OIL AND GAS UPSTREAM WASTE MANAGEMENT

OIL AND GAS UPSTREAM WASTE MANAGEMENT

OIL AND GAS DRILLING LEGACY WASTE TREATMENT AND DISPOSAL PROJECT

CONTRACT No.: 4700000866

END OF PROJECT REPORT

JANUARY, 2017

Approved and forwarded by: Henry Mukisa Executive Director, WNCL

Reviewed by: JoselineNyakato Project Consultant

Compiled by: Godfrey Oluka Project Manager

SOLID WASTE TREATMENT AND DISPOSAL REPORT, MAY-DECEMBER, 2016

END OF PROJECT REPORT SIGN-OFF

WNCL SIGN-OFF

Name:

Title:

Signed:

Date:

Name:

Title:

Signed:

Date:

Name:

Title:

Signed:

Date:

WASTE TREATMENT AND DISPOSAL END OF PROJECT REPORT,

JANUARY 2017

i

Executive Summary

This report presents an account of the Treatment and Disposal of Legacy

Drilling Waste Project which was implemented by White Nile Consults Limited

(WNCL{ XE "WNCL:White Nile Consults Limited" }) in partnership with TEDA

Landoo Oilfield Services Co. Ltd (TLOSCL), on behalf of Tullow Uganda

Operations Pty Ltd (TUOP{ XE "TUOP:Tullow Uganda Operations Pty Ltd" }),

under Contract Number 4700000866.

The overall aim of the project was to ensure environmentally proper, safe and

cost effective management of legacy drilling waste generated from the oil

and gas exploration activities undertaken by (TUOP). Meeting this aim

required the implementing parties (WNCL and TLOSCL) to safely evacuate

the drilling waste from the Waste Consolidation Area in Kisinja (KWCA),

transfer the waste to its treatment and disposal facility in Hohwa, and

undertake waste management activities aimed at changing the

characteristics of the waste from its hazardous nature to a non-hazardous

state so as to make it safer for disposal.

In implementing the project therefore, WNCL provided services and

undertook activities that entailed transportation of the waste and treatment

and disposal of the waste, while ensuring quality management and socio-

environmental protection through continuous monitoring of the waste

management facility and processes, and management of social and

environmental risks.

The waste transportation process was undertaken over a period of five

months (Sept 2015-Feb 2016), using appropriate leak-proof equipment to

move the liquid, solid and decommissioning waste from the KWCA to the

waste treatment and disposal facility in Hohwa. The transported waste

consisted of:

1,841m3 of liquid waste consisting of drilling fluids;

13,473 tons of solid waste consisting of rock cuttings; and

8,384tons of decommissioning waste consisting of concrete, rubble,

HDPE liners, sisal bags and other materials.

A record of the transported waste was made and kept both at the point of

removal in the KWCA and at the point of receipt in the treatment and


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ii

disposal plant. The waste was received and contained in facilities that were

specially designed with required safeguards for safely containing the

respective streams of waste transported, thereby limiting the migration of the

waste materials and contaminants into the surrounding environment. The

liquid waste was contained in specially built pits while the drilling solid waste

was contained in specially constructed surface bunds where it was covered

with HDPE material so as to protect it from possible impact by weather

elements.

Treatment of the liquid waste was done by flocculation, with the aim of

reducing the amount of solid content in the fluids and obtaining clear liquid

with lower content of heavy metals, which would be safer for re-use in the

facility’s waste treatment operations. As a result of rains falling into the pits,

the quantity of liquid waste treated rose to a total of 1999.37m3and with the

addition of96m3of process water; the total quantity of liquid handled was

2095.37m3.

Of this quantity, 30% was separated as solid sediment, giving 628.5m3 of slurry

and 1466.759m3 of clear treated liquid which was all disposed of by re-use in

the drilling solid waste treatment process. The generated slurry was handled

as and was treated along with the other drilling solids.

Treatment of the drilling solids (rock cuttings and slurry) was done through two

methods namely i) bioremediation and ii) stabilization and solidification.

Similarly, disposal of the treated solid material was done through two routes

involving re-use for making bricks and landfilling in a sealing-type landfill.

Treatment by bioremediation involved the use of naturally occurring

microorganisms to remove organic and heavy-metal contaminants

contained in the solid waste.

A total of 5,403 tons of the solid waste was treated through bioremediation,

making up40.11 % of the total quantity of solid waste transported from waste

consolidation area. The bioremediation treatment process took 73 days

which included 13 days for blending the solid waste with manure and peat

soil; and 60 days of composting on the bio-platform. The bio-degradation

process produced 5,479.6 tons of compost of which 100tons were disposed of

byre-use and solidification in brick-making. In this process, the compost was

mixed with stone dust, cement, and sand in the ratio 3:2:1:1respectively, to

produce 2,060 bricks which were made over a period of 11 days. As guided


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by the regulators, as per the letter of no objection issued by NEMA on 10th

August 2016 in approving the waste treatment and disposal methodologies,

the bricks are to be used only within the facility.

Treatment of the solid waste by stabilization and solidification involved the

use of a binding agent in the form of portland cement to immobilize the

waste material and the contaminants it contained. A total of 14296.9 tons of

solid waste were treated by stabilization and solidification, including 8,917.8

tons that were not put through the bioremediation process and 5,379 tons of

compost that was bio-treated but was not used to make bricks. The solid

material that was treated by stabilization and solidification disposed of by

landfilling. The transition from treatment of the solids by bioremediation to

treatment by stabilization and solidification followed guidance from NEMA

and discussions and subsequent agreement with TUOP to hasten the waste

treatment and disposal process, since bio-treatment and disposal of the

product by brick-making would have taken a much longer period of time to

accomplish than the project time that was available.

The findings obtained from both external and internal laboratory analyses

conducted on both the treated liquid and solid waste materials revealed

significant changes in the physical, chemical and biological characteristics of

the waste, thereby generally indicating successful conversion of the originally

hazardous drilling waste into non-hazardous materials that were safe for

disposal.

To ensure strict observance of and compliance of the project with

requirements for environmental and social safeguards, an effective system

was put in place consisting of a complete set of policies, strategies, plans and

tools for assessing, managing and monitoring environmental and social risks

and impacts, and for monitoring the quality of the processes undertaken

during project implementation.

The cost of implementing the project was USD 5,395,793.38.The major

challenges faced during the project included initial low awareness of local

communities about the nature of the materials that were being handled and

the processes through which this was done, which fuelled fears; huge

demands for employment opportunities which overrode the company’s

capacity to provide job opportunities; stoppages due to suspension of

activities by the client; safety stand-downs imposed by the client and those


JANUARY 2017

iv

caused by weather-related hindrances; and delays in issuance of work orders

by the client.

The opportunities and benefits created by the project for the population of

Uganda on the other hand included the provision of employment

opportunities, development of capacity for working in the oil and gas sector

and creation of awareness and appreciation among various stakeholders of

the fact that oil and gas production and associated activities can be

conducted very safely in the region, without necessarily endangering the

environment and people within the region and elsewhere in the country.

Thus with the successful conclusion of the waste treatment and disposal

activities on 22nd December 2016, the project was declared complete on

schedule, a head of the 31st December 2016 deadline.

WASTE TREATMENT AND DISPOSAL END OF PROJECT REPORT, JANUARY

2017

v

Contents Executive Summary .............................................................................................................................. i

Contents ............................................................................................................................................... v

List of Tables ....................................................................................................................................... viii

List of Figures ........................................................................................................................................ ix

List of Acronyms ................................................................................................................................... x

1.0 INTRODUCTION............................................................................................................................... 1

1.1 Background to the project ......................................................................................... 1

1.2 Aims of the Project ....................................................................................................... 2

1.2.1 Project Objectives.................................................................................................. 3

1.3 Project Milestones ........................................................................................................ 3

1.4 Project KPIs .................................................................................................................... 4

1.5 Project Timeline ............................................................................................................. 4

1.5.1 Project Work Plan ................................................................................................... 4

1.5.2 Key dates................................................................................................................. 4

1.5.3 Time lags .................................................................................................................. 5

1.6 Project Cost ................................................................................................................... 6

1.7 Project stakeholders ..................................................................................................... 6

1.8Project performance evaluation ................................................................................ 7

2.0WASTE HANDLING, TREATMENT AND DISPOSAL ............................................................................ 9

2.1 WASTE TRANSPORTATION ............................................................................................ 9

2.1.1 Activities undertaken during transportation: ..................................................... 9

2.1.2 Types and quantities of waste transported ..................................................... 10

2.1.3 Transportation timeframe ................................................................................... 10

2.1.4Equipment used for waste transportation ......................................................... 11

2.1.5 Reception and containment of the transported waste ................................ 11

2.1.6 Overall Outcomes from waste transportation activities ................................ 13

2.2 Evaluation and monitoring of TUOP legacy waste ............................................... 13

2.2.1 Testing and Monitoring Plan ............................................................................... 13


2017

vi

2.2.2 Analysis of the liquid waste ................................................................................. 14

2.2.3 Analysis of the solid waste .................................................................................. 16

2.3 WASTE TREATMENT AND DISPOSAL ........................................................................... 19

2.3.1 Treatment and Disposal of Decommissioning Waste ..................................... 20

2.3.2 Treatment and Disposal of the Drilling Fluids ................................................... 24

2.3.3Overalloutcomes from liquid waste treatment and disposal ........................ 37

2.3.3Treatment and Disposal of the Drilling Solid Waste ............................................. 38

2.3.3.1 Treatment of the drilling solid waste by Bioremediation ............................. 38

2.3.3.2Treatment of the drilling solid waste by stabilisation and solidification, and

disposal by landfilling .................................................................................................... 53

2.3.4Overalloutcomes from the solid waste treatment and disposal processes 76

2.3.5 Post waste treatment and disposal site restoration activities ....................... 76

3.0MONITORING AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL ASPECTS ................... 79

3.1 Environmental and Social Safeguards implemented during waste treatment

and disposal ...................................................................................................................... 79

3.2The Environment, Health and Safety (EHS) aspect of the project ....................... 79

3.2.1 EHS Strategies implemented during the project ............................................. 79

3.2.2 Record of incidents ............................................................................................. 82

3.1.2 Leading and lagging EHS indicators ................................................................. 84

3.2 The Social Performance of the project ................................................................... 87

3.2.1 Obligations under social performance ............................................................ 87

4.2.2 Meeting the social performance obligations .................................................. 87

3.2.3 Avenues used to ensure continuous community engagement and high

social performance during the project ..................................................................... 88

3.3 The Local Content Aspect of the project .............................................................. 90

3.3.1 Obligations under the local content aspect ................................................... 90

3.3.2Performance of the project in relation to labour requirements .................... 90

3.3.3Performance of the project in relation to the procurement of materials and

services............................................................................................................................ 93

3.3.4 Summary of data related to the local content aspect of the project ....... 94


2017

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3.4 Site monitoring aspect of project implementation .............................................. 95

3.4.1 Environmental and social monitoring ............................................................... 95

3.4.3 Process Monitoring and control ....................................................................... 102

3.4.4 Post treatment and disposal monitoring ........................................................ 104

3.5 Project Human Resources ....................................................................................... 104

3.5.1 Project Team ....................................................................................................... 104

3.6 Demobilisation .......................................................................................................... 104

4.0 CHALLENGES, LESSONS LEARNED AND CONCLUSIONS .......................................................... 106

4.1 Challenges and lessons learned ............................................................................ 106

4.1.1 Challenges .......................................................................................................... 106

4.1.2 Lessons learned and recommendations ........................................................ 108

4.2 Conclusions ............................................................................................................... 109

BIBLIOGRAPHY ................................................................................................................................. 111

APPENDICES ..................................................................................................................................... 112


2017

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List of Tables TABLE 1: PROJECT MILESTONES ......................................................................................................................................3

TABLE 2: KEY DATES IN THE IMPLEMENTATION OF THE PROJECT ...........................................................................................5

TABLE 3: LIST OF THE MAJOR STAKEHOLDERS IN THE PROJECT .............................................................................................7

TABLE 4: VOLUMES OF WASTE TRANSPORTED ................................................................................................................ 10

TABLE 5: WASTE TESTING AND SAMPLING PROGRAM ..................................................................................................... 14

TABLE 6: WASTE WATER CHARACTERISATION AS OF JANUARY 2016 ............................................................................... 15

TABLE 7: ANALYSIS OF SOLID WASTE IN TEMPORARY STORAGE AT WNCL-JAN 2016 ...................................................... 17

TABLE 8: ANALYSIS OF SOLID WASTE CONSOLIDATED AT KWCA .................................................................................... 18

TABLE 9: SUMMARY OF THE MAJOR CHANGES MADE TO THE WASTE TREATMENT AND DISPOSAL PROCESSES ....................... 20

TABLE 10: LIQUID WASTE TREATMENT AND DISPOSAL PROCESS STAGES AND ACTIVITY FRAMEWORK ................................... 25

TABLE 11: DAILY TREATMENT RECORDS ......................................................................................................................... 28

TABLE 12: FIELD BASED ANALYTICAL CHECKS ON TREATED WATER (PIT 2) ....................................................................... 29

TABLE 13: FIELD BASED ANALYTICAL CHECKS ON TREATED WATER (PIT 1) ....................................................................... 30

TABLE 14: TREATED WATER CHARACTERISATION BASED ON EXTERNAL TESTING RESULTS ..................................................... 31

TABLE 15: DAILY TREATED WATER RE-USE RECORDS ....................................................................................................... 33

TABLE 16: SOLIDS GENERATED DAILY DISPOSAL RECORDS .............................................................................................. 33

TABLE 17: BIOREMEDIATION PROCESS STAGES .............................................................................................................. 39

TABLE 18: FEED MATERIALS CONSUMPTION DURING TREATMENT ..................................................................................... 44

TABLE 19: DAILY MIXING/BIO-TREATMENT RECORDS ...................................................................................................... 46

TABLE 20: ANALYSIS RESULTS OF COMPOST BASED ON EXTERNAL LAB TESTS ..................................................................... 47

TABLE 21: DAILY FEED MATERIALS CONSUMPTION DURING COMPOST DISPOSAL .............................................................. 48

TABLE 22: DAILY COMPOST LANDFILLING AND BRICK MAKING RECORDS ........................................................................ 49

TABLE 23: PROCESS STAGES AND ACTIVITY FRAMEWORK ............................................................................................... 62

TABLE 24: DAILY SOLIDIFICATION/STABILISATION RECORDS ............................................................................................ 68

TABLE 25: LANDFILLED MATERIAL EXTERNAL LAB ANALYSIS .............................................................................................. 71

TABLE 26: DAILY LANDFILLING AND RECYCLABLE DISPOSAL RECORDS ............................................................................ 72

TABLE 27: RECORD OF INCIDENTS ................................................................................................................................ 85

TABLE 28: SUMMARY OF EHS STATISTICS ...................................................................................................................... 89

TABLE 29: LOCAL CONTENT MONITORING REPORT FOR THE PROJECT ............................................................................. 98

TABLE 30: WORK PLAN FOR EXTERNAL ENVIRONMENTAL AND SOCIAL MONITORING CONDUCTED BY KAM INTERNATIONAL

....................................................................................................................................................................... 101


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List of Figures

FIGURE 1: WASTE DELIVERY AND CONTAINMENT AT THE TREATMENT AND DISPOSAL FACILITY ............................................ 12

FIGURE 2: TAP PROCESS DEVELOPMENT OBSERVATIONS FROM LABORATORY DE-WATERING EXPERIMENT .......................... 16

FIGURE 3: DECOMMISSIONING WASTE TREATMENT AND RE-USE PROCESS ........................................................................ 21

FIGURE 4: PICTORIAL OF THE TREATMENT AND DISPOSAL OF DECOMMISSIONING WASTE .................................................. 22

FIGURE 5: MAIN EQUIPMENT USED IN THE LIQUID WASTE TREATMENT AND DISPOSAL PROCESS ........................................... 26

FIGURE 6: CHEMICAL STORAGE ................................................................................................................................... 27

FIGURE 7: PICTORIAL OF THE LIQUID WASTE TREATMENT PROCESS ................................................................................... 34

FIGURE 8: CROSS SECTION THROUGH A SELF-CONTAINED BIO-PLATFORM ....................................................................... 42

FIGURE 9: MAIN EQUIPMENT USED IN IMPLEMENTING THE BIOREMEDIATION PROCESS ....................................................... 43

FIGURE 10: MANURE SUPPLY FARM LOCATIONS ............................................................................................................ 45

FIGURE 11: PICTORIAL OF THE BIOREMEDIATION TREATMENT PROCESS ............................................................................ 50

FIGURE 12: CROSS SECTION THROUGH WNCL SEALING TYPE LANDFILL .......................................................................... 56

FIGURE 13: PICTORIAL OF THE LANDFILL DESIGN AND CONSTRUCTION PROCESS .............................................................. 58

FIGURE 14: CONSTRUCTION OF THE LEACHATE COLLECTION CHAMBER AND INSPECTION CHAMBER ................................. 61

FIGURE 15: MAIN EQUIPMENT USED DURING STABILISATION/SOLIDIFICATION ................................................................... 63

FIGURE 16: DELIVERY OF CEMENT TO WNCL STORES .................................................................................................... 64

FIGURE 17: SAMPLE OF CEMENT ISSUING TALLY SHEETS USED DURING TREATMENT ............................................................ 65

FIGURE 18: SAMPLE OF WASTE TRANSFER TALLY SHEETS USED DURING TREATMENT ............................................................ 66

FIGURE 19: SAMPLE OF LANDFILL PH MONITORING REPORT USED ................................................................................... 69

FIGURE 20: SAMPLE OF LAND FILL MOISTURE CONTENT MONITORING REPORT USED ......................................................... 69

FIGURE 21: SAMPLE OF LAND FILL EC MONITORING REPORT USED .................................................................................. 70

FIGURE 22: DAILY RATE OF HARDENING IN THE LANDFILL ................................................................................................ 70

FIGURE 23: PICTORIAL OF THE STABILISATION/SOLIDIFICATION AND LANDFILLING PROCESS .............................................. 73

FIGURE 24: REPAIRING OF THE PERIMETER FENCE ........................................................................................................... 81

FIGURE 25: EHS TRAINING .......................................................................................................................................... 86

FIGURE 26: (LEFT) A STAND DOWN JOINTLY FACILITATED BY TUOP AND WNCL PERSONNEL TO ADDRESS MATTERS RELATED

TO HEALTH AND SAFETY DURING WORK. (RIGHT) AN OPERATIONS AND EHS MEETING BEING HELD WITH ALL STAFF ..... 87

FIGURE 27: COMMUNITY ENGAGEMENT THROUGH COMMUNITY MEETINGS .................................................................... 93

FIGURE 28: MAIN SOURCES OF LABOUR USED IN THE PROJECT ....................................................................................... 95

FIGURE 29: LABOUR DISTRIBUTION BY ROLE DURING TREATMENT ..................................................................................... 96

FIGURE 30: LABOUR DISTRIBUTION BY GENDER DURING WASTE TREATMENT AND DISPOSAL OPERATIONS ............................. 96

FIGURE 31: SOURCES OF MATERIALS USED DURING PROJECT IMPLEMENTATION ............................................................... 97

FIGURE 32: REGULATORY AND COMPLIANCE MONITORING OF THE FACILITY AND PROCESSES ........................................ 102


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FIGURE 33: MONITORING OF THE FACILITY AND OPERATIONS BY TUOP ........................................................................ 103

FIGURE 34: EXPERIMENTS CONDUCTED IN THE INTERNAL LAB TO MONITOR AND GUIDE CONTROL OF WASTE TREATMENT

ACTIVITIES ......................................................................................................................................................... 106

FIGURE 35: WNCL LAB PERSONNEL TAKING SOIL SAMPLES FROM AREAS AROUND THE FACILITY ..................................... 107

FIGURE 36: PROJECT STAFFING STRUCTURE ................................................................................................................. 109

List of Acronyms

Acronym Meaning

BOD Biological Oxygen Demand

COD Chemical Oxygen Demand

CSR Corporate Social Responsibility

DWRM Directorate of Water Resources Management

EC Electrical Conductivity

EHS Environment, Health and Safety

EIA Environment Impact Assessment

EMMP Environment Management and Monitoring Plans

ESIA Environment and Social Impact Assessment

KPI Key Performance Indicator

KWCA

WCA

Kisinja Waste Consolidation Area

Waste Consolidation Area

GNL Global Network Limited

NEMA National Environment Management Authority

NPA National Planning Authority

PEPD Petroleum Exploration and Production Department

PPE Personal Protective Equipment

QEHS Quality, Environment, Health and Safety

SOCA Safety Observations and Corrective Actions

SS

(S/S)

Stabilisation-Solidification


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TLOSCL TEDA Landoo Oilfield Services Co. Ltd

TUOP Tullow Uganda Operations Pty Limited

UK WAC United Kingdom Waste Acceptance Criteria

WNCL White Nile Company Limited


JANUARY 2017

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1.0 INTRODUCTION

This report presents an overview of the oil and gas drilling waste treatment

and disposal project implemented by White Nile Consults Ltd (WNCL) and

TEDA Landoo Oilfield Services Co. Ltd (TLOSCL) on behalf of Tullow Uganda

Operations Pty Ltd (TUOP). The report commences with background

information which provides brief facts that are essential to understanding the

project, before detailing the activities, processes and technologies which

were applied in delivering on the general service areas of the handling;

transportation; treatment and disposal of the legacy waste; and monitoring

of the site and its activities, as well as the management of associated

environmental and social risks throughout the life of the project. The report

majorly provides a factual account of the activities that were undertaken in

implementing the project, with only brief and basic descriptions of the

scientific and theoretical bases. The detailed descriptions and analyses of the

scientific and theoretical bases underlying the processes that were

implemented were presented in respective Technical Action Plans which

were submitted to and approved by both TUOP and regulators (NEMA). It is

therefore recommended the report is read alongside and with reference to

the appended Technical Action Plans (Appendix R- Item 1).

1.1 Background to the project White Nile Consults Limited is a legitimate local company which to maintains

a keen focus on valuing the customer, observing statutory requirements of

laws and regulations, and offering systematic waste management solutions

that match the waste management hierarchy.

WNCL owns a 159-acre piece of land in Hohwa village, Kaseeta Sub County,

Hoima district. Of this, 11 acres were approved by NEMA for the construction

a drilling waste treatment and disposal facility. The company is thus validly

licensed to own and operate a drilling waste management facility under

License No.: WD/HW/036/2016 (and earlier WD/HW/074/2015).

The facility provides services to oil companies with regard to treatment,

recovery and disposal of drilling mud, drilling cuttings, drilling waste water,

and other oil field drilling waste.


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The facility is capable of adopting different technologies and equipment in

suit the handling of a given quantity and type of drilling waste, of both

hazardous and non-hazardous nature. The facility’s primary focus is on

prioritizing the recovery of resources from what would be waste and their

subsequent re-use and recycling, thereby considering disposal only as a last

resort.

In the context of the facility’s operations, drilling waste treatment refers to

changing the physical and chemical characteristics of drilling waste to make

it non-hazardous or decreasing the quantity of generated harmful waste or

decreasing or eliminating the hazardous substances. Drilling waste disposal

on the other hand refers to the laying of the drilling waste in a place that

meets internationally recognized requirements of environmental protection.

The objective of treatment and disposal technology is to minimize the harm

of drilling waste to human health and environment.

WNCL entered into a partnership with TLOSCL to go through a competitive

bidding process through a contract was acquired to undertake a project to

treat and dispose of legacy waste generated from oil and gas exploration

drilling activities conducted by TUOP in Block EA-2 South. In this partnership,

WNCL was the lead project implementer, while TLOSCL supported

technology transfer to WNCL by providing and installing equipment for the

treatment of the fluids, and- based on their vast experience and expertise in

the oil and gas sector, training the local (Ugandan) WNCL personnel to

operate the equipment and conduct waste treatment activities.

The treatment and disposal of all of the said waste has been successfully

completed through processes that are detailed in the second section of this

report.

1.2 Aims of the Project The overall aim of the project was to ensure the cost effective, efficiency and

timely management of legacy oil and gas drilling waste in a manner that

prevented or controlled risk to natural and social systems.


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1.2.1 Project Objectives

The objectives of the project were to:

i) Remove and safely transport all drilling waste from the WCA in Kisinjato

the waste treatment and disposal facility in Hohwa.

ii) Treat and dispose of 100% of the received waste by 31st December

2016.

All of the project objectives have been met. A full account of the ways in

which the project objectives were achieved is presented in the “Waste

Handling, Treatment and Disposal” section of the report.

1.3 Project Milestones The contractual milestones for the project were as presented in Table 1.All of

the milestones were reached during project implementation.

Table 1: Project Milestones

Milestones Comments

Acquisition of NEMA License to

Own/Operate Drilling Waste

Treatment and Disposal Facility

The 2015/16 license (License No.:

WD/HW/074/2015) was acquired on

4th June 2015 and renewed for the

2016/17 period on 4th October

2016(License No.: WD/HW/036/2016)

Drilling waste treatment and disposal

facility fully functional and ready to

perform work as stated in the scope

of work.

The readiness of the facility to receive

the waste was verified on 24th July

2015 by a team from TUOP, over a

month before commencement of

performance of the contract. A

commitment was made to ready the

facility for contract execution within 3

months.

Completion of waste removal from

Kisinja WCA

All waste including decommissioning

waste was removed from within the

WCA in Kisinja by 22ndDec 2015 a

head of the deadline of 31st Dec

2015.

Note: however, the waste removal

period extended to 2nd Feb 2016

following identification and


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agreement with TUOP that the

decommissioning waste outside the

WCA should also be moved.

Completion of Waste Treatment and

Disposal

Waste treatment was successfully

completed on 13thDecember 2016

and landfill capping completed on

22nd December 2016.

End of Project Report submitted Submission of this report is in fulfillment

of this milestone

1.4 Project KPIs The Key Performance Indicators for the project were as presented in

Appendix A.

1.5 Project Timeline

1.5.1 Project Work Plan

A copy of the project work plan is presented in Appendix B.

1.5.2 Key dates

The key dates in relation to the execution of the core business of the project

are presented in Table 2.

Table 2: Key dates in the implementation of the project


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Activity Start date End date

Waste Transportation 19thSeptember 2015 2ndFebruary 2016

Treatment of liquid waste 15th August 2016 2nd September 2016

Disposal of treated liquid

(re-use in treatment of the

solids )

4th September 2016

8th September 2016

Treatment of solid waste

1. Treatment by

bioremediation

2. Treatment by

stabilization-

solidification

4th September 2016

15th November 2016

17th November 2016

22nd December 2016

Disposal of treated solids

1. Disposal of

stabilized-solidified

solids by landfilling

2. Disposal of bio-

treated solids by

reuse to make

bricks

15th November 2016

4th December 2016

10th December 2016

16th December 2016

1.5.3 Time lags

A number of lags in project time were recorded, which led to delays in the

execution of project activities. These were mainly caused by:

i) Suspension of the project imposed by the client over the period

between 3rd June 2016 and 14th July 2016, as detailed in section 4.0

of this report on “Challenges, Lessons Learned and Conclusions”.

ii) Safety stand-downs

Two safety stand-downs were recorded during the transportation phase of

the project, the first one occurring as result of an incident caused a third

party (another contractor of TUOP’s) which prompted TUOP to halt WNCL’s

operations as well for the period between 17th and 23rd November 2015; and

the second stand-down occurring in the period between 15th and 17th

November 2015 as a result of occurrence of a spill on the site following heavy

rains.


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iii) Hindrances created by weather conditions.

These were halts to work that were recorded during transportation and

treatment and disposal activities which occurred in the rainy seasons dueto a

weather related spill in October –November 2015, and difficulties imposed on

the mobility of equipment in and around the waste treatment areas of the

facility in October –November 2016.

1.6 Project Cost The cost of implementing the project was as presented in the summary

below:

Work stream Expenditure (USD)

Mobilisation and demobilisation 128,400.00

Transportation of waste 1,327,731.18

Waste treatment and disposal 3, 939,662.20

Total 5,395,793.38

The detailed project cost report is laid out in Appendix C.

1.7 Project stakeholders The major stakeholders for the project were as listed in Table 3.


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Table 3: List of the major stakeholders in the project

Party Role

WNCL and TLOSCL Project implementers

TUOP Client (project originator)

monitoring

Local communities Project affected party

beneficiaries

NEMA Lead agency; Licenser; Regulator

PEPD Lead agency

Hoima District Local Government

(district authorities, Sub County

authorities, Local Council 1 authorities)

Lead agency; regulators

Contractors Commodity and service providers

Pollution control committee Assessments for licensing; monitoring

Ministerial committee on environment

and natural resources (consisting of

various agencies under the Ministry of

Water and Environment )

monitoring

UWA Monitoring for potential impact on the

game reserve located near the waste

management facility

1.8Project performance evaluation With a view to ensuring that to ensuring that project efforts delivered the

required outcomes and met the performance standards and to facilitate

improvement in the contract, the project was evaluated through two

contract performance reviews conducted by TUOP on 8th June 2016 and 2nd

November 2016. These mainly focused on the performance of the project in

the technical and operational; EHS; commercial; Local Content; compliance;

and social performance aspects. Copies of the contract performance review

reports are contained in Appendix R (Item 2).


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8

Continual evaluation of the project was also done based on a Performance

Improvement Plan (PIP) that was developed following the suspension of the

project (see Appendix R- Item 3). The performance of the project in relation

to the PIP was evaluated on a monthly basis.


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9

2.0WASTE HANDLING, TREATMENT AND DISPOSAL

2.1 WASTE TRANSPORTATION The first area of service provided by WNCL was the handling and

transportation of solid and liquid waste from TUOP WCA in Kisinja, to the

treatment and disposal facility in Hohwa.

In compliance with the regulatory requirement for the drilling waste to be

transported by a separate NEMA-licensed entity, the aspect of transferring

the waste from the TUOP’s waste consolidation area to WNCL’s facility was

subcontracted to Global Networks Limited (GNL), a transport and logistics

company which was licensed by NEMA to transport hazardous materials.

Details of the transportation processes and rates are presented in the End of

Transportation report attached in Appendix R (Item 4).

2.1.1 Activities undertaken during transportation:

The activities undertaken during the waste transportation phase of the

project were:

a) Removal of solid and liquid waste from the bunds and pits in which

they were stored at Kisinja. This involved uncovering the pits to remove

the waste from the pits using specialized equipment and uncovering

and removal of the waste contained in the bunds.

b) Movement of the waste from the waste consolidation area to the

treatment and disposal facility in Hohwa. The waste was loaded onto

specialized equipment which was used to transfer the liquid and solid

waste from the consolidation areas to the waste treatment and

disposal site.

c) Decommissioning of waste pits and bunds through the removal of all

unnatural materials from the pits after all the waste had been removed

and transported to the treatment and disposal facility.

d) Removal of decommissioning waste from decommissioned waste pits

and Social Investment activities by TUOP in the Kaiso-Tonya area. The

decommissioning waste was transferred from the consolidation areas

for treatment and disposal at WNCL’s facility in Hohwa.


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10

All these activities were accomplished safely, without any spillage, accidents

or other kind of incidents.

2.1.2 Types and quantities of waste transported

The types of waste moved during the transportation phase of the project

comprised of 3 categories of materials, namely

(i) drilling fluids from Water Based Mud;

(ii) solids/rock cuttings mixed with Water Based Mud; and

(iii) decommissioning waste consisting of concrete, rubble, HDPE, sisal

bags, among other materials.

In compliance with regulatory and contractual requirements, the quantities

of waste handled were recorded and reported using a type of Waste Transfer

Notes that was agreed upon between WNCL and TUOP, and both at the

point of removal from the WCA and at the point of receipt at the treatment

and disposal facility. The total volumes of waste that were transported from

the WCAs to the treatment and disposal site were recorded as indicated in

Table 4.

Table 4: Volumes of waste transported

Type of waste Total Quantity/Volume transported

Liquid waste 1,841m3

Solid waste 13,473 tons

Decommissioning waste 8,384tons

2.1.3 Transportation timeframe

Overall, the transportation phase of the project took a period of

approximately 5.5 months, starting in September 2015 and ending in Feb

2016. The initial timeframe agreed under the contract set a deadline of 31st

December 2015 by which removal of all waste contained in the WCA was to

be completed. This requirement was met ahead of schedule when

transportation of all the waste from the WCA was concluded on

22ndDecember 2015. However, the waste removal period was extended to

2nd Feb 2016 following identification and agreement with TUOP that the

decommissioning waste outside the WCA also needed be moved.


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11

Transportation of liquid waste was completed within 1 month(13th Nov -20th

Dec 2015), while the transportation of solid waste was done over a period of

3 months (19th Sept- 16th Dec 2015), while decommissioning waste was

transported over a period of 1.5 months (17th December 2015 – 2nd Feb 2016).

Refer to the “End of Transportation Report” in Appendix R (Item 4) for the

transportation rates.

2.1.4Equipment used for waste transportation

Drilling fluids

Liquid waste was removed from the pits in Kisinja, transported, delivered and

offloaded into pits in WNCL’s facility using vacuum trucks. 2 vacuum trucks

were used, each with a capacity of 30m³.

Solids

The solid waste, which comprised of drilling mud and cuttings and

decommissioning waste, was delivered using leak proof dumper trucks with

modified tail gates. 11 dumping trucks were deployed, each with a capacity

20 metric tons. However, as a safeguard, each truck was loaded with only

16metric tons of waste per trip.

The other equipment used included 2 excavators, 140-metric ton mobile

weighbridge, 1 sludge pump, 2 escort pickups equipped with mobile spill

response equipment, and 1 service van.

The key human resources used during the waste transportation process

included: 1 EHS supervisor, 1 Site Fleet In-charge, 11 drivers, 8 casual

labourers, 2 security personnel, and 1 Site Mechanic among others.

2.1.5 Reception and containment of the transported waste

Upon arrival at the waste treatment and disposal facility, the

quantities/volumes of waste received were determined and recorded before

the waste was offloaded for containment in pits and bunds. The liquid waste

was received and contained in two double lined open pits which were built

with concrete that had HDPE liner beneath, with capacity to hold (1,035m3)

each. The pits were both barricaded with reptile fences.

The solid waste was received and contained in facilities comprising of two

above-ground, bunds and one concrete pit. The bunds were built out of

earth placed on a layer ofdouble liner containing HDPE membranes (1.00mm


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12

thick). The solid waste that was contained on the bunds was covered with

HDPE membranes so as to prevent its exposure to adverse environmental

conditions and/or minimise potential risks to human health, environment,

safety, and property. The areas around both the pit and the bunds were well

contained with a drainage system leading and ending in to a retention pit.

During the 8 months for which the waste was contained at the facility, both

the liquid and solid waste materials were regularly sampled and monitored to

assess for any changes in the physical, chemical and biological

characteristics of the waste that could have occurred with time, as a result of

exposure to prevailing environmental conditions namely direct sunshine,

heavy rains, strong winds and temperature. These conditions could cause

turbulent mixing of the liquid waste or various spontaneous biochemical

reactions in the solid waste, and could thereby alter the properties of the

respective waste streams.

The characteristics of the liquid waste were periodically monitored against

the National Environment (Standards for Discharge of Effluent into Water or

on Land) Regulations (1999) as required in the scope of work, while that of

the solid waste was monitored against the UK, Waste Acceptance Criteria

(UK WAC) and Uganda’s standards and regulations (1999).

Figure 1: Waste delivery and containment at the treatment and disposal

facility

Liquid Waste delivery Waste water contained in HDPE lined open

pits


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13

Delivery of drilling solid waste

Mud cuttings contained and covered in

bunds

2.1.6 Overall Outcomes from waste transportation activities

A total of 1,841m3 of liquid waste, 13,743tons of solid waste and 8,384 tons of

decommissioning waste were successfully moved from the WCA in Kisinja to

the waste treatment and disposal plant in Hohwa where it was safely

contained. A total of over 33,000kms were covered by the transportation

equipment without any spillages, accidents or other forms of incidents.

2.2 Evaluation and monitoring of TUOP legacy waste

2.2.1 Testing and Monitoring Plan

Upon completion of the transportation and receipt of the waste at the

treatment and disposal facility during the period for which the waste was

temporarily contained, it was imperative for WNCL to undertake analyses

and constant monitoring on all of the streams of the waste received, so as to

ascertain the characteristics of the waste as at the time of receipt, and

hence be able to be design appropriate methods for the treatment and

disposal of the waste. Consequently, a schedule for sampling,

analysing/testing, and monitoring the characteristics of the waste was

developed and implemented as indicated in Table 5.


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14

Table 5: Waste Testing and sampling program

S/N ANALYSIS

FRAMEWORK QUALITY CHECKS DONE STATUS REMARKS

Liq

uid

wa

ste

Pre-treatment

Waste water was analysed prior to

treatment, for all contaminant levels

as required by the regulator and the

client. Initial concentrations were

established and characterisation of

waste water was made.

CLOSED

Waste water

characterisation guided

treatment process

During treatment

At this point ,physical parameters such

as pH, color ,turbidity and chemical

characteristic such as Chlorides were

monitored

CLOSED

Determination of

physical properties

guided the chemical

dosing rates

Post Treatment

After treatment, the sample was taken

to external lab for analysis and

parameters for effluent discharge as

per NEMA scope of work were

analysed.

CLOSED

Post treatment analysis

ascertained readiness of

waste water for

discharge/re-use

So

lid

wa

ste

Pre-treatment

Solid waste was analysed prior to

treatment while at KCWA and also

upon delivery to WNCL facility, for all

contaminant levels as required by the

regulator and the client. Initial

concentrations were determined.

CLOSED

Solid waste

characterisation guided

treatment and disposal

processes

During treatment

Physical parameters were monitored

which included PH, EC, Temperature,

and moisture content

(bioremediation) and EC, MC, and

pH(Solidification/stabilisation)on a

daily basis

CLOSED

Monitoring and

troubleshooting guided

the treatment and

disposal processes

Post Treatment

Treated samples were submitted to

an external laboratory for analysis and

parameters for disposal as per NEMA

scope of work and UK WAC were

analysed and compared to these

standards

CLOSED

Post treatment analysis

ascertained readiness of

treated waste for

disposal

2.2.2 Analysis of the liquid waste

An initial analysis of the liquid waste was conducted and the parameters of

concern identified as: Zn, SO42-

, Cd, COD, BOD, and Benzene. These

parameters were identified as parameters of concern because the

laboratory tests indicated their concentrations to be above the limits as

prescribed by national regulations. The findings were as indicated in Table 6.


JANUARY 2017

15

Table 6: Waste water characterisation as of January 2016

S/N PARAMETERS UNIT NEMA STATUS PIT 1 STATUS PIT 2 STATUS

ORGANIC CONSTITUENTS ANALYSIS

1 1,1,1,trichloroethane mg/l 3 TESTED 1.22 PASSED 1 PASSED

2 1,1,2 trichloroethane mg/l 0.2 TESTED trace PASSED trace PASSED

3 1,1,2,trichloroethene mg/l 1.06 TESTED trace PASSED trace PASSED

4 1,3 dichloropropene mg/l 0.2 TESTED trace PASSED trace PASSED

5 Benzene mg/l 0.2 TESTED 2.33 Fail

6 Dichloromethane mg/l 0.2 TESTED 0.11 PASSED 0.09 PASSED

7 Tetrachloroethylene mg/l 0.1 TESTED trace PASSED trace PASSED

8 Tetrachloro

methane mg/l 0.02 TESTED trace PASSED trace PASSED

9 Trichloro ethylene mg/l 0.3 TESTED trace PASSED trace PASSED

10 1,2-Dichloroethane mg/l 0.04 TESTED trace PASSED trace PASSED

INORGANIC CONSTITUENTS ANALYSIS

1 Lead mg/l 0.1 TESTED 0 PASSED 0 PASSED

2 Aluminium mg/l 0.5 TESTED 0 PASSED 0 PASSED

3 SulpHate mg/l 500 TESTED 312.5 PASSED 564.2 Fail

4 Arsenic mg/l 0.2 TESTED 0.012 PASSED 0.03 PASSED

5 Cadmium mg/l 0.1 TESTED 0.04 PASSED 0.15 Fail

6 Iron mg/l 10 TESTED 12.9 Fail 8.1 PASSED

7 Silver mg/l 0.5 TESTED 0.08 PASSED 0.16 PASSED

8 Zinc mg/l 5 TESTED 45.6 Fail 22.3 Fail

9 Chromium (total) mg/l 1 TESTED 0.34 PASSED 0.52 PASSED

10 Nitrogen total mg/l 10 TESTED 113 Fail 102.5 Fail

PHYSICAL PROPERTIES

1 pH mg/l 6.0-

8.0 TESTED 9.5 Fail 9 Fail

2 BOD 5 mg/l 50 TESTED 396 Fail 512 Fail

3 COD mg/l 100 TESTED 1900 Fail 2100 Fail

4 TSS mg/l 100 TESTED 0.62 Pass 3.65 PASSED

5 E. Conductivity µScm-

1

- TESTED 12000 -

16000 -

These findings guided the design of the drilling fluids treatment and disposal

methods and processes, which focused on a de-watering based process and

re-use respectively, as laid out in the Technical Action Plan (TAP) presented

on Appendix R (Item 1).

Comments: The parameters that did not meet the discharge standards were considered

contaminants of concern.


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16

Figure 2: TAP process development observations from laboratory de-watering

experiment

2.2.3 Analysis of the solid waste

Laboratory analyses were done on the solid waste material to assess the

physical/chemical characteristics of the waste in order to obtain a guiding

basis for the selection of the most effective and efficient treatment and

disposal technology to be used (See Table 7: analysis of TUOP solid waste

from WNC containments in relation to waste consolidated at KWCA in Table

8)


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17

Table 7: Analysis of solid waste in temporary storage at WNCL-Jan 2016

Comments:

Whereas the concentrations most of the contaminants were within accepted disposal levels, the

concentrations of some contaminants were high enough to be of public concern, thereby necessitating

the proper treatment and disposal of the solid waste.


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18

Table 8: Analysis of solid waste consolidated at KWCA


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19

2.3 WASTE TREATMENT AND DISPOSAL The processes that were implemented in treating and disposing of the drilling

fluids and solid waste streams were all based on technical action plans,

which detailed the methods that were used, and that were approved by

both TUOP and NEMA prior to implementation. The methods that were

adopted ensured that the waste was all treated and disposed of in ways that

complied with TUOP’s policies and existing local and international regulatory

requirements. Where changes to the methods or constituent processes were

made, proper steps were taken to ensure the proper management of the

change processes, as presented in the Management of Change Forms which

are attached to this report as Appendix N.

Table 9: Summary of the major changes made to the waste treatment and

disposal processes

Activity/Process Change(s) made

Treatment of fluids Change of solid-liquid phase separation

from separation by centrifuge to

separation by sedimentation

Treatment and disposal of solids 1. change from treatment of the

solids by bio-remediation to

treatment by stabilization and

solidification

2. change from mixing of the solids

with cement in Pit 5 to mixing on

Bunds 1 and 2 and on a platform

adjacent to

(See Appendix N for details)


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20

2.3.1 Treatment and Disposal of Decommissioning Waste

2.3.1.1 Decommissioning waste treatment process

The stages and processes through which the decommissioning waste was

treated are summarized in the process diagram displayed on Figure 3.

Figure 3: Decommissioning waste treatment and re-use process

Upon delivery of the decommissioning waste to the facility, the

decommissioning waste was weighed on a weighbridge so as to confirm the

volume of the waste received and create an auditable chain of custody

documentation. The decommissioning waste was then put through toxicity

tests which were conducted in the onsite laboratory. A sample of the

decommissioning waste was also taken to the external laboratory for quality

analyses. Both tests and analyses conducted in the internal (on-site) and

external laboratories found the decommissioning waste to be non-hazardous

(See toxicity test report in Appendix R- Item 5).

Because the decommissioning waste was mixed with other waste materials

like wood, metal and pieces of poly-liner when it was delivered to the facility,

and in compliance with national waste management regulatory

requirements, it was inevitable for it to be segregated. The segregation was

done manually since the decommissioning waste was non-hazardous.

Toxicity

tests


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21

Appropriate and adequate PPE was provided to all persons who were

involved in the segregation.

2.3.1.2 Disposal of decommissioning waste by re-use

Given that the decommissioning waste was non-hazardous and based on

the waste management hierarchy, a decision was made to re-use all of the

decommissioning waste within the facility. The decommissioning waste was

thus re-used in the following ways:

Reuse in the construction of the foundation of the Bio-platform and retention

pit

A portion of the segregated decommissioning waste was used to fill and level

a foundation pad to an approximate height 1.6 metres, to provide a firm

base for the bio-platform that was used to contain solid waste during

biodegradation. This would ordinarily have required over 10,000tons of

murram to backfill and level. The decommissioning waste was picked with the

aid of an excavator and then crushed and compacted using a roller. A thin

layer (1.5mm) of murram was then applied to create a smooth surface for the

Bio-platform. In A similar way, a portion of the decommissioning waste was

used in the construction of the foundation of the storm water retention pit.

Reuse in the construction of drainage channels

The other portion of the segregated decommissioning waste was crushed

using a pneumatic hammer to create stone dust. Using a mixer, the stone

dust was mixed with stone aggregates and cement in ratios of 3:4:1

respectively, to make concrete that was used in the construction of drainage

channels in the facility.

Figure 4: Pictorial of the treatment and disposal of decommissioning waste

The well prepared area on which the decommissioning waste was received and temporarily

contained during segregation


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22

Segregation of the decommissioning waste prior to disposal by re-use

Decommissioning waste being moved for re-use in the bioremediation area

Decommissioning waste re-used in leveling the bio-remediation platform and in the retention

pit


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23

Drainage channels constructed out of re-used decommissioningwaste

2.3.1.3 Overall outcomes from the treatment and disposal of decommissioning

waste

8,384 tons of decommissioning waste were successfully segregated and

safely re-used within the facility.

The re-use of the decommissioning waste in the construction of the bio-

platform, retention pit and drainage channels in the facility significantly

reduced the facility’s demand for murram and sand, which thereby reduced

the need to extract these resources from the environment, hence

contributing to the minimisation of the alteration and possible degradation of

the natural environment from the creation or expansion of borrow areas and

sand mines.


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24

2.3.2 Treatment and Disposal of the Drilling Fluids

2.3.2.1 Liquid waste treatment process

The stages and processes through which the liquid waste was treated are

summarized in Table 10.

Table 10: Liquid waste treatment and disposal process stages and activity

framework

STAGE PROCESSES REMARKS

CHEMICAL DOSING

Prepared chemical working solutions in

the mixing tanks; Filled chemical

dosing tanks with solution;

SOPs were in place

Pumped waste water from the pit at

an established rate to the chemical

dosing unit; Dosed CAL, PAC, and

PAM in that order and in appropriate

proportions to the waste

Sufficient mixing was

obtained by well-established

dosing rates

SEDIMENTATION

Pumped the flocculating liquid from

the chemical dosing unit to an empty

HDPE lined pit; allowed the gel to

sediment for about 2 days

Faster settling of the gel was

achieved

SUPERNATANT RE-USE Pumped supernatant (clear liquid) at

an established rate to mixing

platform(Pit 5) for re-use in

biodegradation

Settled liquid was not

discharged

DISPOSAL OF SOLID

RESIDUES

Blended the settled mud in the

sedimentation pit with manure and

peat soil; transferred the composite to

bio-platform for bioremediation

Process generated

biodegradable flocs

MONITORING TREATED

LIQUID

CHARACTERISTICS

Performed field based and external

analytical checks on filtered liquid

Chemical dosing rate was

based on trial runs

2.3.2.2Equipment used in the liquid waste treatment process

Liquid waste treatment was done using a chemical-enhanced dewatering

equipment comprising: main inlet pumping unit, chemical mixing unit,

chemical dosing unit, and centrifugal units. The equipment was

commissioned on 22/06/2016; after thorough inspection, maintenance and

testing by competent technicians from the two partner companies namely

TLOSCL and WNCL. The electrical installation and inspection was done by a

competent electrical engineer. The source of electrical power was an

installed 135 KVA diesel generator.


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25

Figure 5: Main equipment used in the liquid waste treatment and disposal

process

De-watering equipment

Vacuum pumps used to pump slurry to Pit 5

where it was consolidated with other solid

waste

Field based spectroquant photometer used for

laboratory analysis to support process

monitoring and quality management

procedures

2.3.2.3Chemicals used in liquid waste treatment

Liquid waste treatment involved the use of inorganic and organic flocculants

to disintegrate the chemical phase of waste water, thereby facilitating solid-

liquid phase separation of the waste. Polyaluminium chloride (PAC; 3.85 Tons)

was used to flocculate inorganic pollutants while Polyacrylamide (PAM; 0.1

tons) was used to flocculate organic pollutants contained in the liquid waste.

Calcium chloride (CAL 3.85 Tons) was used as a gel breaker, to improve


JANUARY 2017

26

solubility of chemicals. Chemical working solutions (96m3) were prepared in

the chemical mixing tanks in the dewatering unit using rain water (free from

chemical impurities), before being dosed into the liquid waste. Pit 4 was used

partly as a rain water reservoir pit before the water was pumped into a tank

(10m3) that was installed on a raised platform with a gentle slope so as to

provide a gravitational flow of water to the chemical mixing tanks. 10% w/v

PAC, 10% w/v CAL, and 0.5% w/v PAM working solutions were prepared

during treatment.

The choice of the chemicals (flocculants and gel breaker used) was directly

based on the characteristics of TUOP liquid waste as found from the initial

laboratory analysis which were conducted upon receipt of the waste at the

WNCL facility.

The decision to use an inorganic flocculant [PolyaluminiumChloride; general

formula: AlnCl(3n-m)(OH)m] was based on the fact that the liquid waste

contained ions of inorganic elements (Cu, Cr, Mn, Ag, Ni, Fe, Zn, and As)

whose salts and hydroxides required to be precipitated by ion exchange for

which PAC found to be very effective. The use of organic flocculant (PAM)

was necessitated by the presence of trace organic compounds

(1,1,1trichloroethane; trichloroethane; tetrachloroethane; 1,1,2

trichloromethane; 1,3 dichloromethane; 1,3 dichloropropene; 1,2

dichloroethane; 1,4 dichloroethane; BTEX; and PAHs), which required to be

flocculated by steric hindrance for which PAM was found to be very

effective.

Figure 6: Chemical storage

Chemical storage area


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27

2.3.2.4Quantity of Liquid Waste Treated

The entire treatment process took 13 days using two feed pumps: P101

(12.6m3/hr) and P103 (17m3/hr). The pumps were operated for a total of

143.05 hours at an average feed pump rate of 13.93m3/hr (min: 12.6m3/hr,

max 16.2m3/hr) to deliver 1999.37m3 of waste water. The volume of liquid

waste that was treated (1999.37m3) was higher than the volume that was

initially received from TUOP (1,841m3). The additional volume (158.37m3) of

waste water treated was generated on site during storage. Rain water

added about 80% more waste volumes and the rest was leachate pumped

from solid waste in Pit 5.

Table 11: Daily treatment records

DAY

PUMP

OPERATING

HOURS

FEED

FLOW

RATE

(m3/hr)

TOTAL

WASTE

TREATED(m3)

CUMMULATIVE

VOL

TREATED(m3)

% VOL

TREATED

CUMMULATIVE

% VOL

TREATED

1 6 12.6 75.6 75.6 4.1065 4.1065

2 6 16 96 171.6 5.2146 9.3210

3 8 12.6 100.8 272.4 5.4753 14.7963

4 13 12.6 163.8 436.2 8.8973 23.6936

5 13.25 12.6 166.95 603.15 9.0684 32.7621

6 13.5 12.6 170.1 773.25 9.2395 42.0016

7 9.75 12.6 122.85 896.1 6.6730 48.6746

8 8.15 16 130.4 1026.5 7.0831 55.7577

9 13.1 12.6 165.06 1191.56 8.9658 64.7235

10 14.5 16.2 234.9 1426.46 12.7594 77.4829

11 14.5 16.1 233.45 1659.91 12.6806 90.1635

12 13.3 16.2 215.46 1875.37 11.7034 101.8669

13 10 12.4 124 1999.37 6.7355 108.6024

TOTAL 143.05 13.930769 1999.37 1999.37 108.60 108.6024

2.3.2.5 Monitoring of the treated water

As a quality management measure taken at the time of liquid waste

treatment, field-based laboratory analyses of the treated waste water were

performed on a daily basis, at time intervals of two hours (see Table 12 and


JANUARY 2017

28

Table 13). A spectroquant photometer was used to guide the chemical

dosing process and thus chemical dosing rates were constantly adjusted to

those that yielded faster flocculation and settling of flocculants. The

parameters that were monitored included: color, pH, turbidity, and chlorides.

At the end of the liquid waste treatment process, a sample of the treated

liquid was submitted to an external laboratory to test for all the parameters as

scheduled in the National Environment (Standards for Discharge of Effluent

into Water or on Land) Regulations (1999)and in accordance with the

contractual scope of work (See Appendix E: external laboratory test

certificate; reproduced on Table 14)

Table 12: Field based analytical checks on treated water (PIT 2)

DAY Parameter Unit TEST METHOD Detection

limit

Acceptable

limit Result Comment

pH N/A GTM 24 0.05 6 to 8 6.5 Pass

1 Chlorides mg/L 114897 10 500 344 Pass

Turbidity FAU EN ISO 7027 1 300 70 Pass

Colour pt/Co APHA 2120B 25 300 1070 Fail

pH N/A GTM 24 0.05 6 to 8 7.4 Pass




pH N/A GTM 24 0.05 6 to 8 7.1 Pass




pH mg/L GTM 24 0.05 6 to 8 6.8 Pass




pH N/A EN ISO 7027 0.05 6 to 8 7 Pass






Turbidity mg/L EN ISO 7027 1 300 50 Pass




Turbidity mg/L EN ISO 7027 1 300 122 Pass

Colour mg/L APHA 2120B 25 300 1782 Fail


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Table 13: Field based analytical checks on treated water (PIT 1)

DAY Parameter Unit TEST

METHOD

Detection

limit

NEMA

standard Result Comments

pH N/A GTM 24 0.05 6 to 8 6.9 Pass


Turbidity FAU EN ISO

7027 1 300 80 Pass

Colour pt/Co APHA

2120B 25 300 1070 Fail

pH N/A GTM 24 0.05 6 to 8 7.4 Pass



7027 1 300 200 Pass

Colour pt/Co APHA

2120B 25 300 2620 Fail

3 pH N/A GTM 24 0.05 6 to 8 6.8 Pass

Chlorides mg/L 114897 10 500 492 Pass


7027 1 300 60 Pass

Colour pt/Co APHA

2120B 25 300 840 Fail

4 pH mg/L GTM 24 0.05 6 to 8 7.6 Pass



7027 1 300 38 Pass

5 Colour pt/Co APHA

2120B 25 300 720 Fail

pH N/A EN ISO

7027 0.05 6 to 8 6.8 Pass



7027 1 300 69 Pass

6 Colour pt/Co APHA

2120B 25 300 1340 Fail



7 Turbidity mg/L EN ISO

7027 1 300 96 Pass

Colour pt/Co APHA

2120B 25 300 1274 Fail


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Table 14: Treated water characterisation based on external testing results

DATE OF TESTING 21/09/2016

S/N PARAMETERS UNIT NEMA UNFILTERED STATUS

ORGANIC CONSTITUENTS ANALYSIS

1 1,1,1,trichloroethane mg/l 3 0.09 PASS

2 1,1,2 trichloroethane mg/l 0.2 0.05 PASS

3 1,1,2,trichloroethane mg/l 1.06 nil PASS

4 1,3 dichloropropene mg/l 0.2 nil PASS

5 Benzene mg/l 0.2 0.11 PASS

6 Dichloromethane mg/l 0.2 nil PASS

7 Tetrachloroethylene mg/l 0.1 nil PASS

8 Tetrachloro methane mg/l 0.02 nil PASS

9 Trichloro ethylene mg/l 0.3 0.11 PASS

10 1,2-Dichloroethane mg/l 0.04 0.15 PASS

11 0il and grease mg/l 10 1.01 PASS

12 Phenols mg/l 0.2 nil PASS

INORGANIC CONSTITUENTS ANALYSIS

1 Lead mg/l 0.1 0.05 PASS

2 Aluminium mg/l 0.5 0.39 PASS

3 SulpHate mg/l 500 440 PASS

4 Arsenic mg/l 0.2 0.02 PASS

5 Cadmium mg/l 0.1 0.01 PASS

6 Iron mg/l 10 1.22 PASS

7 Silver mg/l 0.5 0.01 PASS

8 Zinc mg/l 5 0.201 PASS

9 Chromium (total) mg/l 1 0.251 PASS

10 Nitrogen total mg/l 10 1.32 PASS

11 Cyanide mg/l 0.1 0.08 PASS

12 Selenium mg/l 1 0.044 PASS

13 Chloride mg/l 500 450 PASS

14 Ammonium nitrogen mg/l 10 0.05 PASS

15 Barium mg/l 10 3.22 PASS

16 Boron mg/l 5 0.003 PASS

17 Calcium mg/l 100 4.21 PASS

18 Nickel mg/l 1 0.11 PASS

19 Chromium (VI) mg/l 0.05 0.02 PASS

20 Magnesium mg/l 100 0.99 PASS

21 Nitrite N (Total) mg/l 20 0.22 PASS

22 Copper mg/l 1 0.21 PASS

23 PHospHate soluble mg/l 10 5.9 PASS

24 PHospHate total mg/l 10 11.2 FAIL

25 Mercury mg/l 0.1 <0.03 PASS

26 Cobalt mg/l - 0 PASS

27 Tin mg/l 5 0.11 PASS

28 Detergents mg/l 10 0.55 PASS


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PHYSICAL PROPERTIES

1 pH mg/l 6.0-8.0 6.6 PASS

2 BOD 5 mg/l 50 123 FAIL

3 COD mg/l 100 650 FAIL

4 Total Suspended Solids mg/l 100 10.2 PASS

6 Temperature ◦C 20C to 35C 25 PASS

7 Colour pt-co units 300 600 FAIL

8 Turbidity NTU 300 29 PASS

9 Total dissolved carbon mg/l - 6.2

9 Total dissolved solids mg/l 1200 911 PASS Comments:

The unfiltered liquid was re-used in mud cuttings for mixing

Clarity of treated waste water from both pits was not of high concern as it was intended for

re-use in bioremediation of mud cuttings

2.3.2.6 Disposal/Re-use of treated waste water and solids generated

2.3.2.6.1 Quantities of treated material generated

Total volume of treated liquid and solids generated was 2095.37m3 after

treatment. This comprised treated liquid (1999.37m3) and process water

(96m3). 30% were solids generated (628.5m3) (in form of slurry) and 70%

(1466.759m3) comprised the liquid phase. The generated solids and the

supernatant water were intended for re-use in bioremediation of mud

cuttings.

2.3.2.6.2Re-use of supernatant water

Supernatant water was re-used in bioremediation of mud cuttings to provide

the moisture content (50-60%) which was required for microbial activities. An

electrical pump (12.6m3/hr.) was used on first day to transfer supernatant

water, however, to meet the bioremediation process water requirement of at

least 300m3/day, a fuel pump (capacity 1m3/min) was used to transfer the

supernatant (1466.759 m3) for 4 days. The total re-use time was 28 operating

hours at an average re-use rate of 50.52m3/hr (min 12.6, max 60 m3/hr).


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Table 15: Daily treated water re-use records

DAY

PUMP

OPERATING

HOURS

PUMP RATE

(m3/hr)

VOL RE-USED

(m3)

CUMM VOL

RE-USED (m3) % RE-USED

CUMM % RE-

USED

1 4 12.6 50.4 50.4 2.40530312 2.40530312

2 7 60 420 470.4 20.0441926 22.4494957

3 7 60 420 890.4 20.0441926 42.4936884

4 7 60 420 1310.4 20.0441926 62.5378811

5 3 60 180 1490.4 8.59036828 71.1282494

TOT 28 50.52 1490.4 1490.4 71.12824943 71.12824943

2.3.2.6.3Disposal of generated solids

Flocs (611m3) settled at the bottom of the sedimentation pits. The slurry was

mixed with peat soil (14m3) to lower its fluidity. The composite material(625m3)

was transferred in two days to the mixing platform using a vacuum pump at a

rate of 50m3/hr. The total disposal time was 12.5 operating hours.

Table 16: Solids generated daily disposal records

DAY DISPOSAL

TIME(HR.) PUMP

RATE(m3/HR.) VOL

DISPOSED(m3)

CUMM

VOL

DISPOSED %DISPOSED

%CUMM

DISPOSED

1 7 50 350 350 16.70349389 16.70349389

2 6 50 300 650 14.31728048 31.02077437

TOTAL 13 100 650 650 31.02077437 31.02077437

2.3.2.7 Cleaning of pits

The liquid waste treatment and disposal process ended with the cleaning out

of the pits that were used for receiving and containing the liquid waste (Pit 1

and Pit 2) and the pits that were used to sediment and temporarily store the

treated water (Pit 3 and Pit 4). The cleaning process involved the removal of

all waste material from the pits, removal of liners and accessories like reptile

fences. Cleaning activities also included removal and clearance of all

equipment and materials that were used during the treatment process from

the liquid waste treatment area.


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Figure 7: Pictorial of the liquid waste treatment process

1. Mixing of chemicals to be used in treating the liquid waste

WNCL technicians mixing chemicals to be introduced into the waste to facilitate the flocculation process which

was implemented for treating the drilling liquid waste. The chemicals were mixed to concentrations that had been

predetermined through laboratory tests to be optimum for achieving optimum flocculation of solids from the liquid

waste.

2. Dosing of chemicals into the liquid waste

WNCL technicians operating the dosing the units of the de-watering plant which were used to introduce the

flocculants into the liquid waste. The technicians filled the dosing tanks with premixed chemicals and adjusted the

tanks’ valves to regulate the rates of dosing as/when guided by findings from laboratory monitoring analyses.


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3. Process monitoring for safeguards and quality assurance and management

Left: Laboratory experiments/analysis conducted on the sampled liquid that had been dosed with flocculants.

Right: Joint inspection of the process by TUOP field staff and WNCL facility managers. These routine activities

together formed the process monitoring procedures which were meant to verify that the liquid treatment process

was implemented as required, that the process was as effective as desired, and that the relevant safeguards were

implemented.

4. Sedimentation of the flocculant-dosed liquid waste

Left and centre: Liquid waste dosed with flocculant chemicals being pumped into sedimentation pits after

undergoing treatment with flocculants in the dosing units of the de-watering plant. Right: the liquid waste left to

sediment in the pit; in this process, precipitated and suspended and coagulated solids settled at the bottom of the

pit, leaving a clearer liquid at the surface.


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5. Removal and transfer of the clear treated liquid from sedimentation pit to Pit 5 for re-use

Left: pipes drawing the treated waste water from the sedimentation pit. Centre: A pump and piping used to transfer

the treated waste water to for re-use in Pit 5. Right: A pipe pouring the treated waste water into Pit 5 in which mixing

of solid waste with feed materials was done. A total of 1466.759 m3 of supernatant water was obtained and pumped

into Pit 5 for re-use.

6. Re-use of the treated liquid

Treated waste water being re-used in Pit 5 for the mixing of solid waste with feed materials


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7. Removal and transfer of generated solid sediment (slurry) from the sedimentation pits to Pit 5

where it was consolidated with other drilling solid waste materials

Left: sediment (in form of slurry) left in the pit after removal of the supernatant waste water. Center: a pipe drawing

the slurry from the pit during its transfer to Pit 5 to be consolidated with other solid waste. Right: A pipe pouring the

slurry into Pit 5 where it was consolidated and treated along with the drilling mud and cuttings.

8. Cleaning up of the pits

Pits that were used for containing and sedimenting liquid waste being cleaned after the removal of treated water

and slurry. Cleaning of the pits involved the removal of all materials from the within and out of the pits, including

poly-liners and reptile fences. This activity marked the end of the liquid waste treatment and disposal process.

Left: TUOP and WNCL personnel jointly observing pit-clean out activities to ensure the required safeguards were

implemented during the process. Right: A cleaned out pit awaiting rehabilitation during post-project activities. The

pits will be rehabilitated for use in the facility’s future operations.


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2.3.3Overalloutcomes from liquid waste treatment and disposal

All of the liquid waste that was transported to WNCL facility was successfully

treated and re-used in bioremediation of mud cuttings. TUOP and WNCL EHS

policies were followed, and social performance and local content

obligations were observed.

Based on the results of the laboratory analyses performed on the treated

liquid by the external laboratory (See Table 14), all, except four parameters

namely Phosphate (total), BOD5, COD and colour, were found to meet the

specified discharge/disposal requirement as per the national standards for

discharge of effluent or waste water, stipulated in the National Environment

(Standards for Discharge of Effluent into Water or on Land) Regulations (1999).

The treatment process had thus been effective in changing the physical,

chemical and biological characteristics of the liquid to make it non-

hazardous and safe for disposal. The slightly above-limit content of

Phosphate(total), BOD5, COD and colour (in relation to the national

effluent/wastewater discharge standards) was not of major concern since

the treated liquid would neither be discharged into to the open environment

nor significantly inhibit the treatment processes of the drilling solid waste, in

which the treated liquid was re-used.

The re-use of the treated water in the bioremediation process significantly

reduced the facility’s demand for water at the time of blending the drilling

solid waste with feed materials as it provided a significant portion of the

water that was needed for the process. This consequently reduced to need

for the facility to abstract water from ground and surface sources, thereby

helping to minimise the potential impact that the offset water abstraction

activities would have impacted on the quantity and quality of ground and

surface water at the points from which the water would have been

abstracted.


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2.3.3Treatment and Disposal of the Drilling Solid Waste The treatment and disposal of the solids was accomplished in the period

between 4th September 2016 and 22ndDecember 2016. During this time, two

sets of methods of treatment and disposal of the solids were implemented,

beginning with treatment by bioremediation, followed by treatment through

stabilization and solidification. The change in methods from bio-treatment to

stabilization/solidification was necessitated by guidance of the regulators

and in agreement with TUOP on the need to hasten the completion of the

project. The change in methods of treatment inevitably caused change in

method of disposal from disposal by re-use to disposal by landfilling. The

change in methods was managed as per the Management of Change

plan/form presented in Appendix N.

2.3.3.1 Treatment of the drilling solid waste by Bioremediation

2.3.3.1.1 Bioremediation process description and quality control

Table 17 provides a summary of the major steps and activities that were

undertaken and materials that were used to effectively implement the

bioremediation process.

Table 17: Bioremediation process stages


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39

The bioremediation process involved the use of naturally occurring

microorganisms contained in manure (poultry manure and cow dung), which

require organic carbon as a source of energy for their cell tissue formation,

and the chelating capacity of peat soil (peat soil has a high cationic

exchange capacity) to treat solid waste that was contained in Pit 5 (5,403

tons).In this process the microorganisms feed on and assimilate the organic

carbon and as well capture heavy metals contained in the waste material

within their cell structures, thereby creating a stable end product comprised

of constituent inorganic and organic species which would be in inert state

and would be less toxic, thus producing compost material which would be

suitable for safe disposal. The mechanism of the process is summarized in the

following equation:

Organic fraction + O2 + nutrients + microbe → new cells + resistant organic matter +CO2 +H20 +NH3

+SO42- + heat

The design and implementation of the bioremediation process was guided

by findings from a successful experimental laboratory trial model which was

set up to: establish the presence of microorganisms in the manure; establish

the waste-feed material mixing ratios; establish compost sampling and

monitoring regimes; and establish rate of contaminant disappearance and

compost holding time on bio-platforms. A sample of the material that was

bio-treated in the lab model trial was submitted to the external laboratory for

post-treatment analysis of contaminant levels in relation to UK WAC and

national standards (See Appendix F for the lab model report; refer to Table 5

in the report for test results of bio-model compost sample).

During solid waste treatment process, the solid waste was blended with

manure and peat soil in the ratios of 9 (solid waste): 3 (manure): 1(peat soil)

to form a composite that was allowed to undergo composting on Bio-

platform 1for 60 days, counted from the last day of loading the composite

onto the platform. These ratios and the bioremediation time of 60 days were

determined as being optimum for achieving full and effective treatment of

the solid waste by bioremediation. The excavator bucket was used as the

unit of measurement during the mixing of the waste with feed materials.

The implementation of the bioremediation process required the construction

of platforms on which the composite would be loaded for the period of 60

days to decompose. Four bio-platforms were constructed, although only one

platform Bio-platform 1, with dimensions of 80mX30m, was used to hold the


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40

portion of the solid waste that was treated by bioremediation over a period

of 60 days. The bio-platform was designed as a self-contained system that

allowed for management of runoff, leachate and air supply and hence

facilitated the monitoring and management of the optimum conditions

required to implement an effective bioremediation process (see Figure 8).

2.3.3.1.2 Equipment used during the implementation of bioremediation

process

Main equipment used during the implementation of the bioremediation

process included: 1 excavator for scooping waste from the pit, mixing and

loading composite waste onto trucks; and 25-ton trucks (02) and 5-ton trucks

(02) were used to transfer blended waste to Bio-platform 1. Other tools used

included hoes, spades and an onsite fuel tank. In order to meet air supply

requirements, a compressor (14-18 bars) was used.


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Figure 8: Cross section through a self-contained bio-platform


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42

Figure 9: Main equipment used in implementing the bioremediation process

2.3.3.1.3 Feed materials used and their sources

Main process materials used in bioremediation include: Manure (2125.2 tons),

peat soil (750.3 tons) and fertilisers (60kg). Water (2108.7 m3) was added to

improve on the moisture content of the blend and saw dust (775Kg) was lined

on top of the air supply pipes to prevent clogging of the air vents by the

biodegrading material. Manure was sourced from farms located in Ibanda,

Kampala, Mukono, Buikwe, and Hoima (See Figure 10). Treated wastewater

and storm water collected in the retention pit was used as process water.

Excavators

Dumper trucks

Air compressor


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43

Peat soil was excavated from the surveyed area within WNCL facility. The

quantities of the feed materials used and the rates at which they are

consumed are summarized in Table 18.

Table 18: Feed materials consumption during treatment

DAY MANURE(tons) PEAT SOIL(tons) SAW

DUST(Kg)

FERTILISER(Kg) WATER(m3)

1 11.1 2.1 50 0 3.3

2 18.1 5.1 50 0 5.4

3 37.8 7.7 50 0 0

4 31.8 13.4 50 0 0

5 31.8 11 50 0 0

6 22.7 9 50 0 0

7 160 52 50 0 300

8 160 52 50 0 300

9 330 119 75 12 550

10 330 119 75 12 300

11 330 120 75 12 350

12 332 120 75 12 300

13 330 120 75 12 0

TOTAL 2125.2 750.3 775 60 2108.7

Comments

Manure: Peat soil: Solid waste basis ratio = 3:1:9 respectively

Fertilisers were added to improve C/N ratio of manure

Water was added to improve moisture content of very dry solid waste


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Figure 10: Manure supply farm locations


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45

2.3.3.1.4Timeline and quantity of waste treated by bioremediation

The entire treatment process took a total of 73 days. These included 13 days

of mixing and 60 days of composting on the bio-platform (counted from the

last day of loading the waste onto the platform).

During the mixing period, the specific weight of solid waste (1.512ton/m3) was

established in a series of analytical weighting experiments and a standard

capacity of the caterpillar excavator bucket (1m3) was used as a basis for

the establishment of the treated waste quantities. Average daily waste

buckets scooped were 274.9 (274.9m3) and this amounted to an average of

415.7 tons of waste mixed per day. The rates at which the waste was mixed

with feed materials are summarized in Table 19.A total of 3574 waste buckets

(3574m3) were scooped from the pit, amounting to 5403.888 tons of waste

treated through bioremediation (See Appendix G: Establishment of the basis

bulk density of the solid waste).

Table 19: Daily mixing/bio-treatment records DAY WASTE

BUCKETS

SP.WT(TON/m3) WASTE

MIXED

(TONS)

CUMM WASTE

MIXED(TONS)

%

MIXED

CUMM %

MIXED

1 22.0 1.512 33.3 33.3 0.247 0.247

2 36.0 1.512 54.4 87.7 0.404 0.651

3 55.0 1.512 83.2 170.9 0.617 1.268

4 75.0 1.512 113.4 284.3 0.842 2.110

5 63.0 1.512 95.3 379.5 0.707 2.817

6 45.0 1.512 68.0 447.6 0.505 3.322

7 298.0 1.512 450.6 898.1 3.340 6.662

8 298.0 1.512 450.6 1348.7 3.340 10.002

9 298.0 1.512 450.6 1799.3 3.340 13.342

10 596.0 1.512 901.2 2700.4 6.687 20.029

11 596.0 1.512 901.2 3601.6 6.687 26.716

12 596.0 1.512 901.2 4502.7 6.687 33.403

13 596.0 1.512 901.2 5403.9 6.687 40.09

TOTAL 3574 5403.9 40.090

MEAN 274.9 1.512 415.7 3.084 Comments

Each waste bucket = 1m3

Waste buckets X specific weight = Waste mixed (tons)

% mixed is out of 13,473 tons of solid waste

Total % mixed is 40.09%

2.3.3.1.5 Monitoring of optimum conditions on bio-platforms and analytical

checks

The following optimum conditions were monitored throughout the

composting period (60 days)to ensure conditions were always good to


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46

support microbial life: EC, pH, MC and temperature and these were kept

within the following ranges: pH (6-9), Moisture content (30-40%), and

temperature (30-400c). During monitoring, the diagonal sampling technique

(data obtained following a diagonal line) and composite sampling

technique (data obtained from different points) were used. A total of 13

different pieces of data were picked at different times of the day and

averaged on a daily basis. An analysis of these results was done to establish

the progress of the process (See Appendix F: Bio-platform monitoring report).

After the composting period (60 days), a compost sample was picked and

submitted to an external laboratory for analysis to ascertain the readiness of

the compost for disposal (See Table 20and Appendix H).

Table 20: Analysis results of compost based on external lab tests

S/N PARAMETERS UNIT UK- WAC BIOPLATFORM COMMENT

1 Arsenic mg/Kg 2.11-6.92 <0.01 PASS

2 Barium mg/Kg 100 3.2 PASS

3 Cadmium mg/Kg 1 0 PASS

4 Chromium mg/Kg 10 0 PASS

5 Copper mg/Kg 50 10 PASS

6 Mercury mg/Kg 0.2 <0.002 PASS

7 Molybdenum mg/Kg 10 0 PASS

8 Nickel mg/Kg 10 2 PASS

9 Lead mg/Kg 10 2.8 PASS

10 Antimony mg/Kg 0.7 0 PASS

11 Selenium mg/Kg 0.5 0 PASS

12 Zinc mg/Kg 50 0 PASS

13 Sulphate mg/Kg 20000 198.2 PASS

14 Chloride mg/Kg 15000 131 PASS

15 Fluoride mg/Kg 150 9 PASS

ORGANIC CONSTITUENTS

1 Phenols mg/Kg 1 Trace PASS

2 Total organic

carbon(w/w)

g/100g 5%BTEX 6-L29B 1.63 PASS

3 Dissolved organic

carbon at own pH

mg/Kg 800 2.33 PASS

4 Hydro carbon mg/Kg 500 IFC Trace PASS

PHYSICAL CONSTITUENTS

1 pH 6-8 7.4 PASS

2 TDS mg/Kg 60000 265 PASS Comments

Compost was analysed for all parameters as stipulated in the contractual Scope of

Work and compared to UK WAC (BS12457) standards (Appendix I).

The compost was found to meet disposal standards.

Heavy metal concentrations were found to have reduced considerably (over 60% in

relation to the standard).


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The levels of organic contaminants detected were negligible in relation to the

required standards.

2.3.3.1.6Disposal of compost and non-biodegradable material

The total quantity of material that composted on the bio-platform was 7,828

tons. This included manure (23%), peat soil (7.6%) and biodegradable mud

cuttings (69. 23%).There was a mass reduction (by 30%) of the biodegradable

material after bioremediation, leaving a total of 5,479.6 tons of compost as

the quantity that was available for disposal. 100 tons (1.8%) of this compost

was re-used in making bricks (2,060bricks) that were meant for construction of

embankments around the liquid waste containment pits. The dimensions of

the bricks were 400mm X 200mm X 200mm. The brick mortar was prepared

using compost, cement, stone dust, and sand which were mixed in the ratio

of 3:1:2:1respectively.The bricks were made using a manual brick-making

machine. The other portion (98.2% = 5,379.6 tons) of the compost was further

stabilised and solidified with 268tons (5% w/w) of cement and disposed of by

landfilling in the facility’s sealing type landfill, at an average rate of

909.8tons/day, over a period of 6 days. Additional solid waste material

treated was generated from cleanup activities that were done on the bio-

platform after the removal of the compost.

Table 21: Daily feed materials consumption during compost disposal

DAY CEMENT

USED IN

LANDFILLING

(TONS)

CEMENT

USED IN

BRICKS

(TONS)

STONE DUST

ADDED(TONS)

SAND

ADDED(TONS)

1 52.8 0.805 1.61 0.81

2 40.0 1.9 3.83 1.92

3 42.5 1.76 3.53 1.76

4 40.0 0.51 1.01 0.51

5 56.3 0.77 1.5 0.77

6 41.4 1.92 3.8 1.92

7

8

9

10

11

1.92

1.92

1.92

1.91

0.51

3.8

3.8

3.8

3.8

1.0

1.92

1.92

1.92

1.91

0.51

TOTAL 273.0 15.9 31.7 15.9

Comments

Cement used in landfilling was 5% (w/w).

The ratio used in mixing compost, cement, stone dust and sand materials during brick-

making was 3:1:2:1 respectively.


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48

Approximately 5.4 tons of non-biodegradable materials consisting of small

pieces of liners, stones, and pieces of jumbo bags were segregated from the

compost upon sorting. The segregated stones were used in the construction

of drainage channels around the bio-platforms while the plastic materials

(liners and pieces of compactor bags) were packed in containers and

transported for disposal by destruction at Luwero Industries Limited in

Nakasongola district.

Table 22: Daily compost landfilling and brick making records DAY COMPOST

LANDFILLED

(TONS)

CUMM

LANDFILLED

%

LANDFILLED

%CUMM

LANDFILLED

BRICKS

MADE

CUMM

BRICKS

MADE

%

BRICKS

MADE

%

CUMM

BRICKS

MADE

1 1056 1056 19.6 19.6 105 105 5.25 5.25

2 800 1856 14.9 34.5 250 355 12.5 17.75

3 850 2706 15.8 50.3 230 585 11.5 29.25

4 800 3506 14.9 65.2 66 651 3.3 32.55

5 1126 4632 20.9 86.1 100 751 5.0 37.55

6 827 5459 15.4 101.5 250 1001 12.5 50.05

7 250 1251 12.5 62.55

8 250 1501 12.5 75.05

9 250 1751 12.5 87.55

10 249 2000 12.45 100

11 60 2060 3.3 103.3

TOT

AL

5459 101.5 2066 103.3

Comments

percentage of compost landfilled was calculated out of 5379.6 tons of compost

The percentage of bricks made was determined out of approximately 2000 bricks

Figure 11: Pictorial of the bioremediation treatment process


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49

1. Delivery of feed materials to the mixing area

Left: Manure being delivered to the mixing point. Right: Peat soil at the mixing point. The manure

and peat soil were used to introduce microbes needed to degrade the organic components of

the solid waste and to immobilize heavy metals in cell structures. The peat soil was further required

to improve porosity and ion exchange during the decomposition processes.

2. Blending of the solid waste with feed materials (manure and peat soil)

The blending process involved the mixing of

the drilling cuttings with manure and peat soil,

in the ratio of 9 (solid waste): 3 (manure):

1(peat soil), in the presence of water, to form a

composite that was composted on the bio-

platform. About 5,403tons of the solid waste

(approx. 40.11 % of the total volume of solid

waste transported from Kisinja WCA) were

treated through this method.


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3. Transfer of composite to the bio-platform

Left:composite being loaded onto a truck for transfer to the bio-platform. Right: a truck loading the

composite onto the bio-platform.

4. Composting of the mixed material

Left and Centre: The composite consisting of drilling mud and cuttings left to compost on Bio-platform

1 for 60 days. The bio-platform was design with trenches and a sump for proper mangment of

leachate and runoff.Right: water collected in the sumpt being pumped to Pit 5 for use in the mixing of

solid waste with manure and peat soil.

5. Monitoring and management of the optimum conditions


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Left: A WNCL Lab Technician taking readings of the parameters of pH, temperature, moisture content

and electrical conductivity of the composting material. Monitoring of these parameters was done

daily, over the entire composting period of 60 days, with parameter readings being taken several

times each day. The parameters were used as indicators of the performance of the bioremediation

process and so parameter readings were used to guide the regulation of the conditions of the

composite. Right: an air compressor being used to pump air through the composting material so as to

improve oxygen levels in the composite.

6. Disposal of bio-treated compost by re-use for brick-making

Left and center: Bricks being made from the bio-treated compost. Right: Some of the bricks that were

made out of the compost. Only 100tons (1.8%) of the 5479.6 tons of bio-treated compost from bio-

platform that was available for disposal were used to make the 2,060 bricks that were made. The

bricks were made by mixing the bio-treated compost with stone dust, cement, and sand in the ratio of

3:2:1:1respectively. The bricks will be used within the facility, in the construction of embankments on

the pits.


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52

7. Disposal of bio-treated compost by landfilling

Top Left: bio-treated compost being loaded onto a truck for transfer from the bio-platform to Pit 5. Top

Right: cement being added onto the bio-treated compost to provide further stabilization and

solidification. Bottom Left: The bio-treated compost being mixed with cement. Bottom Right: Stabilised

bio-treated compost being loaded onto a truck for transfer to the landfill. The remaining 5,379 tons

(98.2%) of the bio-treated compost which was not used for making bricks was disposed of through this

method.


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2.3.3.2Treatment of the drilling solid waste by stabilisation and

solidification, and disposal by landfilling

The implementation of these methods of treatment and disposal of drilling

solid waste required the installation of a landfill facility, which was done as

presented below:

2.3.3.2.1 Design and construction of the landfill

The actual design drawings as developed by a registered architect and duly

approved by Hoima District Local Government authorities are attached in

Appendix R (Item 6).

WASTE TREATMENT AND DISPOSAL END OF PROJECT REPORT, JANUARY 2017

54

Figure 12: Cross section through WNCL sealing type landfill


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55

Key landfill design features and safeguards: Feature Specs/Safeguards

Dimensions:

56m x 45mx4.5m

Capacity: 11, 340m3

Volume of landfilled material: 9341.28 m3 (14, 233 tons)

Excess volume: 1998.72 m3(provided to accommodate thick lining and to

provide for additional material from cleanup

activities)

Stable geology: Safely located in a place which has no fault lines

Designed for ecological

protection

•Safely located away from vulnerable or sensitive ecosystems

•Bedrock at the base provides a vital safety feature protecting

the water table

•Base safely above the water board

Designed for Low leachate

generation and effective

leachate containment and

management:

•Thick, multi-layered lining at the base and cap (consisting of

thick layers of clay and murram, geo-membrane liner, HDPE

liner);

•impermeable lining (double poly-lining) on all sidewalls

•perimeter drains;

•landfill cell compaction;

•slopes, and

•re-vegetation.

These features function to: isolate waste and prevent migration

of the waste/leachate into the surroundings; prevent run-on of

precipitation over the landfill, minimize the daily exposed

working face, and reduce infiltration of rainfall.

A 3-degree slope towards the leachate point serves to

facilitate leachate collection.

Designed for easy monitoring Monitoring facilities provided in form of leachate

collection/monitoring chamber and inspection chambers.


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Figure 13: Pictorial of the landfill design and construction process

1. Geophysical study of the site for suitable landfill location

Experts from Living Systems Engineering and Technology (LSET) Ltd conducting geophysical assessments at the

landfill site. The assessments guided the choice of suitable location for the landfill.

2. Excavation of the landfill

Equipment consisting of excavators and bulldozer digging the rocky ground to create a pit for the landfill

A hard-rock bed at the base of the landing providing an additional natural/ecological protective feature for the

landfill


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3. Lining of the landfill

Application of murram to blind the rocks, and leveling of the landfill base prior to lining

Application of black soil to provide cushion for polythene lining materials, preventing damage to the materials

from stones contained in the murram which had been applied to blind the bed rocks.

Geo-membrane liner laid over the entire landfill (base and embankments) to provide primary protection of the

surroundings from any leaching


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Application of lining consisting of a layer of clay placed over the geo-membrane liner

Left: HDPE liner placed over the clay and geo-membrane lining. Right: Laying of the final layer of lining consisting

of layer of clay placed over the HDPE liner. Completion of this layer rendered the landfill ready for use


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Figure 14: Construction of the leachate collection chamber and inspection

chamber


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2.3.3.2.2Stabilisation and solidification process description and quality control

The stages and processes followed during treatment of the solid waste by

stabilization and solidification are summarized in Table 23.

Table 23: Process stages and activity framework

STAGES PROCESSES REMARKS

SUPPLY PROCESS WATER Pumped water (1.8m3/day)

to the mixing platform

Moisture content of

the waste was

above 4%. Also the

rains left the waste

sufficiently wet so this

negated the need to

add more water.

MIX FEED MATERIALS

(20:1)

(CEMENT)

Supplied feed materials

around mixing point; Used

excavator to scoop 596

buckets of waste (901tons);

Pre-segregated waste;

Added 45.05 tons of cement.

Used excavator to mix

Contaminants in solid

waste were stabilized

and encapsulated

DISPOSING CURED MATERIAL

IN THE LANDFILL

Delivered the solidifying

material on trucks to the

landfill area; Used an

excavator/backhoe

stationed in the landfill to

offload, piled, and

compacted solidifying waste

Spread and

compacting

solidifying waste

enhanced the

setting process

FINAL LANDFILL COVER Added draining layer (DPC)

on the waste; added and

graded a deep subsoil layer

(2ft thick); added black soil

(2ft) topmost layer

Black soil facilitated

re-vegetation of the

closed landfill

The stabilisation and solidification process was founded on the principle of

micro-capsulation in which the solid waste (8,069 tons) was mixed with

Portland cement to form a good fast-setting hydration product which formed

a solidified mass of material with a high structural integrity that could be

safely disposed of by landfilling and safely contained in the landfill for a long

time. The design of the stabilization-solidification process that was

implemented for treating the solid waste was guided by results obtained from

a laboratory trial experiment which was set up to establish the most optimum

and appropriate cement binding proportion that yielded a good hydration

product in a highly efficient and cost effective way. The laboratory trial

tested the following proportions: 4%, 5%, 6% and 7% cement. The solidifying

product in each batch was left in containers and the parameters of EC, MC


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and pH were monitored for five days to establish their conditions in relation to

the rate of strengthening/stabilization. After the 5 days of monitoring, samples

of the solidified material were submitted to the external laboratory for

leachability analyses. All of the cement proportions experimented yielded

good hydration products, with a sufficient degree of contaminant stability.

However, the proportion of 5% cement was selected for application during

the actual treatments it was deemed to be the most cost effective

proportion for delivering the best possible hydration product at the most

reasonable cost(See Appendix J: solidification/stabilization model report).

During the treatment process, a batch of solid waste was scooped from the

bunds, segregated and mixed with cement (5%). The product of hydration

was then disposed of in the landfill. The segregation and mixing were

conducted on the bunds, on a platform adjacent to the bunds and in Pit 5.As

a safeguard, the top layers of soil in the bunds and adjacent area were

scooped out during cleanup activities, treated by stabilization and

solidification, and disposed of by landfilling.

2.3.3.2.3 Equipment used during solidification/stabilisation

The main equipment used included: Excavator (02) for scooping,

segregating, and loading solidifying waste; backhoe (01) for spreading

solidifying waste in the landfill; and 25 ton trucks (06) for transferring solidifying

waste to the landfill. The other tools used included hoes, spades, and wheel

barrows. The tools used in sampling/monitoring were Soil MC Tester, Soil EC

Tester.

Figure 15: Main equipment used during stabilisation/solidification

Excavators on site

Backhoe onsite


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2.3.3.2.4The feed materials used and their sources

The main process material used in stabilisation/solidification was Portland

cement (403 tons). This was supplied by Kampala Cement Company Limited

and received by WNCL stores. The cement was stored in containers (40ft). As

a safeguard, removal of cement from storage was done in such a way that

only the required quantity for a particular batch of waste was issued during

the waste treatment process. Water (1.8m3) was added only when the

moisture content of the waste was insufficient to effect setting of the cement.

Figure 16: Delivery of cement to WNCL stores

Trucks on site


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Figure 17: Sample of Cement issuing tally sheets used during treatment

2.3.3.2.5 Quantities of waste treated through solidification/stabilization

The bulk density of the solid waste, which was determined to be 1.512m3/ton,

and the excavator-bucket’s capacity of 1m3 were used as a basis for the

establishment of the quantities treated (See Appendix G: Establishment of a

basis bulk density of the solid waste).Tally sheets were used to record the

quantities of waste scooped from the containments (See figure 18).


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Figure 18: Sample of waste transfer tally sheets used during treatment

The entire treatment process took an average of 12 days. The daily average

number of waste buckets scooped was 491.5(equivalent to 491.5m3of

treated waste), amounting to an average of 743.1tons of treated waste per

day (see Table 24). A total of 5,898 buckets (5,898m3) of solid waste were

scooped and this amounted to an average of 8,917.8 tons of solid waste

treated. The additional solid waste was generated from cleanup activities

and flocculants from the waste water treatment plant.


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Table 24: Daily solidification/stabilisation records DAY WASTE

BUCKETS

SP.WT(TONS/m3) WASTE

STABILISED(TONS)

CUMM

WASTE(TONS)

% WASTE

STABILISED

CUMM

%

1 745.0 1.512 1126.4 1126.4 8.4 8.4

2 623.0 1.512 942.0 2068.4 7.0 15.4

3 608.0 1.512 919.3 2987.7 6.8 22.2

4 456.0 1.512 689.5 3677.2 5.1 27.3

5 607.0 1.512 917.8 4595.0 6.8 34.1

6 78.0 1.512 117.9 4712.9 0.9 35.0

7 562.0 1.512 849.7 5562.6 6.3 41.3

8 595.0 1.512 899.6 6462.3 6.7 48.0

9 463.0 1.512 700.1 7162.3 5.2 53.2

10 492.0 1.512 743.9 7906.2 5.5 58.7

11 46.0 1.512 69.6 7975.8 0.5 59.2

12 623.0 1.512 942.0 8917.8 7.0 66.2

TOTAL 5898 8917.8 66.2

MEAN 491.5 1.512 743.1 5.5

Comments

Each waste bucket =1m3

Waste buckets X Specific weight = Waste stabilised (tons)

% Waste stabilised is out of 13,473 tons of solid waste

Total solidification/stabilisation 66.2%

2.3.3.2.6Quality checks and management during solidification/stabilisation

The following parameters were monitored daily for 7 days during landfilling so

as to guide the binding process and establish the optimum stabilization rates:

EC, MC, and pH. These presented the most suitable indicators of the progress

of the stabilization and solidification processes. The results from the monitoring

generally indicated that there was an increasing rate in the hardening of the

solidified waste in the landfill. The trend of stabilisation recorded is indicated

in Figure 22.A rapid rise in pH increased the redox potentials of heavy metal

ions and was therefore available in a stable and highly immobilised state. This

was indicated by the rapid drop in the E.C per subsequent day. A drop in the

moisture content resulted from exothermic hydration reactions of cement

during setting. A hardened sample was submitted to an external laboratory

for analytical checks on the levels of contamination (See Table 25).


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Figure 19: Sample of landfill pH monitoring report used

Figure 20: Sample of land fill Moisture content monitoring report used


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Figure 21: Sample of land fill EC monitoring report used

Figure 22: Daily rate of hardening in the landfill

4

5

6

7

8

9

10

11

12

1 2 3 4 5 6 7

PA

RA

MET

ER

DAYS

RATE OF HARDENING IN THE LANDFILL

pH MC EC


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Table 25: Landfilled material external lab analysis

S/N PARAMETERS UNIT UK- WAC LANDFILL COMMENT

1 Arsenic mg/Kg 2.11-6.92 <0.01 PASS

2 Barium mg/Kg 100 2.8 PASS

3 Cadmium mg/Kg 1 0 PASS

4 Chromium mg/Kg 10 0 PASS

5 Copper mg/Kg 50 4 PASS

6 Mercury mg/Kg 0.2 <0.002 PASS

7 Molybdenum mg/Kg 10 0 PASS

8 Nickel mg/Kg 10 0.1 PASS

9 Lead mg/Kg 10 1.6 PASS

10 Antimony mg/Kg 0.7 0 PASS

11 Selenium mg/Kg 0.5 0 PASS

12 Zinc mg/Kg 50 0 PASS

13 Sulphate mg/Kg 20000 28.3 PASS

14 Chloride mg/Kg 15000 95 PASS

15 Fluoride mg/Kg 150 2 PASS

ORGANIC CONSTITUENTS

1 Phenols mg/Kg 1 Trace PASS

2 Total organic

carbon(w/w)

g/100g 5%BTEX 6-L29B 1.22 PASS

3 Dissolved organic

carbon at own pH

mg/Kg 800 1.56 PASS

4 Hydrocarbon mg/Kg 500 IFC Trace PASS

PHYSICAL CONSTITUENTS PASS

1 pH 6-8 8.8 PASS

2 TDS mg/Kg 60000 316.2 PASS

Comments

All parameters as stipulated in the contractual Scope of Work were tested against (UK

WAC) and NEMA requirements (Appendix I); and the stabilised waste was found to

meet the respective disposal standards.

As indicated by the high pH, the heavy metal, organic and other contaminants were

stabilised significantly.

2.3.3.2.7 Disposal of the solidified/stabilised waste

The disposal of the stabilized and solidified waste was done by placement in

a sealing type landfill designed to completely isolate and contain all of the

waste material disposed of, thereby preventing the migration of

contaminants in the waste into the environment (see Figure 12).A total

quantity of 8, 917.8 tons of solidifying waste was available for disposal. After

sorting, a quantity of 24 tons of plastic materials consisting of pieces of liner

and compactor bags was segregated out from the mud cuttings, leaving


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8893.8 tons of mud cuttings as the quantity of solid waste that was stabilized

and solidified was stabilized along with 5339.2 tons of bio-treated compost to

give a total of 14, 233 tons of stabilized and solidified material that was

disposed of in the facility’s landfill at an average rate of 735 tons/day (See

Table 26 for the daily disposal rates).

Table 26: Daily landfilling and recyclable disposal records DAY

LANDFILL

DISPOSA

L (TONS)

CUM

LANDFILL

DISPOSA

L (TONS)

%LAN

DFILL

DISPO

SAL

%CUM

LANDFILL

DISPOSA

L

RECYCLAB

LE

(TONS)

CUM

RECYCLAB

LE

(TONS)

%RECY

CLABLE

%CUM

RECYCLAB

LE

1 1115.17 1115.176 12.505

12.505 11.264 11.264 0.126

0.126

2 932.556 2047.732 10.457

22.962 9.420 20.684 0.106

0.232

3 910.103 2957.835 10.205

33.168 9.193 29.877 0.103

0.335

4 682.577 3640.412 7.654

40.822 6.895 36.772 0.077

0.412

5 908.606 4549.018 10.189

51.011 9.178 45.950 0.103

0.515

6 116.757 4665.775 1.309

52.320 1.179 47.129 0.013

0.528

7 841.247 5507.022 9.433

61.753 8.497 55.626 0.095

0.624

8 890.644 6397.665 9.987

71.741 8.996 64.623 0.101

0.725

9 693.055 7090.721 7.772

79.512 7.001 71.623 0.079

0.803

10 736.465 7827.186 8.258

87.771 7.439 79.062 0.083

0.887

11 68.856 7896.042 0.772

88.543 0.696 79.758 0.008

0.894

12 932.556 8828.598 10.457

99.000 9.420 89.178 0.106

1.000

TOTAL 8828.598 99.000

89.178 1.000

AVG 735.7165

7.4315

Comments

% landfilled and % recyclables were calculated out of 8917.8 tons of stabilised waste

Total disposal was 100%

2.3.3.2.7 Landfill capping and closure

The material that was backfilled into the landfill was covered with a rain proof

material (DPM 1000mm gauge) on which a layer of clay was spread. A layer

of murram (600mm thick) was then added, after which a layer of black soil fill

(200mm thick) was added to form the final cover layer. The laying of the layer


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of black soil marked the end of the landfilling process and the complete end

of the entire drilling waste treatment and disposal process.

Figure 23: Pictorial of the Stabilisation/Solidification and landfilling process

1. Sorting/segregation of the drilling solid waste

Left: An excavator scooping waste from the bund .Centre: sorting of the waste done during scooping, thereby

segregating plastic materials contained in the solid waste. Right: Plastic materials (pieces of poly-liners and

compactor bags) segregated from the waste during sorting being placed for temporary storage in leak-proof

containers, awaiting transfer to Luwero Industries Limited for disposal by destruction (incineration)

2. Addition/application of stabilizing and solidifying agent (portland cement) to the waste

Workers adding cement onto the sorted solid waste material prior to mixing. He cement serves as a stabilizer to

limit chemical reactions/transformation of pollutants and solidifier to limit their ability to migrate/move in the

environment


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3. Mixing of the drilling mud and cuttings with cement

Excavators mixing cement into the solid waste. The cement reacts with the moisture contained in the wasteto

form a hydration product, which is a solid mass that binds the waste material, limiting the ability of the waste to

material migrate into the environment.

4. Transfer of stabilised material to the landfill

Stabilised material being loaded onto trucks for transfer to the landfill.

Trucks tipping the stabilised material into the landfill


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Stabilised waste being leveled in the landfill. The operations of the backhoe, excavators and trucks also provided

the function of compacting the stabilised waste loaded in the landfill.

5. Anlysis of stabilised and landfilled material

WNCL Lab Technician conducting analysis of the stabilised material in the landfill as part of the process monitoring

and quality management procedure. Daily laboratory analyses were done to monitor the performance of the

hydration product. This served to guide the waste-cement mixing ratios and process to ensure optimum

performance.


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6. Cleaning up of bunds and areas that were used during mixing of waste with cement

Left: The poly-liners being removed from the bunds after removal and landfilling of the drilling solid waste.

Right: A backhoe scraping a layer of soil from the bunds andareas around the points on which mixing was

done. This was undertaken as a safeguard to offset the possibility of the soil in those places having interacted

with the waste material and got polluted. The scooped soil was treated throug the stabilisation-solidification

method and landfilled

Left and center: Cleaned out bunds. Right: a cleaned out mixing pit (Pit 5). The cleaned bunds and Pit 5 await

rehabilitation for use in the facility’s future operations.


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7. Capping and closure of the landfill

A poly-liner placed over the landfilled material, to form the first layer of the capping lining for the landfill. The

poly-liner serves to seal the landfill completely off, preventing infiltration of rain into the stabilised waste

material.

A layer of fine clay applied over the poly-liner to form the second layer of the capping lining for the landfill.

The clay servs to protect the poly-liner from damage that could be created by stones contained in the murram

layer of the capping. The clay also serves to retain water/moisture, thereby controlling its infiltration into the

landfill.


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A layer of murramplaced over the clay and poly liner, forming the third layer of the capping lining for the landfill.

The thick layer of murram (600mm) serves to reinforce the strength and integrity of the landfill’s capping.

A layer of black soil being applied on the landfill cap to form the fourth and last layer of the capping lining for the

landfill. The layer of black soil serves to facilitte the re-vegatation of the landfill site.


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2.3.4Overalloutcomes from the solid waste treatment and

disposal processes

All TUOP solid waste that was transported to WNCL facility was successfully

treated and disposed of in safe ways, through re-use for brick making and

immobilization by landfilling. TUOP and WNCL EHS policies were followed and

social performance and local content requirements, including provision of

employment opportunities to local communities, were observed.

No major spill occurred during treatment and disposal of the solid waste.

The findings obtained from the laboratory analyses conducted by the

external lab on both the solid waste treated by bioremediation and by

stabilization and solidification to meet the specifications and standards as set

out under the UK WAC and local (Ugandan) requirements for the suitability of

the solid waste for disposal. All parameters as stipulated in the scope of work

were tested against (UK WAC) and national requirements and the chemical

characteristics of both the solid waste material that was treated by

bioremediation and that treated by stabilisation were found to have been

significantly changed in such ways that their heavy metal contents reduced

to safe limits and the content of organic contaminants was reduced to trace

amounts. The treatment methods and processes applied were therefore

effective and successful and thereby created products which were suitable

for safe disposal by re-use and landfilling.

The re-use of the bio-treated compost in the making of bricks for use in the

facility significantly reduced the facility’s demand for sand, soil and clay,

which would have been required in the brick-making process. This thereby

reduced the need to extract these resources from the environment, hence

contributing to the minimisation of the alteration and possible degradation of

the natural environment from the creation or expansion of clay or soil borrow-

areas and sand mines. The making of the bricks has saved WNCL the

expenses and social and environmental risks that would be associated with

buying and transporting bricks from elsewhere.

2.3.5 Post waste treatment and disposal site restoration

activities

Following the completion of waste treatment and disposal activities which

concluded with the completion of the capping of the landfill, site restoration

activities were undertaken with the aim of returning the site, as approximately


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as possible, to pre-project conditions, so as to allow any possible self-

regulation and natural reversal of the environmental alterations created by

project activities; and to protect people and the environment by making the

clean and safe, and thereby facilitate the release of the facility for other

activities.

The site restoration-related activities undertaken included housekeeping,

collection and disposal of materials that were segregated from the solid

waste, and re-installation of the perimeter fence, and re-vegetation of the

landfill area.

2.3.5.1 Housekeeping

This mainly involved the removal and stowage of all usable moveable

equipment, tools and materials; and the removal and subsequent disposal of

all scrap and debris which consisted of all unnatural materials around the site

that were unusable and unwanted. Housekeeping activities also included

filling up of any depressions around the facility that were created by the

movement of the heavy equipment that were used during project activities.

2.3.5.2 Disposal of materials that were sorted out of the solid waste

At the completion of the sorting that was done during the treatment of the

solid waste, the quantity of plastic materials consisting of pieces of poly-liner

and compactor bags that was segregated out of the drilling solid waste

amounted to a total of 24 tons. As a safeguard, these materials were packed

in containers (40ft) for temporary storage. Because these materials had been

in direct contact with the drilling solid waste, they were considered

hazardous and hence they were designated for disposal by destruction. A

NEMA-licensed hazardous waste handler was therefore engaged to transport

the segregated materials for destruction by Luwero Industries Limited in

Nakasongola District (See Appendix K).

2.3.5.3 Restoration of the landfill area

Restoration of the landfill area involved the placement of a layer of black soil

on the top of the landfill so as to enable vegetation to grow and thrive over

the landfill site. Because completion of waste treatment activities occurred

during the dry season, the landfill site was left in a state that could support

any natural vegetation that could sprout on its own during the dry season,

while the planned deliberate planting of native grass species (6,300 plants)

will be conducted upon the return of the next rains.


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Like the other landfill area restoration activities, re-vegetation of the landfill

site will be done in accordance with the landfill site restoration and post

closure management plans presented in the Technical Action Plan for the

Stabilization-Solidification process (presented on Appendix R- Item 1).

2.3.5.4 Re-installation of the perimeter fencing

The sections of the security fence that had been affected by the works that

were undertaken around the landfill area were repaired/re-installed so as to

ensure the fencing around the facility encompassed the entirety of the site,

thus improving the security of the facility and restriction of access by people

and wildlife. The fencing installed was eight (8) feet high, galvanized chain-

link topped with three (3) strands of barbed wire. The fence posts were set firmly

in concrete foundations engineered so as to resist any wind loads.

Figure 24: Repairing of the perimeter fence

The perimeter fence being repaired to limit access to the site and ensure security

2.3.5.5 Replacement of Signage

This involved the replacement of all signage that had come down during

waste treatment and disposal activities and those that were deemed to

have become faint, and placement of new signage at various locations

around the facility.


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3.0MONITORING AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL ASPECTS

3.1 Environmental and Social Safeguards implemented during

waste treatment and disposal In accordance to its own commitment and in compliance with contractual

and regulatory obligations, WNCL undertook a responsibility to insure the

integrity, health and safety of its host environment, its employees and society

at large. Hence, based on the ESIA which constituted the overall risk

assessment framework for the implementation of the project, an

Environmental and Social Management and Monitoring Plan was developed

at the conception of the project, which provided the basis for the

development of systems, policies, strategies and plans addressing the

Environment, Health and Safety (EHS), social performance, local content and

monitoring aspects of the project.

Furthermore, the environmental and social safeguards that were

implemented during waste treatment and disposal activities were identified

through the comprehensive risk assessments which were conducted prior to

the implementation of both liquid and solid waste treatment and disposal-

related activities. The risk assessments identified the potential negative

impacts or damage that could result from the implementation of the

respective treatment and disposal activities, and then identified measures to

prevent or minimise and control the severity and extent of the anticipated

impacts. This was done to ensure that the activities conducted at the site do

not cause negative impacts on the local physical, biological as well as

natural environmental including local communities. The safeguards that were

implemented are presented in Appendix O and Appendix P.

3.2The Environment, Health and Safety (EHS) aspect of the project

3.2.1 EHS Strategies implemented during the project

Right from the inception stages of the project, WNCL set out to plan and

perform its activities in ways that minimized environmental discharges and

disturbances; and to build healthy and safe places and systems of work so as

to ensure that people and the environment within and around the facility

were protected and that no disruptions to work occurred throughout the


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project. In line with these obligations and aspirations, WNCL developed and

implemented effective prevention-oriented EHS systems comprising a range

of policies, strategies, objectives, plans, and procedures, as well as

supervisory and capacity building approaches. Among others, some of the

key strategies adopted to ensure the health and safety of people and the

environment were:

a) Provision of appropriate and adequate Personal Protective Equipment

(PPE):

PPE was provided and its use enforced at all times of operation and in all

areas of the facility in which such equipment was required.

b) Training of personnel

Regular training was provided to all personnel, covering all areas relevant to

EHS so as to enable all staff to perform their duties and responsibilities in ways

that would be healthy and safe for them, the people around them and the

environment in which they were operating. Training activities were

conducted both in-house and externally including participation of some key

staff in NEBOSH/IOSH training.

c) Communication

Open communication was made of all relevant policies, procedures, rules

and codes of conduct governing the behavior of all people who worked,

visited and/or resided at the facility. Avenues of communication included

induction of new entrants, EHS moments during meetings, and display of

information on notice boards.

d) Risk assessments

These were used as the primary tool for managing all significant and

foreseeable risks, as they enabled the identification and control of hazards

and assessment of potential dangers from all inputs, processes and outputs

and the development of strategies for averting or controlling such potential

dangers. Two types of risk assessments were used throughout the project,

namely task-based risk assessments and Job Safety Analyses (JSAs).

Comprehensive risk assessments were conducted for the major tasks of waste

transportation, liquid waste treatment and disposal (see Appendix O), and

solid waste treatment and disposal (See Appendix P). Following the risk


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assessments conducted for the respective tasks, controls were identified and

implemented to ensure safe delivery to WNCL during transportation and to

minimise potential harm to human health, environment and safety during the

treatment and disposal activities. Upon completion, each of the risk

assessments was published and made available for all staff and contractors

in the areas addressed by the assessments.

Job safety analyses and tool box talks were conducted on a daily basis

during transportation and waste treatment and disposal activities, before

commencement of works and involving staff personnel relevant to particular

activities for which the JSAs and tool box talks are conducted. Records of the

JSAs and tool box talks were captured and maintained in JSA and tool box

talk forms.

e) Permit to work

The Permit to Work system was used throughout the project to control work

activities that were deemed to be potentially hazardous. In this system, Work

Permits were issued to authorize works that were performed and to

communicate the processes followed to all affected parties, ensuring that all

tasks were clearly defined and understood, and that all hazards were

evaluated and measures taken to protect all persons, property and the

environment within and around work areas. Duly completed Work Permits

were issued for all major activities conducted including all activities related to

the transportation and treatment and disposal of the drilling waste. To ease

access and for inspection purposes, the Work Permits were displayed at the

respective work sites at all times that were the works were conducted, as well

as in the office area. Routine and spot-check inspections and audits of the

Permits and the PTW system in general were conducted regularly by both

WNCL and TUOP. A record of all of the permits issued, audits and related

action trackers has been kept in the facility’s filing system.

f) Safety observations

The safety observations method was used as a proactive risk management

tool employed to reduce the possibility of accidents and incidents occurring

at work areas and in the facility at large. This was done by allowing staff and

all persons who accessed the facility to report or comment on any unsafe use

or condition of equipment, tools and infrastructure, and/or report or

comment on any environmental and health hazards observed. The SOCA

card system was maintained in a functional state throughout the


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82

transportation and waste treatment and disposal processes so as to enable

the timely identification of hazards and risks, and hence their timely

mitigation. A record of the SOCA cards and related action trackers has been

kept in the facility’s filing system.

g) Control of substances hazardous to health

A system was developed to ensure strict and safe control of any substances

kept at the facility that were deemed to be hazardous to health. This

included the creation of safe space in form of a Chemicals Store for proper

and safe containment of all chemicals that received at the facility and

containers for the containment of cement. The system also included

assessments of chemicals, register of all chemicals, Material Safety Data

Sheets, and procedures for safe handling of the various chemicals that were

held and used at the facility.

h) Good housekeeping

This was adopted as a tool for enhancing safety and efficiency of work areas

by reducing the possibility of accidents occurring as a result of slips, trips and

falls.“Clean as you work” good housekeeping practices were adopted in all

activities undertaken during the waste transportation and treatment and

disposal operations.

3.2.2 Record of incidents

A number of incidents were recorded during the execution of the project, as

indicated in Table 27.

Table 27: Record of incidents

Incident Number Date of

occurrence/reporting

Brief description

151115003 15/11/2015 Spill of potentially contaminated runoff

water from the containment space of

Bund 1 after heavy rains caused the

containment space to fill up and overflow.

151115004 15/11/2015 Accidental offloading of contaminated

murram into an area outside the

designated waste pit due to poor access

to the pit.


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220416001 22/04/2016 Accidental knocking of the facility’s main

entrance gate by a driver of the firm that

was hired to deliver the treatment

equipment.

These incidents were timely reported, investigated, and addressed through

corrective actions which were taken promptly to remedy their impacts.

Mitigative measures were also put in place to minimise the risk of the

incidences reoccurring. Copies of the full incident reports are presented in

Appendix R(Item 7).

Figure 25: EHS training

WNCL’s workforce being trained on

environmental, health and safety aspects of

work in the oil and gas sector. Issues

addressed included permit to work, job

safety assessment/analysis among other EHS

related


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84

Figure 26: (Left) A stand down jointly facilitated by TUOP and WNCL personnel

to address matters related to health and safety during work. (Right) An

operations and EHS meeting being held with all staff

3.1.2 Leading and lagging EHS indicators

A summary of the key EHS statistics is presented in the following matrix(Table

28).


85

Table 28: Summary of EHS Statistics

Mo

nth

s/

Ye

ar

Ma

nh

ou

rs

wo

rke

d

TRI

TRIFR 12M_

AV LTI

LTIFR 12M_

AV

In h

ou

se

TR

IFR

targ

et

In h

ou

se

LT

IFR

Targ

et

Miles Driven

Motor Vehicle

Incidents(MVI)

In hous

e MVC rate MVCR

Medical treatme

nt cases (MTC)

Restricted work

day Cases

(RWDC)

First Aid

Cases

(FAC)

2015-Aug

79,967

2 25.01

1 13

1 1 1575987 0 0 0.00

2 1 0

2015-Sept

43,789

0 -

0 -

1 1 1345632 0 1 0.00

1 1 0

2015-Oct

80,985

15 185.21

9 1 12.348 1 1.2 1456932 1 1

0.69 10 15

0

2015-Nov

97,987

6 0.06

1 10

1 1.2 1565432 1 1 0.64

2 6 0

2015-Dec

20,922

12 0.57

0 -

1 1.2 1589009 0 0 0.00

5 0 0

2016-Jan

10,579

5 0.47

0 -

1 1.2 1583490 0 0 0.00

2 1 0

2016-Feb

20,122

1 0.05

0 -

1 1.2 1584050 0 0 0.00

3 0 1

2016-Mar

19,563

8 0.41

0 -

1 1.2 1584610 0 0 0.00

1 0 0

2016-Apr

19,432

10 0.51

0 -

1 1.2 1585170 0 0 0.00

4 0 0

2016-May

41,760

5 0.12

0 -

1 1.2 1585730 0 0 0.00

6 2 0

2016-Jun

30,678

11 0.36

1 33

1 1.2 1586290 0 0 0.00

2 0 1

2016-Jul

41,229

7 0.17

0 -

1 1.2 1586850 0 0 0.00

4 0 0

2016-Aug

10,452

6 0.57

0 -

1 1.2 1587410 0 0 0.00

1 0 0


86

2016-Sept

20,134

6 0.30

0 -

1 1.2 1587970 0 0 0.00

3 0 0

2016-Nov

20,229

4 0.20

0 -

1 1.2 1588530 0 0 0.00

2 0 0

2016-Dec


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87

3.2 The Social Performance of the project

3.2.1 Obligations under social performance

In cognizance of the contractual and legal requirements and of the fact that

the implementation of the project would inevitably involve contact and

interaction with both local and distant communities, it was imperative for

WNCL to meet the obligations of

a) Upholding and promoting respect for human rights;

b) Identifying and mitigating social risks and harmful impacts, and

enhancing beneficial returns; and

c) Addressing grievances in a timely manner.

These provided the means by which WNCL ensured that the activities

undertaken in delivering the drilling waste transportation and treatment and

disposal services did not pose detrimental effects by creating disturbance or

nuisance factors on the local community and the Ugandan society at large.

4.2.2 Meeting the social performance obligations

To effectively meet the obligatory requirements under the social

performance aspect, WNCL developed asocial performance management

system comprising of dedicated human resources; a community

engagement policy (WNC-HSE-POL-006- COMMUNITY ENGAGEMENT POLICY),

strategy and plan (WNC-HSE-PLN-009- COMMUNITY ENGAGEMENT PLAN);

and a written grievance management procedure (WNC-HSE-PRO-023-

COMMUNITY GRIEVANCE PROCEDURE)

The social performance system functioned well in guiding entry, contact and

interaction of the waste treatment and disposal facility with the surrounding

communities and in integrating communities’ issues into the operations of the

plant and of the company as a whole, as it:

a) Upheld and prioritized engagement of and liaison with all relevant

stakeholders through consultation before and during waste

transportation and treatment and disposal, as evidenced by reports on

the various engagements conducted throughout the life of the project,

which are on record; and

b) Fostered openness and dialogue with employees and community,

providing timely and accurate information and allowing employees

and community members to freely express their concerns and


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88

aspirations in relation to the project and the development of their

community, and to register and track their grievances until final closure.

A number of grievances were recorded during the course of project

implementation. All of the grievances recorded were addressed in a timely

fashion as indicated on the grievance log presented on Appendix R(Item 8).

3.2.3 Avenues used to ensure continuous community

engagement and high social performance during the project

The main methods used included:

i) Engagement of communities and other stakeholders through regular

meetings. Periodic sensitization meetings were organized and held with

Local Councils and community members, by both TUOP and WNCL social

performance teams. The meetings were aimed at constantly keeping the

community involved in the project and constantly keeping the community

aware of the nature of waste that was being handled by WNCL, the

potential effects of a spill if one occurred and response thereof to such an

eventuality, how the waste was being handled without allowing posing any

harm to any community, and the progress of the project. Community

engagements were held throughout the project, right from the time of

transportation of the waste, through the waste holding period (8 months) to

the time of treatment and final disposal of the waste and closure of the

project. A register of the engagements is attached is presented on

Appendix R(Item 9).

ii) Engagement of communities through sporting activities. This approach took

the form of organizing regular football matches with the communities of

Kaseeta and Hohwa. The football matches provided a useful and effective

avenue for members of the communities in the respective villages to interact

directly with the waste treatment team who constituted the facility’s football

squad. Talks and other forms of interaction (such as question and answer

sessions) were organized prior to kick-off, during breaks and at the end of the

football matches. These interactions were useful in helping the facility to

gather information on the concerns, fears and interests of the communities

and in response to allay the fears and concerns that the communities had.

iii) Use of mass media. This was mainly done through the involvement of local

radio stations that included Spice FM, Liberty Radio and Radio Hoima to relay


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89

information to the general public regarding the project and the various

activities that were related to it. Messages were relayed through the radio

stations throughout the period the in which project was implemented.

iii) Enhancing beneficial returns to the community. These included: a)

upgrading of the road leading from the Kaiso main road through Hohwa

trading center to the waste treatment and disposal facility- thereby providing

an improved road both for the facility and the community of Hohwa and the

general public, b) provision of employment and income generating

opportunities to local community as most labour and material requirements

were met with human resources and materials sourced from the surrounding

villages, and c) maintenance of community playground at Hohwa trading

center through regular mowing.

Figure 27: Community engagement through community meetings

Left: and Center: community engagement meetings facilitated by WNCL Social Performance

Coordinator. Right: WNCL’s SPC and locals from inspecting a broken bridge at Kaseeta

following the community’s request for support to get the bridge repaired.

Maintenance of a road in Hohwa which was done as part of Corporate Social Responsibility

and so as to enhance beneficial returns to the local communities


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3.3 The Local Content Aspect of the project

3.3.1 Obligations under the local content aspect

Contractual and regulatory requirements made it incumbent on WNCL to:

a) Insuring employment opportunities for local content by prioritizing the

recruitment of the local (Ugandan) population, while paying particular

attention to gender considerations, and to technology transfer and the

development of the local population’s capacity to meaningfully

participate and benefit from their engagement in the project.

b) Ensure maximum benefit for the local (Ugandan) community from the

project’s procurement by giving preference to Ugandan goods and

services.

These provided the founding principles by which the company operated with

respect to the recruitment of the required human resources, procurement of

required equipment, materials and services and optimization of benefits of

the project for the Ugandan society. The requirements were monitored and

reported regularly. A record of the reports has been maintained in the

company’s records.

3.3.2Performance of the project in relation to labour

requirements

3.3.2.1 Distribution of labour by source

Most of the labor used (65%)was sourced from communities residing in nearby

places which comprise villages located within a 1km radius from the facility,

namely Hohwa, Kaseeta, Kyarusesa and Kyenjojo. The second most

significant amount (20%) of the labour used in the project was sourced from

surrounding villages which were defined as areas falling in a 2-5km radius of

the facility. This mainly consisted of human resources sourced from the

villages of Ssebagoro, Kaiso, Nyairongo, Lwengabi and Kabaale. The wider

Hoima district contributed 10% of the labour used in the project. The other

parts of Uganda provided 4% of the source of the total workforce, and this

was particularly to fill in roles for which more specialized labor was required

which could not be obtained from among the near and surrounding

communities. Foreign (non-Ugandan) labor that constituted 1%of the total

workforce used in the project was sourced from other parts of the world

mainly to temporarily support technology transfer processes by providing


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training to the local (Ugandan) staff on the technologies that were required

and used in implementing the project(See figure 28).

Figure 28: Main sources of labour used in the project

3.3.2.2 Distribution of labour by gender during the project

Throughout the project, a total number of 132 people were enlisted in

different roles. These included permanent staff and support staff in the

categories of gardeners, cooks, cleaners, security guards, and machine

operators. The support team formed the majority of the labour force (more

than 64%)(See figure 29). The team comprised of men (93%) and women

(7%)(See figure 30).This was because most of the work entailed in the

implementation of the project consisted of activities such as construction of

bio-platforms, bunds, pits and drainages, lining engineering structures, sorting

segregated waste, pumping water and operating machines which were

highly labour-intensive and physically demanding and were therefore not

accepted by women, thereby leaving most roles to men as women gave

preference to the less labor intensive activities such as cooking, cleaning,

and gardening. The technical team comprised of 7 highly qualified local

staff. These were: Technical Team Lead (01), Tab Technician (01), EHS team

(02) and technical assistants (03). The participating team involved was

entirely composed only of adults (18-59 years) (100%). Much of the work

0 20 40 60 80 100% labor

Sources of labour

World

Uganda

Within Hoima

Sorrounding places

Nearby places

Key


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92

required physical labor and therefore very young (0-17 years) and elderly (60-

100 years) people could not be enlisted.

Figure 29: Labour distribution by role during treatment

Source of data: WNCL POB records

Figure 30: Labourdistribution by gender during waste treatment and disposal

operations

Source of data: WNCL EHS records

4% 3%

2%

15%

64%

9%

Labor distribution

security guards

cooks

Gardeners

Technical staff

support staff

operators

93%

7%

Gender distribution

Male

Female


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93

3.3.3Performance of the project in relation to the procurement

of materials and services

On average, most (74%) of the materials used during the implementation of

the project were procured from within Hoima district. These mainly consisted

of welfare-related materials (85%), fuel (100%), equipment (70%), stationery

(100%), lining materials (66%) [Clay, murram, DPC, black soil], and

construction materials (80%). 20% of the materials consumed by the project

were obtained from other parts of Uganda and these mainly consisted of

process materials (86%) which included manure, cement and fertilisers. This

high supply resulted from the very high demand. Only 6% of the materials

used during project implementation were imported from other parts of the

world, mainly HDPE liners and liner welding machines (See figure 31).

Figure 31: Sources of materials used during project implementation

Source of data: WNCL Store records

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Sources of materials

Hoima Uganda World


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94

3.3.4 Summary of data related to the local content aspect of the

project

A summary of the data is presented in Table 29.

Table 29: Local Content monitoring report for the project

Ref Description Answer Other Comments

1.00 EMPLOYMENT

1.10 Persons are currently employed by WNCL in Uganda

1.11 Ugandan nationals

1.111 In

management

positions

5 Executive Director, Consultant, Project Manager,

Finance Manager, Human Resource manager.

1.112 In non-

management

positions

95 Technical, Operations, Admin and support staff.

1.12 Non-Ugandan nationals

1.121 In

management

positions

1.122 In non-

management

positions

2 Technical support

2.0 USE OF UGANDAN GOODS

AND SERVICES

Answer Comments

2.10 Current sourcing (in percentage) of works and services under the project

2.11 Ugandan 98% Most of the goods and services were sourced locally.

2.22 Non-Ugandan 2% Treatment equipment shipped from China.


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3.4 Site monitoring aspect of project implementation

3.4.1 Environmental and social monitoring

3.4.1.1 Facility driven monitoring

To honour its own commitment and bolster its compliance to contractual and

regulatory requirement to ensure that its activities do not endanger natural

environmental and social systems; WNCL adopted and prioritized the

precautionary approach of proactively seeking to identify and hence

manage environmental and social risks and impacts in a timely fashion. In this

approach, the company accorded a significantly high degree of attention

to ensuring continual and comprehensive monitoring of the environmental

and social facets of the project, thereby constantly keeping the issues under

surveillance, using both internally and externally driven monitoring processes.

In this respect, WNCL developed an environmental and social monitoring

framework consisting of “internal” monitoring- done by the WNCL workforce,

and “external” monitoring- done by a contracted third-party arrangements,

based on respective monitoring plans.

3.4.1.1.1 Internal environmental and social monitoring

Internal monitoring activities took the form of daily and monthly inspections of

the entire facility, with focus on critical areas and physical infrastructure

around the waste treatment and disposal plant; internal audits; and

community engagements for observing social issues. The daily and monthly

inspection monitoring activities were mainly aimed at ensuring that any

discharges and defects at any part of the facility would be promptly

identified and addressed while the community engagements were meant to

facilitate early and proactive identification of any community concerns. The

inspections and community engagements were systematically based on the

monitoring plan (WNC-EHS-PLN-0026 -ENVIRONMENTAL MONITORING PLAN)

and checklists. A record of the inspections, audit and community

engagement was captured and maintained in the facility’s filing system.

3.4.1.2 External environmental and social monitoring

This was a form of environmental and social monitoring of the facility that, for

purposes of objectivity and quality assurance, was allocated to third party

agencies. This was mainly aimed at fostering processes of continuous

improvement in the state and operations of the facility. External

environmental and social monitoring consisted of two types of monitoring

processes, namely i) routine monthly monitoring (based on the plan of work


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96

shown in Table 30) conducted by KAM International, which comprehensively

assessed water quality, air quality, soil quality, noise and social issues among

other aspects (copies of reports attached on Appendix R- Item 10); and ii)

annual environmental audits, which are a regulatory requirement. An

environmental audit of the facility was conducted by Eco and Partner

Consult (audit report submitted to NEMA in May 2016). Findings and

recommendations from these monitoring activities were used to update the

facility’s environmental and social management plans and processes.


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Table 30: Work Plan for External Environmental and Social Monitoring

conducted by KAM International


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3.4.1.2 Externally driven monitoring

This form of monitoring was conducted by regulatory agencies and by the

client (TUOP).

3.4.1.2.1 Regulatory monitoring

Regulatory monitoring occurred in form of regular visits and inspections by the

relevant regulatory agencies including NEMA and PEPD. These monitoring

activities were mainly aimed at assessing the progress and performance of

the project in terms of quality of the processes and environmental and social

safeguards implemented. The monitoring activities of the regulators were also

aimed supporting the facility’s and project’s compliance with regulatory

requirements and standards, and to support processes of continual

improvement of the operations and processes. Regulatory monitoring

included visits and inspection of the facility by Hoima District Local

Government authorities.

Figure 32: Regulatory and compliance monitoring of the facility and

processes

Left: A team consisting of representatives of NEMA and PEPD inspecting the facility to monitor

performance of the facility and its operations in relation to compliance with regulatory requirements

and standards and implementation of environmental and social safeguards. Right: the team

engaging WNCL personnel in a de-briefing after the inspection.


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A team from Hoima District Local Government inspecting the facility and its operations

3.4.1.2.2 Monitoring of the facility and project by the client (TUOP)

Monitoring of the facility and the waste treatment and disposal activities and

process by TUOP took the form of daily visits by TUOP field team based in

Kisinja; submission of daily reports; weekly visits by the TUOP Project Team and

leadership; weekly meetings between TUOP and WNCL project teams; and

submission of daily and weekly reports. This range of monitoring activities

undertaken were aimed at maintaining a constant awareness of the progress

and performance of the project, and as a means of ensuring quality

assurance and control with respect to the processes and environmental and

social safeguards undertaken by WNCL in implementing the project.

Figure 33: Monitoring of the facility and operations by TUOP

Daily visits by TUOP field personnel

Left and center: TUOP personnel on a daily visit inspecting operations and processes during liquid

waste and solid waste treatment respectively. Right: TUOP personnel in WNCL’s laboratory to discuss

laboratory’s quality control operations and findings during a daily visit.


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TUOP field team engaging WNCL workforce on various aspects of the project operations during daily

visits

Weekly visits by TUOP’s Project Team

TUOP’s Project team engaging WNCL workforce on various aspects of the project operations during

weekly visits

Below: A TUOP-WNCL weekly meeting engagement conducted during a weekly visit to the facility


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Visits by TUOP’s senior leadership

TUOP’s senior leadership engaging WNCL personnel during their visits to and inspection of the facility

and its operations


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102

3.4.3 Process Monitoring and control

Given the hugely process-based nature of the waste treatment and disposal

operations undertaken, it was imperative that means were put in place to

ensure that constant monitoring was done so as to foster proper design and

control of the processes, and hence ensure that the outputs and outcomes

that were recorded were as desired and that areas of improvement were

identified and addressed in a timely fashion. Process monitoring was done

through scientific laboratory analyses which were conducted internally in the

field-based laboratory, and externally by third party laboratories.

3.4.3.1 Internal process monitoring

In compliance with contractual requirements, WNCL set up an internal/on-

site (field-based) laboratory to provide routine analyses meant to guide the

design and implementation of waste treatment and disposal activities and as

well to support routine internal environmental monitoring activities (water and

soil quality monitoring).

Figure 34: Experiments conducted in the Internal Lab to monitor and guide

control of waste treatment activities


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Figure 35: WNCL Lab personnel taking soil samples from areas around the

facility

3.4.3.2 External process monitoring

WNCL entered into Memoranda of Understanding (See Appendix L) with two

external (third party) laboratories, namely Makerere University College of

Agricultural and Environmental Sciences Laboratory and Chemiphar Uganda

Limited to provide quality assurance laboratory analysis services. The analyses

conducted by the external laboratories mainly provided an objective

confirmatory basis, affirming the quality of the outputs and outcomes

attained from the waste treatment activities.

The services of the external laboratories were used for conducting the

mandatory pre- treatment in-depth analyses on both the liquid waste and

solid waste materials with the purpose of identifying and quantifying the full

range of contaminants as listed in the Schedule of standards for discharge of

effluent or waste water contained in the National Environment (Standards for

Discharge of Effluent into Water or on Land) Regulations and UK WAC, and

establishing a baseline for the composition of the waste prior to the

application of the respective agreed liquid and solid waste treatment

processes.

The services of the external laboratories were also used for conducting the

mandatory post- treatment in-depth analyses on both the treated liquid and

solid materials after treatment to assess the effectiveness of the treatment

methods and processes used in the treatment of the waste and to assess for


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the acceptability of the treated materials for disposal, with respect to the

said regulations.

3.4.4 Post treatment and disposal monitoring

To affirm its own commitment to identifying and addressing the impacts of its

activities on the environment and society in and around its facility, and in

compliance with contractual and regulatory requirements to ensure

continued monitoring of the facility after waste treatment and disposal

activities, WNCL developed a plan for monitoring the facility over 5 years as

required under the contract. The plan consists of a two-pronged approach

entailing i) internal monitoring which to be conducted by WNCL staff through

regular site visits; and ii) external monitoring conducted by a third party

agency, namely KAM International, which will undertake comprehensive

assessments and analyses for surface and subsurface water quality, soil

quality, air quality, social issues among other aspects, within and around the

facility as per monitoring plan presented in Appendix M.

Reports from these monitoring activities will be submitted to the client- TUOP

and to regulators (NEMA).

3.5 Project Human Resources

3.5.1 Project Team

The project was managed and implemented by a competent team

indicated in Figure36. In total 105 people were directly employed in the

project. These included staff in managerial, technical and support roles. Care

and effort were made to strategically retain all staff in the project for as long

as possible. As a safeguard, this was applied to causal staff as well; since they

had gained useful training over time and had gained a good understanding

of the project’s operations and the related safety and environmental issues.

3.6 Demobilisation The demobilization of resources that were dedicated to the project but are

not needed in the next phase of project-related activities, which consist of

monitoring, was done in accordance to the demobilization plan presented

on Appendix Q.


105

Figure 36: Project staffing structure


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106

4.0 CHALLENGES, LESSONS LEARNED AND CONCLUSIONS

4.1 Challenges and lessons learned

4.1.1 Challenges

The major challenge faced during project implementation was that of low

knowledge and understanding of the project among the communities living

in the surrounding villages. The communities initially had misconceptions

regarding the waste, with many community members perceiving that the

waste was not hazardous and could thus be dumped without treatment. This

misconception also brought forth a feeling among the communities that the

waste handling processes did not require highly skilled labour, and hence the

communities had very high expectations for employment opportunities,

thereby overwhelming the facility with requests for employment.

Alongside the high demand for employment, the local communities had very

high expectations in relation to wages for un-skilled labour as they

demanded a minimum of UGX 50,000 per day, which was high and above

the average wage paid for un-skilled labour in the country. Some of the

communities also expected the project to provide for the construction of

boreholes, schools and health centers, which was unrealistic given the short

life of the project.

The heavy rains in the months of October and November2016 caused halts

during the construction of the landfill and during the loading the loading of

treated waste into the landfill. The rains made the entrance to the landfill

unusable for the heavy equipment due to slipperiness, thereby causing lags

as more than 10 days were lost altogether. And also earlier in the same

period in 2015, rains affected transportation activities to the extent that we

had a spill which was recordable incident and led to suspension of work by

TUOP(Refer to Incident Reports on Appendix R- Item 7).

There were challenges related to the generic nature of the national

standards for the disposal of the solids, while the national effluent discharge

standards were also too generic to be fully applicable to waste water

handled in the oil and gas sector as most of the organic parameters as

stipulated in the said standards are not applicable to oil and gas sector and

were costly to analyze.

There was also an impact on White Niles original budget that did not cater for

rehabilitations of the government road. The requirement by Tullow for White

Nile to rehabilitate the road connecting from Kaiso Tonya –Hohwa (WNCL

facility) negatively impacted on the company’s cash flow. Our

recommendation on this matter is that since government is a partner in the


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Oil and Gas Sector, it would be fair for the oil company to involve

government so such costs are catered for accordingly.

The other major challenge faced was on efficient and effective availability of

resources. The execution of this contract was done concurrently with other

WNCL infrastructural development. Resource allocation for contract

implementation activities encountered delays at certain times.

Under the section 4 of the contract –Compensation, TUOP required WNCL to

submit invoices with corresponding work orders numbers indicated. However

some jobs were carried out minus work orders being issued to WNCL by TUOP

and this made payment recovery impossible on WNCL’s side. It should be

appreciated that this contract was time bound and therefore need support

from both sides in order to be able to finish on time. This explains why WNCL

went ahead to execute some of the jobs minus work order. Case to mention

was work order number 4500012364 came in August 6months after the job

had been completed. Also the work order for drill cuttings treatment totaling

to 2737MT which had been treated and disposed of in December 2016 had

not yet been received by the time of completing this report in Feb 2017.

We also faced a challenge with TUOP in agreeing on waste quantities that

led to a reconciliation process which was finally settled (Refer to Appendix R-

Item 11). It was clear that the design of the scope of work did not take any

measures to obtain close to accurate quantities of waste especially rubble.

For example the scope of work “Table 1” provides estimates of waste with a

disclaimer at the bottom stating that “PLEASE NOTE THE VALUES ABOVE ARE

ESTIMATES AND SHOULD BE USED AS A GUIDE ONLY’. But later when actual

quantities for decommissioning waste were determined using the

weighbridge on site, TUOP acted uncomfortable by delaying WNCL’s work

order for this job even when the quantities were being monitored, supervised

and signed off by TUOP site representatives. This issue was partially the cause

for WNCL’s suspension on grounds of noncompliance with the contract

requirements to perform jobs with work orders only.

The other reasons for suspension of the contract also included the discomfort

that TUOP had about WNCL’s ability to complete the project on schedule.

Particularly Default Notice Ref CORP-OTHERS-LET-0437 (See copy attached in

Appendix R- Item 12): highlighted the following concerns.

(i) Failure to comply and provide an agreed project schedule

(ii) Failure to undertake the scope of work as set out in the

contract

(iii) Failure to have a completed operational facility on

accordance with the agreed and stipulated schedule

(iv) Continuous failure by WNCL to provide the requisite

resources and materials to facilitate the execution of the

scope of work including completing and having a

functional facility


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Based on the above reasons, TUOP on 2nd June issued WNCL a suspension

letter (See copy attached in Appendix R- Item 13).

However WNCL addressed concerns TUOP raised in the default letter in Letter

(See copy attached in Appendix R- Item 14).

Nonetheless, the contract was completed on schedule as per contract.

4.1.2 Lessons learned and recommendations

The key lesson learned was the importance of and need for continual

engagement of stakeholders throughout the span of the project. It became

evident that there was need to continuously provide comprehensive

information and arrange visits for the community members, local leaders and

district officials to allow them to visualize the facility’s operations and the

processes implemented. This was very instrumental in addressing the

misconceptions, concerns and fears that stakeholders held. It is therefore a

recommendation that stakeholder engagement should be prioritized for all

projects especially those with significant exposure to communities so as to

ensure attainment and maintenance of social acceptability of the projects.

It emerged that due to the high demand for employment, there was need to

devise ways of ensuring and upholding fairness and transparency in

recruitment as this was useful in addressing the fears that the communities

held about the possibility of bias and inequity during recruitment exercises. It

is recommended that recruitment methods such as those based on chance

should be adopted for sourcing un-skilled labour for future projects. For

example a recruitment process was adopted in which the personnel being

recruited were assigned numbered chits which were jumbled and picked at

random, with the persons whose chits were randomly picked being taken on.

The other lessons learned were that: for projects undertaken in the area of

waste handling and management and implemented in the Hoima area, it is

important to target the dry seasons (January to March and July to October)

for the major activities so as to ensure smooth operations; and that

internationally recognized standards and guidelines as such the UK WAC and

IFC EHS Guidelines for Onshore Oil and Gas Development can be referred to

address gaps in the local standards/requirements. Thus, it is recommended

for future projects, considerations of weather conditions particularly in relation

to seasonal changes should be factored into contractual arrangements and

in planning and implementing projects. It is also recommended that NEMA is

engaged to come up with standards that are specific for the oil and gas

drilling waste management in the Ugandan context.


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4.2 Conclusions All oil and gas drilling liquid and solid waste handling, treatment and disposal

activities were successfully completed in cost effective and environmentally

and socially safe ways; and in full compliance with and delivery on the scope

of work, contractual obligations, project KPIs and milestones. The waste

treatment and disposal activities were completed with the laying of a layer of

black soil over the entire top of the landfill on 22nd December 2016, ahead of

the 31st December 2016 deadline. The project has thus been declared

substantially completed, pending re-vegetation of the area over the landfill

and the 5-year post treatment environmental and social monitoring.

The findings obtained from both external and internal laboratory analyses

conducted on both the treated liquid and solid waste materials revealed

significant physical, chemical and biological characteristics of the waste,

generally indicating successful conversion of the originally hazardous drilling

waste into non-hazardous materials that were safe for disposal. This was an

indicator that the technologies, methods and processes that were applied in

handling and treating the drilling waste were effective.

The environmental, social and economic benefits that were recorded from

the re-use of materials that were recovered through the waste treatment

processes demonstrated the project’s approach of prioritizing recovery of

materials and their re-use as being an approach that needs to be promoted

since it is effective and very vital for the prevention and minimisation of

environmental and social risks and impacts from extraction of virgin materials

from the environment.

The implementation of the project was ground breaking both in the national

and regional contexts as it presented the first time the method of bio-

treatment of waste by bioremediation and re-use of recovered materials

through brick-making was being used on a large scale, with satisfactory

results and completed well on schedule. This achievement has demonstrated

d land mark for the future of the oil and gas industry in Uganda.

The project was beneficial to the Ugandan society as it delivered a range of

beneficial returns to the Ugandan population, which included:

a) Provision of employment opportunities through the entire life of the

project as the project was competently implemented majorly by

Ugandan professionals and workers.

b) Building of capacity of individuals and companies in the areas of waste

handling, transportation, treatment and disposal. The project team and

the entire oil and gas industry at large particularly benefited from


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capacity building in the area of oil and gas drilling waste treatment, in

which research/laboratory experiments were undertaken to establish

the most effective and viable methods for treating oil and gas drilling

waste.

c) The creation of awareness and basic understanding of drilling waste

management through the constant engagement of a broad range of

stakeholders that was maintained throughout the project. The local

communities, local/district leaders who originally had little or no

knowledge of and many fears regarding drilling waste accessed an

opportunity to learn about such waste and the possibility and means

through which the waste could be properly treated and disposed of

without causing environmental pollution and its associated risks. This

has been useful in allaying the fears and concerns that these

populations had regarding oil and gas drilling and production

processes in general, thereby allowing them to appreciate the fact

that oil and gas production and associated activities can be

conducted very safely in the region, without necessarily endangering

the environment and people within the region and elsewhere.


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BIBLIOGRAPHY

Ajmal et al, (1996).Studies on removal and recovery of Cr (vi) from

electroplating wastes. Water Res 30-1478-1482.

Robert, E. Pettit. (1989). Organic matter, Humus, Humic acid, Fulvic acid, and

Humin: Their importance in soil fertility and plant growth

Khan A.G.(2005).Role of soil microbes in the rhizospheres of plants growing on

trace metal contaminated soils in phytoremediation.

Paria, S., and Yuet, P.K. (2006). Solidification-stabilisation of organic and

inorganic contaminants using Portland cement: literature reviews 14(4), 217-

255.

White C., Sharman A.K., and Gadd G.M.(2006).An integrated microbial

process for the bioremediation of soil contaminated with toxic metals.

Yilmaz O., Unluk, and Cokca E. (2003).Solidification/stabilisation of hazardous

wastes containing metals and organic contaminants. “Journal of

environmental engineering-ASCE, 129(4), 366-376”


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APPENDICES

Appendix A: Project Key Performance Indicators

Appendix B: Project Workplan/Schedule

Appendix C: Project Cost Report

Appendix D: Waste Transfer Records

Appendix E: Final treated water sampling test certificate from the external

laboratory

Appendix F: Bio-platform monitoring report

Appendix G: Determination of Bulk Density of the Solid waste material

Appendix H: Soil Analysis Certificates for the bio-treated compost

Appendix I: List of standards for solid waste disposal (UK WAC and NEMA) as

stipulated in the contractual S cope of Work

Appendix J: Solidification/Stabilisation Trial Model Report

Appendix K: License of Hazardous waste handler, Certificate of Destruction

of contaminated polythene materials segregated from the drilling solid

waste, and waste transfer notes

Appendix L: Memoranda of Understanding between WNCL and certified

laboratories

Appendix M: 5-Year Post Treatment and Disposal Monitoring Plan

Non-compliance with monitoring requirement; corrective remedial action is

essential

Partial compliance with monitoring requirement; preventive action

needed

Compliance with monitoring requirement; preventive action required

Appendix N: Management of Change Forms

Appendix O: Risk assessment for liquid waste treatment

Appendix P: Risk Assessment for treatment of the solids

Appendix Q: Demobilisation Plan

Appendix R: Other Supporting Documents

OIL AND GAS UPSTREAM WASTE MANAGEMENT

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