EIA 1146 Study Report LPG Tank BAT Likoni (1) - 1146

ENVIRONMENTAL IMPACT ASSESSMENT STUDY REPORT FOR THE
PROPOSED INSTALLATION OF A 2t LIQUEFIED PETROLEUM GAS

STORAGE TANK AND FILLING POINT ON L.R. NO. 209/7139, OFF
LIKONI ROAD IN INDUSTRIAL AREA, NAIROBI
Prepared by:
1. Isaiah B. Kegora - Reg. No. 1893
2. Esther Andere
Approved by:
Philip Abuor- Reg. No. 1710
Date: May 2014

ENVIRONMENTAL IMPACT ASSESSMENT STUDY REPORT 2014
DOCUMENT RELEASE INFORMATION
Client Total Kenya Limited
Project Title Installation of a 2ton Liquefied Petroleum Gas Storage

Tank and Filling Point
Project Location L.R. NO. 209/7139, Off Likoni Road in Industrial Area,
Nairobi
Document Number
520452
Document Title EIA Study Report
Revision Status Final
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DETAILS OF PROPONENT AND FIRM OF EXPERTS
Proponent TOTAL KENYA LIMITED
Contacts Address 30736 00100 Nairobi
Tel (+254)20-2897000, 20-3668000
Fax (+254) 20-3668396
E-mail administrator@total.co.ke
Website www.total.co.ke
PIN No.
Contact Person Francis Saha
Firm of Experts SGS Kenya Limited
NEMA Reg. No. 0280
Contributors: 1. Lead Expert: NEMA Reg. No.1893
Mr. Isaiah B. Kegora
2. Esther A Kabaka
3. Lead Expert NEMA Reg. No.1710
Mr. Philip Abuor
Contacts Address P.O. Box 72118 00200 Nairobi
Tel +254 020 273 3690
Fax +254 20 2733664
E-mail Philip.abuor@sgs.com/isaiah_kegora@sgs.com
Website www.ke.sgs.com
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CERTIFICATION
The preparation of this EIA Study Report was commissioned by the management of Total
Kenya Limited in fulfillment of requirements of the EIA/EA Regulations and Environment
Management and Coordination Act, 1999.
Proponent: Total Kenya Limited
..
Name of Officer Designation
Signature / Date / Official Stamp
Submitted by:
Firm of Experts: SGS Kenya Limited Reg. No. 0280
Official Stamp
Approved by:
.. ..
Signature Date
Mr. Isaiah Kegora:
EIA/EA Lead Expert Reg. No.1893
.. ..
Signature Date
Mr. Philip Abuor:
Environmental Services Manager, EIA/EA Lead Expert Reg. No.1710
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ACKNOWLEDGEMENT
We extend our special thanks to the management of Total (K) Ltd (the Proponent) for
contracting SGS (K) Limited (the Firm of Experts) to prepare this E.I.A study Report for their
proposed installation of their Liquefied Petroleum Gas tank and cylinder filling station at BAT
Kenya, Likoni Road.
We further register our gratitude to the various stakeholders consulted during public
stakeholder consultation for their invaluable contribution, support and cooperation. Their input
contributed enormously towards successful completion of this E.I.A study report.
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ACRONYMS
Acronym Description
API American Petroleum Institute
ARV Anti Retroviral
BS British Standard
dB(A) Decibels on the A-Scale
EA Environment Audit
EHS Environment, Health & Safety
EIA Environment Impact Assessment
EMCA Environmental Management and Coordination Act
ESM Environmentally Sound Management
LPG Liquefied Petroleum Gas
MSDS Material Safety Data Sheet
NEMA National Environment Management Authority
NFPA National Fire Protection Association USA
OSHA Occupational Health and Safety Act
DHP Designated Health Practitioner
HSEQ Health Safety Environment and Quality
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EXECUTIVE SUMMARY
Introduction
Total Kenya limited (proponent) proposes to construct a 2ton LPG storage tank and filling
point on plot L.R. No. 209/7139, which is owned by British American Tobacco Ltd. The facility
will be operated by BAT (K) Ltd, Likoni Road; with the main purpose of providing more LPG
stock at the factory for refilling the forklifts cylinders.
The E.I.A for the project is being coordinated by SGS (K) ltd (NEMA registered firm of
experts). The firm has been appointed by the proponent to complete the EIA study in
accordance with Legal Notice (L.N.) 101: Environment (Impact Assessment and Audit)
Regulations 2003 promulgated under the Environment Management and Coordination Act,
1999.The proposed project is also expected to comply with the energy act and its subsidiary
legislation.
The proposed development activities will mainly involve civil, mechanical and electrical works
associated with the installation of the LPG tank and filling point and thereafter operations of
the facilities. The main activities to be carried out in the development of the proposed project
include excavations or earth works, installation of the tank and pump and pipe works.
The proposed project is expected to start immediately this Study Report is approved by
NEMA and EIA Licence is issued to the Proponent. It is estimated that the project will cost
approximately two million and seven hundred thousand Kenyan Shillings (Kshs 2,700,000.)
to complete.
The project site is located in an industrial set up. The neighborhood is characterized by
light industries such as printing firms, beverage manufacturing, motor vehicles parts
manufacturing plant and warehouses. The project area is served by two main roads;
Likoni Road and Enterprise Road.
Project Objectives
The proposed project aims to increase the availability of LPG at the Nairobi BAT Factory to be
used for powering the forklifts. BAT (K) is in the process of phasing out forklifts which use
diesel in a bid to support Government and their Companies corporate efforts to promote the
use of clean fuels.
Project Cost Estimate
The proponent has undertaken a preliminary estimate of the total project cost using
experienced consultants. The estimated total project cost is approximately Kshs 2,700,000.
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On the basis of the above project cost estimate, the proponent is paying Kshs. Kshs. 10 000
to NEMA as EIA license fee.
Project Description
Technical Description
The proposed project includes the:
Installation of a 2ton LPG Tank, with a diameter of 1.5m and a length of 3.03 m
Construction of a cylinder filling station;
Pipe works
Paint works
Water Sprinkler system
Construction of a Perimeter fence and gate
Safety design, engineering and operation
The proposed project will be designed, constructed, and operated in conformance with
applicable national and international EHS guidelines and standards. Regarding safety at the
facility the proponent will put in place all mechanisms, processes and procedures to eliminate
mitigate or control identified risks and promotes continuous improvement. Further to this the
proponent will apply HSEQ considerations in all planning, decision making, processes and
practices. Various measures have also been put in place to prevent leakages which include
an electronic check scale and manual leak detector. An emergency shutdown system will also
be installed to improve the safety situation at the facility. A hazardous operability study
(HAZOP) will be carried out during the design phase of the facility to incorporate health,
safety and environmental considerations.
An environmental management plan has been prepared which describes the environmental
protection strategies that will be employed at the site. The EMP contains the management
programmes and plans for handling the adverse environmental impacts.
Construction Phase
The LPG Tank will be transported from Mombasa to BAT Premises at Likoni Road in Nairobi.
Most raw materials and fittings required for the LPG facility will be sourced locally. Heavy duty
machinery including cranes, bulldozers, excavators, front-end loaders and electric welding
machines will be used during construction.
Construction activities are expected to generate noise levels to a limit of 85 decibels and
other safety hazards.
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Operational Phase
A fire protection system will be provided. It will by means of two 9Kg Dry powder
extinguishers and a water sprinkler system. The sprinkler system will comprise of 1 1/2" main
water line to tank and filling station, 1" and 3/4" cooling rings to storage tank complete with
thermospray sprinkler nozzles.
The facility will be hooked to the existing electricity supply line of KP&LC while Sewerage and
waste will be managed in accordance with the existing waste management procedures of
BAT Kenya limited and Environmental Management and Coordination (Waste Management)
Regulations of 2006.
Approximately 5 long term job opportunities will be generated through the operation of the
LPG station. Skilled and unskilled labor will be required in technical fields as in operations and
management. Local people will be employed wherever possible.
Noise levels will be kept to a minimum by designing the facility according to the requirements
of Kenyan legislation - The Environmental Management And Coordination (Noise And
Excessive Vibration Pollution) (Control) Regulations, 2009 and ISO: 15664:2001.Noise
impacts shall not exceed the standards [Threshold Limit Values (TLV),] adopted by
International Labor Organization (ILO), World Health Organization (WHO) and American
Conference of Industrial Hygienist (ACGIH) 1989-guideline document.
Approximately 5 long term job opportunities will be generated through the operation of the
LPG station. Skilled and unskilled labor will be required in technical fields as in operations and
management. Local people will be employed wherever possible.
Baseline Description of the Project Environment
The site enjoys temperate tropical climate with two rainy seasons. The mean annual rainfall
ranges between 850-1050mm (Lakin undated). The mean daily temperature ranges between
12 and 26C. The mean monthly relative humidity varies between 36 and 55 per cent.
The site is underlain by ancient core of crystalline rocks of the Basement Complex. The
prominent rock type in the project area is welded tuffs at shallower depths followed by
fractured phonolite. The soils are black cotton soil, which are inorganic clays of medium to
high compressibility and form a major soil group in Nairobi.
The ambient noise level at site is typical of the industrial setting. Existing noise data indicates
that noise levels range between 51.5 dB (A) and 62.5 dB (A). The ambient noise at the site is
mainly influenced by noise from neighboring industrial facilities and traffic on the nearby
Likoni Road.
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The ambient air quality is also typical of industrial setting. Available data on air quality of the
site indicate that the concentration of particulate matter, sulphur dioxide and nitrogen dioxide
in air are generally within guideline limits stipulated under the Draft EMC (Air Quality
Standards) Regulations, 2008.
Pollution from waste
During construction phase, waste will be generated from construction activities, domestic
waste from construction team, sewage, waste oil, treated timber, polythene and plastics
packing material and lubricants, containers of used construction materials and wastewater
from hydrostatic testing.
During operation phase, waste to be generated include domestic waste generated by the
operation staff, components/parts of the facilitys infrastructure been removed during
replacement; and redundant electronic equipment.
Whereas during decommissioning phase, the main waste generated will be demolished parts
of the facility which include; concrete boulders, scrap metals, plastics and rubber among
others. The contractor should develop an integrated solid waste management system for the
site.
Impacts on ambient noise quality
During the construction phase the proposed project will utilize machineries such as hydraulic
excavator, mobile service crane, dump trucks and tipper Lorries which are likely to generate
noise. The contractor at site will be expected to provide proper protective equipment and well
planned programs for equipment usage.
During operation phase noise generation will be from the generator, compressor and the
pumps. The amount of noise will depend on the size and the model of the pump to be used.
As will be the case with the construction phase, the sources of noise during decommissioning
phase, will be mainly machinery and vehicles used in demolition of the facility and removing
the materials from the site. The construction activities will be limited to daytime and the
workers will be provided with personal protective equipment.
Health and safety impacts
The potential health and safety impacts of the proposed project include the occupational
health and safety risks related to the project activities; risks to the public as a result of events
of major disasters such as fire outbreaks and explosions.
A number of activities undertaken during development of the proposed project have potential
risks to health and safety of the workers. During the construction phase, the potential H&S
risks the workers are likely to be exposed to include: Injuries resulting from falling from LPG
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tanks installation; Injuries resulting from operation of machinery, equipment, tools and
construction vehicle, Exposure to diseases, including, typhoid etc. and road accidents.
The potential occupational health and safety impacts during operation phase include injuries
to workers from, routine monitoring and maintenance and deaths and injuries from major
disasters e.g. explosions and fire outbreaks. During the operation phase, the workers may
come in contact with liquid LPG and suffer from severe cold burns whereas during
decommissioning, the potential H&S risks include injuries occasioned by dismantling of the
facility. The proposed project could be of great public concern especially in the event of a
major disaster such as explosions and fire outbreaks. Liquefied Petroleum Gas is a highly
flammable product and can be detrimental to the public safety if measures are not put in
place. The impact significance related to public safety is likely to be high during operation
phase of the project.
Environmental Management and Impact Mitigation
This report presents an environmental management plan which covers on the measures for
mitigating the adverse potential environmental impacts of the proposed project. The EMP
includes programmes and plans for addressing the adverse environmental impacts. The
proposed management programmes includes:
Air quality management programme

Noise management programme
While the plans include:
Construction management plan;
Construction control plan;
Workplace health and safety plan;
Community health and safety plan; and
Emergency management and response plan
The proposed programs and plans will be subjected to monitoring. Monitoring will have two
elements: routine monitoring against standards or performance criteria; and periodic review or
evaluation. Monitoring will often focus on the effectiveness and impact of the programme or
plan as a whole.
Analysis of alternatives
Several alternatives for the proposed project were evaluated. The alternatives considered
include: Location, process/activity/operation, layout, input, and no-go option. On the basis of
these considerations, the proposed project satisfies the overall economic, technical,
environmental and safety criteria used.
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Public Consultation
Public stakeholder consultation was undertaken in order to obtain the views and concerns of
the stakeholders regarding the proposed project. The stakeholders perceived that the project
will not generate adverse environmental impacts. Some of the pertinent issues which were
raised have been addressed in the environmental management plan.
Conclusion and Recommendations
Conclusion
The project, including the construction and operation of the LPG tank and cylinder filling
station is anticipated to provide sufficient stock of LPG at the factory and also lower CO 2
emissions to the atmosphere. The potential adverse impacts associated with the proposed
project are possible to mitigate successfully. The impacts before implementation of
mitigation measures are assessed as very low to medium low and the ratings are
expected to improve further with the implementation of the proposed mitigation
measures. In particular, the LPG facility will be designed, constructed and operated
according to the latest industry norms and standards. Programs and plans developed and
implemented through the EMP will be monitored and audited to ensure compliance.
Recommendation
The mitigation measures proposed in this report should be included in the tender contract
and tender documents so that the contractor who will be selected for the project will be
bound to implement them.
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TABLE OF CONTENTS
DOCUMENT RELEASE INFORMATION ............................................................................................... 2
DETAILS OF PROPONENT AND FIRM OF EXPERTS ........................................................................ 3
CERTIFICATION .................................................................................................................................... 4
ACKNOWLEDGEMENT ......................................................................................................................... 5
ACRONYMS ........................................................................................................................................... 6
EXECUTIVE SUMMARY ........................................................................................................................ 7
TABLE OF CONTENTS ....................................................................................................................... 13
LIST OF FIGURES ............................................................................................................................... 18
LIST OF TABLES ................................................................................................................................. 18
CHAPTER ONE .................................................................................................................................... 19
1 INTRODUCTION ........................................................................................................................ 19
1.1 Project Background ............................................................................................................. 19
1.2 Project Objectives ............................................................................................................... 19
1.3 Data Collection .................................................................................................................... 19
1.3.1 Review of secondary data ............................................................................................... 19
1.3.2 Interviews ........................................................................................................................ 19
1.3.3 Baseline environmental survey ....................................................................................... 19
1.3.4 Noise quality .................................................................................................................... 20
1.3.5 Air Quality Measurement ................................................................................................. 20
1.3.6 Assessing significance of Impacts................................................................................... 20
1.4 Purpose of this Report ........................................................................................................ 23
CHAPTER TWO ................................................................................................................................... 24
2 DESCRIPTION OF THE PROJECT ........................................................................................... 24

2.1 Project Location .................................................................................................................. 24
2.2 Proposed Project................................................................................................................. 25
2.3 Technology .......................................................................................................................... 25
2.3.1 Project Cost ..................................................................................................................... 27
2.3.2 LPG Storage Tank ........................................................................................................... 27
2.3.3 Cylinder Filling Station ..................................................................................................... 27
2.3.4 Perimeter Fencing ........................................................................................................... 27
2.3.5 Fire protection.................................................................................................................. 28
2.4 Construction Phase ............................................................................................................. 28
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2.4.1 Site preparation ............................................................................................................... 28

2.4.2 Materials .......................................................................................................................... 28
2.4.3 Product ............................................................................................................................ 29
2.4.3.1 By-products .............................................................................................................. 29
2.4.3.2 Waste ....................................................................................................................... 29
2.4.3.3 Air Emissions ........................................................................................................... 30
2.4.4 Noise Emissions .............................................................................................................. 30
2.4.5 Commissioning ................................................................................................................ 30
2.4.6 Operation Phase.............................................................................................................. 30
2.4.6.1 Products ................................................................................................................... 31
2.4.6.2 By-products .............................................................................................................. 31
2.4.6.3 Waste ....................................................................................................................... 31
2.4.6.4 Air Emissions ........................................................................................................... 31
2.4.7 Decommissioning Phase ................................................................................................. 31
2.4.7.1 Products and By-products ........................................................................................ 32
2.4.7.2 Waste ....................................................................................................................... 32
2.4.7.3 Air Emissions ........................................................................................................... 32
2.5 Health and Safety System .................................................................................................. 32
2.6 Employment ........................................................................................................................ 33
CHAPTER THREE ................................................................................................................................ 34
3 BASELINE ENVIRONMENT CONDITION ................................................................................. 34

3.1 Physical environment .......................................................................................................... 34
3.1.1 Soils and Geology ........................................................................................................... 34
3.1.2 Topography and Drainage ............................................................................................... 34
3.1.3 Climate ............................................................................................................................ 34
3.1.4 Ambient Noise Level ....................................................................................................... 34
3.1.5 Ambient Air Quality .......................................................................................................... 35
3.2 Biological Environment ....................................................................................................... 35
3.3 Socio-economic environment .............................................................................................. 35
CHAPTER FOUR .................................................................................................................................. 37
4 NATIONAL ENVIRONMENTAL LEGISLATIVE AND REGULATORY FRAMEWORK .............. 37

4.1 Policy ................................................................................................................................... 37
4.1.1 National Environment Policy ........................................................................................... 37
4.1.2 The Constitution .............................................................................................................. 37
4.2 LEGAL FRAMEWORK ........................................................................................................ 37
4.3 Institutional Framework ....................................................................................................... 49
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4.3.1 Ministry of Environment and natural resource ................................................................. 49

4.3.2 EMCA 1999 INSTITUTIONS ........................................................................................... 49
4.3.3 Ministry of Energy ............................................................................................................ 49
4.3.4 Energy Regulatory Commission (ERC) ........................................................................... 50
CHAPTER FIVE .................................................................................................................................... 51
5 ENVIRONMENTAL IMPACT ASSESSMENT ............................................................................ 51

5.1 Assessment of impacts ....................................................................................................... 51
5.2 Potential impacts of the proposed project ........................................................................... 51
5.2.1 Soil and geology impacts ................................................................................................ 51
5.2.1.1 Contamination of soil ................................................................................................ 51
5.2.1.2 Soil erosion............................................................................................................... 53
5.2.2 Air quality Impacts ........................................................................................................... 54
5.2.2.1 Decreased air quality due to dust emission ............................................................. 54
5.2.2.2 Air Pollution from Incidents ...................................................................................... 56
5.2.2.3 Exhaust emissions ................................................................................................... 57
5.2.3 Noise and vibration .......................................................................................................... 58
5.2.4 Impacts of waste generation ........................................................................................... 62
5.2.5 Health and safety ............................................................................................................ 64
5.2.5.1 Occupational health and safety ................................................................................ 64
5.2.5.2 Risk of Large Scale incident..................................................................................... 66
5.2.6 Socioeconomic ................................................................................................................ 68
5.2.6.1 Compatibility with existing and proposed land uses ................................................ 68
5.2.6.2 Creation of employment opportunities ..................................................................... 68
5.2.6.3 Improved Security .................................................................................................... 69
5.2.6.4 General economic growth and increased land value ............................................... 69
5.2.6.5 LPG Provision .......................................................................................................... 70
5.2.7 Cumulative impacts ......................................................................................................... 70
5.3 Summary of Impacts ........................................................................................................... 71
CHAPTER SIX ...................................................................................................................................... 73
6 ANALYSIS OF ALTERNATIVES ................................................................................................ 73

6.1 No Project Scenario ............................................................................................................ 73
6.2 Location Alternative ............................................................................................................ 73
6.3 Design Alternatives ............................................................................................................. 73
6.3.1 Proposed Option.............................................................................................................. 73
6.3.2 Mounded Bullet Option .................................................................................................... 74
6.3.3 LPG spheres.................................................................................................................... 74
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6.4 Input alternatives ................................................................................................................. 75

6.5 Conclusion .......................................................................................................................... 75
CHAPTER SEVEN ................................................................................................................................ 76
7 PUBLIC STAKEHOLDER CONSULTATION ............................................................................. 76

7.1 Objective of Public Stakeholder Consultation ..................................................................... 76
7.2 Approach used in carrying out the PSC .............................................................................. 76
7.3 Comments and Responses from the Stakeholders ............................................................ 76
CHAPTER EIGHT ................................................................................................................................. 79
8 ENVIRONMENTAL MANAGEMENT PLAN ............................................................................... 79

8.1 Approach to environmental impact management ............................................................... 79
8.2 Responsibility and Accountability........................................................................................ 80
8.2.1 Environmental Management Structure ............................................................................ 80
8.2.2 Management of Contractors ............................................................................................ 82
8.2.3 Training, Awareness and Capacity Building .................................................................... 83
8.2.4 Monitoring and Compliance Assessment ........................................................................ 83
8.2.5 Incident handling and Reporting...................................................................................... 84
8.2.6 Checking and corrective action ....................................................................................... 84
8.2.7 Corrective Action ............................................................................................................. 84
8.2.8 Reporting ......................................................................................................................... 85
8.2.9 Management review ........................................................................................................ 85
8.2.10 Liaison .......................................................................................................................... 85
8.3 Overview of the Proposed Project ...................................................................................... 85
8.3.1 Planning and design ........................................................................................................ 85
8.3.2 Construction Phase ......................................................................................................... 86
8.4 Impact mitigation and management .................................................................................... 86
8.4.1 Impacts and mitigation/ management measures ............................................................ 86
8.4.2 Management of impacts during construction phase........................................................ 87
8.4.3 Management of impacts during operation phase ............................................................ 87
8.4.4 Checking and corrective action ....................................................................................... 88
8.4.5 Monitoring ........................................................................................................................ 88
8.4.6 Inspections: construction phase ...................................................................................... 88
8.4.7 Internal and external audits ............................................................................................. 88
8.4.8 Corrective Action ............................................................................................................. 89
8.4.9 Reporting ......................................................................................................................... 89
8.4.10 Management review .................................................................................................... 89
8.4.11 Liaison .......................................................................................................................... 89
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8.5 Impact mitigation and management .................................................................................... 89

8.5.1 Impacts and mitigation/ management measures ............................................................ 90
8.6 Management Programmes ............................................................................................... 103
8.6.1 Air quality management programme ............................................................................. 103
8.6.2 Noise management programme .................................................................................... 104
8.6.3 Occupational Health and Safety Programme ................................................................ 104
8.7 Management Plan ............................................................................................................. 104
8.7.1 Overview........................................................................................................................ 104
8.7.2 Construction Management Plan .................................................................................... 104
8.7.3 Construction Control Plan (CCP) .................................................................................. 107
8.7.4 Labor and Human Resources Plan ............................................................................... 108
8.7.5 Workplace Health and Safety Plan ............................................................................... 108
8.7.6 Community health and safety plan ................................................................................ 108
8.7.7 Emergency Management and Response Plan .............................................................. 109
8.8 Monitoring ......................................................................................................................... 110
8.8.1 Programme Monitoring .................................................................................................. 111
8.8.2 Plan Monitoring.............................................................................................................. 111
CHAPTER NINE ................................................................................................................................. 112
9 INCIDENT PREVENTION AND HAZARD COMMUNICATION ACTION PLAN ....................... 112

9.1 Incident Prevention Construction Phase ........................................................................ 112
9.1.1 Responsibilities with regard to safety ............................................................................ 112
9.1.2 Designation of First Aiders ............................................................................................ 112
9.1.3 Contractor Employee Responsibility with regard to Safety ........................................... 112
9.1.4 Personal Conduct .......................................................................................................... 113
9.1.5 Personal Protective Equipment (PPE) .......................................................................... 113
9.1.6 Fire and Emergency Procedures ................................................................................... 113
9.1.7 Security Procedures ...................................................................................................... 113
9.1.8 Working Tools and Equipment ...................................................................................... 113
9.2 Incident Prevention Operational Phase ......................................................................... 114
9.2.1 Proponents HSE Management System ........................................................................ 114
9.2.2 Emergency Response Plan ........................................................................................... 114
CHAPTER TEN ................................................................................................................................... 115
10 ASSUMPTIONS, UNCERTAINTIES ENCOUNTERED AND GAPS IN KNOWLEDGE ............................... 115

10.1 Assumptions ...................................................................................................................... 115
10.2 Uncertainty and Difficulties in Compiling Information ....................................................... 115
CHAPTER ELEVEN ........................................................................................................................... 116
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11 CONCLUSION AND RECOMMENDATION ......................................................................... 116
ATTACHMENTS ................................................................................................................................. 117
REFERENCE ...................................................................................................................................... 123
List of Figures
FIGURE 1: SATELLITE IMAGE SHOWING THE LOCATION OF THE PROPOSED PROJECT SITE ................................ 24
FIGURE 2: TYPICAL MOUNDED BULLET................................................................................................................. 74
FIGURE 3: AN IMAGE OF LPG SPHERE ................................................................................................................ 75
FIGURE 4: PROPOSED ENVIRONMENTAL MANAGEMENT STRUCTURE ................................................................ 80
List of Tables
TABLE 1: CRITERIA FOR ASSESSING SIGNIFICANCE OF IMPACTS ........................................................................ 21
TABLE 2 : SIGNIFICANCE RATING MATRIX ........................................................................................................... 22
TABLE 3: POSITIVE/NEGATIVE MITIGATION RATINGS AND ASSOCIATED COLOR CODES ..................................... 23
TABLE 4: STANDARDS TO BE USED FOR THE PROPOSED LPG FACILITY ............................................................ 26
TABLE 5: SUMMARY OF LEGISLATIONS APPLICABLE TO THE PROPOSED PROJECT ............................................. 38
TABLE 6: SUMMARY OF IDENTIFIED IMPACTS ...................................................................................................... 71
TABLE 7: LIST OF STAKEHOLDERS CONSULTED DURING PROJECT REPORT PREPARATION ............................. 77
TABLE 8: ADDITIONAL STAKEHOLDERS CONSULTED DURING PREPARATION OF EIA STUDY REPORT .............. 77
TABLE 9: APPROACH USED TO MANAGE POTENTIAL IMPACTS ........................................................................... 79
TABLE 10: FUNCTIONS OF STAFF IN IMPLEMENTATION OF EMP ........................................................................ 81
TABLE 11: MITIGATION AND MANAGEMENT MEASURES FOR THE IDENTIFIED IMPACTS ...................................... 91
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CHAPTER ONE
1 INTRODUCTION
1.1 Project Background
Total Kenya Limited, one of the leading oil marketers in Kenya, which is hereinafter referred
to as Proponent, is proposing to install a 2ton petroleum storage tank and a cylinder filling
station at British American Tobacco Kenya premises, located along the Likoni Road in
Industrial area of Nairobi.
The Legal Notice No. 101 of 2003 (EIA/EA Regulations, 2003) requires the Proponent to
prepare EIA Study Report for approval by National Environment Management Authority
(NEMA) prior to commencement of a new development. As such, Total Kenya Limited
engaged SGS Kenya Limited to undertake environmental impact assessment for the
proposed project.
1.2 Project Objectives
The Proponent is seeking to have sufficient stock of LPG for powering the forklifts used in
their operations. There is an underway plan of phasing out the forklifts that use diesel and
replacing them with those that utilize LPG. The Proponent intents to increase the number of
forklifts that uses LPG gas from 15 to 30. The proposed 2tone tank will ensure the availability
and accessibility of the gas.
1.3 Data Collection
The Firm of Experts employed various approaches in collecting data and information for
assessing the impacts of the proposed project. The following techniques were used:
1.3.1 Review of secondary data
A wide range of environmental and socio-economic data were sought to describe the baseline
conditions at the project area. These included socio-economic, physical and environmental
data and reports from government departments and on-line sources.
1.3.2 Interviews
Interviews were conducted during public stakeholder consultation in order to obtain the views
and concerns of the interested parties as regard to the proposed project. A semi structured
interview checklist was used to capture the responses of the stakeholders.
1.3.3 Baseline environmental survey
Baseline environmental survey was undertaken in order to understand the prevailing

conditions and to predict the likely changes once the proposed project is operationalized. The
baseline survey was done on noise quality and air quality of the proposed site. The survey
reports are appended to this report.
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1.3.4 Noise quality
The ambient noise level at the proposed site was measured using precision type 1 accuracy
Integrating Sound Level Meter accuracy Integrating Sound Level Meter. The instrument was
calibrated using sound level calibrator at 94 dB (A) and 1000 Hz. The calibration was used to
check the sensitivity of the instrument immediately before and after the measurement period.
The meter was set to measure the A-weighted noise level, which varies with the frequency
and intensity like the sensitivity of the human ear.
The sound level meter was held at 1 metre from the ground and the L eq, (the continuous
equivalent sound pressure level) and an indicative of the average noise level over a given
period), sample measurements were taken at various locations in the proposed site.
1.3.5 Air Quality Measurement
Air quality measurement was done to determine the levels of air contaminants of concern
associated with the operations at the project area. The measurements were done using
Minivol air samplers were used at the selected locations for fine particulate monitoring. The
Minivol portable air sampler is an ambient air sampler for particulate matter. The sampler is
positioned with the intake upward in an unobstructed area, free from any obstruction to
airflow. The sampler is fitted with a PM10 inlet, which only allows for particles of an
aerodynamic diameter of less than 10 m (PM10) to pass through it. The sample is drawn
through the unit at a predetermined flow rate and collected onto filter papers over typically 24-
hr sampling periods.
1.3.6 Assessing significance of Impacts
The first stage of impact assessment is identification of environmental activities, aspects and
impacts. The significance of the impacts is then assessed by rating each variable numerically
according to defined criteria as outlined in Table 1.
The purpose of the rating is to develop a clear understanding of influences and processes
associated with each impact. The severity, spatial scope and duration of the impact together
comprise the consequence of the impact and when summed can obtain a maximum value of
15. The frequency of the activity and the frequency of the impact together comprise the
likelihood of the impact occurring and can obtain a maximum value of 10. The values for
likelihood and consequence of the impact are then read off a significance rating matrix (Table
2), and it is determined whether mitigation is necessary using Table 3.
The definitions used in the impact assessment are given below:

An activity is a distinct process or task undertaken by an organization for which a
responsibility can be assigned. Activities also include facilities or components of
infrastructure that are owned by an organization.
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An environmental aspect is an element of an organizations activities, products and

services which can interact with the environment. The interaction of an aspect with the
environment may result in an impact.
Environmental impacts are the consequences of these aspects on environmental resources
or receptors of particular value or sensitivity, for example, disturbance due to noise and health
effects due to poorer air quality.
Receptors can comprise, but are not limited to, people or human-made structures or systems,
such as local residents, communities and social infrastructure, as well as components of the
biophysical environment such as aquifers, flora and palaeontology. In the case where the
impact is on human health or wellbeing, this should be stated. Similarly, where the receptor is
not anthropogenic, then it should, where possible, be stipulated what the receptor is.
Resources include components of the biophysical environment.

Frequency of activity refers to how often the proposed activity will take place.
Frequency of impact refers to the frequency with which a stressor (aspect) will
impact on the receptor.
Severity refers to the degree of change to the receptor status in terms of the
reversibility of the impact; sensitivity of receptor to stressor; duration of impact
(increasing or decreasing with time); controversy potential and precedent setting;
threat to environmental and health standards.
Spatial scope refers to the geographical scale of the impact.
Duration refers to the length of time over which the stressor will cause a change in the
resource or receptor.
Table 1: Criteria for assessing significance of impacts
Consequences
Magnitude of Impact Rating
Negligible 1
Minor 2
Marginal 3
Significant 4
Catastrophic 5
Spatial Scope/Geographic Extent of Rating

Impact
Activity specific 1
Site specific 2
Local area (within 5km of the project site) 3
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Regional 4
National 5
Duration of Impact Rating

One day to one month 1
One month to one year 2
One year to ten years 3
Life of operation 4
Post closure/permanent 5
Likelihood
Frequency/duration of activity Rating
Annually or less 1
6 monthly/temporary 2
Monthly/infrequent 3
Weekly/life of operation 4
Daily/permanent 5
Frequency of impact Rating

Almost never/Impossible 1
Very seldom/highly unlikely 2
Infrequent/ unlikely seldom 3
Often/regularly/likely/possible 4
Daily/highly likely/definitely 5
Table 2 : Significance Rating Matrix

Consequence (Magnitude+ Geographic extent + Duration of the impact
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Likelihood (Frequency of Activity Frequency of Impact
2 4 6 8 10 12 14 16 18 20 22 24 26 28 30
3 6 9 12 15 18 21 24 27 30 33 36 39 42 45
4 8 12 16 20 24 28 32 36 40 44 48 52 56 60
5 10 15 20 25 30 35 40 45 50 55 60 65 70 75
6 12 18 24 30 36 42 48 54 60 66 72 78 84 90
7 14 21 28 35 42 49 56 63 70 77 84 91 98 105
8 16 24 32 40 48 56 64 72 80 88 96 104 112 120
9 18 27 36 45 54 63 72 81 90 99 108 117 126 135
10 20 30 40 50 60 70 80 90 100 110 120 130 140 150
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Table 3: Positive/negative mitigation ratings and associated color codes

Significance Value Color Negative Impact Management Positive Impact Management
rating Code Recommendation Recommendation
Very high 126-150 Propose mitigation measures Maintain current management
High 100-120 Propose mitigation measures Maintain current management
Medium high 77-105 Propose mitigation measures Maintain current management
Low medium 52-75 Maintain current management Improve current management
Low 25-50 Maintain current management Improve current management
Very low 4-24 Maintain current management Improve current management
1.4 Purpose of this Report
This report addresses the requirement for preparation of EIA Study Report in accordance with
EIA/EA Regulations, 2003.
The report presents an overview of the proposed project and the environmental regulatory
framework from which it operates. It identifies and assesses the significance of the impacts of
the project as well as mitigation measures necessary to reduce or prevent impacts from
occurring.
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CHAPTER TWO
2 DESCRIPTION OF THE PROJECT
2.1 Project Location
The proposed project will be developed on Plot No L.R. No. 209/7139 which is along Londiani
Road, off Likoni Road in Industrial Area, Nairobi City. The owner of the land is BAT (K), Likoni
0 0
Road. Geographically, the site is located on Longitude 036 51 19.22 East and Latitude 01
18 17.10 South.
Copy of certificate of title of the land is appended at the end of this report (Appendices 1).
Figure 1 below is a satellite image showing the location of the project site
Londiani Rd
BAT Factory Project site
Likoni Rd
Figure 1: Satellite Image showing the location of the proposed project site
Source: Google Earth
The site is bound by Modular Products Ltd to the West, Vas Auto Center Ltd to the North and
Agro Manufacturing Co. Ltd and Blue Waves. Across the Likoni Road which is on the West, is
the BAT factory.
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2.2 Proposed Project
The proposed project will have a 2ton Liquefied Petroleum Gas aboveground tank, a filling
station and perimeter fencing. The project will occupy an area of approximately (17*8.05)
square meters. LPG cylinders from the forklifts will be brought at the site for refilling.
The task will involve

Excavation through black cotton soil to a depth not exceeding 0.8m to hard rock and cart
away debris
Construction of a tank foundation (4m long by 2m wide by 0.5m deep)
Fabrication of filling shed (1.2m by 1.2m by 2m high).
Casting a reinforced concrete slab for LPG pump(0.6m by 0.6m by 100mm thick)
LPG piping work
Painting work
Purge air from tank and pipelines and commission
Perimeter fencing
Copies of the site layout and drawings showing the respective features of the proposed
project are appended at the end of this report (Appendices, 2 and 3)
2.3 Technology
The primary technologies used for the design, construction and operation of the LPG facility
include various international codes of practice, Standards, Government Acts and Local
Authority Regulations.
In Kenya there are a limited number of regulations covering the technology to be used in the
design, construction and operation of LPG station. Subsequently the country relies on
international codes of practice, standards and guidelines for the design, construction and
operation of such facilities.
The proposed project will be designed and constructed in alignment with the standards
quoted in table 4 below.
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Table 4: Standards to be used for the Proposed LPG facility
Mechanical Works
The handling, storage and distribution of liquefied petroleum gas in Domestic,

commercial and industrial installations-code of practice.
Part 1: Liquefied petroleum gas installations involving gas storage containers
of individual capacity not exceeding 500Land a combined water capacity not
Kenya Standards exceeding 3000L per installation.
KS 1938-3:2006 Part 2: Transportation of LPG in bulk by road.
Part 3: Liquefied petroleum gas installations involving storage vessels of
individual water capacity exceeding 500L
Part 4: Storage and filling sites for refillable liquefied petroleum gas(LPG)
containers not exceeding 15 kg
Steel Wedge Gate Valves for the Petroleum, Petrochemical and Allied
BS 1414
Industries
Steel Check Valves (Flanged and Butt-Welding Ends) for the Petroleum,
BS 1868
Petrochemical and allied Industries
Steel Wedge Gate, Globe and Check Valves 50mm and smaller for the
BS 5352
Petroleum, Petrochemical and Allied Industries.
ASME B 16.9 Factory Made Wrought Steel Butt Welding Fittings
1P part 2 Marketing Safety Code (for all works)
Electrical Works
BS 5467 Specification for XLPE Insulated Cables
BS 5486 Low Voltage Switchgear and Control Gear Assemblies
BS 5501 Electrical Apparatus for Potentially Explosive Atmospheres
BS 7430 Code of Practice for Earthing
BS 7671 Requirements for electrical Installations
IP Part 1 Electrical Safety Code
IEC 502 Specification for XLPE insulated Power Cables
Instrumentation and Control
BS 381 C Colors for Identification, Coding and special Purposes
BS 1363 1 3A plugs, socket-outlets and adapters
BS 4196 Sound Power Levels of Noise Sources
BS 5308 Instrument Cables
Code of Practice for Instrumentation in process Control Code of Practice for
BS 6739
Earthing
Code of Practice for the Instrumentation of in Process Control Systems: socket
BS 6739
outlets and couplers for industrial purposes
P Part 15 Area Classification code for Petroleum Installations
Civil and Structural Standards
BS 8110 Structural use of concrete
BS 8004 Code of practice for foundations
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BS 5328 Specification for concrete

BS 6032 Code of practice for earth works
BS 1881 Testing concrete
BS 812 Testing aggregates
2.3.1 Project Cost
It is approximated that the construction of the proposed project will cost Kshs 2,700,000. This
cost will be shared between the Proponent and BAT (K) Ltd. Therefore, the Proponent will
pay Kshs. 10 000 to NEMA as EIA licence fee.
2.3.2 LPG Storage Tank
The 2 ton storage tank will be transported from Mombasa. It will have a diameter of 1.5m and a
length of 3.03 m. It will be put on a Tank foundation pad u/g measuring 4m long by 2m wide by
0.5m deep, the design is as per BS 8110 Standard. The tank will be located 9m from the filling
point. During construction, the contractor will adhere to international and local standards including
NFPA 28, API 25, API 2510A and KS 1938.
The filling station will be supplied with a fire extinguisher to be used in case of fire emergencies.
2.3.3 Cylinder Filling Station
The cylinder filling area will be reinforced with a thick concrete slab for the LPG Pump. The
pump will be installed 3m from the LPG cylinder and 6m from the filling shed. The shed will
measure 1.2m by 1.2m by 2m high, with a cast slab beneath of measuring 1.2m by 1.2m by
100mm thick.
The filling process will take place in the cylinder filling area. The Plants filling stock
management system will be fully computerized. This will ensure that every single cylinder will
be filled thoroughly and that instances such as over-filling, under-filling, and leakages do not
occur.
Before the LPG cylinders are filled, a pre-fill inspection of the cylinders will be undertaken to
ensure that the cylinders are safe to fill. The cylinders that are found to be in good condition
will be filled, sealed, weighed and taken back to the factory.
2.3.4 Perimeter Fencing
The project will have a perimeter fence of 7.5m, 17m and 3m high. This will be reinforced by
3m long 3" by 3" by 6mm Angle Iron fence supports. Chain links will be bound on the iron
bars and a steel gate of size 1.5m wide by 2.0 m high, will be fabricated and installed.
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2.3.5 Fire protection
The facility will have a comprehensive fire fighting system covering all hazardous areas and
the other areas of the facility. This ensures that any fire within the depot is quickly surpassed
and extinguished. It includes fire water sprinkler systems for the LPG tank, and also two 9Kg
dry powder extinguishers will be mounted at the facility.
2.4 Construction Phase
2.4.1 Site preparation
The site preparation work will consist of the following; site clearing (relocation of pallets and
boxes), excavation followed by backfilling and compaction. The waste generated from site
clearing will be transported and dumped by the waste handlers. The Contractor will be in
charge for the transport of raw materials to site during construction process. Some of the
materials to be delivered to the site include aggregates, masonry stones, cement, iron sheets
and other construction materials.
Environmental protection during the construction phase will address management of

hazardous materials, dust, erosion and sedimentation control. The site will be
maintained in accordance with relevant erosion and sedimentation control standards for
construction sites. Curbs will be incorporated in parking and process areas to allow for storm
water from these areas to be drained to a collection area equipped with a sump where runoff
can be checked prior to release and connected to properly designed oil water separators.
2.4.2 Materials
The exact quantities of materials required for the construction of the proposed project are not
known at this stage of the project. The Proponent will utilize several materials in the
construction of the project. Some of the materials have been sourced locally whereas others
have been obtained from sources outside Nairobi City.
The materials to be used in the construction of the projects consist of the following:
a) Concrete
b) Sandstone
c) Sand
d) Steel rods
e) PVC pipes
f) Water
g) Paint
h) corrugated preprinted roofing
i) energy Diesel and electricity
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2.4.3 Product
The final product after construction phase is LPG storage facility which will comprise
of a 2 ton Aboveground Storage Tank and associated Pipe work and a Gas filling
area.
2.4.3.1 By-products
The Proposed project will generate several byproducts during both construction and operation
phases.
During the construction phase of the project it is envisaged that the by-products might include:
Metal cuttings generated from the construction activities
Any excess construction materials brought to the project site by the contractor which can
be reused later
Excavated material
2.4.3.2 Waste
During construction the proposed project is anticipated to generate different waste which shall
include:
Domestic Waste from the Construction Area
The workers will not be supplied with any forms of foodstuffs. They are expected to buy or
carry their own food. Plastic bags and containers which the workers will use to carry their food
are expected to increase within the site and in the immediate vicinity.
Other forms of waste include sanitary waste and therefore the provision of sanitary facilities
will need to be considered both for the site construction workers and the visiting population.
Site Construction Waste
The project will generate waste from the site construction activities which includes:
Excavated soils and vegetation;
Construction equipment and maintenance wastes;
Dust and fumes;
Scrap metals;
Packaging materials, etc.
The wastes will be segregated in accordance with Legal Notice 121: Waste Regulation, 2006
with recyclable material collected and transported to a recycling facility. An effort will be
made to minimize the amount of waste generated by application of 4-R principles (reduce,
reuse, recycle, recover) to the extent practical. Non-recyclable wastes should be
transported offsite to a permitted landfill. A Waste Management Plan (WMP) will be
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developed for all phases of the Project. The objective of this plan is to minimize waste
discharges and emissions and identify appropriate waste reduction and other mitigative
measures.
Additionally, a Construction Environment Management Plan (CEMP), including plans for

erosion and sediment control measures will be developed prior to commencement of
construction activities and implemented to minimize impacts to water quality from
construction activities. Other measures that will be implemented include:
Programming site activities to minimize the disturbance of the project surface area;
Avoid maintaining open excavations for prolonged periods and compact loose materials;
Compacting soils as soon as excavations, filling, or leveling activities are complete;
Implementing measures to control against sedimentation and erosion, and to ensure that
construction personnel are familiar with these practices and conduct them properly; and
Control of runoff during the construction phase.
2.4.3.3 Air Emissions
Air quality impacts associated with construction activities are generally related to the
generation of dust especially during dry weather conditions and exhaust emissions
from the operation of construction equipment. Control measures, such as use of
dust suppression techniques, will be used in construction zones as required to
minimize the impacts from fugitive dust. The air emissions from the construction
equipment will be localized and temporary, lasting the duration of construction
activities. Routine inspection and maintenance of construction equipment will
minimize exhaust fumes.
2.4.4 Noise Emissions
The target noise levels during construction are set at 75dB (A) (BS 5228, 1997) during the
day and 70 during the night.
2.4.5 Commissioning
The final stage of construction is the start-up and commissioning of the facility. During the
commissioning stage, air will be purged from the tank and pipelines.
2.4.6 Operation Phase
Once commissioned, the tank will be filled with LPG. The gas will be brought in by Total trucks.
The proposed LPG will only serve BAT Kenya, and will be used for refilling the cylinders used
by their forklifts.
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2.4.6.1 Products
The primary product of the proposed project during the operational phase will be Liquid
Petroleum Gas.
2.4.6.2 By-products
During the operational phase of the project it is not expected that there will be any by-
products generated.
2.4.6.3 Waste
Effluent Waste
The following wastewater will be generated during Project operations:

Storm water runoff.
Contaminated waste water from the truck parking area from potential spills which
together with the storm water will be directed through an oil water separator prior to
discharge.
The above effluent water will be discharged offsite through the BAT drainage system.
Domestic Waste
Some of the domestic waste to be generated at the facility will include office waste such as
paper, empty cans among others.
Sewage Waste
The employees of the Proponent who will be based within the project area are expected to
generate sewage waste which will be channeled to the conservancy tank.
The proposed facilities will be designed to international standards. Subsequently emissions

from trucks and lifting machinery etc are expected to be low.
The only emission sources of significance for the project emission inventory during
normal operations include:
Intermittent emissions from routine testing of diesel engine driven emergency generator
for backup power;
Emissions from trucks offloading the LPG gas
Emissions from trucks and other vehicles to be loaded with cylinders.
2.4.7 Decommissioning Phase
Upon decommissioning of the proposed LPG tank, rehabilitation of the project site will be
carried out to restore the site to its original status or a better status than it was originally. This
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will include replacement of top soil and re-vegetation which will lead to improved visual quality
of the area.
2.4.7.1 Products and By-products
During the decommissioning phase it is expected that there will be no product. However the
by-products during decommissioning phase will include:
Metal generated from the decommissioning of Pipe work infrastructure; and
Foundation materials which can be donated to individuals for reuse
2.4.7.2 Waste
During the Decommissioning phase of the proposed project, several waste products are
expected to be generated. These shall include:
Metals from Pipe work infrastructure

Demolition wastes from the office block
Dusts and fumes;
Scrap metals.
The demolition activities that will occur particularly during the demolition process will generate
a considerable amount of dust and other particulates that will be released into the
atmosphere.
The demolition machinery, equipment and trucks brought in by the Contractor are expected to
generate smoke emissions. The concentration of emissions will depend on the maintenance
levels of the equipment, machinery and trucks used by the Contractor.
2.5 Health and Safety System
The potential health and safety impacts of the proposed project include the occupational
health safety risks related to the project activities; risks to the public as a result of events of
major disasters such as fire outbreaks and explosions.
The potential occupational health and safety impacts during construction phase will include
injuries through the construction activities whilst during the operation phase they will include
injuries to workers from, routine monitoring and maintenance and deaths and injuries from
major disasters e.g. explosions and fire outbreaks . Whereas during decommissioning; the
potential H&S risks include injuries occasioned by dismantling of the facility.
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2.6 Employment
The proposed project is expected to create employment in both the construction and
operation phases of the project.
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CHAPTER THREE
3 BASELINE ENVIRONMENT CONDITION
The baseline environmental condition of the proposed project is described in terms of the
existing physical, biological, and social environment.
3.1 Physical environment
The physical characteristics of the proposed project site is described in terms of soils,
geology, topography, drainage, climate, ambient noise levels and non ionizing radiation
levels.
3.1.1 Soils and Geology
The proposed project site is overlain by ancient core of crystalline rocks of the Basement
Complex which underlies the greater part of the plateau areas of Africa which have been
affected by the extensive faulting, displacement and volcanic activity associated with the
Rift Valley System (Ministry of Water and Irrigation 2011). The prominent rock type in the
project area welded tuffs at shallower depths followed by fractured phonolite while the
soils are black cotton soil, which are inorganic clays of medium to high compressibility
and form a major soil group in Nairobi (Ministry of Roads, 2012). They are characterized
by high shrinkage and swelling properties. Because of its high swelling and shrinkage
characteristics, the black cotton soil has been a challenge to the construction engineers.
The soil is very hard when dry, but loses its strength completely when in wet condition.
3.1.2 Topography and Drainage
3.1.3 Climate
The project area and the entire Nairobi City has a temperate tropical climate with two
rainy seasons. The area receives high rainfall between March and April and experiences
short rainy season between November and December. The mean annual rainfall ranges
between 850-1050mm (Lakin undated). The mean daily temperature ranges between 12
and 26C. It is usually dry and cold between July and August, but hot and dry in January
and February (CBS 2003). The mean monthly relative humidity varies between 36 and 55
per cent. The mean daily sunshine hours varies between 3.4 and 9.5 hours (CBS 2003a).
3.1.4 Ambient Noise Level
The ambient noise levels of the proposed site influenced by noise from the neighbouring
industrial facilities and traffic on the nearby Likoni Road.
The data of noise measurement undertaken at the project site in 2012 indicates that
ambient noise levels at the site range between 51.5 dB (A) and 62.5 dB (A). The levels
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are expected to increase during construction phase; however, implementation of the

proposed recommended measures will keep the levels within the acceptable limits.
3.1.5 Ambient Air Quality
The data of ambient air quality measures undertaken at the project site in 2012
indicates that the concentration of particulate matter, sulphur dioxide (SO2) and Nitrogen
dioxide (NO2) in the air are within the 120 g/m3 recommended by the draft EMC (Air
Quality Standard) Regulation, 2008 for an industrial area. The concentrations were: NO2
(32.8 g/m3), SO2 (14.1 g/m3) and particulate matter (15 g/m3). The air quality is
expected to be impacted by construction and demolition activities; however,
implementation of the proposed recommended measures will keep the levels within the
acceptable limits.
3.2 Biological Environment
The project site is mainly covered by buildings and paved surface. There are ornamental
trees on the fence and along the nearby road. A huge acacia tree on the neighbouring
plot to south east has branches hanging over the boundary of the proposed site. The
trees on fence will be removed and a boundary wall erected. A flower garden has been
included in proposed the design of the gym.
3.3 Socio-economic environment
Water
Ground and surface water both play an important role in water supply for Nairobi. The
principal source of water for Nairobi is surface water from the Tana River drainage basin
(Foster and Tuinhof 2005). Freshwater is also found in the three main rivers that flow
through Nairobi, but quality is a problem.
As regards to the project site, the Proponent has two onsite boreholes which supplies
water for general use while drinking water is supplied by a contractor in bottles. Water is
used for flowering, cooking, general cleaning and in sanitary conveniences. The water to
be used in contraction work will supplied from the same sources.
Land use
The Proposed project site is located in an industrial set up. The neighborhood is
characterised by light industries such as printing firms, beverage manufacturing, motor
vehicles parts manufacturing plant and warehouses.
Population
Nairobi has eight per cent of the countrys total population and 25 per cent of Kenyas
urban population (KNBS 2009). The growth of population of Nairobi is partly explained
by net migration into the city. The net immigration flow into the city between 1979 and
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1989 was 772,624 (NEMA, 2003). The forces motivating rural-urban migration to Nairobi
include better economic prospects, opportunities for higher education and higher wage
employment, and the attraction of Nairobi as a market for goods and services (UNEP,
2007). But there is also the phenomenon of diurnal migration of people from the environs
who commute daily into Nairobi for purposes of employment, education or trade.
Projections are that diurnal migration will continue unless deliberate efforts are made to
develop satellite towns and employ strategies to reduce the daily influx of people to the
city.
Infrastructure
The project area is served by two roads; Likoni Road and Enterprise Road. The roads
are normally characterised by heavy traffic congestions partly caused by heavy
commercial vehicles. Other infrastructural facilities available in the project area are:
sewer lines; water reticulation system, telecommunication facilities and electricity.
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CHAPTER FOUR
4 NATIONAL ENVIRONMENTAL LEGISLATIVE AND REGULATORY FRAMEWORK
This section of the report discusses the policy, applicable EHS legislations and institutional
framework.
4.1 Policy
4.1.1 National Environment Policy

Kenya is in the process of developing a National Environment Policy. During this study Draft
No. 5 of the National Policy was reviewed. The Policy will provide for a holistic framework to
guide the management of the environment and natural resources in Kenya. It will also
ensures that the linkage between the environment and poverty reduction is integrated in all
government processes and institutions in order to facilitate and realize sustainable
development at all levels in the context of green economy enhancing social inclusion,
improving human welfare and creating opportunities for employment and maintaining the
healthy functioning of ecosystem.
4.1.2 The Constitution

Kenya promulgated a new constitution in 2010. The new constitution is hailed as a green
constitution as it embodies elaborate provisions with considerable implications for sustainable
development. The provisions range from environmental principles and implications of
multilateral environmental agreements (MEAs) to the right to clean and healthy environment
enshrined in the Bill of Rights. Chapter V covers on land and environment. It also embodies a
host of social and economic rights of an environmental character, such as the right to water,
food and shelter among others.
Article 69 on obligations in respect of the environment requires the Proponent to cooperate

with State organs and other persons to protect and conserve the environment and ensure
ecologically sustainable development and use of natural resources.
4.2 LEGAL FRAMEWORK
The execution of the proposed project will be done in accordance with all applicable
legislation, regulations, approvals and relevant guidelines. Table 5 provides legislations that
are applicable to the proposed project.
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Table 5: Summary of legislations applicable to the proposed project
Legalisation Responsible Main Purpose Relevance to the Proposed Project

Institution/Lead
Agency
The EMCA, 1999 NEMA A framework legislation that Requires the Proponent to:
addresses major issues concerning submit EIA Study Report to NEMA before commencing
any new project.
the environment. The purpose of
engage NEMA approved expert/firm of experts in
the Act is to provide for sustainable conducting EIA studies
management of the environment.
Environment Impact NEMA Provides for the framework for Requires the Proponent to:
Assessment /Environmental carrying out environmental impact
prepare EIA Study report in accordance with the format
Audit Regulations, 2003 assessment in Kenya specified in Regulations and pay attention to issues
specified in the second schedule of the Regulations
carry out corrective measures in the improvement order
from NEMA
carry out corrective measures in the improvement order
from NEMA
allow a NEMA inspector to enter the facility for the
monitoring the effects of its activities on the
environment
mitigate trans-boundary impacts taking into account
regional and international treaties
L.N. 121: Environmental NEMA Formulated for managing various The Regulations requires the Proponent to:
Management and Coordination kinds of waste in Kenya
Acquire valid EIA licence from NEMA prior to engaging
(Waste Management) in an activity that can generate hazardous substance
Regulations, 2006 Segregates their waste (hazardous and non-
hazardous) by type and then disposes the wastes in an
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Institution/Lead
Agency
environmentally acceptable manner.
Transport waste using a vehicle that has an approved
Waste Transportation License issued by the NEMA
Dispose of waste in a licensed disposal facility
Label hazardous wastes containers in accordance with
the requirements provided in section18 of the
Regulation.
L.N. 120: Environmental NEMA Formulated for sustainable The Regulation requires the Proponent to:
Management and Coordination management of water used for
Refrain from any activity which might cause water
(Water Quality) Regulations, various purposes in Kenya pollution.
2006 Not to discharge any liquid, gaseous or solid into water
resource as to cause pollution.
Acquire a valid effluent discharge license to discharge
effluent into the environment.
acquire EIA licence prior to abstracting ground water or
any activity that is likely to have any adverse impact on
the quantity and quality of the water
follow the monitoring guide set out in the Third
Schedule to the regulation when discharging effluent
into the environment
Legal Notice No.61 of 2009: NEMA Promulgated for control of Noise The regulations:
The Environment Management and excessive vibration pollution
Prohibits the Proponent from making or causing to be
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Institution/Lead
Agency
and Coordination (Noise and made noise which annoys, disturbs, injures or
endangers the comfort, repose, health or safety or
Excessive Vibration Pollution)
safety of others and the environment.
(Control) Regulations
Prohibits the Proponent from making or causing to be
made excessive vibration which annoy, disturb, injure
or endanger the comfort, response, health or safety of
others and the environment
Prohibits the Proponent from causing noise which
exceeds any sound level as set out in the First
Schedule to the Regulations
Requires the Proponent (if wishing) to operate or repair
any machinery, motor vehicle, construction equipment
or other equipment, pump, fan air conditioning
apparatus or similar mechanical device or engage in
any commercial or industrial activity which is likely to
emit noise or excessive vibrations to do so within the
relevant levels prescribed in the First Schedule of the
Regulations.
Prohibits the Proponent from operating a motor vehicle
which produces any loud and unusual sound and
exceeds 84 dB (A) when accelerating.
Prohibits the Proponent from operating construction
equipment or perform any outside construction or repair
work so as to emit noise in excess of the permissible
levels as set out in the Second Schedule to the
Regulations.
Requires the Proponent during EIA studies to:
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Institution/Lead
Agency
o Identify natural resources, land uses or activities
which may be affected by noise or excessive
vibrations from construction or demolition;
o Determine the measures which are needed in
the plans and specifications to minimize or
eliminate adverse construction or demolition
noise or vibration impacts
o Incorporate the needed abatement measures in
the plans and specifications.
Prohibits the Proponent from carrying out activities
relating to demolitions without a valid permit issued by
the Authority
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Institution/Lead
Agency
Hazardous Substances Rules, DOSHS Protection of employees from This legislation requires the Proponent to:
2007 exposure to hazardous substances
Ensure that where chemicals come into contact with
in the workplace employees, the exposure limits set out in the First
Schedule of the Regulations are not exceeded.
Ensure that all employees exposed to chemicals in the
workplace are protected adequately from exposure to
hazardous substances that may be present in them
using the hierarchy of hazard control methods
Have a Hazard Communication program implemented
at their workplace.
Maintain an inventory of all MSDSs for the chemicals
stored in their workplace
Dispose of all unused, obsolete or expired chemicals in
an environmentally sound manner.
Label appropriately all containers containing chemicals
as indicated in the MSDS for that chemical.
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Institution/Lead
Agency
Environmental Management NEMA Formulated to provide for The proposed project has potential to impact on air quality.
and Coordination ( Air Quality prevention, control and abatement Dust and fugitive emissions from transport vehicles during
Standards) Regulations, 2008 - of air pollution to ensure clean and construction and decommissioning phases and petroleum
Draft healthy ambient air fumes during operation phase could impact on air quality.
In the light of the above, these Regulations prohibit the

Proponent from:
Acting in a way that directly or indirectly cause or may

cause air pollution to exceed levels set out in the
second Schedule to the Regulations
Allowing particulates emissions into the atmosphere
from any source not listed in the six schedule of the
Regulations
Causing ambient air quality in controlled areas (listed in
Schedule Thirteen) to exceed those stipulated under
second Schedule.
Allowing emission of particulate matter above the limits
stipulated in second Schedule.
Building Code Ministry of Local Formulated to provide rules, The Proponent is required to adhere to the rules, guidelines
Government guidelines and standards to be and standards stipulated in the Code during development of
observed during construction. the proposed project
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Institution/Lead
Agency
The Public Health Act Cap 242 Ministry of Public The Act regulates activities The Act prohibits the Proponent from engaging in activities
Health detrimental to human and that cause environmental nuisance or those that cause
environmental health and safety danger, discomfort or annoyance to inhabitants or is
hazardous to human and environmental health and safety.
The Local Government Act Ministry of Local The Act requires the Proponent to grant the Officers and
(Cap. 265) Government servants of Local Authority access to their premises to
inspect, maintain, alter or repair sewers, drains, pipes,
ventilating shafts or other
The Penal Code (Cap. 63) Judiciary Formulated to define the penal The Code Prohibits the Proponent from:
system in Kenya. It outlines criminal
Voluntarily corrupting or fouling water for public springs
offences and prescribes penalties to or reservoirs, rendering it less fit for its ordinary use
them Making or vitiating the atmosphere in any place to
make it noxious to health of persons/institution in
dwellings or business premises in the neighbourhood
or those passing along public way.
The Occupier Liability Act (Cap The Act Requires the Proponent to ensure that visitors to
34) his premises will be reasonably safe in using the premises
for the purposes for which he is invited or permitted by the
Proponent to be there
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Institution/Lead
Agency
Occupational Health and Safety DOSHS Enacted to provide for the health, It requires the Proponent to:
Act, 2007 safety and welfare of persons
undertaking S&H risk assessments,
employed in workplaces, and for
provide notification of accidents, injuries and dangerous
matters incidental thereto and occurrences, etc
connected therewith. Provide first aid facilities at the workplace
provide PPEs to the employees
Legal Notice No. 25: Noise DOSHS Promulgated for work related noise It requires the Proponent to:
Prevention and Control Rules exposures
Comply with the following permissible noise levels :
a. Workplace Noise- 90 dB (A) over an 8-hour TWA
period over 24-hours; and 140 dB (A) peak sound
level at any given time.
b. Community noise level emanating from a
workplace -50 dB(A) during the day; and 45
dB(A) at night.
ensure that any equipment brought to a site in Kenya
for use shall be designed or have built in noise
reduction devices that do not exceed 90 dB(A).
Medically examine those employees that may be
exposed to continuous noise levels of 85 dB (A) as
indicated in Regulation 16. If found unfit, the
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Institution/Lead
Agency
occupational hearing loss to the worker will be
compensated as an occupational disease.
It is not anticipated that there will be equipment that will
generate noise exceeding the threshold levels of noise
stipulated under the Rules. However, in case there will, it
will be incumbent on the selected contractor to ensure that
their equipment complies with the threshold noise values
given above. Alternatively the selected contractor will be
required to develop, rollout and implement a written hearing
conservation program during the project period
Liquefied Petroleum Gas ERC Promulgated for Management of The Regulations requires the Proponent to:
(LPG) Regulations, 2009 LPG Business in Kenya. It covers
Apply for/obtain licence from ERC prior to operating bulk
on import, export, transport,
LPG storage facility. Application for the licence should be
storage, wholesale and retail of
accompanied by the follow:
LPG
EIA Licence issued in accordance with EMCA, 1999
Proof of compliance with OSHA 2007 and Public Health

Act;
Certificate of compliance issued in accordance with
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Institution/Lead
Agency
Physical Planning Act of 1986;
Copy of approved drawing accordance with Local

Government Act, with specifications and plans in duplicate;
A clearance certificate from Chief Fire Officer;
A declaration of the intended use of LPG that is to be stored
A copy of certificate of adherence to the KS 1938(1-5)
Transport LPG by road in accordance with the Act and

terms and conditions of a valid licence issued by the
Commission;
KS 1938:2006 KEBS/ERC Code of practice for handling, The Standard provides guidelines for:
storage and distribution of LPG in
Design pressure
domestic, commercial and industrial
Fire protection
installations
Construction and initial (production) testing of storage
Part 3: LPG installation involving
vessel
storage vessels of individual water
storage capacity exceeding 500L Filling ratio and volumes of storage vessel
Storage vessel location
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Institution/Lead
Agency
Installation of LPG storage vessels
Installation of vaporizers
Periodic inspection and retesting;
Electrical equipment and other sources of ignition
Filling point for bulk storage vessel;
Filling of portable containers
Container storage areas;
Filling shed for portable containers
Page 48
4.3 Institutional Framework
4.3.1 Ministry of Environment and natural resource

Kenyas Ministry of Environment and Natural Resource is mandated to monitor, protect,
conserve and manage environment and natural resources of the country. The Ministry is to
achieve this task through sustainable exploitation of natural resources for socio-economic
development geared towards eradication of poverty, improving living standards and
maintaining a clean environment for present and future generations.
4.3.2 EMCA 1999 INSTITUTIONS

The EMCA, 1999, make provisions for creation of environmental administrative structures
under MENR. The institutions that have been created under the Act for environmental
management in Kenya are:
NEMA - the principal government authority established under MENR to exercise general
supervision and coordination over all matters relating to the environment in Kenya.
NEC- The apex body under the Act charged with the responsibility of developing the
national environmental policy in Kenya as well as to set annual environmental goals and
objectives.
PCC - formed to investigate environmental complaints against any person, submit their
findings/recommendations to the NEC and to submit periodic reports of its activities to the
NEC.
SERC- established to advise the NEMA on the criteria and procedures for the
measurement of environmental quality in Kenya. Environmental quality relates to air
quality, wastewater quality, waste quality, noise quality, land use quality, etc. Additionally
the SERC is required to recommend to the NEMA minimum environmental quality
standards for all environmental parameters for which subsidiary legislation is or has been
promulgated.
4.3.3 Ministry of Energy

The Ministry of Energy is responsible for the provision of clean, secure, sustainable and
affordable energy services for social-economic development while protecting the environment.
The Minister of Energy is empowered by the Energy Act to make regulations/rules for
managing energy sector. Since 2006, when the Energy Act was amended, the Minister has
made several regulatory instruments for the energy sector. One of the rules applicable to the
proposed development is the Draft Energy (Licensing of Petroleum Retail Business)
Regulation 2011 which prohibits against construction or modification of petroleum dispensing
site without except in accordance with the Act.
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4.3.4 Energy Regulatory Commission (ERC)

The ERC was established under Energy Act to regulate energy sector in Kenya. The ERCs
functions include the protection of consumer, investors and other stakeholder interests as well
as monitoring the energy sector as a whole. Other functions include licensing, enforcement,
dispute settlement and approval of power purchase and network service contracts.
Page 50
CHAPTER FIVE
5 ENVIRONMENTAL IMPACT ASSESSMENT
Several environmental impacts (positive and negative) associated with the proposed project
were identified through the use of experts judgment method. The following section highlights
the impacts anticipated throughout the lifecycle of the proposed project. The associated
impact assessment tables for each impact will be categorized according to project phases,
prior to and post mitigation. Effects of activities are categorized as negative impact and or
positive impact.
5.1 Assessment of impacts
Section one of this report presents the methodology used in assessing the potential impacts
of the proposed project. The key impacts identified for the proposed project are highlighted
according to the relevant project phases.
The Firm of Experts utilized precautionary principles to establish the significance of impacts
and their management and mitigation.
5.2 Potential impacts of the proposed project
The proposed project is anticipated to generate the following impacts, however the
significance of the impacts will range between low to moderate before mitigation and will
further reduce with mitigation measures:
a) soil and Geology Impacts
b) Air quality Impacts
c) Noise and vibration Impacts
d) Impacts of waste generation
e) Socioeconomic impacts
f) Health and Safety Impacts
5.2.1 Soil and geology impacts
5.2.1.1 Contamination of soil

The potential sources of soil contamination during construction phase are leaks or spills from
machinery used in site preparation and demolition. Depending on the size and source of the
spill, liquid and gaseous phase petroleum hydrocarbons may remain mobile for long periods
of time, and can potentially pollute groundwater.
During operation phase soil contamination is not anticipated because of the presence of the
concrete paved surface which will prevent any potential contaminant from reaching the
subsurface layers and is thus not assessed. During decommissioning phase, soil
contamination could occur especially with the use of machinery in demolition of the facility.
Page 51
Construction Phase
Likelihood Consequence Rating
Frequency Frequency Severity of Spatial scope/ Duration
of Activity of Impact Impact Geographical
extent
5 4 1 1 1 Low
Daily likely insignificant site specific One day to negative
one month impact
score 9 3 27
Mitigation Measures for soil contamination
The Contractor shall prepare a hazardous materials and waste management plan. The plan
shall include, but not limited to, measures to prevent: (a) contamination of soils; (b) pollution
of water; (c) and safe siting and storage.
Significance after mitigation

Frequency Frequency Benefit/Severity Spatial Duration

of Activity of Impact of Impact scope/Geographical
extent
5 3 1 1 1 Low
Daily unlikely insignificant site specific One day to negative
one month impact
score 8 3 21
Decommissioning Phase

Frequency Frequency of Severity of Spatial Duration
of Activity Impact Impact scope/Geographical
extent
5 4 1 1 1 Low
Daily likely insignificant site specific One day to one negative
month impact
score 9 3 27
Mitigation Measures
The Proponent and contractor engaged in the demolition of the facility shall ensure machinery
and vehicles used during demolition are adequately serviced to prevent any oil leakages.
Page 52
Additionally, the Proponent shall undertake a further survey to identify any contaminated areas
and remediate them accordingly.

Frequency Frequency Benefit/Severity of Spatial scope/ Duration
of Activity of Impact Impact Geographical
extent
5 3 1 1 1 Low
Daily unlikely insignificant site specific One day to negative
one month impact
score 8 3 21
5.2.1.2 Soil erosion
During construction phase, site preparation activities such as clearance of vegetation,

excavation and demolition will expose the soils at the construction site to agents of erosions
mainly wind and rain water.
During operation phase, soil erosion is not anticipated at the project site because the concrete
surface to be constructed will protect the soil from agents of erosion.
During decommissioning phase, removal of concrete surface will expose the soil to the above
erosion agents.
Construction phase: Soil erosion without mitigation measures
Frequency Frequency Benefit/Severity of Spatial Duration

of Activity of Impact Impact scope/Geographical
extent
5 5 Daily 3 1 1 Low
negative
Daily marginal site specific One day to
impact
one month
score 10 5 50
Mitigation Measures for potential soil erosion
The Proponent and Contractor shall implement soil conservation program described in
section 8.5.1 of this report.
Page 53
Significance of potential soil erosion after mitigation

extent
5 2 Negligible 1 1 Low
negative
Daily Very 1 site specific One day to
impact
seldom one month
score 7 3 21
Decommissioning phase: soil erosion without mitigation

extent
negative
Daily Daily 1 site specific One day to
impact
one month
score 10 3 30
Mitigation Measures
The Proponent shall ensure that the site is restored as much as possible to original state. This
shall be accomplished through surfacing of denuded areas and planting of vegetation.
Significance of soil erosion after mitigation
Frequency Frequency Benefit/Severity of Spatial Duration

extent
negative
Daily Very seldom 1 site specific One day to
impact
one month
score 7 3 21
5.2.2 Air quality Impacts
5.2.2.1 Decreased air quality due to dust emission

During construction decommissioning phases, potential dust pollution will emanate from
site preparation activities such demolition, excavation, stockpiling and preparation of
mortar for construction of substructure. During operation phase, dust pollution is not
Page 54
anticipated as the site will be covered by the proposed project. While during
decommissioning phase, dust emission would be generated from debris and soil resulting
from demolition process.
Construction Phase: Significance of Impacts before Mitigation
Frequency Frequency Severity of Impact Spatial Duration

of Activity of Impact scope/Geographical
extent
5 5 1 1 1 Low
negative
Daily Daily insignificant site specific One day to
impact
one month
score 10 3 30
Mitigation measures for decreased air quality due to dust emission
The Proponent and Contractor shall implement dust abatement measures which shall include:
Sprinkling stockpile with water regularly or cover with a membrane to prevent them from
being blown away and keep them for the shortest time possible;
All loads entering or leaving the site should be covered
Securely cover waste containers and minimize drop height
Erect solid barriers to site boundary
Significance of impact after mitigation

Frequency Frequency Severity of Spatial Duration

extent
5 3 1 1 1 Low negative
Daily unlikely insignificant site specific One day to impact
one month
score 8 3 21
Page 55
Frequency Frequency Severity of Impact Spatial Duration

of Activity of Impact scope/Geographical
extent
5 5 1 1 1 Low
negative
Daily Daily insignificant site specific One day to
impact
one month
score 10 3 30
5.2.2.2 Air Pollution from Incidents

The proposed project will be designed and managed in accordance with the best industry
best standards and practice. However, during operation phase unplanned or unforeseen fire
or explosion incidents may occur as result of acts of vandalism or human error. Such
incidents may generate emissions that have several implications on the human health and
visibility of the site and its environs.
Operation phase potential air pollution incidents before mitigation
Frequency Frequency of Benefit/Severity of Spatial Duration

extent
4 3 4 2 4 Medium
low
Life of unlikely harmful site specific Life of
operation operation
score 7 10 70
Mitigation Measures for air pollution from incidents
The Proponent need to develop, implement and monitor environment, health and safety
measures and procedures, including an emergency preparedness and response plan.

extent
4 3 1 2 4 Low
negative
Life of unlikely Non harmful site specific Life of
impact
operation operation
score 7 7 49
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5.2.2.3 Exhaust emissions

During construction phase exhaust emissions from construction and demolition vehicles (used
in transporting materials) are the only source of gaseous pollutants from the proposed project
During operation phase exhaust emission from trucks entering and exiting the site will be
source of gaseous pollutants.
Construction and Decommissioning phases: Significance of exhaust emissions

without mitigation measures
Frequency Frequency Severity/Magnitude Spatial Duration

extent
5 5 2 1 1 Low
negative
Daily Daily Minor site specific One day
impact
to one
month
score 10 4 40
Mitigation Measures for impacts of exhaust emission
The Proponent should ensure that:

Engines and exhaust systems of construction and demolition vehicles and machinery
should be regularly serviced according to manufacturers recommendations and
maintained to meet statutory limits/opacity tests;
no machinery or vehicle is left idling unnecessarily
Construction and Decommissioning phases: Significance of exhaust emissions with mitigation

measures
Frequency Frequency Severity of Spatial scope/ Duration

of Activity of Impact Impact
Geographical
extent
5 5 1 1 1 Low
negative
Daily Daily Negligible site specific One day
impact
to one
month
score 10 3 30
Page 57
Operation phase: Significance of exhaust emissions without mitigation measures

Frequency Frequency Severity/Magnitude Spatial Duration
extent
4 5 2 1 1 Low negative
Life of Daily Minor site specific One day to impact
operation one month
score 9 4 36
Mitigation Measures for impacts of exhaust emission
The Proponent should ensure that:

Engines and exhaust systems of construction vehicles and machinery should be regularly
serviced according to manufacturers recommendations and maintained to meet statutory
limits/opacity tests;
no truck is left idling unnecessarily at the parking bay
5.2.3 Noise and vibration
Deterioration in ambient noise quality
The construction machinery and vehicles will generate noise of varying magnitude. The
proposed project will utilize machineries such as wheel loading shovel; 30 to 40 Ton tracked
Excavator, Mobile service crane, Dump Truck and Tipper lorry
From the predictions of the specialist study on ambient noise quality measurements it can be
seen that all the above activities are predicted to be largely within the target noise levels,
although highest levels are expected when using pneumatic drills to break hard rock for
foundation when the noise levels would peak at about 68dB (A)
A summary of the predicted noise levels is presented in the table below:
Reception Point Site Preparation (dB Excavation works General

A) Activities
(dB A)
(dB A)
South East Corner of 50 68 58

proposed construction
site.
Page 58
As will be the case with the construction phase, the sources of noise during decommissioning
phase, will be mainly machinery and vehicles used in demolition of the facility and removing
the materials from the site.
Pre-construction and Construction Phase

Unmitigated Impact : Noise above Significance
75 dB (A)
Consequence
Magnitude 2
Geographic extent 1
Duration of impact 1
Total 4
Likelihood
Duration of activity 1
Frequency of impact 1
Total 2
Results (Consequence * Likelihood) - 8 (Very low)
Comment/mitigation:
1. Follow the rules sand regulations set out in the relevant codes of practice and instructions
contained in the Environmental Management Plan (EMP) and construction Environmental
Plan(CEP)
2. Use protective equipment
3. Site the noisy equipment and plant away from occupied building.
4. Maintain equipment and plant.
Mitigated Impact: Noise above 75
dB (A)
Consequence
Magnitude 1
Geographic extent 1
Total 3
Likelihood
Total 2
Results (Consequence * - 6 (Very low)
Page 59
Likelihood)
Comment/mitigation
1. Site the power generator away from the occupied building.
2. Maintenance personnel to use ear defenders.
3. Maintain equipment and plant.
Operation phase and decommissioning
Unmitigated Impact: Noise above 85 Significance
dB(A)
Consequence
Magnitude 2
Geographic extent 1
Total 4
Likelihood
Total 2
Results (Consequence * Likelihood) - 8(very low)
Comment/mitigation:
The Proponent to ensure that the booster pumps to be used during operation phase complies with
national and international noise quality standards. Noise abatement measures will be covered in
the EMP.
Impact with mitigation : Noise
above 85 dB(A)
Consequence
Magnitude 2
Geographic extent 1
Total 4
Likelihood
Total 2
Results (Consequence * Likelihood) - 8 (very low)
Page 60
Impact without mitigation : Significance

Deterioration in ambient noise
quality
Consequence
Magnitude 1
Geographic extent 1
Total 3
Likelihood
Total 3
Comment/mitigation:
The Proponent to ensure that the machinery and vehicles used during demolition comply
with Noise Quality Standards. Noise abetment measures will be included in construction
management programme.
Impact with mitigation :

Deterioration in ambient noise
quality
Consequence
Magnitude 1
Geographic extent 1
Total 3
Likelihood
Total 2
Page 61
5.2.4 Impacts of waste generation
Several wastes are anticipated to be generated throughout the project cycle (Section 2 of this
report provides a description of the waste to be generated). During construction phase,
wastes anticipated from demolition and construction activities will: concrete waste, asbestos
sheets from the existing buildings, excavated soil, metal and timber cuttings among others.
These wastes have potential to cause adverse impacts; for example asbestos materials are
known to cause asbestosis, a chronic inflammatory and fibrotic medical condition affecting the
tissue of the lungs caused by the inhalation and retention of asbestos fibers.
During operation phase, the expected waste from the project will include domestic and
medical waste from the clinic. Medical wastes are potentially dangerous and present a high
risk of infection to the general population and to the staff.
Whereas during decommissioning phase, demolition waste generated will be mainly concrete
boulders, and scrap metals.
Construction phase: Significance before mitigation

extent
4 5 4 2 1 Low
Daily daily significant site specific One day to Medium
one month
score 9 7 63
Mitigation Measures
The Contractor in collaboration with the Proponent will prepare and maintain site waste
management plan which estimate the quantity of each type of waste expected to be produced
and track their recovery and destination throughout the construction phase of the project.
Waste streams could be recovered, segregated and either re-used on site (e.g. crushed
concrete aggregate) or disposed offsite in line with the Proponents Go Green Initiative.
Construction phase: Significance after mitigation

extent
4 5 2 2 1 Low
Daily daily minor site specific One day to Medium
Page 62
one month
score 9 5 45
Operation phase
extent
4 4 2 2 4 Medium
Life Life Minor site specific Life of low
operation operation operation
score 8 8 64
Mitigation Measures
The Proponent will manage waste in accordance with the existing procedures and relevant
legislations. Waste streams could be recovered, segregated and either re-used on site (e.g.
crushed concrete aggregate) or disposed offsite in line with the Proponents Go Green
Initiative. Medical waste will be collected disposed offsite by NEMA approved waste handler.
Operation phase: Significance of Impacts of waste after mitigation

extent
4 4 1 2 4 Medium
Life Life negligible site specific Life of low
operation operation operation
score 8 7 56
Decommissioning phase: Significance of Impacts of waste before mitigation
extent
4 5 2 2 1 low
Daily Daily minor site specific One day
to one
month
score 9 5 45
Mitigation Measures
The Contractor selected for undertake demolition work will in collaboration with the Proponent
will prepare and maintain site waste management plan which estimate the quantity of each
type of waste expected to be produced and track their recovery and destination throughout
the decommissioning phase of the project. Waste streams could be recovered, segregated
Page 63
and either re-used on site (e.g. crushed concrete aggregate) or disposed offsite in line with
the Proponents Go Green Initiative.
Decommissioning phase: Significance of Impacts of waste after mitigation


extent
4 5 1 2 1 low
Daily Daily negligible site specific One day
to one
month
score 9 4 36
5.2.5 Health and safety
5.2.5.1 Occupational health and safety

The development of the proposed facilities involves a number of activities that pose potential
health and safety risks to the workers. The workers are potentially exposed to risks as a result
of working a height, operating tools and equipment and exposure to dust.
During the construction phase, the potential H&S risks include:

Exposure to silica dust
Hazards of falling objects;
Occupational hazards when working at height such as the roofs and walls;
The potential occupational health and safety impacts anticipated for operation phase include:
injuries to workers from preventive and corrective maintenance especially of electrical
equipment, work at height especially renewing coat of paint on the roofs and walls and
handling of medical wastes.
During decommissioning phase, the potential H&S risks include hazards of falling objects;
work at height hazards, injuries from operating tools and equipment.
Construction phase: Health and Safety Risks before mitigation

Frequency of Frequency Benefit/Severity of Spatial Duration
Activity of Impact Impact scope/Geographical
extent
5 5 4 1 1 Low
Daily Daily significant Activity specific One day Medium
to one negative
month impact
score 10 6 60
Page 64
Operation Phase: Health and Safety Risks before mitigation

Frequency of Frequency Benefit/Severity Spatial Duration
Activity of Impact of Impact scope/Geographical
extent
4 5 2 1 4 Medium-
Life of likely small Activity specific Life of low
operation operation negative
impact
score 9 7 63
Decommissioning phase: Health and Safety Risks before mitigation

extent
5 5 2 1 1 Low
Daily Daily small Activity specific One day negative
to one impact
month
score 10 4 40
Mitigation Measures
The Proponent is recommended to enforce the existing H&S operation procedures for
minimizing potential health and safety impacts. During construction phase, the Proponent is
recommended to ensure that tool box talks are done every day. Toolbox talks address actual
and anticipated safety concerns for scheduled project work. The talks provide an opportunity
to relate specific safety concerns with the jobs to be performed.
Construction phase: Health and Safety Risks after mitigation


extent
5 5 1 1 1 Low
Daily Daily negligible Activity specific One day negative
to one impact
month
score 10 3 30
Page 65
Operation Phase: Health and Safety Risks after mitigation
Frequency of Frequency Benefit/Severity Spatial Duration

Activity of Impact of Impact scope/Geographical
extent
4 5 1 1 4 Medium-low
Life of likely negligible Activity specific Life of negative
operation operation impact
score 9 6 54
Decommissioning phase: Health and Safety Risks after mitigation

extent
5 5 1 1 1 Low
Daily Daily negligible Activity specific One day negative
to one impact
month
score 10 3 30
5.2.5.2 Risk of Large Scale incident
The proposed project could be of great public concern especially in the event of major
disaster such as major fire outbreak and explosion caused by third parties. The product to be
stored is highly flammable hence incidents fire or explosions can be detrimental to the public.
The impact significance related to public safety is likely to be low during the rehabilitation and
closure of the facility.
Construction phase
Impact without mitigation: Risk of large Significance

scale incident
Consequence
Magnitude 5
Geographic extent 2
Total 8
Likelihood
Page 66
Total 8
Results (Consequence * Likelihood) - 64 (Low medium)
Comment/mitigation:
Mitigation measures for the potential Occupational Health and Safety impacts will be
covered in the construction Safety Management Plan. The implementation of the
proposed project to be done in accordance to the OSHA 2007 and any other relevant H&S
legislation
Impact with mitigation: Risk of large scale incident
Consequence
Magnitude 1
Geographic extent 1
Total 4
Likelihood
Total 3
Operation Phase
Impact without mitigation: Risk of large Significance
scale incident
Consequence
Magnitude 5
Geographic extent 4
Total 13
Likelihood
Total 7
Results (Consequence * Likelihood) - 91( medium high)
Comment/mitigation:
Page 67
Mitigation measures for impacts resulting from public safety is covered in the emergency
management and response plan presented in the EMP.
Impact with mitigation: risks to public

safety
Consequence
Magnitude 3
Geographic extent 2
Total 7
Likelihood
Total 5
Results (Consequence * Likelihood) - 35 ( low)
5.2.6 Socioeconomic
5.2.6.1 Compatibility with existing and proposed land uses
The proposed project site area consists mainly of light industries. The proposed project is
therefore compatible to the existing as well as future land-uses. Since the proposed project
will not conflict with the existing and perhaps future developments, impacts were therefore not
assessed.
5.2.6.2 Creation of employment opportunities
The proposed project will generate job opportunities (skilled and unskilled Labour) during
construction and operation phases.
It is anticipated that proposed project will provide opportunities for local employment and
service provision, such as the use of local transport companies and sourcing of some
construction materials locally. There also likely to be trickledown effect results from the
employment opportunities as well as services provided by the facility.
Constructions, Operations
Benefits without enhancement: Employment provided by the proposed project

Magnitude Geographic Duration of impact Duration of activity Frequency of impact
Extent
2 2 2 2 4
Result: LOW (+ 36)
Benefits with enhancements
Magnitude Geographic Duration of impact Duration of activity Frequency of impact
Extent
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3 3 4 4 4
Results: MEDIUM HIGH (+ 80)
Mitigation/Comments: Communication and information programs should be used to manage
expectations and target local service providers including those registered through the Public
Participation process. Management and enhancement measures for local employment to be included
in Labour and human resources plan. Local authorities and employment hubs should be consulted
when recruiting local workers and service providers.
5.2.6.3 Improved Security
The proposed project is expected to improve the security situation in the area in that the
project will employ security guards, install security lights and installing alarm systems.
Construction and Operations

Benefits without enhancement: Improved Security
Magnitude Geographic Duration of Duration of Frequency of

Extent impact activity impact
2 2 4 4 4
Results: LOW-MEDIUM(+ 64 )
Magnitude Geographic Duration of Duration of Frequency of
Extent impact activity impact
3 2 4 4 4
Results: LOW MEDIUM (+ 72 )
Mitigation/Comment: Installation of security facilities which includes hiring of security
guards, installing an alarm system will improve the security of the area.
5.2.6.4 General economic growth and increased land value
Due to the proposed project there will be an influx of people searching for jobs. An increase in
economic activities will increase the demand for housing, communication transport and
financial services will significantly increase and thus present a likelihood of increasing the
land values.
Constructions and Operations

Benefits without enhancement: General economic growth and increased land
value
Severity Spatial Duration of Duration of Frequency of
scope impact activity impact
2 3 4 4 3
Result: LOW MEDIUM (+ 63 )
Page 69

2 3 4 4 4
Results: LOW-MEDIUM(+ 72 )
Mitigation/Comments: The direct project workforce will be accommodated within
the Syokimau area and Athi River town area. Choice of the site will increase
value of land in the area and promote overall development of the area.
5.2.6.5 LPG Provision
In the operational phase, the BAT K ltd perceived that there will be increased LPG supply.
Operations Phase
Benefits without enhancement: LPG Provision
2 5 4 4 4
Result: MEDIUM HIGH (+ 88 )
3 4 4 5 4
Results: MEDIUM- HIGH(+ 99 )
Mitigation/Comments: The proposed project will ensure that there is plenty of LPG which
will meet the increasing demand for LPG at the factory.
5.2.7 Cumulative impacts
Cumulative impacts are impacts of an activity that in themselves may not become significant
but may become significant when added to the existing and potential impacts eventuating
from similar or diverse activities or undertakings in the area.
The concrete paving will affect permeability of storm water into the subsurface and
underground water.
The soil once excavated and moved within the site loses its original physical and chemical
composition, structure, arrangement of soil horizons and the transition between those
horizons. These changes cumulatively alter the biological, physical and chemical properties
of the soil and consequently the reaction patterns with pollutants.
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ENVIRONMENTAL IMPACT ASSESSMENT PROJECT REPORT 2013
5.3 Summary of Impacts
Table 6: Summary of Identified Impacts

Impact Significance Rating
Construction Phase Operation phase Decommissioning phase
Without With mitigation Without mitigation With mitigation Without mitigation With mitigation
mitigation
Air Quality
Dust generation low Very low Very low Very low
negative impact negative impact Not anticipated Not anticipated negative impact negative impact
Fugitive Emission Very low Very low Low Low Very low Very low
negative impact Negative impact Negative impact Negative impact Negative impact Negative impact
Health and Safety
Occupational Health Low medium Very low Very low Very low Very low Very low
and Safety negative impact negative impact negative impact negative impact negative impact negative impact
Risk of large incident low medium Very low low medium Low
fire explosion and fire negative impact negative impact negative impact Negative impact Not anticipated Not anticipated
outbreak
Noise and Vibration
Very low Very low Low Low Very low Very low
negative impact Negative impact Negative impact Negative impact Negative impact Negative impact
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Impact Significance Rating
Construction Phase Operation phase Decommissioning phase
Socioeconomic
Employment low Medium High low Medium High Very low High
Positive impact Positive impact Positive impact Positive impact Positive impact Positive impact
LPG Provision - - Medium High Medium High - -
Positive Impact Positive Impact
General Economic Low Low Low Low - -

Growth and increased Medium Medium Medium Medium
land value
Improved Security Low Medium Low Medium - -
Medium High Medium High
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CHAPTER SIX
6 ANALYSIS OF ALTERNATIVES
The following alternative aspects were considered for the proposed project: No Project
Scenario, design and site alternative. Evaluation of the alternatives is governed by a rule of
reason, which requires the evaluation of alternatives necessary to permit a reasoned
choice.
6.1 No Project Scenario
The no Project Scenario is where the proposed project should not be undertaken at all. The
site will remain as it is; covered by grass and few ornamental trees and it will imply that
anticipated benefits from the project would not be realized and similarly the potential adverse
impacts associated with the project will not be experienced. The Project is part of the BAT
Kenya Limited Green Initiative which is geared towards reducing impacts of their operations
on the environment. By implementing the project, the Proponent will enable BAT Kenya
limited to phase out diesel powered forklifts and replace them with LPG powered ones which
are environmentally friendly. Propane-powered forklifts produce significantly less emissions in
the way of carbon monoxide, nitrogen oxide, hydrocarbon, and particulate matter than
comparable gasoline- or diesel-powered forklifts. The No Project Scenario is therefore not
considered as a viable option.
6.2 Location Alternative
The Proponent has only one proposed site for the storage and distribution of Liquefied
Petroleum Gas. The site is located at Premises of BAT, who are the sole users of the product.
This will also go further in reducing logistical constraints of transporting LPG cylinders to the
site on a daily basis.
Additionally, the proposed site is ideal because it is located away from the factory where the
main manufacturing operations occur and hence would not compromise the safety of the
factory.
6.3 Design Alternatives
6.3.1 Proposed Option
The Proponent has proposed to install a 5 ton above ground LPG tank to substitute the
current practice of daily supply of gas in small cylinders.
The proposed design will largely improve the safety of storage and handling of LPG at the
factory and will create a steady supply/stock of LPG gas to BAT. In comparison to mounded
LPG storage tanks described under section 6.3.2 below, the proposed option has smaller
footprint.
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6.3.2 Mounded Bullet Option
LPG can also be stored in a Mounded pressurised bullet which offer a safer option and
eliminates the possibility of BLEVE. The cover of the mound protects the vessel from fire
engulfment, radiation from a fire in close proximity and acts of sabotage, terrorism or
vandalism. The catastrophic failure mode of a cylindrical vessel is also such that it can be
directed away from any processing or occupied areas. Mounded bullet type storage is also
used where visual impact is important. A typical mounded bullet is depicted in Figure 2.
Figure 2: Typical mounded bullet
The disadvantage of mounded bullet storage over spheres is the plot space required. The
bullets themselves have a larger footprint and the space required for mounding adds
additional cost. GLT occupies an area of approximately 11.89 hectares. The buildings
including access roads onsite occupy an area of approximately 7.16 hectares while
undeveloped area and foot ball pitch are 2.05 and 1.68 hectares, respectively. Opting for
mounded bullets storage will drastically diminish the available undeveloped space for future
development including expansion of the existing operations.
6.3.3 LPG spheres
LPG can also be stored in LPG sphere tank, shown by figure 3. The sphere offers the
maximum volume for the least surface area and the required thickness of a sphere is one-half
the thickness of a cylinder of the same diameter. However, they are less safer since it weight
is not distributed evenly on a larger area thus increasing chances of collapse as compared to
LPG tanks described in the previous sections, especially in areas prone to earth quakes.
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Figure 3: An image of LPG Sphere
6.4 Input alternatives
The proposed facility will handle Liquefied Petroleum Gas. The amount of LPG stored will be
dependent on the requirements of BAT (K) Ltd. The input alternatives are thus dictated by the
forklift operations at BAT (K). The design does not allow storage of other products other than
Liquefied Petroleum Gas.
6.5 Conclusion
On the basis of the above considerations, the Firm of Experts concludes that the proposed
project satisfies the overall economic, technical, environmental considerations. BAT K Ltd will
have adequate stock of LPG; will not incur extra cost of land acquisition and will reduce the
cost of daily transportation of LPG to the site.
Finally, the Firm of Experts believes that the No-go option does not compete with the
benefits of proceeding with the project.
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CHAPTER SEVEN
7 PUBLIC STAKEHOLDER CONSULTATION
Public participation is an essential and legislative requirement for environmental authorization.

The firm of experts undertook the public stakeholder consultation (PSC) for the proposed
project in accordance with the requirements for an EIA Study stipulated in the EMCA, 1999
and EIA/EA Regulations 2003.
7.1 Objective of Public Stakeholder Consultation
The objectives of public participation in an EIA are to provide sufficient and accessible
information to Interested and Affected Parties (I&APs) in an objective manner to assist them
to identify issues of concern, and provide suggestions for enhanced benefits and alternatives.
7.2 Approach used in carrying out the PSC
The Firm of Expert consulted the neighbors of the Proponent. The responses from the
stakeholders were captured using the public stakeholder checklist while others were recorded
in the field note book.
Copies of completed checklists are appended at the end of this report (Appendix 6)
7.3 Comments and Responses from the Stakeholders
Generally, all the stakeholders consulted at the project site have no objection to the
establishment of proposed projects. They observed that the proposed project will not
generate any adverse environmental impacts. The responses for concerns raised by the
respondents are provided in Table 7 below.
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Table 7: List of Stakeholders Consulted during Project Report Preparation
No Name Mobile number Residence/ business Person/ Employee
Mercy Kyalo 020 694 2152 BAT Employee, EHS Executive
Samuel Mugo 020 - 694 2150 BAT Employee-
Charles Kimiti 020 - 694 2150 BAT Employee-
Nancy Mburu 0720754874 BAT Clinic
Nyawino Sheila 0722582354 Modular Enterprise
Purity Karimi 0710299676 BAT Clinic
Vas Auto Centre Ltd 020 650283/4 Neighbor -Vas Auto Centre Ltd
Christopher Mutuko 0728810777 Kiosk operator
Mwoshi 020 553356 Likoni Road , Post Bank
Dickson Ogolla 0717261272 Neighbouring cafe
Christopher Indeche 0722588273 BM Security
Evans Kagasi 0738714678 PCCL(Gym)
Colleta Wanjiku Njoka 0720264204 Hotel operator- neighbor
Table 8: Additional Stakeholders Consulted during preparation of EIA Study Report
No Name Contacts
1
Martin Kamau Tel.02002561
2
Jackson Mwangi Irungu P.O. Box 78449-00507, Nairobi
3
Mathew Kariuki Tel.0724423593
4
Ahmed A Tel. 0720585801
5
Jackline Tel. 0713133162
The responses were categorized into the following:
Socio-economic issues
The respondents reported that there will be:
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Availability of more LPG stocks for the factory operations

Enhanced fire safety measures put in place at the project will benefit the neighbors;
Enhanced security at site will also benefit the neighbors.
Creation of job opportunities
Reduction of transport costs
Environmental impacts
All the respondents were of the opinion that the project will have minimal or rather no impacts
on air, noise levels, flora and fauna, water and soil.
Health and Safety Issues
The respondents were of the opinion that during the construction phase workers will be at risk
of
Working at heights
Falling objects;
Exposure to dust and fuel fumes;
Fire risks
Noise
Ergonomic issues
Air pollution in the event of leakage of LPG
Proposed Mitigation measures
Members interviewed were asked to propose mitigations measures for the mentioned EHS
Issues. They proposed the following to be undertaken during the construction and operation
phases:
Continuous risk assessments;
Inducting employees on safety and environment before commencing work;
Use of permit to work systems;
Use of appropriate and inspected tools,
Barricading the area and use of warning signs;
Control of access of the project site;
Operations to be conducted by approved operators;
Have a preventive maintenance programme of the LPG Tank.
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CHAPTER EIGHT
8 ENVIRONMENTAL MANAGEMENT PLAN
This section presents the environmental management plan (EMP) for the proposed project.
The EMP specifies the mitigation and management measures which the Proponent will
undertake and shows how the Project will mobilize organizational capacity and resources to
implement these measures.
The EMP covers information on the management and/or mitigation measures that will be
taken into consideration to address impacts in respect of the following project phases: design,
construction, operation and decommissioning.
8.1 Approach to environmental impact management
The proposed EMP will be the responsibility of the HSE department of the BAT Kenya
Limited; however, it will have links with other departments such as operation and
maintenance. Table 9 presents the range of approaches that will be used to manage potential
impacts of the proposed project.
Table 9: Approach used to Manage Potential Impacts

Approach Description
Avoidance Avoiding activities that could result in adverse impacts and/ or

resources or areas considered sensitive
Prevention Preventing the occurrence of negative environmental impacts and/ or

preventing such an occurrence having negative impacts.
Minimization Limiting or reducing the degree, extent, magnitude or duration of

adverse impacts through scaling down, relocating, redesigning and or
realigning elements of the project
Mitigation Measures taken to minimize adverse impacts on the environment
Enhancement Magnifying and/ or improving the positive effects or benefits of a project
Rehabilitation Repairing affected resources
Restoration Restoring affected resources to an earlier (possibly more stable and

productive) state, typically background or pristine condition.
The environment, health and safety management cycle has five broad components:
Planning and design
Project implementation (covering the construction and operation phases);
Checking and corrective action; and
Management review
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8.2 Responsibility and Accountability
8.2.1 Environmental Management Structure
The Proponent and BAT Kenya Limited will utilize the existing arrangements in the
implementation of the EMP during planning and design, construction, operation and
decommissioning/closure. The Proponent is accountable for ensuring that resources are made
available to effectively implement the EMP and necessary environmental management
measures arising from the project. Figure 4 shows the proposed organizational structure for
the proposed Project, showing the reporting lines of staff to be involved in environmental
management of the project. The Project Manager will take responsibility for the day to day
running of the project and will oversee the detail of implementation of the EMP during
construction phase while during operational and decommissioning phases, will be managed by
the Factory Manager. The two managers will collaborate with the QEHS Manager of TKL and
HSE Manager of BAT Kenya Limited in implementation of the EMP.
Figure 4: Proposed Environmental Management Structure
Project Phase Responsibility
TKL BAT
Construction Phase
HSE Manager
Project Manager QHSE Manager
HSE Executive
Contractor EIA/EA Expert
Construction Manager
Operation Phase QHSE Manager BAT
HSE Manager
HSE Executive
Environmental Auditor HS Advisor Fire Auditor
Decommissioning
Project Manager BAT
Phase
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Table 10 provides details on the functions of each staff member. The environmental, health
and safety management of the project will be the responsibility of the Health, Safety and
Environment (HSE) Manager who reports directly to the East and Central Africa Operations
Manager. The HSE Manager will be supported by EHS Executive.
Environmental monitoring will be undertaken by the EHS Executive, and independent audits
of environmental performance will be conducted from time to time by independent NEMA
approved environmental expert.
Table 10: Functions of Staff in implementation of EMP
Position Responsibility
performing technical and organizational role of construction works

Engineering Manager
overseeing Implementation of EMP
supervising construction works

Project Manager
Schedule preparation and resource forecasting for engineering and
other technical activities relating to the project.
Undertake development of LPG facility in accordance with contract

Contractor(s)
signed with the Proponent;
Adhere to Proponent HSE policies, procedures and other

requirements while undertaking the Project
Implement aspects of EMP assigned to them
Effective implementation of the EMP

Construction Manager
Regular performance reviews
Corrective and/or remedial action where this may be required.
Develop policies and procedures on the environmental, social, health

TKL QHSE Manager
and safety issues
In collaboration with BATs HSE Manager, oversee implementation of

the EMP
Review and analysis of monitoring results and preparation of short

reports to Project Manager
Planning of training programs for personnel in accordance with

relevant laws e.g. OSHA 2007
oversee inspection of the constructed facilities after completion of

construction works
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Overseeing annual environmental, health and safety and fire audits

BAT HSE Manager
Preparation of environmental monitoring reporting and any permit

HSE Executive
applications (if any)
Running of day-to-day requirements for EMP implementation
Overseeing of construction process and ensuring the implementation

of avoidance and mitigation measures
Conducting monitoring and review of EMP implementation by

contractors
inspect the constructed facilities after completion
Periodically commissioned to undertake statutory environmental

NEMA Approved
EIA/EA Expert audits
Guide the Proponent during implementation of the Environmental

Management Plan
Carry out statutory health and safety audit of the GLT including the
DOSHS Approved H&S
Advisor LPG facility
Carry out statutory Fire safety audit of the GLT including the LPG
DOSHS Approved Fire
Auditor facility
8.2.2 Management of Contractors

The Contractors will be responsible for implementation of some of the EMP commitments.
However, the Proponent fully recognizes that it is not absolved from those management
responsibilities. Ultimate responsibility for meeting all commitments lies with the Proponent.
The Proponent will commit contractors to meeting the relevant responsibilities by means of
specific conditions in the contracts of appointment. Where there is concern over the capacity
of contractors to undertake specific activities according to the system stated here, the
Proponent will provide additional training to improve the capacity of the contractors.
Activities of contractors will be overseen by the Project Manager and staff as appropriate.
The Proponent will put in place the following construction phase contractor arrangements to
support EMP implementation:
Contractors will have certain key environmental line functions included in their job
descriptions and performance criteria. Critical among these is the Construction Manager.
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The Construction Manager will be accountable for environmental (including social)

management during the construction phase. Specific responsibilities for the Construction
Manager will include Regular performance reviews and undertake corrective and/or
remedial action where this may be required.
Regular (at least monthly) liaison between the Construction Manager, the Project
Manager and the HSE Manager and his/her team must be carried out. At the
commencement of the construction phase, weekly meetings should occur. Meetings
should review implementation of EMP requirements, highlight issues of concern, identify
required interventions and prescribe corrective actions and schedule, and allocate budget
and appoint responsible parties. The Factory Manager should receive minutes of
meetings and should be invited to attend meetings at least once in a month.
A code of practice for construction teams will be prepared and implemented. This code
will guide the management and behaviour of construction teams. The code will include
items relating to health safety and community relations.
Information on the implications of construction will be disseminated before construction

starts
Contracts will be key tools in managing many potential negative impacts such as transport
related incidents. They will specify required environmental and social practices.
8.2.3 Training, Awareness and Capacity Building

The Proponent will ensure that all contractors staff are inducted on health and safety,
environmental and emergency response procedures. The Proponent will use written
(newsletter/posters/toolbox talks) and verbal (as part of routine briefings) communication
methods to raise awareness on a range of health, safety and environmental issues. This
will be done in both Kiswahili and English languages (as appropriate) to ensure that all
members of the workforce are made aware.
8.2.4 Monitoring and Compliance Assessment

During the construction phase, the Proponent will monitor and inspect contractors written
records to demonstrate compliance with the EMP. This compliance monitoring will verify
that the responsible parties are implementing the specifications contained in the EMP.
Compliance will mean that the contractor is fulfilling contractual obligations.
To determine the effectiveness of the EMP, the Proponent will use a series of internal
and external inspections and audits:
Internal environmental, health and safety inspections will be carried out once every week
by EHS Executive;
Minor non-conformances will be discussed during the inspection and recorded as a

finding in the inspection report. Major non-conformances will be formally reported as an
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incident and will be subject to the Proponents existing incident reporting and handling
procedures
EHS Manager, will arrange for initial and subsequent environmental audits and will
provide relevant information required by relevant authorities including NEMA. The audit
will be carried out in accordance with EMCA, 1999 and its subsidiary legislation, EIA/EA
Regulations, 2003. Any negative findings arising from the audits will be addressed
accordingly.
8.2.5 Incident handling and Reporting

An incident can arise from the following:
Significant non-conformance with the EMP identified during an internal inspection
Any non-conformance identified by either the authorities or an external audit
Accidents or spills resulting in potential or actual environmental harm
Accidents or near misses that did or could result in injury to staff, visitors to site or the
surrounding communities
Significant complaints received from any source.
All incidents will be formally recorded and noted in the General Register in accordance with
requirements of OSHA 2007.
8.2.6 Checking and corrective action
Checking and if necessary implementing corrective action, to ensure that required EMP
management activities are being implemented and desired outcomes are achieved. As
such this component includes four key activities namely:
Monitoring selected environmental quality variables as defined in the objectives and
targets.
Ongoing inspections of the operational controls and general state of the operations.
Internal audits to assess the robustness of the EMP or to focus on a particular
performance issue.
External audits to provide independent verification of the efficacy of the EMP.
8.2.7 Corrective Action
There are several mechanisms for implementing corrective action, both during the
construction and operational phases. The main mechanisms to address transgressions
include verbal instruction (in the event of minor transgressions from established
procedure, usually following a site inspection); written instruction (identifying source(s) of
problems, usually following an audit) and contract notice (following possible breach of
contract).
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8.2.8 Reporting
The findings of all of the above will be structured into instructive reporting that provides
information to all required parties on EHS performance, together with clearly defined
corrective action where this is seen to be required. Both the monitoring and inspections
are to be reported continuously.
8.2.9 Management review
The Proponent will organize for formal management review at defined intervals both
during the construction and operational phases. The purpose of the management review
is for senior project management to review the environmental management performance
during the preceding period and to propose measures for improving that performance in
the spirit of continuous improvement.
8.2.10 Liaison
Throughout the project cycle, the Proponent will liaise with authorities especially NEMA
Kenya to ensure ongoing feedback on the environment performance of the project.
8.3 Overview of the Proposed Project
The EMP addresses the planning and design, pre-construction and construction,
operational and closure phases of the proposed project.
8.3.1 Planning and design

Planning and design is necessary to ensure that mitigation and impact management can
be effectively implemented in the context of the HSE approach. Planning involves the
following activities:
Identifying and defining the various environmental aspects and related potential positive
and negative impacts that can result from the companys activities.
Establishing a procedure to identify legal and other requirements to which the

organisation is subject.
Identifying and defining appropriate mitigation and management measures, including

those reinforcing positive impacts.
Establishing and maintaining documented, scheduled environmental objectives and

targets at each relevant function and level within the organisation.
In the case of the proposed Project the environmental aspects and potential impacts will
mainly emanate from the site preparation and construction activities.
The proposed project will comprise of 2 ton LPG tank and filling station. Detail description of
the project is provided in Chapter 2 of this report.
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Impacts have been described and rated in terms of their potential significance. The
management measures presented in this EMP have been developed in response to these
impacts. Anticipated positive impacts/benefits from the preconstruction and construction,
operation and closure of the proposed projects include the following: creation of employment
creation of market for supply of goods and services and contribute to BATs green initiative as
LPG propelled forklifts are more eco-friendly than the diesel propelled ones.
The anticipated negative impacts which could arise with mitigation during preconstruction
and construction, operation and closure of the proposed facility include the following:
Impact on air quality emanating from decreased air quality due to dust emission; fugitive
emissions and air pollution from incidents
Impacts on soil due to erosion and contamination from spilled fuel
Noise and vibration from construction
Pollution from waste generation
Health and safety impacts; occupational health and safety and public safety
8.3.2 Construction Phase

The EMP contains measures to avoid and mitigate impacts and optimize benefits arising from
activities during the pre-construction (e.g. clearing of the construction site) and construction
phase (e.g. construction of required infrastructure) of the Project. The principal focus of
Project management for construction will include: personnel and contractor management and
training; conduct and site management; maintenance of complaints register; emergency
preparedness; and management and mitigation of impacts such as surface runoff, noise,
dust, safety and pollution.
Assignment of responsibility and contractor management is especially important during the

construction phase. Contractors will be held to the highest HSE performance requirements to
ensure they meet Proponents, national and international standards.
8.4 Impact mitigation and management
This study identified potential impacts of the proposed project. The subsequent sections
provide description of the management plans and programmes within which
management and mitigation measures will be implemented. The actions and activities for
decommissioning phase are dealt with in the rehabilitation and closure plan which also
addresses the mitigation measures that will be ongoing once operations have ceased.
8.4.1 Impacts and mitigation/ management measures
Table 11 presents the EMP for the proposed project. It covers on the proposed
management and mitigation measures for the identified impacts. The information
presented addresses the dual objective of the EMP, namely to fully disclose the
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commitments undertaken by the Proponent, and to provide the Proponents as well as

Contractor(s) staff with a clear framework for EMP implementation.
In addition, the EMP provides a schedule for the implementation of

management/mitigation activities, sub-divided by project phase. The schedule shows at a
glance, the timing of the many actions required under the EMP. It is particularly useful
where management/mitigation measures extend across phases.
8.4.2 Management of impacts during construction phase
The EMP will put in place measures to avoid and mitigate impacts and optimize benefits
arising from activities during construction phase of the project. The principal focus of project
management for construction phase will include:
Personnel and contractor management
Conduct and site management
Landowner relations
Maintenance of complaints register
Emergency preparedness; and
Management and mitigation of impacts such as noise, dust, safety and pollution.
Assignment of responsibility and contractor management is important during the construction

phase and operation phase the contractor is used to carry out maintenance work. The
contractor will be held to the highest EHS performance requirements to ensure they meet
national and international standards.
8.4.3 Management of impacts during operation phase
The operation phase of the proposed project will be mainly receipt, storage and delivery of
LPG to the customers.
For the purpose of the EMP there are three principal mechanisms for the implementation of
management and mitigation measures:
Facilities these can be either specific facilities that have a dedicated HSE management
functions or additions to facilities that are central to the proposed project activity.
Procedures- in a similar vein, procedures can be stand-alone procedures with a dedicated

HSE function (such as a waste management procedure) or can be a modification to an
existing activity process to affect the HSE management.
Assignment of responsibility and contractor management this important when the

contractor will be used on an ongoing basis for a range of maintenance and other
functions. The contractor will be held to the same HSE performance requirements that
govern BAT(K) ltd.
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The mechanisms for effecting the EMP requirements are collectively called operational
controls. Such operational controls require that a responsible party, a budget and in
implementation schedule are specified and allocated, to further enable and facilitate
implementation. In addition, roles and responsibilities need to be defined for the EMP. These
roles include dedicated HSE management roles as well as the HSE responsibilities of other
company personnel (ultimately all personnel will have an HSE role). To facilitate coordinated
and purposeful implementation, the EMP management and mitigation measures are grouped
in programmes and plans.
8.4.4 Checking and corrective action
Checking and if necessary implementing corrective action, form the fourth component of the
EMP management cycle. They ensure that:
The required EMP management activities are being implemented; and
The desired outcomes are being achieved.
As such this component includes four key activities. These are:
Monitoring selected environmental quality variables as defined in the objectives and

targets.
Ongoing inspections of the operational controls and general state of the operations.
Internal audits to assess the robustness of the EMP or to focus on a particular

performance issue.
External audits to provide independent verification of the efficacy of the EMP.
8.4.5 Monitoring
The environmental variables that are to be monitored are described in the description of the
baseline environment. Monitoring results must be structured and presented for review on an
ongoing basis so that if objectives and targets are not met, corrective action can be taken.
8.4.6 Inspections: construction phase
An ongoing but pragmatic inspections regime will be developed that allows for potential HSE
transgressions to be identified proactively, so that mitigation can be quickly and effectively
implemented.
8.4.7 Internal and external audits
Where the monitoring data and the inspection reports highlights problems, an internal audit
can be used to ascertain the source of the problem and to define action to prevent its
recurrence. The three key areas for audit are facilities (are they operating properly?), project
procedures (are they properly designed and implemented?) and finally, and perhaps most
importantly Contractors HSE performance.
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8.4.8 Corrective Action
There are several mechanisms for implementing corrective action, both during the
construction and operational phases. The main mechanisms to address transgressions
include verbal instruction (in the event of minor transgressions from established procedure,
usually following a site inspection); written instruction (identifying source/s of problems,
usually following an audit) and contract notice (following possible breach of contract).
8.4.9 Reporting
The findings of all of the above will be structured into instructive reporting that provides
information to all required parties on HSE performance, together with clearly defined
corrective action where this seen to be required. Both the monitoring and inspections are
reported on continuously. Within the reporting structure it is necessary to create a review
function that continuously assesses the reporting and prescribes any necessary corrective
action. Reporting will include the provision of information on the HSE performance to external
stakeholders and surrounding communities.
8.4.10 Management review
The final component of the EMP management cycle is a formal management review that
takes place at defined intervals both during the construction and operational phases. The
purpose of the management review is for senior project management to review the
environmental management performance during the preceding period and to propose
measures for improving that performance in the spirit of continuous improvement.
8.4.11 Liaison
Throughout the project, ongoing liaison will be maintained with authorities and communities
alike to ensure the following:
Advance warning of any project activities that may have some adverse impact on
surrounding communities, e.g. clearing of construction site, installation of storage tanks;
and
Ongoing feedback on the environment performance of the project.
8.5 Impact mitigation and management
This section presents mitigation and management measures for the identified potential
impacts of the proposed project. The section also provides description of the management
plans and programmes within which management and mitigation measures will be
implemented. The actions and activities for decommissioning phase are dealt with in the
rehabilitation and closure plan which also addresses the mitigation measures that will be
ongoing once operations have ceased.
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8.5.1 Impacts and mitigation/ management measures
Table 11 presents the EMP for the proposed project. It covers on the proposed management
and mitigation measures for the identified impacts. This information presented addresses the
dual objective of the EMP, namely to fully disclose the commitments to be undertaken by the
Proponent to provide managers and staff with a clear framework for EMP implementation.
In addition, the EMP provides a schedule for the implementation of management/mitigation

activities, sub-divided by project phase. The schedule shows at a glance, the timing of the
many actions required under the EMP. It is particularly useful where management/mitigation
measures extend across phases.
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Table 11: Mitigation and Management measures for the identified Impacts
Aspect Impact Mitigation Objective Performance Monitoring Timing of Cost Responsibility
Measure/Enhancement Indicators or Mitigation/ Estimate
measures Acceptance Criteria Enhancement
Measures
Air Degradation of Relevant legislative and To achieve air No receipt of air Non-compliance Throughout project No Proponent,
Quality Air Quality Kenya Standard design quality quality-related and incident cycle significant Contractor and
material User (BAT
requirements will be objectives of complaints from reporting will be additional Kenya Limited)
adhered to where the Draft Air neighbouring closed out t to cost
appropriate. quality sensitive ensure prompt

Regulations receptors. rectification and
Vehicles and machinery
2008 during change
will be regularly Documentation
construction management as
maintained. of regular
and operation. required.
servicing/mainte
Maintenance activities
To minimise the nance of all Neighbours
requiring purging of gas
potential for vehicles and complaints will be
will be minimised and
construction, plant recorded and
conducted under
operation and components. closed out.
favourable
decommissioni
meteorological Regular reporting
ng activities to
conditions (to facilitate and audits will be
adversely affect
rapid atmospheric undertaken by the
sensitive
dispersion). Production
receptors.
Manager in
Install standard leak
To maintain accordance with the
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Measures
detectors for hazardous acceptable requirements of the
area installations. limits of LPG (Safety)
vehicular and
Any detected leaks will The results of leaks
machinery
be repaired as a high detection and
operating
priority. estimates of the
emissions.
volume of any gas
Best practice measures
To minimise vented, and
are implemented to
gaseous and recommendations
minimise the potential for
dust emissions. and corrective
dust to be generated and
actions shall be
escape off-site.
implemented.
Audit of vehicle
servicing records.
Audit of the plant

maintenance
records for leaks
detection and
repair.
Noise Noise Pollution Construction activities To minimise the No noise related Landholder Construction, 100,000 Proponent and
Quality from Incidents Operation and monitoring User
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Measures
near sensitive places potential for complaints complaints relating Decommissioning cost per
phases schedule
shall be restricted to noise to received from to noise will be
normal working hours adversely affect residents and recorded and
(typically 7.00 am to 6:30 sensitive landholders. closed out.
pm, 7 days a week) receptors
Documentation Regular audits and
unless otherwise agreed during project
of repair and will be undertaken,
with the potentially cycle.
replacement of and
affected stakeholder(s).
To achieve faulty equipment recommendations
Relevant legislative and relevant as soon as and corrective
Kenya Standard design environmental possible. actions shall be
requirements will be acoustic quality implemented.
Documentation
adhered to where objectives of
of consultation Noise survey(s) will
appropriate. the Legal
and planning for be undertaken as
Notice No. 61
Adequate community atypically noisy appropriate and
of 2009, during
notice of any scheduled, events. No noise upon request from
project cycle.
atypical noise events will related the administering
be provided. complaints authority.
received from
Equipment will be fitted Noise surveys at
residents and
with noise control relevant nearest
landholders.
devices where possible local residences will
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Measures
and appropriate. Documentation be undertaken as
of repair and appropriate.
replacement of
faulty equipment
as soon as
possible.
Documentation
of consultation
and planning for
atypically noisy
events.
Waste Pollution Develop strategies To minimise No evidence of Housekeeping Construction, No material Proponent,
additional
from waste (waste management any negative uncontrolled checks to ensure operation and Contractor and
costs
generation Decommissioning are User
plan) for management of impacts waste (i.e., not in waste is being phases anticipated
specific waste streams associated with appropriate stored correctly and above
general
prior to construction waste containers) at no litter is budgets for
responsibiliti
phase. generation above ground occurring.
es of EHS
through facilities during Manager for
Stockpile and salvage Regular audits and the
adoption of the inspections. implementati
reusable and recyclable reviews will be
on of the
waste
wastes, such as timber Record of undertaken, and plan.
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Measures
skids, fibre/nylon rope management regulated waste recommendations
spacers, pallets, drums hierarchy. disposal. and corrective
and scrap metals. actions shall be
No spills of Number of
implemented.
Store hazardous wastes hazardous Waste Spill
in bunded areas away waste fluids Reports. Waste will be
from watercourses. (e.g., oil). tracked and
appropriately
Collect and remove (via Safe and
recorded.
NEMA approved waste proper disposal
handler) waste from site of waste. Report hazardous
for recycling, reuse or waste spills.
disposal at facility
Review of
licensed to accept such
operations waste
wastes.
management
All personnel will be procedures, and
instructed in project quantity of
waste management regulated wastes
practices as a generated.
component of the
environmental induction
Page 95

Measures
process.
Where practical, wastes

(e.g., scrap metal) will be
segregated and
reused/recycled.
All litter and general

waste disposal will be at
a local municipal landfill
utilising an approved
waste contractor.
Records of all controlled

wastes stored, and
removed from site will be
maintained.
Safety and response

training will be provided
for all personnel.
Materials and equipment

for responding to
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Measures
hazardous spill incidents
will be provided and
maintained.
Soil Degradation of Minimising the areas to To avoid or Documentation Non-compliance Construction phase No material Proponent and
additional
Quality soil be excavated of regular and incident Contractor
minimise soil costs
are
disturbance/conta servicing/mainte reporting will be
Re-vegetating disturbed anticipated
mination. nance of all closed out by senior above
areas once construction general
vehicles and management to budgets for
and demolition works are
responsibiliti
plant ensure prompt
completed; during es of EHS
components. rectification and Manager for
construction and
change the
decommissioning The extend of implementati
management as on of the
phases respectively; excavated area
required. plan.
Ensuring that
Neighbours
vehicles/equipment used
complaints will be
during construction and
recorded and
decommissioning
closed out.
phases are serviced
regularly. Regular reporting
and inspections will
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Measures
be undertaken
Audit of vehicle
servicing records.
Water Degradation Develop strategies for To minimise any No evidence of Housekeeping Construction, No material Proponent,
Quality of water negative impacts operation and additional Contractor and
management of water uncontrolled checks to ensure
quality costs
on water decommissioning are User
resources. waste (i.e., not in waste is being
resources during anticipated
construction, appropriate stored correctly and
Regular checking and above
operation and containers) at no litter is general
maintenance of all plant budgets for
decommissionin above ground occurring.
and machinery to g phases. responsibili
facilities during ties of EHS
minimize the risk of fuel Regular audits and
inspections. Manager
or lubricant leakages reviews will be for the
Record of undertaken, and implementa
Storing hydrocarbons,
regulated waste recommendations tion of the
fuels, lubricants and plan.
disposal. and corrective
chemicals to be used in
actions shall be
bunded and lockable oil Number of
implemented.
storage tanks, with Waste Spill
hoses and gauges kept Reports. Waste will be
within the bund. tracked and
appropriately
Leaving vegetation in
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Measures
situ wherever possible, recorded.
and re-vegetation of bare
Report hazardous
soil before the next rainy
waste spills.
season.
Review of
Exposed ground and
operations waste
stockpiles will be
management
minimised to reduce silty
procedures, and
runoff, and if necessary
quantity of
measures such as
regulated wastes
geotextiles will be used
generated.
to shield spoil mounds.
Preventing wet concrete

and cement from
entering watercourse;
Stockpiles to be kept
away from watercourses
Health Occupational Development and To minimise Occupational Workplace - Construction, No material - Proponent and
additional
and health and implementation of impacts on health injury and illness inspection to operation and Contractor
costs
Safety safety impacts decommissioning are
occupational health and and safety during incidents. ensure phases anticipated
safety plan. The Plan will construction, above
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Measures
cover on the following: operation and Workforce health operations/activities general
budgets for
decommissioning are being
Formulation of EHS Process safety responsibiliti
phases. es of EHS
Management system undertaken in
manager for
accordance with the the
Development of health implementati
safe operating on of the
and safety programme plan.
procedures,
Additionally,
Risk assessment and standards and the health
and safety
health monitoring for regulations audit of the
facility will
workers
Regular audits and not be
carried out in
Contractor selection reviews will be isolation,
undertaken, and instead it will
criteria in relation to
be audited
health and safety recommendations together will
other
and corrective facilities
Job description to
actions shall be onsite during
include health and safety annual
implemented. statutory
requirements audit of the
Personnel will be entire plant
hence no
trained on health additional
cost is
and safety. anticipated
Socio- Creation of During construction Maximize impacts Construction, No additional- Proponent, and
Kenya Labour Laws Compliance with-
economic employment phase, the Contractor on local economy operation and cost is Contractor
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Measures
and supply of will be encouraged to and employment Kenyan Laws decommissioning anticipated
goods and during project phases
source where possible
services
labour from the local phases
opportunities
community;
During operation phase,

the Proponent will utilize
their existing human
resource policy in hiring
personnel required to
operate the plant. The
Proponent will ensure
that hiring of personnel
follows the Kenya
Labour Laws and that
there will be no
discrimination on the
grounds of race,
ethnicity, religion,
gender, and political
affiliation. The
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Measures
contractors will similarly
be required to apply the
same policy.
The Proponent will utilise

their existing
procurement policy and
ensure that where
possible goods and
services are sourced
from the local area.
Page 102
8.6 Management Programmes
This section presents the programmes for managing the identified impacts. It is worth noting
that the use of management programmes to manage the impacts is necessitated by the fact
that most of the mitigation measures cannot be implemented as discrete, isolated actions
because there are spatial, temporal and casual interactions among impacts. The programmes
recommended for managing the potential impacts of the proposed project include:
Air quality management programme

Noise management programme
Occupational Health and Safety
The implementation of the EMP is also linked to a series of comprehensive management

plans. Management and mitigation measures should be in compliance with legislative
requirements. Where no legal guidance is provided, industry and/or international good
practices should be applied as far as is practicable.
8.6.1 Air quality management programme
The aim of this programme is to ensure that air quality is maintained through construction, as
well as operation phases. The air quality management programme includes the following:
Dust management
Dust abatement measures shall be implemented to control dust generated by

construction activities. Refer to the construction control plan and construction
management plan.
A complaints register and protocol will be drawn up as a means for surrounding

landowners, residents and public residents to voice their issues and concerns, particularly
those relating to the nuisance effects of dust and noise The register will be set up prior to
the commencement of construction activities. These public complaints should be
responded to as a matter of urgency and where possible, measures taken to minimize the
cause of dust and noise.
Emissions
The Contractor shall ensure that the construction machinery and equipment are
appropriate and fit to prevent fugitive emissions, as per national standards or international
practices. The Proponent shall ensure the regular maintenance of this equipment.
A maintenance plan for the construction machinery and vehicles shall be implemented to
prevent excessive emissions during the construction phase of the project.
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8.6.2 Noise management programme
This programme aims to ensure that noise generated by construction and operation
activities is kept to a minimum and adheres to relevant noise standards. The noise
management programme includes the following:
The Contractor shall ensure that construction activities are limited to working hours (i.e.
between 06h 00 and me 9h 00 daily) from Monday to Saturday, or as required in terms of
legislation and/or negotiated with local landowners.
Noise generating equipment will be designed to control and dampen noise emissions,
and will be located at a distance far enough from the nearest noise sensitive
development, to ensure that the increase in ambient noise level will comply with ISO
standards.
Landowners, residents and public shall be able to register their complaints and concerns
about noise through complaints register set up prior to the commencement of construction
activities. These public complaints should be responded to as a matter of urgency and
where possible measures must be taken to minimize the noise
8.6.3 Occupational Health and Safety Programme
The aim of this programme is to ensure that the Safety and Health of the employees quality is
maintained through construction, as well as operation phases. The OHS management
programme includes the following: Undertaking S&H risk assessments, S&H audits, Provision
of adequate and appropriate firefighting equipment, Provision of Personal Protective
Equipment to the workers and Issuing of work permit systems for hot jobs at the site.
8.7 Management Plan
8.7.1 Overview
The following management plans will be implemented during construction, operation, and
decommissioning phase of the proposed project:
Construction management plan

Construction control plan
Labour and human resources plan
Workplace health and safety plan
Community safety plan
Emergency management and response plan
Rehabilitation and closure management plan
8.7.2 Construction Management Plan
The construction management plan for the proposed project shall include the following:
Page 104
Management of fuels and other hazardous materials
The Contractor shall comply with all applicable laws, regulations, permit and approval
conditions and requirements relevant to the storage, use, and proper disposal of
hazardous materials.
The Contractor shall manage all hazardous materials and waste in a safe and responsible
manner, and shall prevent contamination of soils, pollution of water and/ or harm to
people or animals as a result of the use of these materials.
The Contractor shall prepare a hazardous materials and waste management plan for
inclusion in the site specific environmental plan to be submitted to the Proponent prior to
establishment on site. The plan shall include, but not limited to, measures to prevent: (a)
safe siting and storage;
The contractor shall place on-site tools and equipment, such as generators, compressors
on bermed impermeable sheeting to prevent oil spills/leaks from causing subsurface
contamination.
The contractor shall ensure oil spills/leaks are prevented or minimized. This can be
achieved through: instructing employees not to overfill diesel bowsers and equipment
tanks; regular auditing to verify that no leaking or defective equipment is brought/used
onsite; any oils or lubricants discharged during servicing of the machinery or vehicles are
contained in dry trays or other appropriate containment measures.
The Contractor shall ensure that fueling and repairs are carried out by trained personnel
familiar with spill containment and clean-up procedures.
The Contractor shall ensure that all the employees working onsite are trained on good
housekeeping practices.
Management of the construction site
The contractor shall prevent littering and the random discard of any solid waste on or
around the construction site
The contractor shall manage hazardous waste
The Contractor to determine safe traveling speeds for the construction site and ensure
that restrictions are enforced.
Emergency Preparedness
The Contractor shall develop an emergency plan that will enable rapid and effective
response to all types of environmental emergencies in accordance with recognized
national and international standards. The emergency plan shall include establishment of a
network of communication between the Contractor and emergency services including
police, ambulance services, and fire brigades among others.
Page 105
The Contractor shall test emergency preparedness with drill operations and shall review
drills, conduct mock emergencies and remedy shortcomings to ensure a high level of
emergency readiness to deal with environmental and third party incidents.
Fire Prevention and management
The Contractor shall take all necessary precautions to prevent fires caused either
deliberately or accidentally during construction process.
The Contractor shall prepare a fire prevention and fire emergency plan as a part of the
Environmental Plan to be submitted to BAT Kenya Ltd.
The Contractor shall provide adequate fire fighting appliances at specified localities on
the worksite to meet any emergency resulting from ignition of a fire.
The Contractor shall ensure that hot work is prohibited under specified meteorological
conditions with high fire risks and that appropriate and adequate firefighting equipment
would be required to be on standby at all times where hot work is being carried out.
Management of air quality
The Contractor shall institute appropriate measures to minimize or avoid air quality
impacts. This can be achieved through formulation of air quality management plan.
The Contractor to minimize/control emission of dust due to traffic movement and wind
erosion of stockpile material and exposed soil.
The Contractor to mitigate emissions of gases vapours and odours by conducting initial
risk assessment and the installation of procedures to control the risk.
The Contractor to ensure that all equipment used and all facilities erected on site are
designed and operated to control the emission of smoke, dust, fumes and any other air
impurity into the atmosphere.
Noise Management Programme
The noise management programme is geared towards minimizing the amount of noise
generated by the construction and operation activities as well ensure adherence to the
relevant noise standards. The noise management programme includes the following:
The Contractor shall comply with the legal requirements for the management of noise
impact specified in the recently promulgated noise quality regulations.
The Contractor shall formulate noise management plan for minimizing the generation of
noise and vibration from construction activities occurring on site and its impact on
surrounding residents, businesses and workers.
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Neighboring land owner and occupier relations
The Contractor shall respect the property and rights of neighboring landowners and
occupiers at all times and shall treat all persons with deliberate courtesy.
The Contractor shall respect any special agreements between the Proponent and the
neighbors
Complaints register
The Contractor shall establish and maintain a register for periodic review by the Proponent
that logs all the complaints raised by the neighbors or the general public about construction
activities. The register shall be regularly updated and records maintained including the name
of the complainant, his/her domicile and contact details, the nature of the complaint and any
action taken to rectify the problem.
Health management
The Contractor shall comply with all relevant legislative requirements governing worker
health and safety (e.g. OSHA 2007 and its subsidiary legislations).
The Contractor shall prepare and implement a programme to minimize diseases likely to
be contracted by the construction workers as a result of the proposed project such as HIV
Aids.
8.7.3 Construction Control Plan (CCP)
The CCP for the proposed project shall cover on the following:
Control of access
The contractor shall ensure that the construction is not accessed by authorized persons.
Control of top soil and subsoil
The contractor shall store topsoil excavated from the site in a wind row or stockpile which
shall be discernibly separate from wind rows or stockpiles of any other excavated
materials.
Top soil shall be protected from any contaminant that might impact on vegetation.
The Contractor shall temporarily stockpile topsoil in a location that will minimize any loss
due to erosion or mixing with other material.
The Contractor shall ensure that topsoil is stockpiled in a manner and for a period of time
that does not result in deterioration in its plant support capacity.
Control of material supply and burrow areas
The Contractor shall, as far as possible, source all material needed to construct the
proposed project from the licensed mines
Page 107
In instances where materials are to be obtained from a new borrow area; the Contractor
shall comply with relevant legislations.
The Contractor shall prepare a method statement including plans, detailing the expected
quantity of excavation, temporary and permanent drainage control, the final contouring of
the borrow pit and the proposed method of rehabilitation.
Rehabilitation
After completion of construction activities, the Contractor shall clear the site of
construction materials and dispose wastes in appropriate disposal sites.
The Contractor shall remove all temporary works on the construction site and grow grass
on the sloppy areas where retaining wall will not be constructed to control soil erosion
8.7.4 Labor and Human Resources Plan
In designing the Labour and human resources plan Contractor shall:
Comply with the provisions of Employment Act, 2007
Wherever possible, give priority to qualified local people when hiring employees.
8.7.5 Workplace Health and Safety Plan
The workplace health and safety plan to be implemented by Total, BAT and Contractor shall
include the following key measures:
All relevant national legislation, including the OSHA 2007 and related regulations, shall be
adhered to ensure that health and safety of proximate communities and the public at
large are not threatened during construction and operational phases of the Project.
the Proponent shall ensure workplace health and safety during the operational phase of
the facility
Health and safety performance will be continuously monitored and procedures reviewed
with the aim of eliminating risk as far as reasonably practicable.
8.7.6 Community health and safety plan
The community health and safety plan to be implemented by the Contractor, Total K Ltd and
BAT K Ltd shall include:
Adherence to OSHA 2007 Act and its subsidiary legislations to ensure that health and
safety of immediate neighbors and the public is not threatened.
The Contractor to ensure that construction work is undertaken in manner not likely to
pose risks to community health and safety.
The Proponent to undertake an independent quantitative risk assessment prior to

operation of the facility. The findings of this assessment will inform the development of an
emergency safety plan
Page 108
The Total (K) Ltd and BAT (K) Ltd to create awareness among the neighbors on the
community safety procedures.
8.7.7 Emergency Management and Response Plan
The Proponent shall rollout and implement their documented emergency response plan at the
completed footprint. The EMRP shall include:
Emergency management planning
The components of the EMRP shall include:
a) Structure and operation of the emergency management team
b) Establishment of an emergency management centre
c) Information retained by the emergency management team
d) Incidents requiring activation of the plan
e) Incident severity classification
f) Process to be followed in the event of an emergency
Information pertaining to emergency management shall be reported through the HSE

reporting process
A quantitative risk assessment report will be compiled by an independent company prior

to commissioning of the facility.
Emergency Response Plan
The Proponent shall implement a community health and safety plan which shall include the
following measures:
BAT Kenya Limited will compile a comprehensive safety emergency management plan
(SEMP) for the facility. The SEMP will cover the following aspects:
a) Kenyas Safety regulations
b) Scope of the SEMP
c) Notification of local authorities
d) Details of the facilitys system
e) Aim of the SEMP
f) Objectives of SEMP
g) Roles and responsibilities in the event of an emergency
h) Information requirements in the event of an emergency
i) Evacuation of people
j) The role of local communities
k) Regular testing of the SEMP
l) Planning for the eventuality of failure on the facility
m) Causes of the facilitys failure
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n) Probability of facilitys failure

o) Size and duration of the facility
p) Hazards and effects of facilitys failure
q) Hazard range and emergency planning distances
r) Anticipation of worst credible incidents
Rehabilitation and decommission management plan
The rehabilitation and decommissioning management plan include the following:
Planning for closure
The Proponent shall develop rehabilitation and decommissioning plan in conjunction with
relevant stakeholders at least one year before the end of facilitys operations.
The Proponent shall investigate practical options for closure of the facility at least one
year before decommissioning and submit a report to relevant authorities NEMA included.
The Proponent to explore options of re-use and recycling of the facilitys

components/structures.
Decommissioning
The Proponent shall take into consideration the health and safety of personnel,
contractors, neighbors and the public during the planning and implementation of the
demolition process.
The Proponent shall undertake a further survey to identify any contaminated areas
remediate them accordingly.
Post Closure
The Proponent shall ensure that the facilitys site is free of impacts associated with the
abandonment/closure.
The Proponent shall develop, rollout and implement a monitoring plan that includes:
a) Monitoring of the rehabilitated site to confirm whether progress is satisfactory.
b) Outline of how land improvement and future land use will be affected by he past operation
and decommissioning of the LPG tank.
8.8 Monitoring
The proposed programmes and plans will be subjected to monitoring. Monitoring will have two
elements: routine monitoring against standards or performance criteria; and periodic review or
evaluation. Monitoring will often focus on the effectiveness and impact of the programme or
plan as a whole.
During construction phase, the Proponent shall monitor the contractors activities in order to
verify that the management measures/procedures/specifications are implemented as
Page 110
contained in the EMP. Compliance will mean that the Contractor is fulfilling their contractual
obligation.
During operation phase, the Proponent will monitor facilitys operations to ensure compliance
with management measures in the EMP and operation procedures. As part of this monitoring,
the Proponent will undertake statutory initial environmental audit as required by the EIA/EA
Regulations, 2003 and subsequent annual self environmental audits.
8.8.1 Programme Monitoring
The Proponent shall regularly monitor programme implementation. The process will include
the regular monitoring of:
Erosion of soil resulting in the immediate surroundings of the facility caused by the
presence of facility or impacting on structures associated with the facility
Air quality and ambient emissions, including dust generated by construction activities
Noise generation during construction and operation phases
8.8.2 Plan Monitoring
All of the management plans make provision for monitoring and evaluation. Special attention
should be given to the monitoring arrangements relating to biophysical impacts, occupational
health and safety, facility operational and emergency response.
During the construction phase of the project, the Contractors HSE Officer shall report all
environmental impacts as well as accidents and incidents to the Proponents HSE Officer.
The reported impacts and incidents will be captured on a database to ascertain trends and
track progress in the implementation of preventive and corrective actions, and benchmarking
against other, similar operations.
Depending on the level of severity, accidents and incidents will be investigated by the
Contractors HSE division, with key input from the line management to ensure accountability.
During operation, the Proponents HSE department will monitor the health and safety of
personnel and contractors, in compliance with legislative requirements. Emergency incidents
should be reported to the relevant authorities. The reported impacts and incidents will be
captured on a database to identify weakness in the emergency response plan and track
progress in the implementation of preventative and corrective and benchmarking against
other similar operations.
Page 111
CHAPTER NINE
9 INCIDENT PREVENTION AND HAZARD COMMUNICATION ACTION PLAN
The construction and operation activities of the proposed project might generate incidents and
hazards to the health and safety of the employees. It is therefore imperative that the project
is constructed and operated in a safe and incident free manner particularly in compliance with
Kenyan legislation on safety (e.g. Legal Notice No. 40 titled Building Operations and Works
of Engineering Construction Rules, 1984) and the Proponents HSE management system
requirements. This section recommends the incident prevention and hazard communication
actions that the Proponent should undertake in the construction and operations phase of the
project.
9.1 Incident Prevention Construction Phase
Contractor health and safety is an essential component of incident prevention during the
construction phase of the project. It is recommended that contractor health and safety rules
be implemented for the project containing the elements described below.
9.1.1 Responsibilities with regard to safety
The responsibilities with regard to safety must be documented by the Proponent for all
contractors to follow while working at the project site. The Proponents responsibility is to
issue procedures, safety rules and safety induction training for all contractors working on site.
It is the responsibility of all contractors to strictly adhere to the Proponents HSE standards
and to ensure that every person in the contractors employment observes the requirements of
the Proponents regulations.
The contractor will be required to nominate a contractor supervisor for the project. This
person will be responsible for all HSE compliance requirements of subordinates and will issue
instructions regarding safety and health which have to be carried out by all contract
employees.
9.1.2 Designation of First Aiders
In accordance with the Legal Notice 160 of 1977 (First Aid Rules), the contractor shall ensure
that an adequate number of certified first aiders are available at the project site with properly
equipped first aid boxes. At least one first aider for every 50 employees is recommended.
9.1.3 Contractor Employee Responsibility with regard to Safety
Any contractor employee who observes or is involved in an accident will immediately report
such incident to the contractor supervisor who will record the details in a General Register as
stipulated under the Occupational Safety and Health Act, 2007. The Contractors Supervisor
on site shall fill out an Accident Report Form and submit it to the nearest provincial DOHSS
office within 24-hours of the accident.
Page 112
9.1.4 Personal Conduct
It will be the responsibility of the contractor to ensure that their employees do not engage in
any of the following practices during the construction phase of the project:
Smoking;
Personal business; and
Misconduct
9.1.5 Personal Protective Equipment (PPE)
Each contractor working at the project site shall ensure that all their employees are provided
with appropriate and adequate PPE. The contractor will be required to maintain a register
indicating the issuance, control and use of PPE which includes the following:
Safety shoes;
Safety helmets (hard hats);
Hand protection (gloves);
Eye and face protection (safety glasses);
Hearing protection (ear plugs, ear defenders); and
Clothing (overalls).Safety Procedures
The contractor will be required to issue the Proponent with a comprehensive Safety Method
Statement for carrying out each phase of the construction works. The contractor will further
be required to comply with the safety procedures of the Proponent EHS Management
System.
9.1.6 Fire and Emergency Procedures
The contractor and all the employees working for them shall be required to be familiar with the
Proponents fire and emergency procedures. The safety induction training to be provided by
the Proponents Consultant for all contractors working at the project site will include the
Proponents emergency and evacuation procedures.
9.1.7 Security Procedures
The contractor will be required to familiarize themselves with the Proponents security
procedures and shall ensure that all employees comply with those security procedures.
9.1.8 Working Tools and Equipment
The contractor will ensure that no unsafe tools are used at the project site. The contractor will
further ensure that all scaffolding and ladders, cranes, welding machines, compressors, etc.
are in good serviceable condition at all times during the construction phase of the project and
have been certified by DOHSS approved persons.
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9.2 Incident Prevention Operational Phase
9.2.1 Proponents HSE Management System
The Proponent will develop, rollout and implement a detailed HSE management system for
their project. It is expected that relevant parts of such an HSE management system will be
rolled out and implemented at the project site during the operational phase of the project.
9.2.2 Emergency Response Plan
In the event of an emergency at the project site the Proponents Emergency Response Plan
will be activated in accordance with the procedures laid out in it. It will therefore be necessary
for the Proponent to develop, rollout and implement their documented emergency response
plan prior to the construction phase.
The emergency response plan should as a minimum include the headings given below.
Introduction;
Purpose;
Scope;
Abbreviations;
Definitions;
Emergency response organization;
Emergency notification system;
Evacuation procedures;
Emergency response plan activation;
Contingency plans;
Emergency management resources and logistics;
Crisis control center;
Deactivation and recovery plan;
Training;
Emergency response plan maintenance; and
Emergency response plan distribution.
Page 114
CHAPTER TEN
10 Assumptions, Uncertainties Encountered and Gaps in Knowledge
10.1 Assumptions
The Firm of Experts made the following assumptions in preparing this E.I.A Study Report.
All the technical data and information provided by the Proponent and the specialists are
accurate and up-to-date
The public involvement process has been sufficiently effective in identifying the critical
issues that needed to be addressed
The Proponent and the Contractor will implement the measures in the proposed EMP
The Proponent will undertake monitoring to track the implementation of the EMP to
ensure that management measures are effective to avoid, minimize and mitigate impacts;
and that corrective action is being undertaken to address shortcomings and/or non-
performances.
10.2 Uncertainty and Difficulties in Compiling Information
Uncertainty arises from a variety of aspects in any development, and for this particular EIA
study has emanated from the following:
The changes that may occur in baseline conditions, due to external factors over the lifetime of
the project;
Uncertainty related to Proponents policy initiatives that might influence the assessment of
future baseline and post-development conditions;
Uncertainty in design information which should be dealt with by the definition of design
parameters for the development by the Contractor and Proponent; and
Uncertainty in relation to project planning and implementation as the detailed program and
means of construction may be influenced by the choice of Contractor and the detailed design
of the development.
The difficulties in compiling the information for this EIA study have related principally to the
above sources of uncertainty. To obviate these difficulties the Firm of Experts has used their
past experience wherever possible and consultation with Proponents having similar projects
to gauge and recommend appropriate mitigation measures in this EIA study.
Page 115
CHAPTER ELEVEN
11 CONCLUSION AND RECOMMENDATION
From the findings of this EIA Study, the following conclusions and recommendations are
made:
(a) The proposed installation of LPG tank has the support of the stakeholders,
(b) The project will be designed, constructed, and operated according to the acceptable
industry norms and standards
(c) Though there are a number of potential adverse impacts associated with it, it is possible
to mitigate them successfully. Successful implementation of the proposed EMP will help
to minimize or reduce the environment impacts to the acceptable levels.
(d) The proposed project will generate socio-economic benefits which would not be realized if
the no development of option is considered.
Page 116
ATTACHMENTS
The following attachments provide supplementary information used in the preparation

of this E.I.A study report.
Attachment No. Description
1. photographs
2. Site Layout
3. Copies of Public Stakeholder Consultation
Checklists
4. Copies of proof of ownership documents
Page 117
The proposed place where the LPG Tank and filling facility Acacia tree at the neighbouring premises which was
are to be installed. The site was currently used as a leaning towards the poposed site. BAT (K) Ltd was to liaise
storage area for tobacco pallettes. with the occupier to prune the branches of the tree.
The building neighbouring the proposed project, currently The ground surface at the proposed site
being used as a warehouse.
Page 118
The main gate, which is off Londiani Road leading to the The main gate leading to the premise. The proposed
proposed site project will share the premise with BAT Gym, Clinic and
clinic.
Page 119
Site Layout
Page 120
Copies of Public Stakeholder Consultation Checklists
Page 121
Copies of proof of ownership documents
Page 122
REFERENCE
The following list of references was referred to in preparing this EIA Report:
1. Government of Kenya: The Environment Management and Coordination Act 1999
2. Government of Kenya: The Environment (Impact Assessment and Audit)

Regulations 2003
3. Government of Kenya: The Physical Planning Act 1996
4. Government of Kenya: Occupational Safety and Health Act,2007
5. Government of Kenya: Factories and Other Places of Work (Safety and Health
Committee) Rules 2004
6. Government of Kenya: Factories and Other Places of Work (Medical Examination)

Rules 2005
7. Government of Kenya: Water Quality Regulations, 2006
8. Government of Kenya: Waste Management Regulations, 2006
9. Government of Kenya: The Occupational Safety and Health Act, 2007
10. Government of Kenya: The Safety and Health Committee Rules 2004
11. Government of Kenya: Medical Examination Rules 2005
12. Government of Kenya: Noise Prevention and Control Rules 2005
13. Government of Kenya: Fire Risk Reduction Rules, 2007
14. Government of Kenya: Hazardous Substances Rules, 2007
15. Government of Kenya: Embakasi District Development Plan, 2008-2011.
16. Government of Kenya: Factories and Other Places of Work (Noise Prevention and
Control) Rules 2005
17. British Standard (BS) 8233:1999: Sound Insulation and Noise Reduction for
Buildings
18. British Standard (BS) 5228 Part 1, 1997: Noise and Vibration Control on Construction
and Open Sites
19. British Standard (BS) 5228 Part 4, 1997: Noise Control on Construction and Open Sites:
Code of Practice for Noise and Vibration Control applicable to piling operations
Page 123

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ENVIRONMENTAL IMPACT ASSESSMENT STUDY REPORT FOR THE

PROPOSED INSTALLATION OF A 2t LIQUEFIED PETROLEUM GAS

1. Isaiah B. Kegora - Reg. No. 1893

Philip Abuor- Reg. No. 1710

Date: May 2014

DOCUMENT RELEASE INFORMATION

Client Total Kenya Limited

Project Title Installation of a 2ton Liquefied Petroleum Gas Storage

Document Title EIA Study Report

Revision Status Final

DETAILS OF PROPONENT AND FIRM OF EXPERTS

Proponent TOTAL KENYA LIMITED

Contacts Address 30736 00100 Nairobi

Tel (+254)20-2897000, 20-3668000

Fax (+254) 20-3668396

Contact Person Francis Saha

Firm of Experts SGS Kenya Limited

NEMA Reg. No. 0280

Contributors: 1. Lead Expert: NEMA Reg. No.1893

Mr. Isaiah B. Kegora

3. Lead Expert NEMA Reg. No.1710

Mr. Philip Abuor

Contacts Address P.O. Box 72118 00200 Nairobi

Tel +254 020 273 3690

Fax +254 20 2733664

Proponent: Total Kenya Limited

Name of Officer Designation

Signature / Date / Official Stamp

Firm of Experts: SGS Kenya Limited Reg. No. 0280

Mr. Isaiah Kegora:

EIA/EA Lead Expert Reg. No.1893

Mr. Philip Abuor:

Environmental Services Manager, EIA/EA Lead Expert Reg. No.1710

API American Petroleum Institute

ARV Anti Retroviral

dB(A) Decibels on the A-Scale

EHS Environment, Health & Safety

EIA Environment Impact Assessment

EMCA Environmental Management and Coordination Act

ESM Environmentally Sound Management

LPG Liquefied Petroleum Gas

MSDS Material Safety Data Sheet

NEMA National Environment Management Authority

NFPA National Fire Protection Association USA

OSHA Occupational Health and Safety Act

DHP Designated Health Practitioner

HSEQ Health Safety Environment and Quality

Project Cost Estimate

The proposed project includes the:

Safety design, engineering and operation

Baseline Description of the Project Environment

Pollution from waste

Impacts on ambient noise quality

Health and safety impacts

Environmental Management and Impact Mitigation

Air quality management programme

Conclusion and Recommendations

DOCUMENT RELEASE INFORMATION ............................................................................................... 2

DETAILS OF PROPONENT AND FIRM OF EXPERTS ........................................................................ 3

EXECUTIVE SUMMARY ........................................................................................................................ 7

TABLE OF CONTENTS ....................................................................................................................... 13

LIST OF FIGURES ............................................................................................................................... 18

LIST OF TABLES ................................................................................................................................. 18