TO THE PARLIAMENTARY COMMITTEE ON ENVIRONMENT AND NATURAL RESOURCES AND NEMA REGARDING TULLOW WORK IN TURKANA
Madam Chair, I submit the following as MP Turkana County and as an environmentalist. I had raised the same issues to the Committee in January 2015 and the Committee was to summon NEMA and the Ministry to respond.
Madam Chair, given the recent events in Changamwe, where a Metal refinery factory has led to health hazards and deaths of local people resulting from the release of LEAD posion into the environment, I am concerned that if precaution is not taken, the same will happen in Turkana where Oil and Gas activities are taking place.
Issue 1: Environmental audit of Oil and Gas (O&G) facilities in Turkana
After visiting some oil and gas facilities in Turkana County and interacting with the Community Advisory committee members on the ground, I am convinced of the urgent need for conducting a comprehensive Environmental Audit
of all facilities currently in operation in Turkana County.
Let me stress that such an audit must be totally independent, conducted by external experts intimately familiar with the industry, international standards, and accepted "best practices".
I therefore suggest that each O&G facility be audited by a team of experts including O&G environmental and safety experts. A report for each facility should be produced and given to the relevant government bodies including this committee and the Turkana leadership.
- Sewage effluent disposal and disposal of hazardous waste
- Air pollution (given complaints from Lokichar that mornings have become extremely hot around and near the sites, reports of thick smokelsoot in the skies emitted from the facilities)
- Safety of water resources for both pastoralists and livestock
- Safety of pastoralists living around the O&G sites
- Occupational safety and health: Safety of workers (given stories of workers who have been injured and one who collapsed and died – need to know and prevent the causes)
- Check on whether there are Dangerous materials (such as PCBs)on site
A probable pre-audit checklist
- Layout of site with building use and storage areas (including hazardous materials storage areas and waste storage areas) labeled; surface water drainage system; sewage collection and treatment system; all storage tanks and reservoirs; water supply and fire-fighting system;
- Simplified flow diagram of processes undertaken at site
- Building Permit and special conditions (if any)
- Construction Completion Certificate
- Business License and special conditions
- NEMA approval and special conditions
- Previous Environmental Audit
- Agreement with contractor for sewage effluent disposal; Records of waybills for transmission of treated effluent to disposal site;
- Agreement with contractors for solid waste collection and disposal including collection of recycled waste (paper, plastic bottles) and batteries); Records of waybills for transmission of sorted solid wastes to disposal sites;
- Agreement for disposal of hazardous waste; Records of waybills for transmission of hazardous wastes;
- Records of volumes and composition of hazardous waste transported to hazardous waste disposal sites;
- Records of environmental training for employees
- Poisons Permit
- MSDS for all dangerous materials kept on site
- Annual compliance reports with conditions of NEMA (and probably County) License since inception;
- Record of any accidental spills or environmental releases, including: air emissions; storage of dangerous materials; odor or air pollution outside the facility; Records to include date of occurrence, description of release, and response action taken; Report to include date and time of event; date and time event concluded; signature of environmental manager responsible.
- Annual reports on number of hours of operation of diesel generator;
- List volumes of storage tanks; list volumes of bund; and calculate ratio; Highlight any bund that has less storage volume than 110%
Additional Notes for clarity of abbreviations above
MSDS is a Materials Safety Data Sheet
: A material safety data sheet (MSDS), safety data sheet (SDS), or product safety data sheet (PSDS) is an important component of product stewardship and occupational safety and health. It is intended to provide workers and emergency personnel with procedures for handling or working with that substance in a safe manner, and includes information such as physical data (melting point, boiling point, flash point, etc.), toxicity, health effects, first aid, reactivity, storage, disposal, protective equipment, and spill-handling procedures. MSDS formats can vary from source to source within a country depending on national requirements.
PCBs are Poly-chlorinated-biphenyl
: Polychlorinated biphenyls were widely used as dielectric and coolant fluids, for machinery and drilling. Due to PCBs' environmental toxicity and classification as a persistent organic pollutant, PCB production was banned by the United States Congress in 1979 and by the Stockholm Convention on Persistent Organic Pollutants in 2001. According to the U.S. Environmental Protection Agency (EPA), PCBs have been shown to cause cancer in animals and in humans.
To find out from NEMA whether the Strategic Environmental Assessment of the O&G Industry for Kenya, which was to be funded by World Bank has been undertaken. This is related to issue 1 above if implemented. I am interested in how the County can benefit from this assessment.
Issue 3: Tullow issues
- Has Tullow embarked on the Extended Well Tests, which had been planned for?
- Do they have NEMA approval for the EWTs?
- If they have NEMA approval why was the ESIA not posted on NEMA website?
- Could NEMA have been compromised to agree to include the Extended Well Tests under the broad approval Tullow had earlier received for 'Exploration'?