guidelines (IFC guideline, 1998); * Guidelines for Plantations (IFC, 1998): * Guidelines for Pesticides Handling and Application (IFC, 1998); * Wastewater reuse (IFC guideline, 1998); * Hazardous Material management (IFC guideline, 2001); * Waste Management Facilities (IFC guideline, 1998); Doing better business through effective public consultation and disclosure: a good practice manual (IFC 2000).

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APPENDIX A

TERMS OF REFERENCE TERMS OF REFERENCE (TOR) FOR ENVIRONMENTL ASSESSEMENT KAKIRA SUGAR WORKS BAGASSE COGENERATION EXPANSION

1. Introduction. Kakira Sugar Works (1985) Ltd. (KSW), formed in 1985, currently has a crushing capacity of 2500 tones of cane per day (TCD). In 1995-96, KSW decided to expand its sugar processing facilities to 5000 TCD based on the envisaged market for sugar in Uganda and the study on agriculture options for the South Busoga region of Uganda. As a consequence of this basic expansion, KSW decided to expand its cogeneration capacity from the current 4.5MW. In general such cogeneration capacity expansions would be sized to meet the additional requirements of the expanded sugar crushing plant. However, this practice would result in considerable underutilization of the bagasse, the excess of which would be bumed in the field. In light of the need for additional electricity generation capacity in the grid network, KSW submitted a proposal to the Government offering to expand its cogeneration facility beyond its own needs, and supply electricity to the national grid network.

2. KSW already has prepared and received approval from the National Environmental Management Agency (NEMA) of Uganda for an EIA covering the overall sugar expansion program to 5000 TCD including the expanded cogeneration facility for the estimated increased bagasse supply of 160,000 TB/y.

3. In subsequent discussion, the Government reduced its requirement of electricity supply from KSW to peak hours only (1800-2400hours) and KSW decided to implement a phased expansion programme for the expansion of its factory and cogeneration facilities.

4. In the current phase, KSW plans expansion it factory capacity to 4000 TCD and installing a new cogeneration facility of 14-15 MW. KSW's existing cogeneration facilities would be retained in-situ and would be used if required when the new cogeneration facility is not operational. The new cogeneration facility would provide electricity for KSW's own envisaged needs (which would be scheduled to be up tO 9 MW off-peak and up to 6 MW during peak hours) and electricity for the national grid of up to 7 MW during peak hours only.

The current KSW cogeneration project is comprised of: (a) an additional boiler (b) a new 14-15 MW turbo-generator (c) related piping, cabling, electrical equipment, instrumentation and control systems (d) additional bagasse handling equipment (e) the necessary civil works for all of the above, (f) a new electrical sub-station at Kakira (g) A new 33kV distribution from Kakira to the UEDCL Jinja Industrial Substation at Mailombili, running parallel to the existing 33KV distribution line from Kakira to Wairaka and installed above the existing 33KV distribution line from Wairaka to Mailombili.

5. KSW anticipates accessing World Bank funds from the Energy for Rural Transformation (ERT) Project for the cogeneration facility expansion. Therefore, the proposed new EIA for KSW's new cogeneration facility must comply with the Environmental and Social Management framework developed for the ERT subproject such as this one, the World Band must also review the EIA and issue a "no- objection" before funds are released under the ERT Project. For this reason and EIA focusing on the cogeneration facility must be prepared.

6. Objectives. The objective of this assignment is to prepare an Environmental Impact Assessment focusing on the KSW new cogeneration facility, including relevant aspects of related investments such as a new distribution line for evacuating power to the main grid, if necessary.

7. Environmental Assessment Requirements. The EIA will be consistent with the following regulations and guidelines which will govern the conduct of the assessment and specify the content of its report.

* The World Bank's Operation Policy (OP) and Bank Procedure (BP) 4.01: "Environmental Assessment," The Pollution Abatement and Control Handbook, and other pertinent policies and procedures; * National laws and/or regulations on environmental reviews and impact assessments, including the Environmental and Social Management Framework prepared for the ERT Project; * Regional, provincial or communal environmental assessment regulations; * Environmental assessment regulations of any other financing organizations involved in the Kakira Cogeneration project.

8. Study Area. The study will focus on the cogeneration facility within the context of the sugar plant. Therefore, relevant major aspects of the factory operation will also be included in the analysis as they relate to the cogeneration facility. The study will also include directly related investment such as transmission facilities, if any, required for power evacuation to the main grid.

9. Scope of Work.

9.1 Task 1. Description of the Proposed Project. Provide a brief description of the relevant parts pf the project, using drawings where necessary, and including the following information: location (provide map); general layout; size, capacity, etc.; pre-construction activities; construction activities; schedule; staffing and support; facilities and services; operation and maintenance activities; required offsite investments; life span, and expected future growth, if any. 9.2 Task 2. Description of the Environment. Assemble, evaluate and present baseline data on the relevant environmental characteristics of the study area. Include information on any changes anticipated before the project commences.

(a) Physical environment: topography; soil; climate and meteorology; ambient air quality; surface and ground - water hydrology; existing sources of air emissions; existing water pollution discharges; and receiving water quality. (b) Biological environment: flora; fauna; rare or endangered species; sensitive habits; including parks or preserves, significant natural sites, etc; species of commercial importance; and species with potential to become nuisances, vectors or dangerous. (c) Socio-cultural environment (include both present and projected where appropriate): population; land use; planned development activities; community structures; employment; distribution of income, goods and services, recreation; public health; cultural properties; tribal people; and customs, aspirations and attitudes. Include a description of the history and current status of the relations between KSW and the surrounding communities.

9.3. Task 3. Legislative and Regulatory Considerations. Describe the pertinent regulations and standards governing environmental quality, health and safety, protection of sensitive areas, protection of endangered species, sitting, land use control, etc, at international, national, regional and local levels. This should include identification of World Bank safeguard issues that could potentially be triggered by the project.

9.4. Task 4. Determination of the Potential Impacts of the Proposed Project. In this analysis, distinguish between significant positive and negative impacts, direct and indirect impacts, and immediate and long-term impacts. Identify impacts which are unavoidable or irreversible. Wherever possible, describe impacts quantitatively, in terms of environmental costs and benefits. Assign economic values when feasible. Characterize the extent and quality of available data, explaining significant information deficiencies and any uncertainties associated with predictions of impact. Include implications for local work force, if any. Identify potential stakeholders in the project as well as social impacts of land acquisition (if any) associate with the project, including the transmission lines.

9.5. Task 5. Analysis of Alternatives to the Proposed Project. Analyze the alternative of not constructing the project, in order to demonstrate environmental conditions without it.

9.6. Task 6. Development of Environmental and Social Management Plan, with focus on three generic areas. Mitigation measures, institutional strengthening and training and monitoring. Descriptions of the latter two should be prepared in the context of the overall ERT Project, and in particular, the Environmental and Social Management Framework prepared for that project. Mitigation of environmental and social impact: Recommend feasible and cost effective measures to prevent or reduce significant negative impacts to acceptable levels. Estimate the impacts and costs of those measures. Consider compensation to affect parties for impact which cannot be mitigated. The plan should include proposed work programs, budget estimates, schedules, staffing and training requirements, and other necessary support services to implement the mitigating measures.

Institutional Strengthening and training: Identification of institutional needs to implement environmental assessment recommendations and indicate how these will provide for.

Monitoring: Indicate how monitoring implementation of mitigation measures and the impact of the project during construction and operation will be handled. Include in the plan an estimate of capital and operation costs and description of other imputes (such as training and institutional strengthening) needed to carry it out.

9.7 Task 7. Assist in Public/NGO Participation. Identify affected groups and NGOs which represent them, if any, and assist in obtaining their views. This will include keeping records of meetings and other activities, communications, and comments.

10. Report. The environmental assessment report should be concise and limited to significant environmental issues. The main text should focus on findings, conclusions and recommended actions, supported by summaries of the data collected and citations for any references used in interpreting those data. Detailed or interpreted data are not appropriate in the main text and should be presented in appendices or a separate volume. Unpublished documents used in the assessment may be readily available and should also be assembled in an appendix. Organize the environmental assessment report according to the outline below.

Executive Summary Policy, Legal Administrative Framework Description of the Proposed Project Baseline Data Significant Environmental and Socio Impacts Analysis of Alternatives Environmental and Social Management Plan Appendices. List of Environmental and Social Assessment Preparers References Record of Interagency/Forun/ Consultation Meetings

11. Other Information. It is expected that much of the material required for this assessment will be available from the previous EIA prepared for the full plant. WRDROP

APPENDIX B

AIR EMISSIONS ASSESSMENT AND DISPERSION MODELLING SUMMARY Sample Emission Rate Calculations for C02 Emissions from Bagasse-Fired Boiler (Boile No. 1) Assumptions: Please note that the following calculations and SCREEN3 model were completed using all of the assumptions and documents referred to in Wardrop (2002; Appendix Il -BAirEmissions Assessment and Dispersion Modelling). The only modification to this original document is that the bagasse feed rate to the four boilers was increased by 100%. In order to assess the worst case situation, it was assumed for the purpose of this assessment that no other pollution control systems would be in place.

Emission Rate (g/s) = Bagasse Feed Rate (MT/s) x Emissions Factor (g/MT)

MT = Metric Tons (1000 kg = 1 MT)

Convert Bagasse Feed Rate to MT/s: Factory Data: 32 MT/h Bagasse Feed Rate: 32MT/h 3600 s/h = 8.89E-03 MT/s

Convert Units of Emission Factors Obtained from USEPA AP-42 Table 1.8-1 Emission Factor for C0 Assumptions:~2 ~ Tnne/h15603 lb of pollutant / Ton of wet, as fired bagasse containing approximately 50% moisture

Multiply by0.5 to convert units to kg ofpollutant /MT ofwet, as fired bagasse. Multiply byl1000to convert to g.

Emission Factor for CO2 = 1560 lb/ton x 0.5 (kg/lb) (ton/ MT) x 1000 (g/kg) = 780,000 g/MT

Calculate Emission Rate

Emission Rate =s8.89E-03 MT/s x 780,000 g/MT Emission Rate = 6,933 g/s

Table B.1. Emission Factors and Rates for Pollutants Vented from Bagasse Boilers

Source Pollutant Bagasse Feed Rate Emission Factor Emission Rate otonineWdrop ( lb/ton g/MT g/s Boiler No. 1 (Si) CO2 32 1560 780,000 6,933 bagasse feed1.2 600 5.3 systems______Particulate 31.2 (1) 15,600 139 Boiler No. 2 & 3 CO2 36 1560 780,000 7800 Emission Rate (g/s) =1.2 600 6 MT______Particulate 31.2 (1) 15,600 156 Boiler No. 4 (S3) CO2 32 1560 780,000 6,933 Bagasse Feed= Rate: 32MT/h1.2 600 5.3 ______ParxtP i-cuIa teI 31.2 (1) 1 15,600 1 139 Note (1) - USEPA emissions factor was multiplied by 2 to account for unwashed cane. This may in fact be overstated and is therefore considered conservative. Boiler Emission Summary (Screen 3 Dispersion Model Results)

Contaminant Emission Rate 1 Max Concentration (gg/m3) Standards Wgs) 3 1 -hr avg -8-h-v'g hravg Annual Avg 3 (gg/m ) Avg. time Reference

Carbon Dioxide 21,666 324,773 227,341 129,909 25,982 200 8 hr Uganda AQS 4 Nitrous Oxides 17 255 178 102 20 125 6 24 hr Uganda AQS Nitrogen Dioxide 12 180 126 72 14 100 Annual NAAQS 100 Annual Equador 5 300 24 hr Uganda AQS Total Particulate 434 6,506 4,554 2,602 520 80 24 hr Equador I______I______150 24 hr N A A QS (PM -10) Maximum Screen 3 Dispersion Factors (DF) for 1-hour average 14.99 lig/m3 at base case of 1 g/s. 3 (I.e. 14.99 l_g/m /1 g/s x 21,666 g/s = 324,788 pg/m3)

Technical Notes: (1) Represents the sum total of emissions from all boilers stacks (2) Max Conc. = Emission rate (g/s) x Dispersion Factor (3) USEPA Multiplying factors to convert 1-hour averaging time concentration to other averaging periods:

Averaging Period Multiplying Factor 8 hr 0.7 24 hr 0.4 Annual 0.08 Ref: Screening Procedures for estimating the Air Quality Impact of Stations Sources, revised EPA-454/R-92-019 p.4-16

(4) Proposed Environmental Air Quality Standards and Guidelines for Uganda Fourth Draft February 2002 (5) Emission rate has been multiplied by and factor of 2 to account for the fact that KSW does not pre-wash cane (6) Nitrogen dioxides are assumed to be 70% of total nitrous oxides as per USEPA (7) NAAQS = US EPA National Ambient Air Quality Standard Kakira Boilers - Estimated Carbon Dioxide Emitted During Operation

250000 ______. . ______

~. 200000 -- - -- _ _------______- - - _ _ _ _ _ - - - -

-_ - *n 150000 ______. .______. ______°50000 C

* ~100000 - -_ _ - -- _ _ _ _ -- ______- - _ _ ------_ _ _

0 C.) 0 0 -

Uganda AQS Standard - 2001ig/m3

Distance from Plant (m)

H-Current Operation 00FutureOper 07/02/03 13:08:08 SCREEN3 MODEL RUN - VERSION DATED 96043 *'

Kakira Current Operation - C02

COMPLEX TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 10833.0 STACK HT (M) = 38.1000 STACK DIAMETER (M) = 2.1000 STACK VELOCITY (M/S) = 9.6143 STACK GAS TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 29.298 M**4/S**3; MOM. FLUX = 73.185 M**4/S'*2.

FINAL STABLE PLUME HEIGHT (M) = 94.1 DISTANCE TO FINAL RISE (M) = 151.3

'VALLEY 24-HR CALCS **SIMPLE TERRAIN 24-HR CALCS** TERR MAX 24-HR PLUME HT PLUME HT HT DIST CONC CONC ABOVE STK CONC ABOVE STK U10M USTK (M) (M) (UG/M''3) (UG/M*-3) BASE (M) (UG/M'*3) HGT (M) SC (MIS)

157. 3200. .2043E+05 .2043E+05 94.1 .0000 .0 0 .0 .0 07/02/03 13:08:08 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Current Operation -C02

SIMPLE TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 10833.0 STACK HEIGHT (M) = 38.1000 STK INSIDE DIAM (M) = 2.1000 STK EXIT VELOCITY (M/S)= 9.6143 STK GAS EXIT TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL BUILDING HEIGHT (M) = 25.0000 MIN HORIZ BLDG DIM (M) = 145.2000 MAX HORIZ BLDG DIM (M) = 226.6000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED. BUOY. FLUX = 29.298 M*4/S**3; MOM. FLUX = 73.185 M*^4/S*'2.

FULL METEOROLOGY

SCREEN AUTOMATED DISTANCES

-TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES

DIST CONC U1OM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M*'3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

1 0 1 1 1.1 320 283.79 2.8 2.77 NO 100 1.58E+05 6 4 8.3 10000 49.37 5.46 19.52 HS 200 1.62E+05 6 4 8.3 10000 56.84 9.65 26.51 HS 300 1.25E+05 6 4 8.3 10000 63.12 13.54 31.12 HS 400 7.36E+04 6 4 8.3 10000 68.71 17.27 31.89 HS 500 5.97E+04 4 10 12.2 3200 57.18 36.69 35.69 HS 600 5.47E+04 4 10 12.2 3200 57.18 43.18 37.6 HS 700 6.12E+04 1 1 1.1 320 283.79 167.71 224.58 NO 800 6.43E+04 1 1 1.1 320 283.79 185.21 291.58 NO 900 6.05E+04 1 1 1.1 320 283.79 202.72 369.85 NO 1000 5.59E+04 1 1 1.1 320 283.79 220.2 459.25 NO 1100 5.18E+04 1 1 1.1 320 283.79 237.6 559.71 NO 1200 4.82E+04 1 1 1.1 320 283.79 254.92 671.27 NO 1300 4.52E+04 1 1 1.1 320 283.79 272.14 793.94 NO 1400 4.25E+04 1 1 1.1 320 283.79 289.27 927.8 NO 1500 4.02E+04 1 1 1.1 320 283.79 306.3 1072.9 NO 1600 3.81E+04 1 1 1.1 320 283.79 323.23 1229.31 NO 1700 3.67E+04 2 1 1.1 320 283.79 257.14 207.85 NO 1800 3.73E+04 2 1 1.1 320 283.79 269.57 219.81 NO 1900 3.75E+04 2 1 1.1 320 283.79 281.95 231.9 NO 2000 3.74E+04 2 1 1.1 320 283.79 294.29 244.13 NO 2100 3.70E+04 2 1 1.1 320 .283.79 306.59 256.47 NO 2200 3.64E+04 2 1 1.1 320 283.79 318.83 268.92 NO 2300 3.56E+04 2 1 1.1 320 283.79 331.04 281.46 NO 2400 3.48E+04 2 1 1.1 320 283.79 343.19 294.09 NO 2500 3.39E+04 2 1 1.1 320 283.79 355.3 306.81 NO 2600 3.30E+04 2 1 1.1 320 283.79 367.37 319.61 NO 2700 3.21E+04 2 1 1.1 320 283.79 379.39 332.48 NO 2800 3.12E+04 2 1 1.1 320 283.79 391.37 345.43 NO 2900 3.04E+04 2 1 1.1 320 283.79 403.3 358.43 NO 3000 2.96E+04 2 1 1.1 320 283.79 415.19 371.5 NO 3500 2.81E+04 5 1.5 2.4 10000 106.58 159.96 57.53 HS 4000 2.77E+04 5 1.5 2.4 10000 106.58 180.12 60.2 HS 4500 2.71E+04 5 1.5 2.4 10000 106.58 200.04 62.75 HS 5000 2.64E+04 5 1.5 2.4 10000 106.58 219.73 65.2 HS 5500 2.57E+04 5 1.5 2.4 10000 106.58 239.22 67.57 HS 6000 2.58E+04 5 1 1.6 10000 116.49 258.74 65.06 NO 6500 2.59E+04 5 1 1.6 10000 116.49 277.84 67.43 NO 7000 2.58E+04 5 1 1.6 10000 116.49 296.78 69.73 NO 7500 2.56E+04 5 1 1.6 10000 116.49 315.57 71.95 NO 8000 2.53E+04 5 1 1.6 10000 116.49 334.22 74.11 NO 8500 2.50E+04 5 1 1.6 10000 116.49 352.73 76.2 NO 9000 2.46E+04 5 1 1.6 10000 116.49 371.12 78.25 NO 9500 2.41E+04 5 1 1.6 10000 116.49 389.39 80.24 NO 10000 2.36E+04 5 1 1.6 10000 116.49 407.54 82.18 NO 15000 1-87E+04 6 1 2.1 10000 97.6 388.8 59.77 HS 20000 1.63E+04 6 1 2.1 10000 97.6 501.24 64.58 HS

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 1. M: 183 1.62E+05 6 4 8.3 10000 55.75 9 25.4 HS

DWASH= MEANS NO CALC MADE (CONC = 0.0) DWASH=NO MEANS NO BUILDING DOWNWASH USED DWASH=HS MEANS HUBER-SNYDER DOWNWASH USED DWASH=SS MEANS SCHULMAN-SCIRE DOWNWASH USED DWASH=NA MEANS DOWNWASH NOT APPLICABLE, X<3*LB

SCREEN DISCRETE DISTANCES

'''TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES***

DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M^^3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M) DWASH

650 5.44E+04 1 1 1.1 320 283.79 158.98 195.4 NO

^ SUMMARY OF TERRAIN HEIGHTS ENTERED FOR ^

^ SIMPLE ELEVATED TERRAIN PROCEDURE *

TERRAIN DISTANCE RANGE (M) HT (M) MINIMUM MAXIMUM

0. 1. 20000. 0. 650. --

REGULATORY (Default) PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL (BRODE, 1988)

CAVITY CALCULATION - 1 CAVITY CALCULATION - 2 CONC (UG/M**3) = .0000 CONC (UG/M**3) = .0000 CRITWS @10M (M/S) = 99.99 CRITWS @10M (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 25.00 CAVITY HT (M) = 25.00 CAVITY LENGTH (M) = 121.42 CAVITY LENGTH (M) = 103.63 ALONGWIND DIM (M) = 145.20 ALONGWIND DIM (M) = 226.60

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET = 0.0 END OF CAVITY CALCULATIONS

...... ***...... SUMMARY OF SCREEN MODEL RESULTS

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M*'3) MAX (M) HT (M)

SIMPLE TERRAIN .1624E+06 183. 0.

COMPLEX TERRAIN .2043E+05 3200. 157. (24-HR CONC)

REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS '' 07/02/03 13:14:36 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Future Operation - C02

COMPLEX TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) 21666.0 STACK HT (M) = 38.1000 STACK DIAMETER (M) = 2.1000 STACK VELOCITY (M/S) = 9.6143 STACK GAS TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 29.298 M''4/S''3; MOM. FLUX = 73.185 M''4/S*'2.

FINAL STABLE PLUME HEIGHT (M) = 94.1 DISTANCE TO FINAL RISE (M) = 151.3

*VALLEY 24-HR CALCS' -SIMPLE TERRAIN 24-HR CALCS** TERR MAX 24-HR PLUME HT PLUME HT HT DIST CONC CONC ABOVE STK CONC ABOVE STK U10M USTK (M) (M) (UG/M*'3) (UG/M''3) BASE (M) (UG/M*'3) HGT (M) SC (M/S)

157. 3200. .4086E+05 .4086E+05 94.1 .0000 .0 0 .0 .0 07/02/03 13:14:36 - SCREEN3 MODEL RUN - VERSION DATED 96043

Kakira Future Operation - C02

SIMPLE TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 21666.0 STACK HEIGHT (M) = 38.1000 STK INSIDE DIAM (M) = 2.1000 STK EXIT VELOCITY (M/S)= 9.6143 STK GAS EXIT TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL BUILDING HEIGHT (M) = 25.0000 MIN HORIZ BLDG DIM (M) = 145.2000 MAX HORIZ BLDG DIM (M) = 226.6000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED. BUOY. FLUX = 29.298 M**4/S**3; MOM. FLUX = 73.185 M*^4/S**2.

FULL METEOROLOGY

-SCREEN AUTOMATED DISTANCES-

TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES

DIST CONC U1OM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M*^3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M) DWASH

1 0 1 1 1.1 320 283.79 2.8 2.77 NO 100 3.16E+05 6 4 8.3 10000 49.37 5.46 19.52 HS 200 3.24E+05 6 4 8.3 10000 56.84 9.65 26.51 HS 300 2.51E+05 6 4 8.3 10000 63.12 13.54 31.12 HS 400 1.47E+05 6 4 8.3 10000 68.71 17.27 31.89 HS 500 1.19E+05 4 10 12.2 3200 57.18 36.69 35.69 HS 600 1.09E+05 4 10 12.2 3200 57.18 43.18 37.6 HS 700 1.23E+05 1 1 1.1 320 283.79 167.71 224.58 NO 800 1.29E+05 1 1 1.1 320 283.79 185.21 291.58 NO 900 1.21E+05 1 1 1.1 320 283.79 202.72 369.85 NO 1000 1.12E+05 1 1 1.1 320 283.79 220.2 459.25 NO 1100 1.04E+05 1 1 1.1 320 283.79 237.6 559.71 NO 1200 9.65E+04 1 1 1.1 320 283.79 254.92 671.27 NO 1300 9.04E+04 1 1 1.1 320 283.79 272.14 793.94 NO 1400 8.50E+04 1 1 1.1 320 283.79 289.27 927.8 NO 1500 8.03E+04 1 1 1.1 320 283.79 306.3 1072.9 NO 1600 7.61E+04 1 1 1.1 320 283.79 323.23 1229.31 NO 1700 7.33E+04 2 1 1.1 320 283.79 257.14 207.85 NO 1800 7.46E+04 2 1 1.1 320 283.79 269.57 219.81 NO 1900 7.50E+04 2 1 1.1 320 283.79 281.95 231.9 NO 2000 7.47E+04 2 1 1.1 320 283.79 294.29 244.13 NO 2100 7.39E+04 2 1 1.1 320 283.79 306.59 256.47 NO 2200 7.27E+04 2 1 1.1 320 283.79 318.83 268.92 NO 2300 7.12E+04 2 1 1.1 320 283.79 331.04 281.46 NO 2400 6.96E+04 2 1 1.1 320 283.79 343.19 294.09 NO 2500 6.78E+04 2 1 1.1 320 283.79 355.3 306.81 NO 2600 6.60E+04 2 1 1.1 320 283.79 367.37 319.61 NO 2700 6.42E+04 2 1 1.1 320 283.79 379.39 332.48 NO 2800 6.25E+04 2 1 1.1 320 283.79 391.37 345.43 NO 2900 6.08E+04 2 1 1.1 320 283.79 403.3 358.43 NO 3000 5.91E+04 2 1 1.1 320 283.79 415.19 371.5 NO 3500 5.63E+04 5 1.5 2.4 10000 106.58 159.96 57.53 HS 4000 5.54E+04 5 1.5 2.4 10000 106.58 180.12 60.2 HS 4500 5.42E+04 5 1.5 2.4 10000 106.58 200.04 62.75 HS 5000 5.28E+04 5 1.5 2.4 10000 106.58 219.73 65.2 HS 5500 5.13E+04 5 1.5 2.4 10000 106.58 239.22 67.57 HS 6000 5.16E+04 5 1 1.6 10000 116.49 258.74 65.06 NO 6500 5.18E+04 5 1 1.6 10000 116.49 277.84 67.43 NO 7000 5.17E+04 5 1 1.6 10000 116.49 296.78 69.73 NO 7500 5.13E+04 5 1 1.6 10000 116.49 315.57 71.95 NO .8000 5.07E+04 5 1 1.6 10000 116.49 334.22 74.11 NO 8500 4.99E+04 5 1 1.6 10000 116.49 352.73 76.2 NO 9000 4.91E+04 5 1 1.6 10000 116.49 371.12 78.25 NO 9500 4.82E+04 5 1 1.6 10000 116.49 389.39 80.24 NO 10000 4.72E+04 5 1 1.6 10000 116.49 407.54 82.18 NO 15000 3.75E+04 6 1 2.1 10000 97.6 388.8 59.77 HS 20000 3.26E+04 6 1 2.1 10000 97.6 501.24 64.58 HS

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 1. M: 183 3.25E+05 6 4 8.3 10000 55.75 9 25.4 HS

SCREEN DISCRETE DISTANCES

***TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES***

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

650 1.09E+05 1 1 1.1 320 283.79 158.98 195.4 NO

^ SUMMARY OF TERRAIN HEIGHTS ENTERED FOR ^ ' SIMPLE ELEVATED TERRAIN PROCEDURE

TERRAIN DISTANCE RANGE (M) HT (M) MINIMUM MAXIMUM

0. 1. 20000. 0. 650. --

REGULATORY (Default) PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL (BRODE, 1988)

CAVITY CALCULATION - I CAVITY CALCULATION - 2 CONC (UG/M**3) = .0000 CONC (UG/M'*3) = .0000 CRIT WS @10M (M/S) = 99.99 CRIT WS @10M (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 25.00 CAVITY HT (M) = 25.00 CAVITY LENGTH (M) = 121.42 CAVITY LENGTH (M) = 103.63 ALONGWIND DIM (M) = 145.20 ALONGWIND DIM (M) = 226.60

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET = 0.0 END OF CAVITY CALCULATIONS

SUMMARY OF SCREEN MODEL RESULTS

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UGI/M*3) MAX (M) HT (M)

SIMPLE TERRAIN .3247E+06 183. 0.

COMPLEX TERRAIN .4086E+05 3200. 157. (24-HR CONC)

**REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS * Kakira Boilers - Estimated Nitrous Oxides Emitted During Operation

140 Uganda AQS Standard - 125 Pg/m3

120 ______-______.______--- ______

-ooJ

._ _ 10080 - . . _-- . _-___ ---- __-- \ - _ - . . _ 0 - _- ______------._ --- ._. _ _ ._ ___ _-

0I z

6 0 - - -~ ~~~- - - - - _-- 20 _-- _--- .__ _

0 -~~~~~~~

Distance from Plant (in)

- Current Oper-ati-on- Future Operationj 07/02/03 13:22:50 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Current Operation - Nitrous Oxides

COMPLEX TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 8.30000 STACK HT (M) = 38.1000 STACK DIAMETER (M) = 2.1000 STACK VELOCITY (M/S) = 9.6143 STACK GAS TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 29.298 M**4/S**3; MOM. FLUX = 73.185 M**4/S**2.

FINAL STABLE PLUME HEIGHT (M) = 94.1 DISTANCE TO FINAL RISE (M) = 151.3

*VALLEY 24-HR CALCS* **SIMPLE TERRAIN 24-HR CALCS** TERR MAX 24-HR PLUME HT PLUME HT HT DIST CONC CONC ABOVE STK CONC ABOVE STK U10M USTK (M) (M) (UG/M*-3) (UG/M**3) BASE (M) (UG/M'*3) HGT (M) SC (M/S)

157. 3200. 15.65 15.65 94.1 .0000 .0 0 .0 .0 07/02/03 13:22:50 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Current Operation - Nitrous Oxides

SIMPLE TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 8.30000 STACK HEIGHT (M) = 38.1000 STK INSIDE DIAM (M) = 2.1000 STK EXIT VELOCITY (M/S)= 9.6143 STK GAS EXIT TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL BUILDING HEIGHT (M) = 25.0000 MIN HORIZ BLDG DIM (M) = 145.2000 MAX HORIZ BLDG DIM (M) = 226.6000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED. BUOY. FLUX = 29.298 M--4/S-'3; MOM. FLUX = 73.185 M**4/S**2.

FULL METEOROLOGY

SCREEN AUTOMATED DISTANCES

TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UGIM**3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

1 0 1 1 1.1 320 283.79 2.8 2.77 NO 100 121.2 6 4 8.3 10000 49.37 5.46 19.52 HS 200 124.2 6 4 8.3 10000 56.84 9.65 26.51 HS 300 96 6 4 8.3 10000 63:12 13.54 31.12 HS 400 56.42 6 4 8.3 10000 68.71 17.27 31.89 HS 500 45.74 4 10 12.2 3200 57.18 36.69 35.69 HS 600 41.89 4 10 12.2 3200 57.18 43.18 37.6 HS 700 46.92 1 1 1.1 320 283.79 167.71 224.58 NO 800 49.29 1 1 1.1 320 283.79 185.21 291.58 NO 900 46.36 1 1 1.1 320 283.79 202.72 369.85 NO 1000 42.79 1 1 1.1 320 283.79 220.2 459.25 NO 1100 39.66 1 1 1.1 320 283.79 237.6 559.71 NO 1200 36.96 1 1 1.1 320 283.79 254.92 671.27 NO 1300 34.62 1 1 1.1 320 283.79 272.14 793.94 NO 1400 32.57 1 1 1.1 320 283.79 289.27 927.8 NO 1500 30.76 1 1 1.1 320 283.79 306.3 1072.9 NO 1600 29.15 1 1 1.1 320 283.79 323.23 1229.31 NO 1700 28.09 2 1 1.1 320 283.79 257.14 207.85 NO 1800 28.57 2 1 1.1 320 283.79 269.57 219.81 NO 1900 28.73 2 1 1.1 320 283.79 281.95 231.9 NO 2000 28.62 2 1 1.1 320 283.79 294.29 244.13 NO 2100 28.31 2 1 1.1 320 283.79 306.59 256.47 NO 2200 27.86 2 1 1.1 320 283.79 318.83 268.92 NO 2300 27.29 2 1 1.1 320 283.79 331.04 281.46 NO 2400 26.66 2 1 1.1 320 283.79 343.19 294.09 NO 2500 25.99 2 1 1.1 320 283.79 355.3 306.81 NO 2600 25.3 2 1 1.1 320 283.79 367.37 319.61 NO 2700 24.61 2 1 1.1 320 283.79 379.39 332.48 NO 2800 23.93 2 1 1.1 320 283.79 391.37 345.43 NO 2900 23.27 2 1 1.1 320 283.79 403.3 358.43 NO 3000 22.64 2 1 1.1 320 283.79 415.19 371.5 NO 3500 21.55 5 1.5 2.4 10000 106.58 159.96 57.53 HS 4000 21.22 5 1.5 2.4 10000 106.58 180.12 60.2 HS 4500 20.77 5 1.5 2.4 10000 106.58 200.04 62.75 HS 5000 20.24 5 1.5 2.4 10000 106.58 219.73 65.2 HS 5500 19.67 5 1.5 2.4 10000 106.58 239.22 67.57 HS 6000 19.78 5 1 1.6 10000 116.49 258.74 65.06 NO 6500 19.86 5 1 1.6 10000 116.49 277.84 67.43 NO 7000 19.8 5 1 1.6 10000 116.49 296.78 69.73 NO 7500 19.65 5 1 1.6 10000 116.49 315.57 71.95 NO 8000 19.42 5 1 1.6 10000 116.49 334.22 74.11 NO 8500 19.13 5 1 1.6 10000 116.49 352.73 76.2 NO 9000 18.81 5 1 1.6 10000 116.49 371.12 78.25 NO 9500 18.46 5 1 1.6 10000 116.49 389.39 80.24 NO 10000 18.09 5 1 1.6 10000 116.49 407.54 82.18 NO 15000 14.36 6 1 2.1 10000 97.6 388.8 59.77 HS 20000 12.48 6 1 2.1 10000 97.6 501.24 64.58 HS

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 1. M: 183 124.4 6 4 8.3 10000 55.75 9 25.4 HS

SCREEN DISCRETE DISTANCES

^^^TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES***

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M^^3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

650 41.68 1 1 1.1 320 283.79 158.98 195.4 NO

^ SUMMARY OF TERRAIN HEIGHTS ENTERED FOR ^

' SIMPLE ELEVATED TERRAIN PROCEDURE *

TERRAIN DISTANCE RANGE (M) HT (M) MINIMUM MAXIMUM

0. 1. 20000. 0. 650. -

REGULATORY (Default) PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL (BRODE, 1988)

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET = 0.0 END OF CAVITY CALCULATIONS

SUMMARY OF SCREEN MODEL RESULTS

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M''3) MAX (M) HT (M)

SIMPLE TERRAIN 124.4 183. 0.

COMPLEX TERRAIN 15.65 3200. 157. (24-HR CONC)

'' REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS ** 07/02/03 1317:47 SCREEN3 MODEL RUN 1:4 VERSION DATED 96043

Kakira Future Operation - Nitrous Oxides

COMPLEX TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 17.0000 STACK HT (M) = 38.1000 STACK DIAMETER (M) = 2.1000 STACK VELOCITY (M/S) = 9.6143 STACK GAS TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 29.298 M**4/S**3; MOM. FLUX = 73.185 M**4/S**2.

FINAL STABLE PLUME HEIGHT (M) = 94.1 DISTANCE TO FINAL RISE (M) = 151.3

'VALLEY 24-HR CALCS* -SIMPLE TERRAIN 24-HR CALCS** TERR MAX 24-HR PLUME HT PLUME HT HT DIST CONC CONC ABOVE STK CONC ABOVE STK U10M USTK (M) (M) (UG/M*'3) (UG/M'*3) BASE (M) (UG/M**3) HGT(M) SC (M/S)

157. 3200. 32.06 32.06 94.1 .0000 .0 0 .0 .0 07/02/03 13:17:47 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Current Operation - Nitrous Oxides

SIMPLE TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 17.0000 STACK HEIGHT (M) = 38.1000 STK INSIDE DIAM (M) = 2.1000 STK EXIT VELOCITY (M/S)= 9.6143 STK GAS EXIT TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL BUILDING HEIGHT (M) = 25.0000 MIN HORIZ BLDG DIM (M) = 145.2000 MAX HORIZ BLDG DIM (M) = 226.6000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED. BUOY. FLUX = 29.298 M**4/S**3; MOM. FLUX = 73.185 M**4/S^*2.

FULL METEOROLOGY

SCREEN AUTOMATED DISTANCES

TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M) DWASH

1 0 1 1 1.1 320 283.79 2.8 2.77 NO 100 248.3 6 4 8.3 10000 49.37 5.46 19.52 HS 200 254.4 6 4 8.3 10000 56.84 9.65 26.51 HS 300 196.6 6 4 8.3 10000 63.12 13.54 31.12 HS 400 115.6 6 4 8.3 10000 68.71 17.27 31.89 HS 500 93.68 4 10 12.2 3200 57.18 36.69 35.69 HS 600 85.8 4 10 12.2 3200 57.18 43.18 37.6 HS 700 96.11 1 1 1.1 320 283.79 167.71 224.58 NO 800 101 1 1 1.1 320 283.79 185.21 291.58 NO 900 94.96 1 1 1.1 320 283.79 202.72 369.85 NO 1000 87.64 1 1 1.1 320 283.79 220.2 459.25 NO 1100 81.23 1 1 1.1 320 283.79 237.6 559.71 NO 1200 75.71 1 1 1.1 320 283.79 254.92 671.27 NO 1300 70.92 1 1 1.1 320 283.79 272.14 793.94 NO 1400 66.72 1 1 1.1 320 283.79 289.27 927.8 NO 1500 63.01 1 1 1.1 320 283.79 306.3 1072.9 NO 1600 59.71 1 1 1.1 320 283.79 323.23 1229.31 NO 1700 57.53 2 1 1.1 320 283.79 257.14 207.85 NO 1800 58.52 2 1 1.1 320 283.79 269.57 219.81 NO 1900 58.84 2 1 1.1 320 283.79 281.95 231.9 NO 2000 58.62 2 1 1.1 320 283.79 294.29 244.13 NO 2100 57.99 2 1 1.1 320 283.79 306.59 256.47 NO 2200 57.05 2 1 1.1 320 283.79 318.83 268.92 NO 2300 55.9 2 1 1.1 320 283.79 331.04 281.46 NO 2400 54.6 2 1 1.1 320 283.79 343.19 294.09 NO 2500 53.23 2 1 1.1 320 283.79 355.3 306.81 NO 2600 51.82 2 1 1.1 320 283.79 367.37 319.61 NO 2700 50.41 2 1 1.1 320 283.79 379.39 332.48 NO 2800 49.02 2 1 1.1 320 283.79 391.37 345.43 NO 2900 47.67 2 1 1.1 320 283.79 403.3 358.43 NO 3000 46.37 2 1 1.1 320 283.79 415.19 371.5 NO 3500 44.13 5 1.5 2.4 10000 106.58 159.96 57.53 HS 4000 43.45 5 1.5 2.4 10000 106.58 180.12 60.2 HS 4500 42.53 5 1.5 2.4 10000 106.58 200.04 62.75 HS 5000 41.45 5 1.5 2.4 10000 106.58 219.73 65.2 HS 5500 40.28 5 1.5 2.4 10000 106.58 239.22 67.57 HS 6000 40.52 5 1 1.6 10000 116.49 258.74 65.06 NO 6500 40.67 5 1 1.6 10000 116.49 277.84 67.43 NO 7000 40.56 5 1 1.6 10000 116.49 296.78 69.73 NO 7500 40.24 5 1 1.6 10000 116.49 315.57 71.95 NO 8000 39.77 5 1 1.6 10000 116.49 334.22 74.11 NO 8500 39.19 5 1 1.6 10000 116.49 352.73 76.2 NO 9000 38.52 5 1 1.6 10000 116.49 371.12 78.25 NO 9500 37.8 5 1 1.6 10000 116.49 389.39 80.24 NO 10000 37.05 5 1 1.6 10000 116.49 407.54 82.18 NO 15000 29.41 6 1 2.1 10000 97.6 388.8 59.77 HS 20000 25.57 6 1 2.1 10000 97.6 501.24 64.58 HS

MAXIMUM 1-HR CONCENTRATION ATOR BEYOND 1. M: 183 254.8 6 4 8.3 10000 55.75 9 25.4 HS

SCREEN DISCRETE DISTANCES

'''TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES***

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M*'3) STAB (MIS) (M/S) (M) HT (M) Y (M) z (M) DWASH 650 85.37 1 1 1.1 320 283.79 158.98 195.4 NO

' SUMMARY-OF TERRAIN HEIGHTS ENTERED FOR ' * SIMPLE ELEVATED TERRAIN PROCEDURE *

TERRAIN DISTANCE RANGE (M) HT (M) MINIMUM MAXIMUM

0. 1. 20000. 0. 650. -

REGULATORY (Default) PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL (BRODE, 1988)

CAVITY CALCULATION - 1 CAVITY CALCULATION - 2 CONC (UG/M**3) = .0000 CONC (UG/M**3) = .0000 CRITWS @1OM (M/S)= 99.99 CRITWS @1OM (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 25.00 CAVITY HT (M) = 25.00 CAVITY LENGTH (M) = 121.42 CAVITY LENGTH (M) = 103.63 ALONGWIND DIM (M) = 145.20 ALONGWIND DIM (M) = 226.60

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONG SET = 0.0 END OF CAVITY CALCULATIONS

...... ***

SUMMARY OF SCREEN MODEL RESULTS

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M*'3) MAX (M) HT (M)

SIMPLE TERRAIN 254.8 183. 0.

COMPLEX TERRAIN 32.06 3200. 157. (24-HR CONC)

'' REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS Kakira Boilers - Estimated Nitrogen Dioxide Emitted During Operation

120

NAAQS and Eauador Standard - 1OOLtq/m 3) 100 _

> 80 .

0) -J

0 z

20 (U~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~l(

I 0 Distance from Plant (m)

L40_CurrentOperation __ Futu_t peration 07/02/03 13:29:52 SCREEN3 MODEL RUN 1:5 VERSION DATED 96043

Kakira Current Operation - Nitrogen Dioxide

COMPLEX TERRAIN iNPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 5.80000 STACK HT (M) = 38.1000 STACK DIAMETER (M) = 2.1000 STACK VELOCITY (M/S) = 9.6143 STACK GAS TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 29.298 M^-4/S^^3; MOM. FLUX = 73.185 M^^4/S*^2.

FINAL STABLE PLUME HEIGHT (M) = 94.1 DISTANCE TO FINAL RISE (M) = 151.3

*VALLEY 24-HR CALCS^ -SIMPLE TERRAIN 24-HR CALCS** TERR MAX 24-HR PLUME HT PLUME HT HT DIST CONC CONC ABOVE STK CONC ABOVE STK U10M USTK (M) (M) (UG/M^^3) (UG/M^^3) BASE (M) (UG/M^^3) HGT (M) SC (M/S)

157. 3200. 10.94 10.94 94.1 .0000 .0 0 .0 .0 07/02/03 13:29:52 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Current Operation - Nitrogen Dioxide

SIMPLE TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 5.80000 STACK HEIGHT (M) = 38.1000 STK INSIDE DIAM (M) = 2.1000 STK EXIT VELOCITY (M/S)= 9.6143 STK GAS EXIT TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL BUILDING HEIGHT (M) = 25.0000 MIN HORIZ BLDG DIM (M) = 145.2000 MAX HORIZ BLDG DIM (M) = 226.6000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED. BUOY. FLUX = 29.298 M^4/S**3; MOM. FLUX = 73.185 M^^4/S^^2.

FULL METEOROLOGY

SCREEN AUTOMATED DISTANCES

TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

1 0 1 1 1.1 320 283.79 2.8 2.77 NO 100 84.71 6 4 8.3 10000 49.37 5.46 19.52 HS 200 86.81 6 4 8.3 10000 56.84 9.65 26.51 HS 300 67.09 6 4 8.3 10000 63.12 13.54 31.12 HS 400 39.43 6 4 8.3 10000 68.71 17.27 31.89 HS 500 31.96 4 10 12.2 3200 57.18 36.69 35.69 HS 600 29.27 4 10 12.2 3200 57.18 43.18 37.6 HS 700 32.79 1 1 1.1 320 283.79 167.71 224.58 NO 800 34.44 1 1 1.1 320 283.79 185.21 291.58 NO 900 32.4 1 1 1.1 320 283.79 202.72 369.85 NO 1000 29.9 1 1 1.1 320 283.79 220.2 459.25 NO 1100 27.71 1 1 1.1 320 283.79 237.6 559.71 NO 1200 25.83 1 1 1.1 320 283.79 254.92 671.27 NO 1300 24.19 1 1 1.1 320 283.79 272.14 793.94 NO 1400 22.76 1 1 1.1 320 283.79 289.27 927.8 NO 1500 21.5 1 1 1.1 320 283.79 306.3 1072.9 NO 1600 20.37 1 1 1.1 320 283.79 323.23 1229.31 NO 1700 19.63 2 1 1.1 320 283.79 257.14 207.85 NO 1800 19.97 2 1 1.1 320 283.79 269.57 219.81 NO 1900 20.08 2 1 1.1 320 283.79 281.95 231.9 NO 2000 20 2 1 1.1 320 283.79 294.29 244.13 NO 2100 19.79 2 1 1.1 320 283.79 306.59 256.47 NO 2200 19.46 2 1 1.1 320 283.79 318.83 268.92 NO 2300 19.07 2 1 1.1 320 283.79 331.04 281.46 NO 2400 18.63 2 1 1.1 320 283.79 343.19 294.09 NO 2500 18.16 2 1 1.1 320 283.79 355.3 306.81 NO 2600 17.68 2 1 1.1 320 283.79 367.37 319.61 NO 2700 17.2 2 1 1.1 320 283.79 379.39 332.48 NO 2800 16.72 2 1 1.1 320 283.79 391.37 345.43 NO 2900 16.26 2 1 1.1 320 283.79 403.3 358.43 NO 3000 15.82 2 1 1.1 320 283.79 415.19 371.5 NO 3500 15.06 5 1.5 2.4 10000 106.58 159.96 57.53 HS 4000 14.83 5 1.5 2.4 10000 106.58 180.12 60.2 HS 4500 14.51 5 1.5 2.4 10000 106.58 200.04 62.75 HS 5000 14.14 5 1.5 2.4 10000 106.58 219.73 65.2 HS 5500 13.74 5 1.5 2.4 10000 106.58 239.22 67.57 HS 6000 13.82 5 1 1.6 10000 116.49 258.74 65.06 NO 6500 13.88 5 1 1.6 10000 116.49 277.84 67.43 NO 7000 13.84 5 1 1.6 10000 116.49 296.78 69.73 NO 7500 13.73 5 1 1.6 10000 116.49 315.57 71.95 NO 8000 13.57 5 1 1.6 10000 116.49 334.22 74.11 NO 8500 13.37 5 1 1.6 10000 116.49 352.73 76.2 NO 9000 13.14 5 1 1.6 10000 116.49 371.12 78.25 NO 9500 12.9 5 1 1.6 10000 116.49 389.39 80.24 NO 10000 12.64 5 1 1.6 10000 116.49 407.54 82.18 NO 15000 10.04 6 1 2.1 10000 97.6 388.8 59.77 HS 20000 8.723 6 1 2.1 10000 97.6 501.24 64.58 HS

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 1. M: 183 86.93 6 4 8.3 10000 55.75 9 25.4 HS

SCREEN DISCRETE DISTANCES

-TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES***

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M*^3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

650 29.13 1 1 1.1 320 283.79 158.98 195.4 NO

^ SUMMARY OF TERRAIN HEIGHTS ENTERED FOR

• SIMPLE ELEVATED TERRAIN PROCEDURE *

TERRAIN DISTANCE RANGE (M) HT (M) MINIMUM MAXIMUM

0. 1. 20000. 0. 650. -

REGULATORY (Default) PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL (BRODE, 1988)

CAVITY CALCULATION - 1 CAVITY CALCULATION - 2 CONC (UG/M''3) = .0000 CONC (UG/M**3) = .0000 CRIT WS @10M (M/S) = 99.99 CRIT WS @10M (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 25.00 CAVITY HT (M) = 25.00 CAVITY LENGTH (M) = 121.42 CAVITY LENGTH (M) = 103.63 ALONGWIND DIM (M) = 145.20 ALONGWIND DIM (M) = 226.60

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET = 0.0 END OF CAVITY CALCULATIONS

SUMMARY OF SCREEN MODEL RESULTS

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M*^3) MAX (M) HT (M)

SIMPLE TERRAIN 86.93 183. 0.

COMPLEX TERRAIN 10.94 3200. 157. (24-HR CONC)

^^ REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS ^^ 07/02/03 13:33:49 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Future Operation -Nitrogen Dioxide

COMPLEX TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 12.0000 STACK HT (M) = 38.1000 STACK DIAMETER (M) = 2.1000 STACK VELOCITY (MIS) = 9.6143 STACK GAS TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 29.298 M**4/S**3; MOM. FLUX = 73.185 M**4/S**2.

FINAL STABLE PLUME HEIGHT (M) = 94.1 DISTANCE TO FINAL RISE (M) = 151.3

*VALLEY 24-HR CALCS* -SIMPLE TERRAIN 24-HR CALCS** TERR MA-X 24-HR PLUME HT PLUME HT HT DIST CONC CONC ABOVE STK CONC ABOVE STK U10M USTK (M) (M) (UG/M*'3) (UG/M**3) BASE (M) (UG/M**3) HGT(M) SC (M/S)

157. 3200. 22.63 22.63 94.1 .0000 .0 0 .0 .0 07/02/03 13:33:49 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Future Operation - Nitrogen Dioxide

SIMPLE TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 12.0000 STACK HEIGHT (M) = 38.1000 STK INSIDE DIAM (M) = 2.1000 STK EXIT VELOCITY (M/S)= 9.6143 STK GAS EXIT TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL BUILDING HEIGHT (M) = 25.0000 MIN HORIZ BLDG DIM (M) = 145.2000 MAX HORIZ BLDG DIM (M) = 226.6000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED. BUOY. FLUX = 29.298 M**4/S'*3; MOM. FLUX = 73.185 M**4/S**2.

FULL METEOROLOGY

SCREEN AUTOMATED DISTANCES

TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M*'3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

1 0 1 1 1.1 320 283.79 2.8 2.77 NO 100 175.3 6 4 8.3 10000 49.37 5.46 19.52 HS 200 179.6 6 4 8.3 10000 56.84 9.65 26.51 HS 300 138.8 6 4 8.3 10000 63.12 13.54 31.12 HS 400 81.57 6 4 8.3 10000 68.71 17.27 31.89 HS 500 66.13 4 10 12.2 3200 57.18 36.69 35.69 HS 600 60.56 4 10 12.2 3200 57.18 43.18 37.6 HS 700 67.84 1 1 1.1 320 283.79 167.71 224.58 NO 800 71.26 1 1 1.1 320 283.79 185.21 291.58 NO 900 67.03 1 1 1.1 320 283.79 202.72 369.85 NO 1000 61.86 1 1 1.1 320 283.79 220.2 459.25 NO 1100 57.34 1 1 1.1 320 283.79 237.6 559.71 NO 1200 53.44 1 1 1.1 320 283.79 254.92 671.27 NO 1300 50.06 1 1 1.1 320 283.79 272.14 793.94 NO 1400 47.09 1 1 1.1 320 283.79 289.27 927.8 NO 1500 44.48 1 1 1.1 320 283.79 306.3 1072.9 NO 1600 42.15 1 1 1.1 320 283.79 323.23 1229.31 NO 1700 40.61 2 1 1.1 320 283.79 257.14 207.85 NO 1800 41.31 2 1 1.1 320 283.79 269.57 219.81 NO 1900 41.53 2 1 1.1 320 283.79 281.95 231.9 NO 2000 41.38 2 1 1.1 320 283.79 294.29 244.13 NO 2100 40.94 2 1 1.1 320 283.79 306.59 256.47 NO 2200 40.27 2 1 1.1 320 283.79 318.83 268.92 NO 2300 39.46 2 1 1.1 320 283.79 331.04 281.46 NO 2400 38.54 2 1 1.1 320 283.79 343.19 294.09 NO 2500 37.57 2 1 1.1 320 283.79 355.3 306.81 NO 2600 36.58 2 1 1.1 320 283.79 367.37 319.61 NO 2700 35.58 2 1 1.1 320 283.79 379.39 332.48 NO 2800 34.6 2 1 1.1 320 283.79 391.37 345.43 NO 2900 33.65 2 1 1.1 320 283.79 403.3 358.43 NO 3000 32.73 2 1 1.1 320 283.79 415.19 371.5 NO 3500 31.15 5 1.5 2.4 10000 106.58 159.96 57.53 HS 4000 30.67 5 1.5 2.4 10000 106.58 180.12 60.2 HS 4500 30.02 5 1.5 2.4 10000 106.58 200.04 62.75 HS 5000 29.26 5 1.5 2.4 10000 106.58 219.73 65.2 HS 5500 28.43 5 1.5 2.4 10000 106.58 239.22 67.57 HS 6000 28.6 5 1 1.6 10000 116.49 258.74 65.06 NO 6500 28.71 5 1 1.6 10000 116.49 277.84 67.43 NO 7000 28.63 5 1 1.6 10000 116.49 296.78 69.73 NO 7500 28.4 5 1 1.6 10000 116.49 315.57 71.95 NO 8000 28.07 5 1 1.6 10000 116.49 334.22 74.11 NO 8500 27.66 5 1 1.6 10000 116.49 352.73 76.2 NO 9000 27.19 5 1 1.6 10000 116.49 371.12 78.25 NO 9500 26.68 5 1 1.6 10000 116.49 389.39 80.24 NO 10000 26.15 5 1 1.6 10000 116.49 407.54 82.18 NO 15000 20.76 6 1 2.1 10000 97.6 388.8 59.77 HS 20000 18.05 6 1 2.1 10000 97.6 501.24 64.58 HS

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 1. M: 183 179.9 6 4 8.3 10000 55.75 9 25.4 HS

SCREEN DISCRETE DISTANCES

-*TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES*^*

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M--3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

650 60.26 1 1 1.1 320 283.79 158.98 195.4 NO

* SUMMARY OF TERRAIN HEIGHTS ENTERED FOR ^ * SIMPLE ELEVATED TERRAIN PROCEDURE

TERRAIN DISTANCE RANGE (M) HT (M) MINIMUM MAXIMUM

0. 1. 20000. 0. 650. --

REGULATORY (Default) PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL (BRODE, 1988)

CAVITY CALCULATION - 1* CAVITY CALCULATION -2 CONC (UG/M*-3) = .0000 CONC (UG/M**3) = .0000 CRITWS @1OM (M/S)= 99.99 CRITWS @10M (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 25.00 CAVITY HT (M) = 25.00 CAVITY LENGTH (M) = 121.42 CAVITY LENGTH (M) = 103.63 ALONGWIND DIM (M) = 145.20 ALONGWIND DIM (M) = 226.60

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET = 0.0 END OF CAVITY CALCULATIONS ...... *......

''' SUMMARY OF SCREEN MODEL RESULTS

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M*'3) MAX (M) HT (M)

SIMPLE TERRAIN 179.9 183. 0.

COMPLEX TERRAIN 22.63 3200. 157. (24-HR CONC)

*- REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS Kakira Boilers - Estimated Particulates Emitted During Operation

______3000

E 2500 - _

2000

______C) 2000 -_ - _-----_- __ __

C,0

LI) 1500 _

.2-

L) i, 1000 A .

Uqanda AQS Standard - 300Ltq/M3 .2| ------500 _ -_--- -

0 6o O°tz O z O N o 6o° (o°o o o o O°z v t22OOE2 O°e° 1

Distanceafrom Plantn(m)

-Current Operation --- Future Operation 07/02/03 12:56:07 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Current Operation - Particulates

COMPLEX TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 217.000 STACK HT (M) = 38.1000 STACK DIAMETER (M) = 2.1000 STACK VELOCITY (M/S) = 9.6143 STACK GAS TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 29.298 M*'4/S*'3; MOM. FLUX = 73.185 M*4/S**2.

FINAL STABLE PLUME HEIGHT (M) = 94.1 DISTANCE TO FINAL RISE (M) = 151.3

*VALLEY 24-HR CALCS* ''SIMPLE TERRAIN 24-HR CALCS-* TERR MAX 24-HR PLUME HT PLUME HT HT DIST CONC CONC ABOVE STK CONC ABOVE STK U10M USTK (M) (M) (UG/M''3) (UG/M*'3) BASE (M) (UG/M''3) HGT (M) SC (M/S)

157. 3200. 409.2 409.2 94.1 .0000 .0 0 .0 .0 07/02/03 12:56:07 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Present Operation - Particulates

SIMPLE TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 217.000 STACK HEIGHT (M) = 38.1000 STK INSIDE DIAM (M) = 2.1000 STK EXIT VELOCITY (M/S)= 9.6143 STK GAS EXIT TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL BUILDING HEIGHT (M) = 25.0000 MIN HORIZ BLDG DIM (M) = 145.2000 MAX HORIZ BLDG DIM (M) = 226.6000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED. BUOY. FLUX = 29.298 M''4/S**3; MOM. FLUX = 73.185 M'4/S^'2.

FULL METEOROLOGY

SCREEN AUTOMATED DISTANCES

TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES

SIGMA DIST CONC U1oM USTK MIX HT PLUME SIGMA z (M) DWASH (M) (UG/M^*3) STAB (M/S) (M/S) (M) HT (M) Y (M)

2.77 NO 1 0 1 1 1.1 320 283.79 2.8 19.52 HS 100 3169 6 4 8.3 10000 49.37 5.46 26.51 HS 200 3248 6 4 8.3 10000 56.84 9.65 31.12 HS 300 2510 6 4 8.3 10000 63.12 13.54 31.89 HS 400 1475 6 4 8.3 10000 68.71 17.27 35.69 HS 500 1196 4 10 12.2 3200 57.18 36.69 37.6 HS 600 1095 4 10 12.2 3200 57.18 43.18 224.58 NO 700 1227 1 1 1.1 320 283.79 167.71 291.58 NO 800 1289 1 1 1.1 320 283.79 185.21 369.85 NO 900 1212 1 1 1.1 320 283.79 202.72 459.25 NO 1000 1119 1 1 1.1 320 283.79 220.2 559.71 NO 1100 1037 1 1 1.1 320 283.79 237.6 671.27 NO 1200 966.4 1 1 1.1 320 283.79 254.92 793.94 NO 1300 905.2 1 1 1.1 320 283.79 272.14 927.8 NO 1400 851.6 1 1 1.1 320 283.79 289.27 1072.9 NO 1500 804.3 1 1 1.1 320 283.79 306.3 1229.31 NO 1600 762.1 1 1 1.1 320 283.79 323.23 207.85 NO 1700 734.4 2 1 1.1 320 283.79 257.14 219.81 NO 1800 747 2 1 1.1 320 283.79 269.57 231.9 NO 1900 751.1 2 1 1.1 320 283.79 281.95 244.13 NO 2000 748.3 2 1 1.1 320 283.79 294.29 256.47 NO 2100 740.2 2 1 1.1 320 283.79 306.59 268.92 NO 2200 728.3 2 1 1.1 320 283.79 318.83 281.46 NO 2300 713.5 2 1 1.1 320 283.79 331.04 294.09 NO 2400 697 2 1 1.1 320 283.79 343.19 306.81 NO 2500 679.4 2 1 1.1 320 283.79 355.3 319.61 NO 2600 661.4 2 1 1.1 320 283.79 367.37 332.48 NO 2700 643.4 2 1 1.1 320 283.79 379.39 391.37 345.43 NO 2800 . 625.7 2 1 1.1 320 283.79 358.43 NO 2900 608.5 2 1 1.1 320 283.79 403.3 371.5 NO 3000 591.9 2 1 1.1 320 283.79 415.19 57.53 HS 3500 563.3 5 1.5 2.4 10000 106.58 159.96 60.2 HS 4000 554.7 5 1.5 2.4 10000 106.58 180.12 62.75 HS 4500 542.9 5 1.5 2.4 10000 106.58 200.04 65.2 HS 5000 529.1 5 1.5 2.4 10000 106.58 219.73 67.57 HS 5500 514.2 5 1.5 2.4 10000 106.58 239.22 65.06 NO 6000 517.2 5 1 1.6 10000 116.49 258.74 67.43 NO 6500 519.2 5 1 1.6 10000 116.49 277.84 69.73 NO 7000 517.7 5 1 1.6 10000 116.49 296.78 71.95 NO 7500 513.6 5 1 1.6 10000 116.49 315.57 74.11 NO 8000 507.6 5 1 1.6 10000 116.49 334.22 76.2 NO 8500 500.2 5 1 1.6 10000 116.49 352.73 78.25 NO 9000 491.7 5 1 1.6 10000 116.49 371.12 80.24 NO 9500 482.6 5 1 1.6 10000 116.49 389.39 82.18 NO 10000 472.9 5 1 1.6 10000 116.49 407.54 59.77 HS 15000 375.5 6 1 2.1 10000 97.6 388.8 20000 326.4 6 1 2.1 10000 97.6 501.24 64.58 HS

MAXIMUM 1-HR CONCE TRATION AT OR BEYOND 1 M: 183 3253 6 4 8.3 10000 55.75 9 25.4 HS

'''TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES***

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

650 1090 1 1 1.1 320 283.79 158.98 195.4 NO

' SUMMARY OF TERRAIN HEIGHTS ENTERED FOR ' SIMPLE ELEVATED TERRAIN PROCEDURE

TERRAIN DISTANCE RANGE (M) HT (M) MINIMUM MAXIMUM

0. 1. 20000. 0. 650. --

t REGULATORY (Default) PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL (BRODE, 1988)

CAVITY CALCULATION - 1 CAVITY CALCULATION - 2 CONC (UG/M**3) = .0000 CONC (UG/M**3) = .0000 CRITWS @IOM (M/S) = 99.99 CRITWS @10M (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 CRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 25.00 CAVITY HT (M) = 25.00 CAVITY LENGTH (M) = 121.42 CAVITY LENGTH (M) = 103.63 ALONGWIND DIM (M) = 145.20 ALONGWIND DIM (M) = 226.60

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET = 0.0 END OF CAVITY CALCULATIONS

** SUMMARY OF SCREEN MODEL RESULTS

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M*^3) MAX (M) HT (M)

SIMPLE TERRAIN 3253. 183. 0.

COMPLEX TERRAIN 409.2 3200. 157. (24-HR CONC)

REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS 07/02/03 13:02:38 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Future Operation - Particulates

COMPLEX TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 434.000 STACK HT (M) = 38.1000 STACK DIAMETER (M) = 2.1000 STACK VELOCITY (MIS) = 9.6143 STACK GAS TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) =293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

BUOY. FLUX = 29.298 M^^4/S*^3; MOM. FLUX = 73.185 M**4/S**2.

FINAL STABLE PLUME HEIGHT (M) = 94.1 DISTANCE TO FINAL RISE (M) = 151.3

*VALLEY 24-HR CALCS* -SIMPLE TERRAIN 24-HR CALCS*^ TERR MAX 24-HR PLUME HT PLUME HT HT DIST CONC CONC ABOVE STK CONC ABOVE STK U10M USTK (M) (M) (UG/M*^3) (UG/M^^3) BASE (M) (UG/M*3) HGT (M) SC (MIS)

157. 3200. 818.4 818.4 94.1 .0000 .0 0 .0 .0 07/02/03 13:02:38 SCREEN3 MODEL RUN VERSION DATED 96043

Kakira Future Operation - Particulates

SIMPLE TERRAIN INPUTS: SOURCE TYPE = POINT EMISSION RATE (G/S) = 434.000 STACK HEIGHT (M) = 38.1000 STK INSIDE DIAM (M) = 2.1000 STK EXIT VELOCITY (M/S)= 9.6143 STK GAS EXIT TEMP (K) = 408.0000 AMBIENT AIR TEMP (K) = 293.0000 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL BUILDING HEIGHT (M) = 25.0000 MIN HORIZ BLDG DIM (M) = 145.2000 MAX HORIZ BLDG DIM (M) = 226.6000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED. BUOY. FLUX = 29.298 M^^4/S*'3; MOM. FLUX = 73.185 M**4/S^*2.

FULL METEOROLOGY

SCREEN AUTOMATED DISTANCES

-TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M^^3) STAB (M/S) (M/S) (M) HT (M) Y (M) z (M) DWASH

1 0 1 1 1.1 320 283.79 2.8 2.77 NO 100 6339 6 4 8.3 10000 49.37 5.46 19.52 HS 200 6496 6 4 8.3 10000 56.84 9.65 26.51 HS 300 5020 6 4 8.3 10000 63.12 13.54 31.12 HS 400 2950 6 4 8.3 10000 68.71 17.27 31.89 HS 500 2392 4 10 12.2 3200 57.18 36.69 35.69 HS 600 2190 4 10 12.2 3200 57.18 43.18 37.6 HS 700 2454 1 1 1.1 320 283.79 167.71 224.58 NO 800 2577 1 1 1.1 320 283.79 185.21 291.58 NO 900 2424 1 1 1.1 320 283.79 202.72 369.85 NO 1000 2237 1 1 1.1 320 283.79 220.2 459.25 NO 1100 2074 1 1 1.1 320 283.79 237.6 559.71 NO 1200 1933 1 1 1.1 320 283.79 254.92 671.27 NO 1300 1810 1 1 1.1 320 283.79 272.14 793.94 NO 1400 1703 1 1 1.1 320 283.79 289.27 927.8 NO 1500 1609 1 1 1.1 320 283.79 306.3 1072.9 NO 1600 1524 1 1 1.1 320 283.79 323.23 1229.31 NO 1700 1469 2 1 1.1 320 283.79 257.14 207.85 NO 1800 1494 2 1 1.1 320 283.79 269.57 219.81 NO 1900 1502 2 1 1.1 320 283.79 281.95 231.9 NO 2000 1497 2 1 1.1 320 283.79 294.29 244.13 NO 2100 1480 2 1 1.1 320 283.79 306.59 256.47 NO 2200 1457 2 1 1.1 320 283.79 318.83 268.92 NO 2300 1427 2 1 1.1 320 283.79 331.04 281.46 NO 2400 1394 2 1 1.1 320 283.79 343.19 294.09 NO 2500 1359 2 1 1.1 320 283.79 355.3 306.81 NO 2600 1323 2 1 1.1 320 283.79 367.37 319.61 NO 2700 1287 2 1 1.1 320 283.79 379.39 332.48 NO 2800 1251 2 1 1.1 320 283.79 391.37 345.43 NO 2900 1217 2 1 1.1 320 283.79 403.3 358.43 NO 3000 1184 2 1 1.1 320 283.79 415.19 371.5 NO 3500 1127 5 1.5 2.4 10000 106.58 159.96 57.53 HS 4000 1109 5 1.5 2.4 10000 106.58 180.12 60.2 HS 4500 1086 5 1.5 2.4 10000 106.58 200.04 62.75 HS 5000 1058 5 1.5 2.4 10000 106.58 219.73 65.2 HS 5500 1028 5 1.5 2.4 10000 106.58 239.22 67.57 HS 6000 1034 5 1 1.6 10000 116.49 258.74 65.06 NO 6500 1038 5 1 1.6 10000 116.49 277.84 67.43 NO 7000 1035 5 1 1.6 10000 116.49 296.78 69.73 NO 7500 1027 5 1 1.6 10000 116.49 315.57 71.95 NO 8000 1015 5 1 1.6 10000 116.49 334.22 74.11 NO 8500 1000 5 1 1.6 10000 116.49 352.73 76.2 NO 9000 983.5 5 1 1.6 10000 116.49 371.12 78.25 NO 9500 965.1 5 1 1.6 10000 116.49 389.39 80.24 NO 10000 945.8 5 1 1.6 10000 116.49 407.54 82.18 NO 15000 750.9 6 1 2.1 10000 97.6 388.8 59.77 MS 20000 652.8 6 1 2.1 10000 97.6 501.24 64.58 HS

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 1. M: 183 6505 6 4 8.3 10000 55.75 9 25.4 HS

SCREEN DISCRETE DISTANCES

-*TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES***

DIST CONC U1oM USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M) DWASH

650 2179 1 1 1.1 320 283.79 158.98 195.4 NO

^ SUMMARY OF TERRAIN HEIGHTS ENTERED FOR ' • SIMPLE ELEVATED TERRAIN PROCEDURE *

TERRAIN DISTANCE RANGE (M) HT (M) MINIMUM MAXIMUM

0. 1. 20000. 0. 650. -

REGULATORY (Default) PERFORMING CAVITY CALCULATIONS WITH ORIGINAL SCREEN CAVITY MODEL (BRODE, 1988)

' CAVITY CALCULATION - 1 CAVITY CALCULATION - 2 CONC (UG/M**3) = .0000 CONC (UG/M**3) = .0000 CRIT WS @10M (M/S) = 99.99 CRIT WS @1 OM (M/S) = 99.99 CRIT WS @ HS (M/S)= 99.99 CRIT WS @ HS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 DILUTION WS (M/S) = 99.99 CAVITY HT (M) = 25.00 CAVITY HT (M) = 25.00 CAVITYLENGTH (M) = 121.42 CAVITYLENGTH (M) = 103.63 ALONGWIND DIM (M) = 145.20 ALONGWIND DIM (M) = 226.60

CAVITY CONC NOT CALCULATED FOR CRIT WS > 20.0 M/S. CONC SET = 0.0 END OF CAVITY CALCULATIONS ......

...... SUMMARY OF SCREEN MODEL RESULTS

CALCULATION MAX CONC DiST TO TERRAIN PROCEDURE (UG/M**3) MAX (M) HT (M)

SIMPLE TERRAIN 6505. 183. 0.

COMPLEX TERRAIN 818.4 3200. 157 (24-HR CONC)

*- REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS *- Particulates Distance 1Hour Average 8 Hour Average 24 Hour Average Annual Average 1Hour Average 1 0 0 0 0 0 100 3169 2218.3 1267.6 253.52 1.58E+05 200 3248 2273.6 1299.2 259.84 1.62E+05 300 2510 1757 1004 200.8 1.25E+05 400 1475 1032.5 590 118 7.36E+04 500 1196 837.2 478.4 95.68 5.97E+04 600 1095 766.5 438 87.6 5.47E+04 700 1227 858.9 490.8 98.16 6.12E+04 800 1289 902.3 515.6 103.12 6.43E+04 900 1212 848.4 484.8 96.96 6.05E+04 1000 1119 783.3 447.6 89.52 5.59E+04 1100 1037 725.9 414.8 82.96 5.18E+04 1200 966.4 676.48 386.56 77.312 4.82E+04 1300 905.2 633.64 362.08 72.416 4.52E+04 1400 851.6 596.12 340.64 68.128 4.25E+04 1500 804.3 563.01 321.72 64.344 4.02E+04 1600 762.1 533.47 304.84 60.968 3.81EE+04 1700 734.4 514.08 293.76 58.752 3.67E+04 1800 747 522.9 298.8 59.76 3.73E+04 1900 751.1 525.77 300.44 60.088 3.75E+04 2000 748.3 523.81 299.32 59.864 3.74E+04 2100 740.2 518.14 296.08 59.216 3.70E+04 2200 728.3 509.81 291.32 58.264 3.64E+04 2300 713.5 499.45 285.4 57.08 3.56E+04 2400 697 487.9 278.8 55.76 3.48E+04 2500 679.4 475.58 271.76 54.352 3.39E+04 2600 661.4 462.98 264.56 52.912 3.30E+04 2700 643.4 450.38 257.36 51.472 3.21 E+04 2800 625.7 437.99 250.28 50.056 3.12E+04 2900 608.5 425.95 243.4 48.68 3.04E+04 3000 591.9 414.33 236.76 47.352 2.96E+04 3500 563.3 394.31 225.32 45.064 2.81 E+04 4000 554.7 388.29 221.88 44.376 2.77E+04 4500 542.9 380.03 217.16 43.432 2.71E+04 5000 529.1 370.37 211.64 42.328 2.64E+04 5500 514.2 359.94 205.68 41.136 2.57E+04 6000 517.2 362.04 206.88 41.376 2.58E+04 6500 519.2 363.44 207.68 41.536 2.59E+04 7000 517.7 362.39 207.08 41.416 2.58E+04 7500 513.6 359.52 205.44 41.088 2.56E+04 8000 507.6 355.32 203.04 40.608 2.53E+04 8500 500.2 350.14 200.08 40.016 2.50E+04 9000 491.7 344.19 196.68 39.336 2.46E+04 9500 482.6 337.82 193.04 38.608 2.41E+04 10000 472.9 331.03 189.16 37.832 2.36E+04 15000 375.5 262.85 150.2 30.04 1.87E+04 20000 326.4 228.48 130.56 26.112 1.63E+04 C02 Nitrous Oxides 8 Hour Average 24 Hour Average Annual Average 1Hour Average 8 Hour Average 24 Hour Average 0 0 0 0 0 0 110740 63280 12656 121.2 84.84 48.48 113470 64840 12968 124.2 86.94 49.68 87710 50120 10024 96 67.2 38.4 51548 29456 5891.2 56.42 39.494 22.568 41790 23880 4776 45.74 32.018 18.296 38269 21868 4373.6 41.89 29.323 16.756 42868 24496 4899.2 46.92 32.844 18.768 45031 25732 5146.4 49.29 34.503 19.716 42357 24204 4840.8 46.36 32.452 18.544 39095 22340 4468 42.79 29.953 17.116 36232 20704 4140.8 39.66 27.762 15.864 33768 19296 3859.2 36.96 25.872 14.784 31633 18076 3615.2 34.62 24.234 13.848 29757 17004 3400.8 32.57 22.799 13.028 28105 16060 3212 30.76 21.532 12.304 26635 15220 3044 29.15 20.405 11.66 25662 14664 2932.8 28.09 19.663 11.236 26103 14916 2983.2 28.57 19.999 11.428 26250 15000 3000 28.73 20.111 11.492 26152 14944 2988.8 28.62 20.034 11.448 25865 14780 2956 28.31 19.817 11.324 25452 14544 2908.8 27.86 19.502 11.144 24934 14248 2849.6 27.29 19.103 10.916 24353 13916 2783.2 26.66 18.662 10.664 23744 13568 2713.6 25.99 18.193 10.396 23114 13208 2641.6 25.3 17.71 10.12 22484 12848 2569.6 24.61 17.227 9.844 21868 12496 2499.2 23.93 16.751 9.572 21266 12152 2430.4 23.27 16.289 9.308 20685 11820 2364 22.64 15.848 9.056 19684 11248 2249.6 21.55 15.085 8.62 19383 11076 2215.2 21.22 14.854 8.488 18970 10840 2168 20.77 14.539 8.308 18494 10568 2113.6 20.24 14.168 8.096 17969 10268 2053.6 19.67 13.769 7.868 18074 10328 2065.6 19.78 13.846 7.912 18144 10368 2073.6 19.86 13.902 7.944 18088 10336 2067.2 19.8 13.86 7.92 17948 10256 2051.2 19.65 13.755 7.86 17738 10136 2027.2 19.42 13.594 7.768 17479 9988 1997.6 19.13 13.391 7.652 17185 9820 1964 18.81 13.167 7.524 16863 9636 1927.2 18.46 12.922 7.384 16527 9444 1888.8 18.09 12.663 7.236 13118 7496 1499.2 14.36 10.052 5.744 11403 6516 1303.2 12.48 8.736 4.992 Nitrogen Dioxide 24hour Annual Average 1Hour Average 8 Hour Average 24 Hour Average Annual Average Particulate 0 0 0 0 0 300 9.696 84.71 59.297 33.884 6.7768 300 9.936 86.81 60.767 34.724 6.9448 300 7.68 67.09 46.963 26.836 5.3672 300 4.5136 39.43 27.601 15.772 3.1544 300 3.6592 31.96 22.372 12.784 2.5568 300 3.3512 29.27 20.489 11.708 2.3416 300 3.7536 32.79 22.953 13.116 2.6232 300 3.9432 34.44 24.108 13.776 2.7552 300 3.7088 32.4 22.68 12.96 2.592 300 3.4232 29.9 20.93 11.96 2.392 300 3.1728 27.71 19.397 11.084 2.2168 300 2.9568 25.83 18.081 10.332 2.0664 300 2.7696 24.19 16.933 9.676 1.9352 300 2.6056 22.76 15.932 9.104 1.8208 300 2.4608 21.5 15.05 8.6 1.72 300 2.332 20.37 14.259 8.148 1.6296 300 2.2472 19.63 13.741 7.852 1.5704 300 2.2856 19.97 13.979 7.988 1.5976 300 2.2984 20.08 14.056 8.032 1.6064 300 2.2896 20 14 8 1.6 300 2.2648 19.79 13.853 7.916 1.5832 300 2.2288 19.46 13.622 7.784 1.5568 300 2.1832 19.07 13.349 7.628 1.5256 300 2.1328 18.63 13.041 7.452 1.4904 300 2.0792 18.16 12.712 7.264 1.4528 300 2.024 17.68 12.376 7.072 1.4144 300 1.9688 17.2 12.04 6.88 1.376 300 1.9144 16.72 11.704 6.688 1.3376 300 1.8616 16.26 11.382 6.504 1.3008 300 1.8112 15.82 11.074 6.328 1.2656 300 1.724 15.06 10.542 6.024 1.2048 300 1.6976 14.83 10.381 5.932 1.1864 300 1.6616 14.51 10.157 5.804 1.1608 300 1.6192 14.14 9.898 5.656 1.1312 300 1.5736 13.74 9.618 5.496 1.0992 300 1.5824 13.82 9.674 5.528 1.1056 300 1.5888 13.88 9.716 5.552 1.1104 300 1.584 13.84 9.688 5.536 1.1072 300 1.572 13.73 9.611 5.492 1.0984 300 1.5536 13.57 9.499 5.428 1.0856 300 1.5304 13.37 9.359 5.348 1.0696 300 1.5048 13.14 9.198 5.256 1.0512 300 1.4768 12.9 9.03 5.16 1.032 300 1.4472 12.64 8.848 5.056 1.0112 300 1.1488 10.04 7.028 4.016 0.8032 300 0.9984 8.723 6.1061 3.4892 0.69784 300 8hour 24hour annual C02 Stds. NOX Stds. N02 Stds. 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 200 125 100 Particulates Distance 1Hour Average 8 Hour Average 24 Hour Average Annual Average 1Hour Average 1 0 0 0 0 0 100 6339 4437.3 2535.6 507.12 3.16E+05 200 6496 4547.2 2598.4 515.68 3.24E+05 300 5020 3514 2008 401.6 2.51 E+05 400 2950 2065 1180 236 1.47E+05 500 2392 1674.4 956.8 191.36 1.19E+05 600 2190 1533 876 175.2 1.09E+05 700 2454 1717.8 981.6 196.32 1.23E+05 800 2577 1803.9 1030.8 206.16 1.29E+05 900 2424 1696.8 969.6 193.92 1.21E+05 1000 2237 1565.9 894.8 178.96 1.12E+05 1100 2074 1451.8 829.6 165.92 1.04E+05 1200 1933 1353.1 773.2 154.64 9.65E+04 1300 1810 1267 724 144.8 9.04E+04 1400 1703 1192.1 681.2 136.24 8.50E+04 1500 1609 1126.3 643.6 128.72 8.03E+04 1600 1524 1066.8 609.6 121.92 7.61E+04 1700 1469 1028.3 587.6 117.52 7.33E+04 1800 1494 1045.8 597.6 119.52 7.46E+04 1900 1502 1051.4 600.8 120.16 7.50E+04 2000 1497 1047.9 598.8 119.76 7.47E+04 2100 1480 1036 592 118.4 7.39E+04 2200 1457 1019.9 582.8 116.56 7.27E+04 2300 1427 998.9 570.8 114.16 7.12E+04 2400 1394 975.8 557.6 111.52 6.96E+04 2500 1359 951.3 543.6 108.72 6.78E+04 2600 1323 926.1 529.2 105.84 6.60E+04 2700 1287 900.9 514.8 102.96 6.42E+04 2800 1251 875.7 500.4 100.08 6.25E+04 2900 1217 851.9 486.8 97.36 6.08E+04 3000 1184 828.8 473.6 94.72 5.91E+04 3500 1127 788.9 450.8 90.16 5.63E+04 4000 1109 776.3 443.6 88.72 5.54E+04 4500 1086 760.2 434.4 86.88 5.42E+04 5000 1058 740.6 423.2 84.64 5.28E+04 5500 1028 719.6 411.2 82.24 5.13E+04 6000 1034 723.8 413.6 82.72 5.16E+04 6500 1038 726.6 415.2 83.04 5.18E+04 7000 1035 724.5 414 82.8 5.17E+04 7500 1027 718.9 410.8 82.16 5.13E+04 8000 1015 710.5 406 81.2 5.07E+04 8500 1000 700 400 80 4.99E+04 9000 983.5 688.45 393.4 78.68 4.91 E+04 9500 965.1 675.57 386.04 77.208 4.82E+04 10000 945.8 662.06 378.32 75.664 4.72E+04 15000 750.9 525.63 300.36 60.072 3.75E+04 20000 652.8 456.96 261.12 52.224 3.26E+04 C02 Nitrous Oxides 8 Hour Average 24 Hour Average Annual Average 1Hour Average 8 Hour Average 24 Hour Average 0 0 0 0 0 0 221480 126560 25312 248.3 173.81 99.32 227010 129720 25944 254.4 178.08 101.76 175420 100240 20048 196.6 137.62 78.64 103110 58920 11784 115.6 80.92 46.24 83580 47760 9552 93.68 65.576 37.472 76510 43720 8744 85.8 60.06 34.32 85750 49000 9800 96.11 67.277 38.444 90090 51480 10296 101 70.7 40.4 84700 48400 9680 94.96 66.472 37.984 78190 44680 8936 87.64 61.348 35.056 72450 41400 8280 81.23 56.861 32.492 67543 38596 7719.2 75.71 52.997 30.284 63266 36152 7230.4 70.92 49.644 28.368 59521 34012 6802.4 66.72 46.704 26.688 56210 32120 6424 63.01 44.107 25.204 53270 30440 6088 59.71 41.797 23.884 51324 29328 5865.6 57.53 40.271 23.012 52206 29832 5966.4 58.52 40.964 23.408 52493 29996 5999.2 58.84 41.188 23.536 52297 29884 5976.8 58.62 41.034 23.448 51737 29564 5912.8 57.99 40.593 23.196 50897 29084 5816.8 57.05 39.935 22.82 49868 28496 5699.2 55.9 39.13 22.36 48713 27836 5567.2 54.6 38.22 21.84 47488 27136 5427.2 53.23 37.261 21.292 46228 26416 5283.2 51.82 36.274 20.728 44968 25696 5139.2 50.41 35.287 20.164 43729 24988 4997.6 49.02 34.314 19.608 42525 24300 4860 47.67 33.369 19.068 41370 23640 4728 46.37 32.459 18.548 39375 22500 4500 44.13 30.891 17.652 38766 22152 4430.4 43.45 30.415 17.38 37940 21680 4336 42.53 29.771 17.012 36981 21132 4226.4 41.45 29.015 16.58 35938 20536 4107.2 40.28 28.196 16.112 36148 20656 4131.2 40.52 28.364 16.208 36288 20736 4147.2 40.67 28.469 16.268 36183 20676 4135.2 40.56 28.392 16.224 35896 20512 4102.4 40.24 28.168 16.096 35476 20272 4054.4 39.77 27.839 15.908 34958 19976 3995.2 39.19 27.433 15.676 34370 19640 3928 38.52 26.964 15.408 33726 19272 3854.4 37.8 26.46 15.12 33047 18884 3776.8 37.05 25.935 14.82 26243 14996 2999.2 29.41 20.587 11.764 22813 13036 2607.2 25.57 17.899 10.228 Nitrogen Dioxide Annual Average 1 Hour Average 8 Hour Average 24 Hour Average Annual Average 0 0 .0 0 0 19.864 175.3 122.71 70.12 14.024 20.352 179.6 125.72 71.84 14.368 15.728 138.8 97.16 55.52 11.104 9.248 81.57 57.099 32.628 6.5256 7.4944 66.13 46.291 26.452 5.2904 6.864 60.56 42.392 24.224 4.8448 7.6888 67.84 47.488 27.136 5.4272 8.08 71.26 49.882 28.504 5.7008 7.5968 67.03 46.921 26.812 5.3624 7.0112 61.86 43.302 24.744 4.9488 6.4984 57.34 40.138 22.936 4.5872 6.0568 53.44 37.408 21.376 4.2752 5.6736 50.06 35.042 20.024 4.0048 5.3376 47.09 32.963 18.836 3.7672 5.0408 44.48 31.136 17.792 3.5584 4.7768 42.15 29.505 16.86 3.372 4.6024 40.61 28.427 16.244 3.2488 4.6816 41.31 28.917 16.524 3.3048 4.7072 41.53 29.071 16.612 3.3224 4.6896 41.38 28.966 16.552 3.3104 4.6392 40.94 28.658 16.376 3.2752 4.564 40.27 28.189 16.108 3.2216 4.472 39.46 27.622 15.784 3.1568 4.368 38.54 26.978 15.416 3.0832 4.2584 37.57 26.299 15.028 3.0056 4.1456 36.58 25.606 14.632 2.9264 4.0328 35.58 24.906 14.232 2.8464 3.9216 34.6 24.22 13.84 2.768 3.8136 33.65 23.555 13.46 2.692 3.7096 32.73 22.911 13.092 2.6184 3.5304 31.15 21.805 12.46 2.492 3.476 30.67 21.469 12.268 2.4536 3.4024 30.02 21.014 12.008 2.4016 3.316 29.26 20.482 11.704 2.3408 3.2224 28.43 19.901 11.372 2.2744 3.2416 28.6 20.02 11.44 2.288 3.2536 28.71 20.097 11.484 2.2968 3.2448 28.63 20.041 11.452 2.2904 3.2192 28.4 19.88 11.36 2.272 3.1816 28.07 19.649 11.228 2.2456 3.1352 27.66 19.362 11.064 2.2128 3.0816 27.19 19.033 10.876 2.1752 3.024 26.68 18.676 10.672 2.1344 2.964 26.15 18.305 10.46 2.092 2.3528 20.76 14.532 8.304 1.6608 2.0456 18.05 12.635 7.22 1.444 24hour 8hour 24hour annual Particulate Stds. C02 Stds. NOX Stds. N02 Stds. 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 300 200 125 100 ARDROP

APPENDIX C

KAKIRA SUGAR WORKS (1985) LTD. PERMITS FORM B

ORIGINAL Permit No. NEMA/RBILSNWT/049

REPUBUC OF UGANDA (REGULATION 12 & 23) Fee paid: UShs. 100,000/=

No. 4 of 1995. THE NATIONAL ENVIRONMENT STATUTE, 1995 Statute Lake Shores Management) Regulations, 2000. The National Environment (Wetlands, River Banks and IN A WETLAND/RIVER BANK/LAKE SHORE * PERMIT TO CARRY OUT A REGULATED ACTIVITY

Name KAKIRA SUGAR WORKS (1985) LIMITED

Address P.O. BOX 121, JINJA

(s) in a vA?wiver/bank as applied for. You are hereby granted a permit to cany out the activity FOR SUGAR CANE GROWsING Locationoofhthe enriverbank nl*iFS* CHICO STREAM DIVISIONS) (BUTEMBE,KAKIRA-KABYAZA,KARONGO, CHICO

JINJA DISTRICT

mention more than one) (District, county, sub-county, villageAJtere necess 04 to 2ND JANUARY 20 06 2 years). The permit is granted valid from 2ND rB&A*n 0

The permit is subject to the following conditions attached

_ (Please attach on separate sheet where necessary)

i Date 30TH DECEMBER,2003_i

Vseal andA5A' Sigiature of The Executive Director National Environment Management Authority

*Delete whichever is not applicable- ORIGINAL: Developer; DUPLICATE: Lead Agency; TRIPLICATE: The Authority. - CONDITIONS FOR ISSUING A PERMIT

For Sugar Cane growing along the banks of River Chico and other streams

issued to Kakira Sugar Works (1985) Limited located in Jinja, Butembe, Kakira-Kabyaza, Karongo and Chico divisions - Jinja District

In addition to implementing the mitigation measures identified in the Project Brief, the developer shall ensure that:

(i). No other authorised activities other than for which the Permit has been issued (Sugar Cane Growing) are carried out within the regulated zones of the rivers;

(ii). A 5m (five meters) no encroachment zone is maintained along River Chico and other streams in the whole sugar plantation and planted with grass to ensure that the sediment from the fields are trapped;

(iii). Any use of surface or ground water along the river must be in accordance with the Water Resources Regulations 1998, which requires among others obtaining a permit in case of 3 using a motorised pump or abstraction of water of over 400m /day;

(iv). The riverbank shall not be fenced off near the facility so as to allow continued public access and use of the riverbank such as getting access to the river whenever the need arises;

(v). In accordance with Section 23(4) of the National Environment Statute 1995, any additional undesirable environmental impacts that may arise during the construction and operation of the facility, but not contemplated during the issuing of this permit are mitigated;

(vi). Undertake monitoring and report to this Authority and/or the Directorate of Water Development any incidents of pollution of the river and also undertake immediate remedial action where this pollution is caused by activities of your company.

Page 1 of 2 Signuwdin 7Cmpafa on Tuesda, 09 fDecember 2003

|~~~~~~~~~~I SeafandfS41tureof/ The Executive Director National Environment management Authority

C.C. The Chief Administrative Officer JINJA District JINJA

The District Environment Officer JINJA District JINJA

Page 2 of 2 THE REPUBLIC OF UGANDA WASTE WATER DISCHARGE PERMIT (The Water Statute, No. 9 of 1995, the Water (Waste Discharge) Regulations, 1995 and the Water Resources Regulations,

In exercise of the powers conferred upon the Director by sections 5, 18 and 29 of the Water Statute, 1995; and in accordance with regulation 7 of the Water (Waste Discharge) Regulations, 1998, this is to grant a Waste Water Discharge Pernit

Number: JJAlOO098/3WDMD W2001 To Kakira Sugar Weks- (1985) Limited P.0. Box 121, Jinja to discharge waste in accordance with the terms and conditions of this permit. The permit is granted in the terms and conditions set here in the Annex, which is part of this permit, and under all other terms and conditions set in the Water Statute, 1995, the Water (Waste Discharge) Regulations, 1998 and the Water Resources Regulations, 1998..

This permit is granted for a period not exceeding 3 year(s), which come into force on Monday, November 19, 2001 until Friday, November 19, 2004.

Issuance Date: Monday, November 19, 2001

p.o. angire DI TOR OF WATE DEVELOPMENT

Wednesday, December 19,2001 Page I of 4 WASTE DISCHFARGE PERMIT - STANDARD CONDITIONS Water Statute, 1995: Section 20a3 not cause or allow any water to be polluted; Section 20b prevernt damage to the source from which water is taken, or to which water is discharged aster use; Section 20c take precautions to ensure that no activities on the land where water is used results Swhich may reder water in the accumulation of any substance less fit for the purpose for which it maay be reasnably used; Section 22(1) Iwhere in the opinion of the Director the water available in the area is, or is likely to become, insufficient Iquality for the needs of dte persons using or in quantity or seeking to use fromit that source, the Diretor meay, by notice [holder of a in witing to the water pemit for that area, suspend or vary the water pernit. Section 22(2) [The Director iay impose conditions to any permit varied, suspended or granted under [compenstion subsection (I) including requiring to a holder of a water permit by another holder of a water permiit. Section 29(9) [The Directornay, at any time, amend the terms of; suspend the operation oCsor cancel [opinion, it is necessary to a waste discharge permit it in his protc the environmet or to prevent the pollution ofaany water. Section 26 (1) Subject to section 33, where the Director isof the opinion tat in order to make water necessary to cancel or vary available fora public purpose it ist a water permit, the Direcr nmaycanel or vary the water permit. 1(2) The Minister may, by notice in the Gazstte, declare any pur'pose to be a public purpose for purpose of this section. Section 37 An authorised person miay enter land for purposes of - (a) inspeting works or use of water or (b) taking samplesbr making tests, to find out whether:- (i) water is being wasted, misused or polluted; (ii) the termis of any water permit, waste dischag pernmit or any other permtit ganted under being complied with; this Part of the Statute are S(iii) an offence is being committed against this Part of the Statute, or the Statute is otherwise being complied with. Regulation 31(q) A person commnits an offence who, unless authorsed under this Part of th Statute, causes or allows- (a) waste to come into contact with any water, (b) waste to be discharged dieciy or indiretly into water, (c) water to be polluted.

Regulation 31(2) The provisions of subsection (,) shall apply to permits granted and works IStatute. constructed before the commencement of this

Regulation 321(4) A pern or public authority contravening the provisions of subsection (1)dtrough which damiage to pay thecost of reedying the damiage caused and is caused, shall be liable reinstating the environrmnt, as far as is possible, to the would have existe if the danmge was not caused. condition that

Water (Waste DischAn Regulations, 199r: Regulation 10 (1) A person who becomes the owner or occupier of any premises in respect continue to discharge waste from of which a waste discharge permit exists shall the premises in accordance with the conditions and terms discharge permit for spelt out in that waste a period of three months from the date on which that person prernises. becomes the owner or occupier of the (2) Alter the expiry of the period referred to in sub-regulation (1) of this regulation the Director shall, application of the persn referned to in sub-regulation upon receipt of the (1), made in Form C set out in the Sixth Schedule, a waste discharge permit on conditions grant that person which are not more onerous to the applicant than the conditions previous waste discharge permit relating to attached to the those premises and if the Director is satisfied that the purposes premises are to be used and the for which the nature of any waste will not change in any material respect. Offence Penalties Various sections of the Water Statute, 1995 and Regulations -Offence and Penalties.

Wednesday, December 19,2001 Page 2 of 4 ANNEX SPECIAL TERMS AND CONDITIONS FOR WASTE DISCHARGE PERMIT Name: KAKIRA SUGAR WORKS (1985) Ltd Permit Number: JJA100098/3WDMDW 2001

1. Location of point of waste discharge: Basin Lake Victoria/ Lake Kyoga Catchment Lake Victoria/ Lake Kyoga District Jinja County Kakira

2. Description of Discharge

(i) Numbers of existing Discharge: I (ii) Type of discharge: Industrial waste (i i i) Nature of discharge: ... (iv) Means of discharge: Channel (v) Water body to which waste is discharged Lake Kyoga (vi) Maximum instantaneous rate of discharge should not exceed I. 12m 3/sec. (vi i) Volume discharged shall not exceed 1610 m3/day in a period of 24 hours

3. Discharge Composition a) The discharge shall: (i) not exceed a temperature of 20 -350C (ii) contain no visible signs of oil or grease in excess of 10mg/I b) For the following determinants, in any series of samples of the final effluent taken over a twelve month period, shall not be: (i) in excess of 335mg/I of biochemical oxygen demand (BOD) measured after Sdays at 20 degrees Centigrade (refer to special permit conditions) (ii) in excess of 175milligrams of suspended solids (measured after drying for Ihour at 105 degrees Centigrade); (iii) in excess of 300NTU of turbidity (iv) a pH value of less than 6.0Or greater than 8.0 (v) in excess of 1450mg/l of COD (refer to special permit conditions). (vi) in excess of 500mg/I of Sulphates (vii) in excess of 10mg/I of Total Phosphorus as P. (viii) in excess of 10mg/1 of Total Nitrogen as N (ix) in excess of l .Omg/l of sulphide

Wednesday, December 19,2001 Page 3 of 4 ANNEX SPECIAL TERMS AND CONDITIONS FOR WASTE DISCHARGE PERMIT Name: KAKIRA SUGAR WORKS (1985) Ltd Permit Number: JJA100098/3WDMDW 2001

4. In addition to the conditions specified in the Statute and any other law in force, this permit is subject following terms and conditions: to the a) This permit shall not be taken as providing a statutory defense against poisonous, a charge of pollution in respect of any noxious or polluting constituents not specified in the permit. b) Except with the agreement of the person making the discharge under this permit, revoking the permit no notice shall be served or modifying the conditions before Friday, November 19, 2004 c) You shall provide and maintain facilities, which enable the Director's representatives measurements of the final to take flow waste effluent, which is discharged to the outlet. The discharger facility with a clearly visible shall identify the sign, distinguishing it from any other and provide a device indicating the visible notch, mark or level equivalent to the maximum instantaneous permitted flow. d) You shall provide and maintain facilities, which shall enable the Director's composite representatives to take discrete or samples of final waste effluent, which is discharged at the the facility outlet. The discharger shall identify with a clearly visible sign distinguishing it from any other. e) You shall provide to the Director's satisfaction a drawing showing the precise location of provided in accordance with the facilities conditions c) and d) above not later than one month prior .enforcement of this permit. to the date of

f) Facilities shall be provided for the safe and convenient access to enable the Director's representatives time to take samples, cany at any out flow measurements and inspection to ensure that the permit are complied with. conditions of this

The Discharger shall pay an annual charge of UShs: 1,000,000 Date to be paid 19/11/02 g) You shall put in place wastewater treatment facility within the first 2 years of operation under permit. h) You shall put in place flow measuring devices and take samples of (a) upstream of the discharge (b) effluent discharge on point; and; a monthly basis for chemical analysis at own cost. The parameters during monitoring shall include: to be measured

(a) pH (g) Turbidity (b) Electrical Conductivity (h) Faecal Coliforms (c) Total Suspended Solids (1050 C) (i) BOD (d) Dissolved Oxygen (j) COD (e) Temperature (k) Total Nitrogen (f) Total Phosphorus

i) You shall improve on the quality of the final wastewater within the first year of operation under permit. As a minimum the final TSS, COD and BOD, be reduced by 50% within the 3 years of operation under permit j) You shall ensure that the effluent at all times must not exceed the levels prescribed substances. of heavy metals and other k) You shall under take monitoring of the volume of wastewater discharge on a monthly basis.

Wednesday, December 19, 2001 Page 4 of 4 FORM Cl

THF REPUBLIC OF UGANDA SURFACE WATER ABSTRACTION PERMIT (wh 111car Stalute, No.9aT.V 1.9.95sand tew ateLorResurces RZealicm, 1 998) In exercise of the powersm conferred upon the Director by sections 5 and 18 of the Water Statute, 1995; and in accordance with regulations 3, 7 and 10 of the Water Resources Regulations, 1998, this is to grant a Surface Water Permit

Number: JJAM00176/4SWMT?W 2000 To: Kaki-Lra Sugar Works (1985) Limited P. O Box 121 JINJA to abstract surface water in accordance with the terms and conditions of this permit. The permit is granted in the terrns and conditions set here on the reverse side of this form and in the Annex, which is part of this permit, and under all other terms and conditions set in the Water Statute, 1995 and the Water Resources Regulations, 1998. This permit is granted for a period not exceeding 5 year(s), which come into force on Tuesday, March 28, 200Q until Monday, March 28, 2005.

Issuance Date: Tuesd, y, March 28, 2000

angire DIRETOR OF WA ER DEVELOPMENT

Tuesday, Mardi 28, 2000 Page 1 of 3 SURFACE WATER PERMIT - STANDARD Water Statute, 1995: CONDMTIONS 1. Section 20 (a) not cause or allow any water to be polluted; 2. Section 20 (b) prevent damage to the source from which water is taken, or to which water is discharged after use; 3. Section20 (c) take precautions to ensure that no activities on the land where water is used results in the accumulation ofany substance which mnay render water less fit for the purpose for which it may be reasonably used; 4. Section 22 (1) Wherein the opinion ofthe Director the water available in the area is, or is likely to become, insufficient in quantity or quslityfortheneeds ofthepersons usimgor seeiingto use it fromthat source, the Director may, bynotice in wntingtothe hsolder of a water permit for that ares, suspend or vary the water permiL. 5. Section 22 (2) The Director may impose conditions to any permit varied, suspended or granted under subsection (1) including requiring [compensation to a holder of a water permit by another holder of a water pernitI 6. Section 25 The Director may cancel a water pennit where in his opinion the holder of a water permit has- (a) failed to comply with any express or implied condition to which the water permit is subject; (b) taken or used more water than he is eatitled to take in any period; (c) taken or used water for a purpose other than that for which he is entitled; (d) failed to comply with any provision of this Statute; (e) not made full beneficial use ofthe permit wihin the two preceding years. 7. Section 26 I() Subjectto section 33, where the Director is ofthe opinion that in order to make water available for a public purpose it is ecessary to cancel or vary a water permit, the Director may cancel or vary the water permit. (2) The Minister may, by notice in the Gazette, declare any purpose to be a public purpose for purpose ofthis section. 8. Section 37 An authorised person nay enter land for purposes ofk- (a) inspecting works or use ofwate-, or (b) taking samnples or numing tests, to find out whether:- (i) water is being wasted,nisused or polluted; (ii) the terms of any water permit, waste discharge permit or any other permit granted under this Part ofthe Statute are being complied with; (iii) an offence is being committed against this Part ofthe Statute, orthe Statute is otherwise being conplied with. 9. Section 18 (7) IA grant of an application under this section does not imply any represantation or guarantee by the Director, authorised person or public authority that water will be available at the place. 10. Regulation 31 (1) A person commits an offence who, unless authorised under this Part ofthe Statute, causes or allows- (a) waste to cone into contact with any water, (b) waste to be discharged directly or indirecly into water, (c) water to be polluted. 11. Regulation 31 (2) The provisions of subsection (1) shall applyto permits granted and works constructed beforethe commencement of this Statute. 12. Regulation 31 (4) Aperson orpublic authority contraveningthe provisions of subsection (I)through which damage is caused, shall be liableto paythe cost of rcnedyingthe damage caused and reinstatingthe environment, as far as is possible, to the condition that would have existed ifthe damage was not caused. Water Resources Regulations, 1998: 13. Regulation 7 (3) Aperson who becomes the owner or occupier of any premises in resped ofwhich a water pernit exists shall continue to abstrac water in accordance with the conditions and terms spelt out in that water permi for a period of three months from the date on which that person becomes the owner or occupier of the prnnises. 14.Regulation 8 (1) A holder of a water permit granted under regulation 3 or 10 may before the expiry of his permit, apply to the Director for the renewal ofthe permiL (2) An application referred to in sub-regulation (I) ofthis regulation shall, (a) be made in a form and manner determiined by the Director, (b) contain such inforantion as the Director may specify, (c) be accomnpanied by the fee specified in the Second Schedule to these regulations. (3) The Director shall, in considering an application refcrred to under this regulation, take into account the factors specified in regulation 6 ofthese regulations. (4) Where the Director renews a permit he/she nay renew such penit on such conditions, subject to these regulations, as he or she may determine. 15. Penalties FVarious sections ofthe Water Statute, 1995 and Regulations -Offence and Penalties.

Tuesday, March 28, 2000 Page 2 of 3 ANNEX SPECIAL TERMS AND CONDMIONS FOR THE ABSTRACTION OF SURFACE WATER Name : Kakira Sugar Works (1985) Limited Permit Number JJA100176/4SWMDW 2000 1. Specifications:

Source of Water Uptake Lake Specific Source: Lake Vidoria at Kakira District fmjja

County Butembe

SubCounty Kakira

Village/Parish

2. National grid reference of point of water uptake: Latitude: 531275 Longitude: 053000 3. Purpose of Water Use Multiple Uses - 3 4. Maximum Amount of water to be taken (m /day) 9,022 5. Frequency of any withdrawal or diversion of water Daily 6. Maximum Rate of abstraction (m3/s) 7. In addition to the conditions specified in the Statute and any other law in force, this permit is subject to the following terms and conditions: a) Methods Authorised for the water abstraction: Motorized Pumping

b) The Protection of the environment and other user Water cmtaining cheiicals used for irrigation should be carefully monitored for quality. c) The installation and use of Measuring Devices or Pumps:

d) Name and Location of Land where water is used or will be used: Kakira Sugar Works Estate e) Regulation 7(2)b the permit shall be granted subjec to such oinditions as are relevant to the specified particular types of uses dtemined by the Committee-, f) Regulation 7(2)n paymait for the water used;

g) Regulation 7(2)o 'he protedion ofthe environment;

h) Regulation 7(2)p e conservation policy ofthe Goverment;

i) Regulation 7(2)q lbe efficint use ofwater resources; j) Regulation 7(2)r the manner in which the applicant is to compensate any person whose existing authorised use of water may be adversely affeeded by the allocation or use ofwater under permit;

The Water User shall pay an annual charge of UShs: 100,000 Date to be paid 28/03/01

k) Any Other specific Condition for this permit:

Tuesday, March 28,2000 Page 3 of 3 Not Transferable ORIGINAL

THE FORESTS ACT FORM E

PERMIT .(' -I

DaIe: ...... ) ...... stationS. 42...... '..

Subject to the conditions of the Forests Act and any Rules made thereunder and to the terms and conditions stated herein; 0 L V,,V f2-4 W- -7AC'c-() ThIV-

...... is herebv authorised to ...... 4 " - C~ - 0/ ~1 ,...... !...... L.. in the . , ...... I...... Eorest Reserve. 4 This permit expires on. . .l J g ...... g O

...... >...... / ITsuing Officer .... p...... i ..... Designation.

CONDITIONS

I. The permit holder shall take all precautions to prevent unnecessary damage to other forest produce arising out of the operations under this permit and shall be responsible for the acts of their servants, employees or agents.

2. The permit holder and their servants and employees shall at all times assist forest officers in the prevention and extinction of fires in or threatening the area the subject of this permit, and in the prevention and detection of forest offences.

3. In the event of a breach of the Forests Act or any Rules thereunder or any term or condition of this permit, this permit may be cancelled without prejudice to any proceedings which may be taken in respect of the said breach.

4. 'Fle permit holder shall, on the expiry of this permit, surrender it to the issuing officer.

5. The permit holder ilay,1:atny time terminate this permit by giving the issuing officer not less than ....X days notice thereof.

6. The Permit holder shall abide by other additional conditions that may be attached in special circumstances. ADDITIONAL CONDITIONS

7- The Permit Holder shall be responsible for planting a Forest Plantations equivalent in Area to Butamira Forest Reserve in South Busoga Forest Reserve within Mayuge District of Busoga Region and maintain it for one year before handing over to Forest Department. The above planting shall be completed as per agreed planting programme within a period of 8-10 years from the date of issue of this permit.

8. The Permit Holder shall ensure that uncultivated strips of land along the streams and rivers in the Reserve are preserved as protection measure against their silting.

9. The Permit Holder shall ensure the protection of the Hilltops and their steep sides are protected against erosion and land degradation while establishing the'said sugar plantations.

1 0.The Permit Holder shall put in place a monitoring programme to monitor chemical residues (herbicides and fertilizers) in the environment used in the growing of sugar cane.

l CS'mS l WARDROP

APPENDIX D

LIST OF ENVIRONMENTAL AND SOCIAL ASSESSMENT PREPARERS

I~~~~~~~~~---- VARDROP

ENVIRONMENTAL AND SOCIAL ASSESSMENT PREPARERS

The following personnel were involved in the preparation of this environmental assessment report:

x Mr. Peter Komelson, P.Eng. - Project Manager x Mr. Wayne Slack, P.Eng. - Project Director x Ms. Krstina Farmer, M.Sc., P.Ag. - Lead Assessor x Dr. Patrick Mwesigye, Ph.D. - Assessor *x Ms. Jennifer Van de Vooren, M.N.R.M. - Assessor * Ms. Sarah Wakelin, M.Sc. - Assessor * Mr. Ed Wolowich, M.Sc., P.Eng. - Advisor ARDROP

APPENDIX E

COMMENTS FROM WORLD BANK AND CORRESPONDING RESPONSE VAtDROP

Appendix E: Comments from World Bank and Consultant Response

Comments from the Social Reviewer:

I have reviewed the Environmental Assessment for 'Kakira Sugar Works Cogeneration Expansion", which is a component of the Energy for Rural Transformation Program in Uganda (not the Private Utility Sector Reform as is indicated on a sticker on the report). The Kakira component will expand its cogeneration facility and thereby supply electricity (7 MW) to the national grid network. Physical installations which will potentially have an impact on people and property include a new electrical sub-station at Kakira and a new 33 kV distribution line (16 km) from Kakira to Jinja.

The land required for the Kakira sub-station is approximately 30 meters x 30 meters and is located next to the foundry and I understand, on KSW company grounds. Unless people are squatting on this area, it will not be an issue. An environmental assessment (EA) has not yet been carried out for the distribution line, however it will be carried out once the exact route has been determined and a resettlement action plan (RAP) will be prepared. It is recommended that the RAP be prepared at the same time as the EA, in order to save time.

I find that the EA is close to being adequate as it is, just a few sections that need to better address the issues and which will require some more work, see below: If the crushing of sugar cane will increase from 3000 tonnes per day to 5000 tonnes per day, this must mean that the area of sugar cane plantations will need to almost double. Which is the land that will be used for expansion of the plantations? Is it owned by KSW already, is anyone using it, how will it be otherwise acquired?

The increase in cane supply will be achieved as follows:

* The major increase in cane supply will be from horizontal expansion of small outarowers. New farmers have been encouraged by the profitable and successful experience of the existing 3,600 out-grower farmers who are registered with and supply cane to the company. Out-grower cane supply to KSW has already increased from 385,000 TC/y in 2001-02 to 439,0000 TC/y in 2002-03 with a target of 506,000 TC/y in 2003-04 with further increases of about 200,000 TC/y in the following 2 years. * Additional 90,000 - 100,000 TC/y (to reach about 600,000 TC/y) through vertical expansion of improved agricultural practices on the Company owned Nucleus Estate. Including re-introduction of spray irrigation on approx. 2,800 hectares. The land is already owned and used by KSW * No land acquisition is envisaged.

A minor issue is in "Administrative Framework", where it would be appropriate to mention the Environmental and Social Management Framework, which also includes a resettlement policy framework. Under the same heading, paragraph 2.1.5, it would be appropriate to mention that the World Bank's policy on Involuntary resettlement (4.12) 1ARDROP

will be triggered and the policy used as guidance to prepare resettlement/compensation plan as needed.

No resettlement activity is envisaged, but appropriate reference is made in the report.

Not related to safeguards but to social development aspects in general, is the fact that social issues and social impact are not thoroughly discussed (in chapters 4.5 and 5.2) and those sections could be developed better.

For example, what will the almost doubling of cane crushing and expansion mean for the workforce of about 6,000? Will it remain the same? How is the workforce organized on the estate and how have the employees participated in the development of the expansion idea? What are the social and economic circumstances of their existence? For one thing, will the energy surplus to the national grid benefit them?

Since the major expansion in cane supply is to come from out-grower farmers, the company's employment is not expected to increase significantly

Increased Nucleus Estate intensity of agricultural operations has already required an increase of about 500 farm workers and this is likely to be the steady state situation.

The KSW work-force is represented by The National Union of Plantation and Agricultural Workers (NUPA W), whose chairman is Kutosi Esau, and General Secretary is Hon Pajobo Joram Bruno. The Union is affiliated to the National Organisation of Trades Unions, Uganda.

The increased energy supply to the national grid during peak hours will provide relief to the national short fall and will result in reduced load shedding for the country as a whole.

If Kakira did not plan to self-generate the additional electric power that will be required for the factory expansion this would have imposed a further demand burden on the national grid.

The Company's own infrastructure (including housing, schools, hospital, etc.) will be provided self generated power instead of the present supply from the national grid - providing the employees reliable electricity supply with out load shedding.

Will the expansion involve modemisation in terms of equipment and will that affect the number of people employed?

Whilst modern technology will be used for the new Cogeneration Plant, this will be an augmentation to KSW's facilities and no retrenchment of factor workers is envisaged.

2 NIRDROP

A public consultation meeting of local leaders was held on 5 March 2004 at Kakira and these issues were discussed in detail. The minutes of the meeting are attached in Appendix F of the report.

How will retrenchment be addressed? Agreed, this is not an social assessment but one will need to know more about the 6,000 people who work on the estate and who will be affected in one way or another.

There might not be extensive retrenchment since the increase in crushing capacity will more than compensate the introduction of new technology. The economies of scale of production (about 150, 000 tons per year in 4-5 years) will result in less production costs and the company will be more competitive against the cheap imported sugar.

Ideally, Kakira works very closely with its outgrowers. This means that the company will be able to monitor the relocation of employees from the company to work with the outgrowers. The employees likely to be most affected will be the drivers of the company who have been ferrying away the excess bagasse to the fields for burning.

Comments from the Environmental Reviewer:

I read the EA report and have the following comments:

1. Page 8. The World Bank Safeguard Policies need to be identified and explained how these safeguard policies will be addressed. The Environmental Assessment Safeguard Policy applies. The World Bank Pest Management Safeguard Policy might apply as well. In case the pest management policy applies a pest management plan needs to be prepared for the increase in sugar cane production by outgrowers, which would likely result in increased pesticide production, to be used by the factory for sugar manufacturing. It is not clear if pesticides are used by outgrowers (needs to be discussed with the TTL). KSW itself does not use pesticides for sugar cane cultivation. The outgrower project should also not result in destruction of natural forest (clearance of natural forest for agricultural production, this would trigger the World Bank's Natural Habitat Safeguard Policy).

Kakira's out-growers do not generally use pesticides as there are no pests that affect sugar cane plantations in the South Busoga area.

Expansion of out-grower cane areas is not expected to result in any destruction of natural forests. Kakira encourages farmers to only utilise two thirds of their land for sugarcane; the balance one third is suggested to be used for food crops, grazing and forestry. It is expected that the area planted to trees will actually increase as farmers plan to utilise timber for other economic activity on a sustainable basis.

Kakira's Out-growers Department visit each out-grower farmer prior to registration and ensures that farmers comply with national environmental regulations and

3 VARDROP

also leave adequate land for cultivation of subsistence / food crops etc. The company has instituted a clearly defined policy on outgrowers. Kakira has acquired a Global Position System (GPS) to map out boundaries of sugar cane estates owned by outgrowers. The coordinates are to be used to derine the actual size of the fields and the actual boundaries with fragile and sensitive ecosystems (the company does not deal with any outgrowers who are growing sugar in sensitive ecosystems). If the out-grower is to increase the acreage of the fields, the company will have to be informed and it approves the proposed changes. These will again be entered in the database with the outline map drawn. It will therefore not be possible to change the size of the fields without consent from Kakira.

2. Page 11. The consultants should use also the following guidelines: Sugar Manufacturing, Pollution Prevention and Abatement Handbook (PPAH), 1998, which specifies the air emission, liquid effluent and ambient noise standards and monitoring requirements for sugar manufacturing, (the EA states the date of this report is 2001, should be corrected); General Environmental Guidelines, PPAH, 1998; IFC Occupational Health and Safety Guidelines (on website: www.ifc.org); Monitoring, PPAH, 1998. The PPAH can be found on the IFC website: www.ifc.ora and on the World Bank website; www.worldbank.ora. The project should also comply with the applicable Ugandan pollution control standards; whichever standard is more stringent (Ugandan or World Bank standard).

This has been effected in the report.

The emission rates of g/s should also be converted in the units of the World Bank guidelines, e.g. mg/Nm3 (table B1, table 5, etc.).

There are no direct conversion factors to convert g/s to mg/Nm3. In order for us to present our findings in mg/Nm3 we would require re-modelling of freshly collected data from the field. Our main intention of using an emission rate of g/s was to emphasize the load of the emissions coming out of the stack. It should also be noted that the correct and reasonable usage of the guidelines is for comparison of "already dispersed"maximum ground level concentrations, which is the air people are actually exposed to.

2. Figure 4 and Figure 6 are the same.

Fixed in the final report

3. Page 29. The World Bank noise standard for cane mills is not 90 dBA, but 70 dBA in industrial areas and 55 dBA in day time in residential/educational areas, being reduced during night time to 45 dBA (22:00-07:00). See PPAH page 403. The noise standards for the project need to be adapted to the World Bank guideline which is more stringent than the Ugandan noise standard. Construction noise levels will be higher, but need to be mitigated. Operational noise levels need to comply with the 70 dBA, which means that mitigation measures, such

4 IWIDROP

as isolation of noise sources might be required.

This has been changed in the report.

4. The 24-hour maximum ambient guideline for nitrogen oxides of 150 micrograms/m3 as mentioned in the General Environmental Guidelines of the PPAH needs to be respected.

Noted

5. Total Particular Matter emissions are high. The General Environmental Guidelines of the World Bank (PPAH, 1998 page 437) mention standards for ambient particulate matter: Annual arithmetic mean of 50 microgram/m3; and Maximum 24 hour average of 70 microgram/m3. These standards need to be complied with. Noted

6. Page 39. almost at the bottom of the page: ..... The maximum pollutant concentrations are found at 183 m from the source. It would be useful to mention which concentration of S02 is found at this distance.

We state in section 5.1.1 that "emissions of sulfur dioxide from the boilers are also considered negligible, owing to the characteristically low levels of sulfur associated with bagasse." Therefore dispersion of the gas up the stack will render it extremely negligible at 183 m.

7. Page 43. Transformer oils should be tested if they are PCB oils. If they are PCB oils, they should be shipped to Europe for incineration. In Africa at present there is not such an incineration facility and indefinite storage is not an option. The project include a budget should for the transport and incineration of the PCBs.

The costs have been included in the report.

8. Page 48. It should be stated which are the expected wastewater discharge concentrations at the outlet of the wastewater plant. The effluent needs to comply with effluent standards mentioned in the Sugar Manufacturing guideline of the World Bank (PPAH, 1998). Strict adherence will be required since communities downstream use the river as a drinking water source.

Appropriate changes have been made in the report

9. Page 59. states that a comprehensive environmental monitoring plan will be developed. The World Bank requires that this environmental monitoring plan is part of the present EA.

The plan has been included in the report.

5 VARDROP

APPENDIX F

MINUTES OF PUBLIC CONSULTATION MEETING Minutes of the Public Consultative Environment Impact Assessment (ELA) meeting held with the staff and community of Kakira Sugar Works Ltd

A meeting was held on Friday, 8th March 2004 at Kakira Sugar Works Ltd (KSW) as part of the requirements for the EIA report. The meeting was chaired by the General Manager of KSW who introduced the consultants from Wardrop. The consultants explained that since project was funded the by the World Bank, an EIA and a consultative meeting public was required and thus the reason for meeting. The the above other members were asked to introduce themselves. members comprised The of heads of departments, factory staff, District Environmental Officer Jinja and Local Council representatives of the surrounding villages as shown below: 1. Mr C.R.B. Orr General Manager 2. Dr Mwesigye Patrick Wardrop Consultant 3. Ms Barbara Batumbya Wardrop Consultant 4. Mr Dickson Lufafa District Environmental 5. Officer Jinja Mr G. Wabomba Safety, Health & Environmental 6. Mr Supt Ganesan. S Electrical Engineer Manager 7. Mrs Asiimwe J T/ Welfare Officer 8. Mr Otieno Michael Educ. Officer/ LCII Chairman Kakira 9. Buzu Noah LCI Chairman s/Qrts 10. Mr Okot Franco A.G.C/MAN LCI Mabati Village 11. Maboni Jerome Chairman Kliz Village 12. Vudriga Akulino Chairman PPG Village 13. Sabwe Jonathan Rep Chairman III 14. Ariki Joseph Chairman LC II Karongo 15. Parish Kalibusi Salim Deputy Electrical Engineer 16. Ofutra Mohammed Ali Branulia Secretary 17. Florence Akalya Area Women co-ord Kakira 18. Ongula Peter Lab Superintendent 19. Mutanje A Rashidi Process Supt KSW 20. Ssali Iddi Chairman LC II Mawoito 21. Mujongola Nathan Chairman LCI Bungalow 22. Opale Daniel C/person LCI Maji Mazrui 23. Amule Village Amosi C/person LCI Terego Village The Kakira electrical engineer then gave a brief background cogeneration of the project. He explained that power generated from the steam from the bagasse would be sold to Uganda Distribution Electricity Company Ltd (UEDCL). He also said cheapest that this was the form of biomass generation of power. He the-bagasse said that presently is left to rot in the field and decompose and back into then mixed the soil. However, sometimes the bagasse is carbondioxide burnt releasing into the air and thus adding to the green house this way the gases. In energy is being wasted and yet it can be harnessed used for and the benefit of Uganda. So the project will produce not only for electricity use on the estate but also for the country at large.

------The chairman then handed over the meeting to Dr Mwesigye, one of the consultants to get the views of the people on the project. He emphasized that law requires an EIA to be conducted for a new project followed by a public consultative meeting with the stakeholders. He briefly talked about voluntary and involuntary resettlement and emphasized that the objective of the meeting was to get the views of the people concerning the project. Their views were in form of questions, which were as follows; 1. Will the project make the electricity bills lower? 2. Will the houses, which don't have, power presently benefit? 3. Will the people really benefit since the project is funded World Bank? by the 4. Will the nearest people to Kakira have access to electricity cheaper cost? and at 5. Will it be possible to change from Uganda Electricty Distribution to the Kakira electricity and what are the possible costs? 6. In Uganda, how many of such projects exist, or is this the first? 7. Give details of voluntary and involuntary settlement and will there be compensation for both types of resettlement? 8. What is the advantage to the government on implementation project? of the 9. Is the project bringing free electricity to the people? 10. What is the biggest advantage concerning the people of Kakira? 11. How much electricity is being generated in the country at moment, what the are the future plans concerning electricity production and what is the current percentage use of electricity the people of Uganda? by 12. Is it safe for Kakira to produce electricity given being the fact that it produced from steam generated by the baggasse? 13. Will the project utilize all the baggasse or will there baggasse? still be excess 14. How will the continuous steam production be taken the care of since machines will have to shut down once maintenance? in a while for Reactions to the questions * Only 5% of 24 million have access to electricity, positive so the project is a one. Only 1% of this electricity is in the government's rural areas and target is to increase from 1% to 10% areas. Kakira in the rural will therefore help to meet part of this Kakira has target. So already obtained an Independent Power license according Producing to the law and a Power Purchasing Agreement been made between has UEDCL and Kakira, all that is lacking money from the is the World Bank for implementation of the project. * Other factories like Kasese Cobalt are also producing electricity its not enough. but * It was made clear that Kakira will not set up its own distribution station but will sell directly to UEDCL. * About having free electricity, the general manager said that a policy decision would have to be made concerning the possibility of free electricity but it is not a guarantee. However there are plans to connect all the camps which do not presently some have electricity and of the electricity will also be used for irrigation. * Involuntary and voluntary resettlement will be discussed at a later stage at the transmission line phase. However, he briefly said for those within that the camps, there would be internal resettlements. But for those outside the camps the resettlement will be according to the RAP which will be put in place and communicated to the concerned parties at a similar meeting. * It is safe for Kakira to produce the electricity since steam will be restricted to the inside of the factory and none will come out. There are safety valves to release the high pressure built up by the steam. Besides Kakira is presently producing electricity for its own consumption so they are experienced. Internally in-house protection safety will be taken care of especially sound for which ear-plugs will be provided. * The Safety, Health and Environment Superintendent of Kakira also said that the project will reduce excess baggasse which is presently a nuisance to the people's health. Fly ash arrestors will be installed and will prevent ash from getting to people's clothes and houses and consequently reduce complaints from neighbours. * The general manager said that KSW is considering sugarcane to import varieties with less fibre and more sugar. reducing This will help in the baggasse. Small projects of producing baggasse charcoal from are also being considered such that baggasse even the excess that has not been used in producing electricity utilized. will be * To take care of the continuous steam production, two mills which will operate side by side. When one is shut down for maintenance, then the other one will be working. Storage of the baggasse also be taken will be care of to ensure constant supply of electricity days a year. 365 * Kakira will sell the electricity to UEDCL therefore some profit will be obtained. However part of the proceeds will be used to service the loan from the World Bank. * The DEO of Jinja had a chance to talk to the forum about the need for EIA and what it is about. * The general manager said that Kakira is committed to the environment protecting and as such there are quarterly Environmental meetings to which the DEO of Jinja is also invited to discuss environmental issues pertinent to Kakira. Benefits of the project * Uganda as a country will benefit by having more power. * Employment opportunities for the people who will be the project. involved in * Out growers will benefit since there will be more demand for sugarcane by Kakira Sugar Works Ltd. It is projected that demand from the out growers will double in the next 4-5 years. As a monitoring programme result a for the out growers is being put in place such that before the farmers expand their field, management will be consulted to make sure that the sensitive environment like wetland is not interfered with. * For the workers benefit, management is planning an expansion of the factory consequently increasing the number of workers so as to lower the cost of production. This will reduce the threat of the cheaper sugar dumped into the country. Therefore the workers may not have direct benefits of profit but will have more job security. * Camps in Kakira which do not presently have electricity will access electricity as a result of this project. The people's view on negative impacts of the project. * Vandalism of the electric wires * Jobs lost particularly the baggasse drivers * Resettlement of the people. Reactions to the above views * The people will be sensitized and a task force will also be put in place to take care of any vandalism. Under ground cables may also be considered as a means of minimizing the vandalism of cables, however underground cables have peculiar disadvantages as well. * In the case of drivers who have been driving the baggasse trucks, none of them will lose a job directly as a result of the project. This is because turnover of the drivers is high and some have reached retirement age, while others will be taken to do other jobs. * A Resettlement Action Plan will be drawn up and disclosed to the parties concerned. Compensation of the affected parties will then be effected according to the prevailing district compensation rates. * The General Manger also went ahead to explain that he had a chance of speaking to the president and floated the idea of using sugar molasses to get ethanol. This ethanol would mixed with fuel. This would save on the fuel budget and would decrease on the 'nguli' distillers who use sugar molasses to make alcohol and dispose the dregs into the stream making water unsafe for the people. The president was keen on the project. The General manager thanked the participants and closed the meeting. 1 Nt%[AcY CVD-t - C, P

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ClF ep L.c1- - 2i3 A BY MARK KIRUMIRA 74-year-old corporation embarked on the project i . following , ,Rakira recommendations in 1986 by K Sugzar Works' (KSW) application SOFIRECO, '' an indcpcildent rescarch group for generating and selling powcr is being fromi K France. rcviewcd anid the outcome will bc out in KSW, May, Frank whicih currently produces 4MW of Sebboxva, the executive director of power, i the Electricity is sclf-sufficient in terms of power. Regulatory Authiority (ERA), has Initially, '...4i said. it had promised to generate 30MW of ~~, Sebbowa, whiich 18MW would be connected to the grid whlo was speaking at a conisultative on . .,_ workshop a 24 hiou r basis. However, the Ministry of Energy to hcar the public's views on the and 1 company's Minleral Development requested KSW to go , project proposal and application for down power to 7MW of power for six hours a day in the gencrationi, said that it would be in the peak interest period of 1800hrs to 2400 because the of the ERA to approve the project. The UETCL half-day workshop would only neced 7MW for the peak . was hlcid on April 20th at period from Sunset Hotcl, Jinja. 1800 to 240Ohrss According to thle Energy Pu "The ERA can rejcct, order variations hase Agreenient or (EPA) of 31st July2003 b n KSW, accept the project but Iost probably we siall UETCL (Uganda Elcctricity Transmission Company) not reject it bccause it might takc us too back,' said Scbbowa. and UEDCL (Uganda Electricity Distribution Company), it was agreed He said the project was good that Kakira would because it generate and sell power to would increase electricity supply, especially the UETCL at a ate in of US cents 4.9 per unit for 10 years. Busoga. Also, the surplus sold by Kakira peak timc at Some members of the public, however, wouild help alleviate load shedding, their voiced l-.. which stems concern that KSW might charge high tariffs. a from limiited power supply, addedd iut arhan | Sebbowa. said that people should know that W generating l l RO "Uniless we power from renewable sources is take on people like KSW then load more expensive Hawaii shedding is here and costs around 5 US cents Jinja (originated co-generation), ;& to stay," he said. globally, municipality's deputy Ethiopia, South Only 5%of the total mayor, Africa, Thailand e population (24 million KSW has submitted Bagoole Kirimwitta, and Indonesia. people) in Uganda have its Environmental Impact commended Now Tanzania and :.' electricity in their Statement (EIS) to the Madhvani Kenya are looking homes, said ERA chairman the National Environment business empire at it. Ben Dramadri. In Management for what he called At the close of the rural areas, only 2% Authority (NEMA). The good public hearing, of the population use Environmental Impact social responsibility and Sebbowa called electricity. Construction of a Review was completed in welcomed upon people to new power dam February 2004, and is now the project. look at electricity on Bujagali falls, whiich would augment awaiting approval. Co-generation in a commercial power Saidi Balaba of the UEDCL is done in perspective so as to supply, has been bogged down said that given the countries such as India, steer the by the growth of 8% in electricity consumption Mauzitius country to economic development. stupcndous cost of the project. President levels, (where 80% of power is KSW's project was welcome and it would derived Museveni commissioned the project in 2002. help from sugarcane and bagasse), While meet the increasing demand among UEDCL's See reIidstreso.apaoges2and6 presenting the KSW's proposal, the customers. project director, Nakhood Farhan, Fle added that more 80MW would be said that the produced by Kira Dam by 2005/06. To PAGE24 LADY BEHIND DEAL: Energy and Mlneral Devolopment minister Syda Bbumba l EW|UN Locals ipowr~~~~~~iraes I O uee By ASUBAXER MUKOSE Ricks KayIzzl - RESIDENTS of Jinja have asked district authorities to subsidise . ,. the price atgwichKaki- ... ra Sugar Works (KS W) Ltd will be selling elec- .- tricity. During a public hearing - at Sunset Hotel recently, the residents said leaving KSW to sell K. electricity would lead to exploitation. The hearing was organised by the Elec- tricity Regulatory Authority (ERA) to hear residents' views ...... on KSW's application to sell electricity to the national grid. "We have not been consulted on the charges and that may lead to exploitation by the power generators," said Simon Mukyawe. a THIS IS IT: ERA's chairman resident. Ben Dramadri, lawyer Johnson Kwesigabo and Ssebbowa Dr. Frank Ssebbowa, KSW would produce and would be sold the ERA chief executive sell power at $4.9 bagasse, which is used in officer, said to Uganda cents (sh95) to UETCL. the production a power pur- Electricity Distribution He said of elec- chase agreement had Company the company tricity. been Ltd (UEDCL) had invested $14mn into '"With signed between which would sell it to the increased Kakira and the Uganda consumers. project. bagasse, we wish to Electricity It also planned to increase Trransmis- Farhan Nakhooda, the expand electricity gener- sion Company Ltd Madhvarni the production ation to between 14 and (UTETCL). Group power capacity to 4000 tonnes of l5mega project manager, said cane watts in a co-gen- He said under the deal, each per day to ensure a eration arrangement," he electricity unit high generation of said.