E386VOL. 2

Environmental ImpactAssessment for Rehabilitationof Specific Umeme/UEDCLElectric Distribution SystemComponents

Peare4 ByPrepared By

Prepared By

Prepared by:ENSR Corporationfor the Government of Uganda

e *z~, "' ii' December 2004Document Number 10694-001-500

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CONTENTS

1.0 INTRODUCTION .1-1

2.0 SYSTEM DESCRIPTION AND ENVIRONMENTAL REVIEW METHODOLOGY ......................... 2-1

2.1 System Overview ........................................................................ 2-1

2.2 Environmental Review Methodology ........................................................................ 2-3

3.0 REGULATORY FRAMEWORK ........................................................................ 3-1

3.1 Ugandan Environmental Regulations ........................................................................ 3-1

3.2 World Bank Group Safeguard Policies and Environmental Guidelines ................................. 3-4

4.0 ENVIRONMENTAL REVIEW FINDINGS ........................................................................ 4-1

4.1 Observations ........................................................................ 4-14.1.1 Substations ........................................................................ 4-14.1.2 Distribution Lines ........................................................................ 4-2

5.0 ENVIRONMENTAL ISSUES AND CORRECTIVE ACTIONS ........................................................ 5-1

5.1 Description of Rehabilitation Activities and Potential Associated Environmental Issues ...... 5-15.1.1 Substation Transformer Rehabilitation ........................................................................ 5-15.1.2 Pole and Conductor Replacement ........................................................................ 5-15.1.3 Installation of Distribution Transformers ...................................................................... 5-25.1.4 Installation of New Electricity Connections ................................................................. 5-2

5.2 Recommended Corrective Actions .................................. ....................................... 5-35.2.1 Transformer Replacement ............................ ............................................ 5-35.2.2 Pole Replacement ........................................................................ 5-45.2.3 Consultation with NEMA and General Recommendations ......................................... 5-5

5.3 Cost Estimate for Implementation of Rehabilitation-Related Mitigation ........... ..................... 5-5

6.0 ENVIRONMENTAL MANAGEMENT PLAN ........................................................................ 6-1

6.1 Summary of Impacts ........................................................................ 6-1

6.2 Mitigation Measures ........................................................................ 6-26.2.1 Transformer Replacement ............................... .......................................... 6-2

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l~~~~

CONTENTS (Cont'd)

6.2.2 Pole Replacement .6-36.2.3 Consultation with NEMA and General Recommendations .6-4

6.3 Monitoring and Recordkeeping .. 6-46.4 Institutional Support .. 6-5

7.0 BIBLIOGRAPHY..7-1

LIST OF FIGURES

Figure 2-1 UEDCL System Map .............. 2-2

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1.0 INTRODUCTION

The project description of the rehabilitation work to be funded by IDA is as follows:

1. The concession agreement for the Uganda Electricity Distribution Company Ltd., between theGovernment of Uganda and the Umeme consortium comprising Globeleq Ltd. (a unit of CDCof the UK) and Eskom Enterprises (a unit of Eskom of South Africa), was signed on May 17,2004 . The Government of Uganda, in conjunction with Umeme and International DevelopmentAssociation, are preparing a distribution rehabilitation component proposed to be financedunder the Fourth Power Project (Credit 3545-UG). This new component aims to: (a) improvethe reliability and the quality of power supply and reduce power system losses; and (b) provideaccess to new consumers.

2. The proposed project would consist of US$8-11 million for the following distributioninvestments which involve rehabilitation of existing assets (there are no new greenfield lineextensions, no high voltage transmission lines, and no resettlement): (a) 33/11 kV and11 kV/400K transformer rehabilitation; (b) distribution transformers; (c) distribution systemelectric meters and circuit breakers, (d) pole replacement and provision of new conductor; (e)about 18,900 new electricity connections, and (f) switchgear.

Physical Description of the Proposed Umeme Distribution Component:

* Supply of six 1 OMVA and four 5MVA 33/11 kV transformers; US$2.0 million

* Supply of 1150 distribution transformers; US$1.56 million

* Supply of 18900 electricity meters and circuit breakers; US$1.23 million

. Supply of 7.700 poles and 600 km of conductor; US$4.48 million

. Supply of material for 18900 new electricity connections; US$1.03 million

* Supply or switchgear; US$0.7 million

The report that follows is an Environmental Impact Assessment (EIA) and identifies thepollution/contamination that could potentially exist in the vicinity of proposed rehabilitation activities andidentifies remedial actions and/or mitigative measures that may be required to conduct therehabilitation in compliance with Uganda environmental regulations and World Bank safeguardpolicies. The EIA also provides recommendations for an environmental management plan that is to beimplemented by Umeme/UEDCL to ensure that rehabilitation activities comply with environmentalrequirements going forward.

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This EIA report, developed by ENSR on behalf of the Govemment of Uganda, presents the findings ofan environmental review performed by ENSR and provides both recommendations related to remedialactions and/or mitigative measures and an initial draft of an Environmental Management Plan.Chapter 2 provides an overview of the UEDCL system and describes the study approach that wasfollowed in performing the environmental review. This is followed in Chapter 3 by a summary of theUgandan and World Bank guidelines and regulations that are the basis for the evaluation of potentialenvironmental issues associated with the funded rehabilitation. Chapter 4 presents the environmentalassessment findings and identifies specific areas of environmental concern. Section 5 identifiesenvironmental issues associated with rehabilitation activities and provides a listing of recommendedcorrective actions. Section 6 provides an initial draft of an Environmental Management Plan that willbe further developed by Umeme/UEDCL and implemented in conjunction with funded rehabilitationactivities. Section 7 provides a bibliography, listing the previous reports, environmental laws andregulations, and other documentation reviewed in association with the EIA.

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2.0 SYSTEM DESCRIPTION AND ENVIRONMENTAL REVIEW METHODOLOGY

2.1 System Overview

The electricity generation, transmission and distribution system in Uganda dates back to the 1930's.The East African Power and Lighting Company, based in Nairobi, Kenya, operated the generation,transmission and distribution system from 1936 until 1948, when the Government of Ugandaestablished the Uganda Electricity Board (UEB). In the 1990s the Government initiated the process ofprivatizing these assets and eventually split them into three separate entities: the Uganda ElectricityGeneration Company Ltd. (UEGCL) with responsibility for the generation of needed power; theUganda Electricity Transmission Company Ltd. (UETCL) with responsibility for wholesale import andexport of power; and the Uganda Electricity Distribution Company Ltd. (UEDCL) whose responsibility isfor retail delivery of power.

The UEDCL distribution system, the subject of this environmental review, is the 33 kV and 11 kVdistribution component of the country of Uganda's electrical system and services approximately235,000 industrial, commercial and residential, and municipal clients throughout Uganda. Figure 2-1 isa map of Uganda that shows the major nodes of the UEDCL electrical distribution system. Facilitiespotentially affected by planned rehabilitation activities include UEDCL's 33 kV/1 1 kV distributionsubstations and the "downstream" components of the electrical system (poles, service lines, anddistribution transformers).

The UEDCL system includes fifty-three 33 kV/11 kV distribution substations. ENSR visited arepresentative subset of these substations. The primary criteria used for selection of stations for sitevisits were the age of equipment and regional location of the substations. The age of equipment wasprioritized, based first on the age of power transformers and then on the age of other equipment (toaccount for differences in historic facility upgrades). The geographical locations assigned to thevarious facilities (Central, West, East and North) were based on regional designations originallydeveloped by NEMA. In addition to age and geographical location, the size of the substation, asindicated by the number of power transformers, was also a factor in the substation selection process.Other major facilities in the UEDCL system potentially affected by planned rehabilitation includenumerous distribution transformers (approximately 600 MVA total capacity).

UEB and UEDCL have expanded and upgraded the distribution system several times. Recent majorimprovements to the system (discussed further below) include reconstruction of mostly urbansubstations in the 1990's, as funded by German, Swiss and Japanese aid organizations.

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PRESENT AND FUTURE UEDCL & UETCL NETWORK

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2.2 Environmental Review Methodology

The environment review of the UEDCL facilities, in support of IDA funding, is intended to identify thepollution/contamination that could potentially exist in the vicinity of proposed rehabilitation activities andidentify remedial actions and/or mitigative measures that may be required to conduct the rehabilitationin compliance with Uganda environmental regulations and World Bank safeguard policies. Theapproach used for this review is consistent with accepted environmental review practices as applied tolarge systems/companies, where it is impractical to review every facility. The methodology considersboth the historic and on-going activities (oil storage, waste disposal, maintenance, etc.) at the variousproperties and the applicable environmental laws and regulations and evaluates the potential impactsthat rehabilitation activities may pose in the future to sensitive resource areas (surface andgroundwater resources, soils, air quality, etc.).

Due to the size of the UEDCL system, it was not practical to inspect each of the potentially affectedfacilities/locations during the allotted two-week time period. Therefore, a representative sample of thevarious types of assets was visited. The selection of assets for inspection was based on an evaluationof the potential environmental risks posed by the operations at those assets. In addition, due to safetyconcerns regarding continued military activity in the northern region of Uganda, sites in the northerndistrict were excluded from the inspection process. Specific facilities inspected by ENSR wereselected in consultation with the companies' management personnel based on the nature ofoperations, facility age, suspected or known environmental impacts, and location.

* Substations: A total of fifty-three 33 kV/11 kV substations exist throughout the system,including two dismantled substations. ENSR visited 28 of these substations, selected onthe basis of their age (the oldest were of particular interest), size, reported releases ofdielectric fluid (if any), and/or unique characteristics of the substation.

* Distribution Lines: During the course of visits to the substations, ENSR inspected arepresentative subset of distribution lines, focusing on right-of-way management (i.e., treetrimming).

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3.0 REGULATORY FRAMEWORK

The framework law that set the stage for the development of environmental regulations in Uganda (theNational Environment Act) was enacted in 1995. It expressed the overall goal of providing a safe andhealthful environment for all citizens in Uganda. A national body, the National EnvironmentManagement Authority (NEMA), was created to oversee the development and enforcement ofanticipated standards and guidelines. The law embodied the concept of environmental impactassessment as a necessary activity prior to commencing activities that could cause harm to theenvironment and identified electrical infrastructure as one of these activities. It also established theenvironmental audit as the means of reviewing activities approved as the result of environmentalimpact assessment, to ensure that the project was operating within the parameters agreed upon.Licenses were to be issued for activities that caused pollution, with fines levied for those operating inviolation of a license. Restoration plans could be required to reverse environmental damage, with boththe development of the plans and the costs of their implementation being the responsibility of thosefound to have caused the environmental damage.

3.1 Ugandan Environmental Regulations

In its compilation in April 2004 of laws relating to the environment, NEMA identified 24 laws that itconsidered major and of primary importance for lead agencies and others involved in environmentalenforcement. The NEMA document was current through December 31, 2003 and addressedeverything from industrial regulation, such as the Mining Act of 2003, to resource protection such asthe Water (Waste Discharge) Regulations of 1998. Only a limited number of these are applicable tothe proposed project. The key aspects of the laws and regulations that are fundamental to anassessment of the UEDCL assets and a determination of contamination are summarized below.

The National Environment Act

This act, which was passed in 1995, establishes the basic framework for current environmentalregulation in Uganda. It has 16 parts that deal separately with institutional arrangements, planning,regulation, standards, environmental management, pollution control, environmental restoration orders,recordkeeping, and fines and penalties. Among the important definitions contained in Part I of the actare the following:

* A hazardous substance is any chemical or waste which is injurious to human health or theenvironment.

* A mixture containing oil means a mixture with a specific content defined by the Ministry or ifsuch content is not specified, a mixture with an oil content of at least one hundred parts permillion.

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* Oil includes crude oil, diesel oil, fuel oil and lubricating oil.

* An owner is defined to include the registered proprietor as well as the lessee.

* A pollutant is any liquid, solid or gas which directly or indirectly alters the quality of thereceiving environment so as to adversely affect its beneficial use or is hazardous orpotentially hazardous to human health.

Pollution, therefore, means any direct or indirect alternation of the physical, thermal, chemical orbiological properties of the environment resulting from discharging, emitting or depositing wastes so asto adversely affect beneficial use. Pollution licenses are required for activities that would result inexceedance of established standards and guidelines.

The institution set up to carry out the provisions of the act starts at the federal level with a nationalauthority, NEMA, supported by various boards, committees and staff. It also specifies districtcommittees and district environmental officers as well as local environment committees. There is aconcerted effort to provide linkages to the many ministries and non-governmental groups whoseactivities have the potential to affect the environment. With a current total of 56 districts in Uganda theresult is an extensive array of those involved in environmental review and enforcement.

Part V of the act establishes the need for environmental impact assessment of activities with thepotential for significant impact to the environment. Under the third schedule of this part, activitiesrelated to electrical infrastructure, specifically electrical substations, are projects to be considered forenvironmental impact assessment. The results of an environmental impact assessment aredocumented in an environmental impact statement. Environmental inspectors, per Section 22, arecharged with performing environmental audits to determine conformance with predictions made in anenvironmental impact statement.

Part VI stipulates that standards will be set for air quality, water quality, the discharge of effluents towater, odor, noise, vibration, and soil quality. As of the date of this report, water quality, effluent, andnoise standards have been established. Air quality standards were published in 2000, but remain onlyin draft form. No regulations have yet been promulgated that relate to disposal of substances in soil.Section 56 establishes that the person who discharges a hazardous substance, chemical, oil or amixture containing oil into any waters or other segment of the environment that is in violation of alicense or permit, has committed an offense and must pay the cost of removal as well as the costs toany third party that include reparation, restoration, restitution or compensation. Part IX establishes theenvironmental restoration order as the mechanism for specifying the terms and conditions of theresulting obligations.

Part XII establishes that fines shall be levied for those who refuse environmental inspection, refuse toprepare a required environmental impact assessment, fail to keep required records, or violateenvironmental standards and guidelines. Fines can also be levied for failure to properly manage

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chemicals and hazardous waste, improper disposal of chemicals and hazardous waste, andwithholding information about the management of chemicals and hazardous wastes.

The Land Act

Part 1ll, Section 43 of the act establishes that the owner or occupant of land must manage and use theland in accordance with all laws including the Forests Act, the National Environment Act, the Water Actand the Uganda Wildlife Act. The subsequent section establishes the need to protect sensitive areasthat are defined to include natural lakes, rivers, ground water, natural ponds and streams, wetlands,forest reserves and national parks. Licenses or permits are required in order to obstruct, dam, divert orpollute any of the above water resources.

The Environmental Impact Assessment Regulations, 1998

Most of the substations in the UEDCL system were constructed before this regulation took effect.Future activities, including new stations as well as major repairs, extensions and routine maintenanceof existing infrastructure, would be subject to the regulation. Equipment replacement and rehabilitationwithin the confines of existing substations, as envisioned in this project, would be exempt from thisregulation.

The National Environment (Waste Management) Regulations, 1999

These regulations are directed at the storage and disposal of all wastes, including domestic waste, andto the licensing of waste disposal facilities including landfills, sanitary fills and incinerators. At thesource, hazardous wastes are to be separated from non hazardous wastes. Licenses are required forthe transport and storage of waste. Industrial waste cannot be discharged or disposed of withoutproper treatment. Waste treatment plants or disposal sites must be at least 1000 meters fromresidential areas, commercial areas and water sources.

Wastes are defined as hazardous based on corrosiveness, carcinogenity, flammability, persistence,toxicity or radioactivity. Hazardous wastes are listed in the 'fifth schedule" of a statutory instrumentsupplement (S.l. No. 30, published in 1999). This fifth schedule calls out PCB-containing waste asbeing a hazardous waste. Those licensed to transport or store waste must conform to requiremrentsregarding labeling of waste, provision of appropriate storage facilities, and training of employeeshandling waste. Licenses issued for the transportation or storage of waste are valid for one year.

The National Environment (Wetlands, River Banks and Lake Shores Management) Regulations,2000

This regulation defines water to include rivers, streams, reservoirs, wells, dams, canals, channels,lakes, swamps, open drains or underground water. A wetland is an area that is permanently or

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seasonally flooded and includes swamps, mambos, peatland, mountain bogs, riverbanks, as well asareas of impeded drainage. The principle of sustainable use originally set forth in the NationalEnvironment Act is reinforced, as is the need for environmental impact assessment prior to initiatingdevelopment. Wetlands can either be fully protected, partially protected or subject to conservation bythe local community. Those undertaking activities adjacent to wetlands are obligated to prevent thedegradation or destruction of the wetland and maintain the ecological and other functions of thewetland. Those failing to do so are considered to have committed an offense. Part IlIl of the Actaddresses river banks and lake shores. Depending on the classification of the river, a protection zoneis defined at either 100 meters or 30 meters of the high water mark. No activity can be conductedwithin the protection zone without prior approval. Lake shores similarly have protection zones of 200meters or 100 meters of the low water mark, depending on their classification. Wetlands, river banksand lake shores that have been degraded are subject to the issuance of a restoration order.

The Water (Waste Discharge) Regulations, 1998

These regulations define waste to include sewage and any other matter that if solid, liquid or gaseouswhen added to water could cause pollution. Discharge to land or water is done subject to a permit.Accidental discharges must be reported within 24 hours and carry the obligation to mitigate thedamage resulting from the accidental discharge. Environmental inspectors are empowered to sampleand analyze at any time activities specified in a discharge permit.

3.2 World Bank Group Safeguard Policies and Environmental Guidelines

The World Bank Group has developed an extensive set of policies, sectoral guidelines, and projectreview procedures and guidance notes to guide loan applicants through the environmental review thatis required as part of bank participation in a project. The World Bank's environmental and socialsafeguard policies, often referred to simply as the safeguard policies, are fundamental to theprevention and mitigation of harm to both people and their environment. The World Bank safeguardpolicy that may be applicable to the proposed project is the following:

Environmental Assessment (OP 4.01): This policy seeks to ensure that Bank supportedprojects are environmentally sound and that the full range of environmental risks and impactsare considered during project review. Project assessments consider all aspects of the naturaland human environment and seek to prevent impacts whenever possible.

World Bank sectoral guidelines are more focused and relate to the evaluation of existing conditionsand the determination of the need for remediation. The sectoral guidelines that are applicable to theUEDCL system are summarized below.

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Electric Power Transmission and Distribution

This environmental, health and safety guideline was developed by the International FinanceCorporation. It is applicable to electric power transmission and distribution systems and includestransmitting stations, switches and related equipment. It includes specifications for the development ofrights of way, ambient noise, and solid and liquid wastes. It specifically prohibits the installation ofnew PCB containing transformers and directs that any existing equipment that contains PCBs will bephased out. New process equipment and central cooling systems should be free of CFCs and existingequipment that contains CEO should be phased out. Storage and liquid impoundment areas for fuels,solvents and wastes should be designed with secondary containment to prevent spills andcontamination of soil, groundwater and surface water.

Polychlorinated Biphenyls (PCBs)

Also developed by the International Finance Corporation, these guidelines identify the majorenvironmental issues associated with the use, maintenance and disposal of PCB transformers andPCB contaminated equipment. The guideline notes that the World Bank allows for PCB equipment toremain in service but that PCB-free transformers must be installed as old transformers are replaced.Labeling is required on all equipment where PCB concentrations exceed 50 ppm. This labeling appliesto in-service equipment as well as equipment that has been taken out of service. Monitoring isrequired on a regular basis for all transformers and storage sites. Where leaks are identified,equipment must be immediately removed from service. Where retrofilling is preferred to replacement,dielectric fluid must be removed and filtered prior to being returned to the same unit. Any equipmentcontaining more than 500 grams of PCB mixture can only be transported under specified conditions.Wastes containing more than 50 ppm PCB must be secured and monitored prior to disposal. Areasused for storage must have roofs and walls sufficient to prevent water from reaching the storedmaterials. Storage areas must have a concrete floor with continuous curbing and must have no drains,joint lines, sewer lines or other openings that would allow liquids to flow from the curbed area. Thepreferred means of disposal is via high temperature incineration where there is a minimumtemperature of 1200 0C and a residence time of more than 2 seconds, achieving 99.99 percentdestruction. Chemical dechlorination is an option or for properly packaged PCB articles disposal in ahazardous waste landfill. Because of the danger associated with exposure to PCBs, all transformersites must be secured against unauthorized access.

Project Specific Environmental Audit

The environmental audit is used to determine the nature and extent of all environmental areas ofconcern at an existing facility. The audit identifies and justifies appropriate measures to mitigate theareas of concern, estimates the cost of the measures and recommends a schedule for implementingthem. As regards the proposed distribution investment component, the objective of the environmentalaudit is to identify present pollution and its potential clean-up costs, inadequate environmental

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management, and occupational health and safety issues in the facilities to be rehabilitated and todetermine the need for remedial actions necessary to bring these facilities into compliance with WorldBank safeguard policies and to recommend actions to improve and strengthen Umeme'senvironmental, health and safety management, if required. The audit is carried out by an independentparty. The audit results are documented in a report which summarizes the project, the applicableenvironmental regulations, the approach used in the audit, and the areas of concern. As appropriate,mitigation measures are identified and estimates provided for the cost of implementing the mitigationmeasures.

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4.0 ENVIRONMENTAL REVIEW FINDINGS

The environmental review of the UEDCL facilities was completed during a two-week visit to Uganda,from August 2 to August 13, 2004. Based on the sampling previously described, ENSR's reviewincluded visits to facilities potentially affected by the proposed IDA-funded rehabilitation (twenty-eight33 kV/1 1 kV substations) and a general visual inspection of distribution lines and distributiontransformers. Each facility was inspected with regard to potential for environmental contamination;specifically that which could be affected by planned rehabilitation activities.

4.1 Observations

4.1.1 Substations

ENSR visited twenty-eight of UEDCL's fifty-three 33 kV/1 1 kV substations, including both oldersubstations and substations reconstructed after 1990 using funding provided by the German,Japanese and Swiss governments. The 33 kV/1 1 kV substations had many similarities, with typicalelectrical equipment consisting of one or two power transformers and associated switchgear, batteryareas and circuit breakers. Substations reconstructed using funding by each foreign government tendto be very similar across the system.

The German and Swiss type substations typically contain a small on-site building (plant house). Theplant houses contain a battery room, a switchgear room and room for the station transformer. Most ofthe buildings are constructed of concrete block with metal roofing. Ventilation for the battery room isprovided by vents, placed high and low on separate exterior walls. Floors are epoxy-covered to resistcorrosion from any spilled acid. The Japanese substations feature switchgear and batteries in self-contained weatherproof units that are directly accessed from the exterior. Batteries are also enclosedin such units, which are typically of metal construction with rubber seals to prevent the intrusion ofwater. The older substations tend to be smaller facilities that contain exterior switch gearing andbattery boxes mounted on wooden poles.

The ages of the 33 kV/1 1 kV substations range from 3 to 68 years. Each substation is manned only bya security guard and has fencing and controlled access. These substations are inspected for properoperation on an occasional basis (reportedly twice per year) by UEDCL employees. It is during theseinspections that any releases/leaks of dielectric fluid from the electrical equipment are identified. Amore detailed inspection is done annually. Records of these inspections are maintained at the mainoffice.

As discussed above, the substations share many similarities and, during the course of the review,certain issues of concern appeared to be in common between different facilities. Thus, a generaloverview of issues affecting the system is offered. As the proposed rehabilitation at substations is

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associated with replacement of power transformers and switchgear, these units were the primary focusof the review and are addressed below.

The 33 kV/ 11kV transformers at almost every site visited by ENSR were observed to containtransformer oil leaks. In most cases, the leaks were relatively minor in nature, affecting the concretepad and perhaps a small area of adjacent soil. Overall, the Japanese manufactured units appeared tobe in the best condition with the least amount of leakage observed. The worst facilities were the oldestones, which had not been retrofitted or renovated. Three substations had what was consideredserious leakage of transformer oil to the soil. At one of these substations, this leak potentially couldimpact the local water supply system. For the most part, the releases appear to have impactedshallow soil and would not be complicated to remediate (i.e., removal of a few shovels full of soil).

4.1.2 Distribution Lines

During the course of visits to the substations, ENSR inspected a representative subset of distributionlines, focusing on right-of-way management (i.e., tree trimming). Based on interviews with UEDCLpersonnel and observations during the environmental review, most of UEDCL's distribution linesextend along roadways and, therefore, require minimal right-of-way maintenance. Where linestraverse undeveloped lands, the company's practice is to install towers that exceed the height ofsurrounding vegetation, thereby significantly reducing or eliminating the need to clear vegetation bymechanical or chemical means.

For the lines along the roadside or that are at or below tree-top level, according to UEDCLmanagement personnel, trees are not cut down unless absolutely necessary. Typically, thevegetation/branches on trees that are directly in the path of the distribution lines are removed.UEDCL also minimizes environmental disturbance by not maintaining access roads beneathdistribution lines. Very little in the way of tree trimming or maintenance appears to be conducted byUEDCL, and no chemicals are used for this purpose. According to representatives of UEDCL, noherbicides are used due to the relatively high cost of using such methods of clearance.

Vegetation control within UEDCL's primary substations is accomplished almost entirely manually (i.e.,by hand). However, some herbicides use was observed at one substation (Ggaba), where all of thevegetation within the station had been killed. This appeared to be the exception however, and was notobserved elsewhere within the system.

Most of the connections appeared to be acceptable; however, certain areas were observed to containillegal connections and substandard wiring as a result.

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5.0 ENVIRONMENTAL ISSUES AND CORRECTIVE ACTIONS

Section 1.0 (Introduction) of this report provided an overview of the planned distribution systemrehabilitation program which is to be funded by IDA. This section provides a more detailed descriptionof the types of construction activities envisioned. Based on these activities and environmental reviewfindings, this section identifies potential environmental concerns and recommends the correctiveactions to be taken to address these concerns.

5.1 Description of Rehabilitation Activities and Potential Associated Environmental Issues

5.1.1 Substation Transformer Rehabilitation

The 33/11 kV and 11 kV/400V transformer rehabilitation program will consist of removal of existing olderand/or leaky primary electrical transformers at distribution system substations, replacement with newtransformer units, and (at certain locations) installation of new switchgear. At certain locations,transformer rehabilitation will likely involve removal of an existing transformer from an existing concretepad and placement of a new transformer in the same location on the same concrete pad. At otherlocations (e.g. at substations located in ecologically sensitive areas), this may involve removal of botha transformer and the pad on which it currently sits, installation of a concrete secondary containmentpit, and installation of a new transformer above the new containment pit.

Potential environmental issues associated with these activities include:

* Removal of oil from the old transformer and disposal of the transformer and the oil (note thatit is possible that the oil in these older units may contain PCBs);

* Where existing concrete pads are replaced with new concrete containment pits, excavationfor new pits will involve disturbance of soil which may be oil-contaminated and/or PCBcontaminated.

5.1.2 Pole and Conductor Replacement

The overall system rehabilitation program will include a structural improvement component in whichdamaged and/or broken wooden distribution system poles will be replaced with new, structurally soundpoles and damaged conductor will be replaced with new conductor. It is likely that new poles will bewood poles, although the potential use of concrete poles (if economically feasible) will be evaluated.Pole replacement will likely be implemented in one of three ways:

* Removal/disposal of the existing pole and insertion of the new pole in the existing hole,

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* Removal/disposal of the existing pole, backfill of the old hole, and augering of a new hole forthe new pole, or

• Leaving the existing pole in-place (with lines attached) and placing the new poleimmediately adjacent to the existing pole in a newly augered hole. This is sometimes donewhen there are numerous lines on the existing pole and the new pole is needed only to lendstructural support to the existing pole.

Potential environmental issues associated with pole replacement are relatively insignificant andinclude:

* Appropriate disposal of the old poles and

* Management of soil removed during pole augering activities, including inspection forcontamination and appropriate stockpiling to minimize the potential for sediment instormwater runoff.

It is expected that there will be no significant environmental issues associated with replacement ofconductor.

5.1.3 Installation of Distribution Transformers

New distribution transformers will be installed both as replacement for certain failing existingdistribution transformers and in association with the extension of electrical service to new customers(e.g., in support of the 18,900 new electricity connections included in the rehabilitation program).Distribution transformer installation will most often involve removal of an old pole-mounted distributiontransformer and installation of a new distribution transformer at the same location. New distributiontransformers may also be installed either on existing or newly installed distribution system poles.

The only potential environmental issues associated with installation of distribution transformer wouldinvolve the removal of oil from the old distribution transformer and disposal of the transformer and theoil. As with substation transformers, it is possible that the oil contained in older distributiontransformers could contain PCBs.

5.1.4 Installation of New Electricity Connections

The funded rehabilitation program will include the installation of approximately 18,900 new peri-urbanelectricity connections. In most cases, this is expected to involve the installation of a new service wirefrom an existing pole in the street to the point of connection at residential or commercial building andthe installation of a new meter/circuit breaker at the connection point. In certain cases, extension ofservice may also involve installation of one or more new poles (depending on the distance from thedistribution system to the connection point) and possibly could include installation of a new distribution

QA\mw97\Projects\1 06401 \500\aII.doc 5~-2 December, 2004

transformer. Potential environmental issues for installation of new service connections will be relativelyinsignificant and similar to those discussed previously under pole replacement and installation ofdistribution transformers.

5.2 Recommended Corrective Actions

The several activities associated with the proposed system rehabilitation are limited in their potential toimpact the environment. It is expected that only activities associated with transformer replacement(both substation transformers and distribution transformers) and installation of new poles could,potentially have environmental consequences. All other activities are simple equipment replacementsthat are interior to buildings or the installation of new equipment that would result in no disturbance tothe environment.

As noted above, the primary concern related to transformer replacement at substations is related to thehandling and disposal of the old transformers (and associated oil). It is possible that these older unitsmay contain PCBs, which could trigger specific handling, storage, labeling and disposal requirementsfor the unit and the oil. Older distribution transformers could possibly also contain PCBs. Soildisturbance at certain substations, associated with installation of secondary containment pits, may alsobe an issue, as the soil may contain oil and possibly PCBs. Environmental concerns related to polereplacement are primarily associated with the disposal of old poles (likely containing creosote) and, toa lesser degree, the management of soil removed from augered holes. The corrective actions andrecommendations to achieve good environmental management are listed below. Also listed are aseries of organizational activities that should occur to insure proper training on the part of involvedoperations staff and proper coordination with NEMA.

5.2.1 Transformer Replacement

Listed below are corrective actions (i.e., mitigative measures) that are recommended to minimizepotential environmental impacts associated with the replacement of transformers and disposal of oldunits and their oil:

1. New transformer units and new transformer oil will be 'PCB-free", in accordance with in-placeUEDCL (and future Umeme) technical specifications.

2. Prior to implementing the transformer replacement program, UEDCL/Umeme should consultwith NEMA relative to the proximity of substations to known areas of ecological sensitivity.Special procedures prescribed by NEMA should be incorporated into the overall transformerinstallation plan that will be followed during the replacement process.

3. Based on the discussions with NEMA, UEDCL/Umeme should prioritize the order ofsubstations for equipment replacement, working first at stations that are in ecologically

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m m m m m m~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

sensitive areas. Where called for (due to observed significant soil staining), soil andgroundwater testing should be conducted as directed by NEMA to ensure that prior activitiesas well as replacement activities will not compromise area resources.

4. A checklist for how to conduct the transformer replacement activities should be developed.This checklist will serve to inventory existing site conditions, noting in particular evidence andextent of leaks. Samples of transformer oil should be taken and tested so as to classify howthe old transformer should be handled. If a transformer is found to have PCB-containing oils,then separate and appropriate procedures should be followed. If the transformer does notcontain such oils, the replacement can proceed, again following a prescribed protocolestablished to ensure that oil containing liquids are not spilled on or off site, solid waste iscollected and transported back to a central location, and any disturbance to areas outside thesubstation is restored to the condition that it was prior to the replacement activity.

5. Where it is determined that spill containment pits should be installed beneath new transformerunits, this will be done following a prescribed protocol again established to ensure that thereare no off site environmental impacts. This protocol, for example, would direct that disturbedsoils be stockpiled for reuse on site. Any liquid wastes generated as part of on-site concretemaking should be collected in barrels that will be returned to a central facility for consolidationand disposal with other similar materials.

6. Operations staff who will be involved in the transformer replacement activities will be properlytrained in the requirements associated with the handling and disposal of PCB containingmaterials. Their maintenance vehicles will be equipped with proper personal protectiveclothing/equipment and with appropriate spill containment/cleanup equipment. It isrecommended that each work crew be provided with a notebook containing a full set of theprotocols associated with all work anticipated at the substations. This notebook should beprepared prior to and made an integral part of what would be a one day refresher course forthe operations staff.

7. A central location should be established which will be used to store old transformers andcollected solid and liquid wastes. Wastes identified as hazardous will be separated, labeledand handled appropriately. In concert with NEMA, these wastes will be disposed of inaccordance with applicable Ugandan regulations.

5.2.2 Pole Replacement

Listed below are corrective actions (i.e., mitigative measures) that are recommended to minimizepotential environmental impacts associated with pole replacement:

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1. To minimize environmental impacts, to the extent practicable, new poles should be placed inthe same locations as existing poles. If new locations are used, excavated soils should beinspected for contamination (e.g., presence of oils) and, as appropriate, collected andtransported to the central disposal facility.

2. Old poles, which it is assumed have been treated with creosote, should be collected andreturned to the designated collection facility and not left in the local area where they could beused for fuel or other domestic purposes.

3. Consideration should be given to the use of cement or steel structures. If wooden poles are tobe used, every effort should be taken to ensure that they are purchased from a source that hasprepared them properly.

5.2.3 Consultation with NEMA and General Recommendations

As noted, several activities should be done in concert with NEMA. NEMA is the federal body chargedwith protection of the environment. They have an established network of district officers charged withseeing that Uganda's environmental laws are carried out and are responsible for the monitoring ofactivities that have a potential to impact the environment. UEDCLUUmeme will need to work withNEMA. This interaction should involve first discussions at the federal level, to define the overallrehabilitation program. UEDCUUmeme should then interact with NEMA on the local level by workingwith the district officers during the actual implementation effort.

It is recommended that UEDCL/Umeme be proactive in this regard and work with NEMA to use theseveral reporting mechanisms that it has established to report on its program. It is expected thatUEDCUUmeme will have one person charged with overall responsibility for environmental maKters forthe company and that he/she will serve as the main point of contact with NEMA in Kampala. It is alsoexpected that at least two regional environmental officers will be appointed within UEDCUUmeme andthat these persons will serve as the main points of contact with NEMA within their region.

Based on the results of the environmental review, there is no recommendation at this time to prepare asystem-wide remediation action plan. Substations were identified as having a low potential for off siteenvironmental impact and were not identified as presenting an imminent threat to human health andthe environment. Should soil and groundwater testing programs a particular location identify offsiteimpacts, site specific remediation plans would be developed and reviewed with NEMA.

5.3 Cost Estimate for Implementation of Rehabilitation-Related Mitigation

The key components of the corrective actions and/or mitigation called for in this section are thefollowing:

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(i) the appointment of an Environmental Manager and at least two Regional EnvironmentalOfficers to be responsible for the environmental aspects of Umeme's operations;

(ii) training for employees involved in the rehabilitation program;(iii) implementation of soil and groundwater testing (on a site-specific basis);(iv) coordination with NEMA with respect to scoping work in ecologically sensitive areas and

recordkeeping/monitoring requirements; and(v) development of environmental policies and procedures for rehabilitation activities (for

incorporation into the Environmental Management Plan).

The table below presents a cost estimate for these activities.

EstimatedAction Cost (U.S. $) Timing Responsible Entity

Salary for Environmental Manager and Two years UmemeDistrict Managers January 31,(assume 1 full-time Environmental Manager $130,000 2005 - Januaryand two half-time District Managers) over a 31, 2007two-year period.Environmental training for employees May 1, 2005 - Umemeinvolved with rehabilitation $10 000 June 1, 2005(assume implementation of trainingprogram for 15 to 20 employees)Implementation of soil/groundwater testing June 1, 2005 - Umemeon a site-specific basis $15,000 August 1, 2005(assume testing at 10 substation sites)Coordination activities with NEMA February 1, Umemeregarding rehabilitation activities in $10,000 2005 - May 1,ecologically sensitive areas and 2005monitoring/recordkeeping requirementsDevelopment of environmental policies and February 1, Umemeprocedures for rehabilitation activities (for $50,000 2005 - May 1,incorporation into the Environmental 2005Management Plan) I_IEstimated Total Costs $215,000 I I

Staffing and training to implement the proposed rehabilitation program in a manner that is consistentwith good environmental practices is estimated to cost approximately 215,000 (U.S. dollars). Prior toinitiating the rehabilitation program, necessary task-specific environmental policies and procedures willbe developed and incorporated into Umeme's Environmental Management Plan (EMP). Thesepolicies and procedures will serve as the basis for a training program for the staff from each districtresponsible for implementation of the rehabilitation program and for implementation of site-specific soiland groundwater testing programs.

Umeme will be responsible for the implementation of the EMP for the IDA-financed distributionrehabilitation activities and employee training and will work closely with NEMA to ensure that staff are

Q\mw97\Projects\10694001\500\ail.doc 5-6 December, 2004

trained in methods acceptable to the agency. Umeme will also consult with NEMA regardingrehabilitation activities in ecologically sensitive areas and with regard to appropriate monitoring andrecord keeping requirements and will report semi-annually to UEDCL on progress made in theimplementation of the EMP.

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m - -~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

6.0 ENVIRONMENTAL MANAGEMENT PLAN

Umeme is working with the Government of Uganda and the World Bank's International DevelopmentAssociation (IDA) to finance the rehabilitation of the distribution systems under IDA's Power IV Project(Credit 3545-TA). Proposed work includes rehabilitation of distribution system substations (repair orreplacement of 33 kV/1 1 kV transformers, 11 kV/ 400 V transformers, and switchgear), replacement ofpoles and conductor, repair or replacement of distribution transformers, and completion of as many as18,900 new electricity connections.

The Environmental Management Plan (EMP) that follows provides an overview of the mitigation,monitoring and institutional measures that should be taken to ensure that the implementedrehabilitation program would comply with Ugandan environmental regulations and follows what areaccepted standards of good environmental management (e.g., World Bank safeguards). This EMPbuilds upon the potential impacts and corrective actions/recommended actions identified in Section 5of this report and establishes the framework for the development of a more definitive management plangoing forward.

The EMP should be viewed as a living document that will be updated to reflect changes and/orincorporate additional information as the scope and location of the rehabilitation activities are furtherdeveloped and as initial rehabilitation activities are undertaken. Details related to required monitoringand reporting should be incorporated as they are developed, both intemally and based on interactionswith NEMA. Given that the distribution system is an existing system being taken over by a neworganization, only a broad new organizational framework is specified. The framework builds from theregulatory structure within Uganda, but would be expected to be revised and updated as the neworganization acquires it own operational experience.

The following sections of the plan address the potential impacts of the rehabilitation program based onplanned activities and environmental review observations, mitigation measures needed to correctcurrent problems and reduce the potential for future environmental effects, monitoring andrecordkeeping required to confirm that mitigation is being accomplished and, lastly, the environmentalorganization that will be needed in order to execute the plan. The starting premise for the plan isacceptance of the dual responsibility to provide reliable electricity and operate in the sustainablemanner prescribed by Ugandan law.

6.1 Summary of Impacts

Potential impacts of the rehabilitation programs have been discussed previously in Section 5 and aresummarized in this EMP section. The several activities associated with the proposed systemrehabilitation are limited in their potential to impact the environment. It is expected that only activitiesassociated with transformer replacement could potentially have environmental consequences. All

Q:\mw97\Projects\10694001\500\aIl.doc 6-1 December, 2004

other activities are simple equipment replacements that are interior to buildings or the installation ofnew equipment that would result in no disturbance to the environment.

The primary concern related to transformer replacement at substations is related to the handling anddisposal of the old transformers (and associated oil). It is possible that these older units may containPCBs, which would trigger specific handling, storage, labeling and disposal requirements for the unitand the oil. Older distribution transformers could possibly also contain PCBs. Soil disturbance atcertain substations, associated with installation of secondary containment pits, may also be an issue,as the soil may contain oil and possibly PCBs. Environmental concerns related to pole replacementare primarily associated with the disposal of old poles (likely containing creosote) and, to a lesserdegree, the management of soil removed from augered holes.

6.2 Mitigation Measures

Mitigation measures and corrective actions associated with the rehabilitation program have beendiscussed previously in Section 5 and are repeated here to form the initial component of this EMP.

6.2.1 Transformer Replacement

Listed below are corrective actions (i.e., mitigative measures) that are recommended to minimizepotential environmental impacts associated with the replacement of transformers and disposal of oldunits and their oil:

1. New transformer units and new transformer oil will be 'PCB-free", in accordance with in-placeUEDCL (and future Umeme) technical specifications.

2. Prior to implementing the transformer replacement program, UEDCUUmeme should consultwith NEMA relative to the proximity of substations to known areas of ecological sensitivity.Special procedures prescribed by NEMA should be incorporated into the overall transformerinstallation plan that will be followed during the replacement process.

3. Based on the discussions with NEMA, UEDCL/Umeme should prioritize the order ofsubstations for equipment replacement, working first at stations that are in ecologicallysensitive areas. Where called for (due to observed significant soil staining), soil andgroundwater testing should be conducted as directed by NEMA to ensure that prior activitiesas well as replacement activities will not compromise area resources.

4. A checklist for how to conduct the transformer replacement activities should be developed.This checklist will serve to inventory existing site conditions, noting in particular evidence andextent of leaks. Samples of transformer oil should be taken and tested so as to classify howthe old transformer should be handled. If a transformer is found to have PCB-containing oils,

Q:\mw97\Projects\1 0694001\500\a11.doc 6-2 December, 2004

then separate and appropriate procedures should be followed. If the transformer does notcontain such oils, the replacement can proceed, again following a prescribed protocolestablished to ensure that oil containing liquids are not spilled on or off site, solid waste iscollected and transported back to a central location, and any disturbance to areas outside thesubstation is restored to the condition that it was prior to the replacement activity.

5. Where it is determined that spill containment pits should be installed beneath new transformerunits, this will be done following a prescribed protocol again established to ensure that thereare no off site environmental impacts. This protocol, for example, would direct that disturbedsoils are stockpiled for reuse on site. Any liquid wastes generated as part of on-site concretemaking should be collected in barrels that will be returned to a central facility for consolidationand disposal with other similar materials.

6. Operations staff who will be involved in the transformer replacement activities will be properlytrained in the requirements associated with the handling and disposal of PCB containingmaterials. Their maintenance vehicles will be equipped with proper personal protectiveclothing/equipment and with appropriate spill containment/cleanup equipment. It isrecommended that each work crew be provided with a notebook containing a full set of theprotocols associated with all work anticipated at the substations. This notebook should beprepared prior to and made an integral part of what would be a one day refresher course forthe operations staff.

7. A central location should be established which will be used to store old transformers andcollected solid and liquid wastes. Wastes identified as hazardous will be separated, labeledand handled appropriately. In concert with NEMA, these wastes will be disposed of inaccordance with applicable Ugandan regulations.

6.2.2 Pole Replacement

Listed below are corrective actions (i.e., mitigative measures) that are recommended to minimizepotential environmental impacts associated with pole replacement:

1. To minimize environmental impacts, to the extent practicable, new poles should be placed inthe same locations as existing poles. If new locations are used, excavated soils should beinspected for contamination (e.g., presence of oils) and, as appropriate, collected andtransported to the central disposal facility.

2. Old poles, which it is assumed have been treated with creosote, should be collected andreturned to the designated collection facility and not left in the local area where they could beused for fuel or other domestic purposes.

Qa\mwO7\Projects\1 0694001 \500 I.doc 6-3 December. 2004

l~~~~~~~~~~~ l l

3. Consideration should be given to the use of cement or steel structures. If wooden poles are tobe used, every effort should be taken to ensure that they are purchased from a source that hasprepared them properly.

6.2.3 Consultation with NEMA and General Recommendations

As noted, several activities should be done in concert with NEMA. NEMA is the federal body chargedwith protection of the environment. They have an established network of district officers charged withseeing that Uganda's environmental laws are carried out and are responsible for the monitoring ofactivities that have a potential to impact the environment. UEDCUUmeme will need to work withNEMA. This interaction should involve first discussions at the federal level, to define the overallrehabilitation program. UEDCUUmeme should then interact with NEMA on the local level by workingwith the district officers during the actual implementation effort.

It is recommended that UEDCUUmeme be proactive in this regard and work with NEMA to use theseveral reporting mechanisms that it has established to report on its program. It is expected thatUEDCUUmeme will have one person charged with overall responsibility for environmental matters forthe company and that he/she will serve as the main point of contact with NEMA in Kampala. It is alsoexpected that at least two regional environmental officers will be appointed within UEDCUUmeme andthat these persons will serve as the main points of contact with NEMA within their region.

Based on the results of the environmental review, there is no recommendation at this time to prepare asystem-wide remediation action plan. Substations were identified as having a low potential for off siteenvironmental impact and were not identified as presenting an imminent threat to human health andthe environment. Should soil and groundwater testing programs a particular location identify offsiteimpacts, site specific remediation plans would be developed and reviewed with NEMA.

6.3 Monitoring and Recordkeeping

The purpose of monitoring and recordkeeping is twofold: the first is to respond to regulatoryrequirements to monitor permitted discharges and emissions and the second is to maintain the recordsthat can demonstrate that committed mitigation is being implemented.

Based on a review of existing Ugandan environmental laws and regulations, it appears that most of theactivities to be conducted as part of the rehabilitation program would not require specific environmentalpermits. There is a possibility that certain activities, primarily associated with storage and disposal ofwastes (especially if PCBs are present), could be deemed subject to permit requirements; however, afurther review of the on-going storage/disposal practices and interpretation of the existing regulationswould be required to confirm if any permits are required.

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In general, environmental regulations have slowly come into effect in Uganda since the passage of theNational Environment Act in 1995. While the "third schedule" of the Act includes "electricalinfrastructure" among the listed facilities requiring environmental impact assessment and associatedapproval, most of the distribution system was in place before this requirement took effect. Goingforward, new facilities could be subject to the environmental impact assessment requirements of theAct. Current and future operations may also be subject to additional environmental permitting and/ormonitoring requirements, due to finalization and revision of existing regulations are promulgation ofnew regulations. It does not appear, however, that rehabilitation activities would be of the scope ormagnitude to warrant development of a formal environmental impact assessment.

Recordkeeping is essential to good environmental stewardship. Umeme will review the limited recordsthat UEDCL has maintained and consider, within the context of its staff and their resources, how bestto develop and implement the following recordkeeping components:

1. Inspection records that document facility conditions on a regular basis. This would includeevaluation of the condition of existing substation transformers and switchgear, distributiontransformers, and poles to facilitate decisions regarding rehabilitation priorities.

2. Equipment and chemical inventory records that track the types, quantities and characteristicsof all equipment and chemicals purchased for facility operation and/or stored at the variousfacilities. This would provide confirmatory information regarding the presence of PCBs at thevarious facilities and within the various transformer units.

3. Waste management records that track the amount and types of waste generated (especiallyPCB containing oils (if any), mercury containing light bulbs and asbestos) and where and howthese wastes are disposed. Transformers removed as part of the rehabilitation program wouldbe included in these records.

4. Development of checklists to be used for the various rehabilitation programs with potentialenvironmental impacts (transformer replacement, pole replacement, etc.)

Each of these systems will be important to the long-term environmental stewardship of the Umemesystem.

6.4 Institutional Support

Several institutional challenges exist in terms of achieving good environmental stewardship. One ofthe major challenges will be to overcome tradition and establish work practices that are not widelyrecognized in industrial operations in Uganda. It will be important to address this, as withoutenvironmental awareness on the part of employees and training in the proper handling and disposal ofchemicals and materials used in system operation, all efforts at remediation will have been in vain.

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I~~~~~~~~ I M

Recognizing the need to create a new climate of environmental awareness, the following steps areseen as critical in Umeme's development of a system-wide environmental support organization withinthe larger distribution system:

1. A single person will be identified to have overall responsibility for environmental mattersthroughout the distribution system. This person will be an experienced environmentalprofessional familiar with material handling requirements and the basic aspects of goodenvironmental management. Umeme will expand on the preliminary organization specifiedhere, develop the monitoring and recordkeeping systems identified above and draft a set ofgoals and objectives for the environmental performance of the distribution system. The latterwill be supported by company policies and procedures and will specify environmentalperformance related to operational activities, rehabilitation and eventually new development.

2. The environmental manager's position is anticipated to be a full time position that initially maybe the only environmental position in the organization. As systems are developed, it would beexpected that at least two regional environmental officers to assist in the local/regionalimplementation of environmental. The regional environmental officers would be responsible,likely on a part time basis, for environmental matters at the facilities in their region. They wouldperform the routine facility inspections that are anticipated and be responsible for training staffat each facility in the proper handling of materials and equipment to ensure environmentalcompliance.

3. Early in the operation of the new system, it is expected that training would be conducted for allemployees. This training would include a session on environmental regulations applicable tothe distribution system, safe handling of chemicals and equipment used in the system, trainingin routine activities that could have environmental consequences and review of new wastemanagement systems, recordkeeping and monitoring. Depending on system requirements,this training may be done at the district level and combined with associated training health andsafety procedures.

4. To complement the initial effort of this Environmental Management Plan, environmentalpolicies and procedures will be developed and included in this document so that it will serve asreference document for employees. The document should include Ugandan specifiedreporting forms, sampling procedures, logs for all sampling activities and similar document.Copies of potentially applicable regulations should be also provided for reference.

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7.0 BIBLIOGRAPHY

ESG Intemational Inc. and WS Atkins. Budagali Hydropower Project Executive Summary. AES NilePower. Richmond, UK, March 2001.

ESG International Inc. and WS Atkins. Buiaaali Proiect Transmission System EIS. AES Nile Power.Richmond, UK, March 2001.

Food and Agriculture Organization of the United Nations. Case Study: Uganda.http://www.fao.org/docrep/003/x9419e/x9419eO7.htm

Hagler, Bailly. Environmental Review of UEB's Operations. October 15, 2000.

The International Bank for Reconstruction and Development. Pollution Prevention and AbatementHandbook 1998. Washington, D.C., 1999.

Karokora, Hon. Justice Alfred. Recent Developments in Uaanda Relating to Strengthening the Legaland Institutional Framework for Promoting Environmental Management.

National Environment Management Authority. Environmental Legislation of Uganda, Volume 1.Kampala, Uganda, April 1, 2004.

National Environment Management Authority. State of the Environment Report for Uganda.2000/2001. Kampala, Uganda, 2001.

National Environment Management Authority. Environmental Audit Guidelines for Uganda. Kampala,Uganda, 1999.

National Environment Management Authority. State of the Environment Report for Uganda. 1996.Kampala, Uganda, 1997.

National Environment Management Authority. State of the Environment Report for Uganda. 1994.Kampala, Uganda, 1995.

Malick Ak. John. Environmental and Social Management Framework for Kampala Industrial BusinessPark at Namanve. Uaanda Investment Authority. Kampala. Uganda, February 27, 2004.

The Ramsar Convention on Wetlands. National Report of Uganda for COP7.http://www.ramsar.org/cop7 nr uganda.htm

Q:\mw97\Projects\1 0694001\500\all.doc 7-1 December, 2004

Stone & Webster Management Consultants, Inc. Assessment of the CAPEX and OPEX of the UqandaElectricity Distribution Company. Houston, Texas, October, 2003.

United Nations Environment Programme. Joint Project on Environmental Law and Institutions inAfrica. Report on the Development and Harmonization of Environmental Standards in East Africa:Uganda Country Report. httx://www. unep.orm/padelia/publicationsNOLUME2U. htm

United Nations Environment Programme. Partnership for the Development of Environmental Lawsand Institutions in Africa. Part One: Framework Laws and Regulations, Uganda. 1996.http://www. unep.org/padelia/lublications/laws.html.

Q:\mw97\Projects\1 0694001\500\all.doc 7-2 December, 2004