REPUBLIC OF KENYA

MIN IS TR Y O F WAT ER AND IRRIGAT ION

L A K E V I C T O RI A N O RT H W A T E R CE N T R AL R I F T V A L L E Y W AT E R W O R K S
W O R K S DE V E L O P M E N T A G E N C Y D E V E L O P ME N T A G E N C Y

CO N S U L TA NC Y S ER VI C ES F O R D E S IG N R E VI E W A ND
CO N S T RU C T IO N S UP ER V IS IO N O F MA LA B A W AT E R S U P P LY AN D
S AN I TA T IO N P R O J EC T

DR AF T NE M A AP P EA L P AP ER

PREPARED BY
 1. Back ground Information on NEMA Application
The Environmental Impact Assessment for Malaba sanitation project was done and submitted to
NEMA in September 2019, the request for further public participation through adverts were
received in October 2019 and successfully advertised between December to January 2020 in the
local dailies, local radio and the Kenya Gazette and the same evidences submitted to NEMA.
The NEMA review process took a very long time and the 1st review comments were received on 17th
November 2020 which were adequately addressed and responses shared with NEMA on 14 th
January 2021. The advance copy of the second review comments were send to the agency on 4th
May 2021.
In the second review, the authority raised pertinent issues as shown below
i) The proposed site for the wastewater treatment plant extends into a wetland which is an
environmentally sensitive area.
ii) The wastewater treatment plant is located within two rivers i.e., Malakisi and Komiria rivers
that join downstream into Transboundary River Malaba draining into Lake Kyoga in
Uganda. River Malaba is a shared resource between Kenya and Uganda and there is No
evidence of consultation and/or notification with the Uganda Authorities in line with the
guidelines on shared resources in East Africa.
iii) A comprehensive risk assessment and analysis of alternatives of the project and its
associated facilities and amenities had not been undertaken to inform the project location
and have the appropriate environmental and social safeguards.
iv) Precautionary principle: the project has potential public health risks, transboundary
resource use conflicts and other uncertainties due to its scale and nature in relation to
adjacent environmentally sensitive area.

The Authority further advised as follows:

• The project proponent to seek an alternative site

• The is a right to appeal the decision at the National Environmental Tribunal (NET).:

This paper therefore has been prepared for submission to the authority for reconsideration for the
issuance of an EIA license under the provision of Emca 1999

The paper comprises of the following three sections

Sections 1 Demonstration of Technical Considerations

Section 2 ; Added Precautions Taken

Section 3 ; Environment and Social Interventions

 2. Demonstration of Technical Considerations
The scope and areas to be generally affected by the proposed project are:-

The Malaba sewerage project consists of two main areas:

a) Setting up a new sewerage pipeline system
b) Setting up a sewerage treatment plant

Project site Proposed project activity

Amoni village Proposed site for Sewerage system collection and treatment
(Mapped as Priority a possible conflict area)
Malaba Town Proposed Sewer pipeline targeting the affected population to be
relocated
(Mapped as possible conflict hotspot area)

3.3: The Scope of the proposed Works

Sector Scope of work
1. Sanitation ❖ New Wastewater Treatment Plant: 4,000 m3/day
❖ New Trunk main for sewerage
❖ New Ablution blocks: 5EA

The following key Aspects of project design were considered and can be discussed briefly as follows

a) Types of waste and quantities of waste water

The composition of the liquid waste depends on its source. The three main sources are
• Residential,

• Commercial, And

• Industrial Areas. Organic waste

Stormwater is also a source of liquid waste and an allowance of 15 % of infiltration of ground water
and storm drain has been allowed in this design. Liquid waste from domestic sources can be classified
as blackwater, which contains excreta, and greywater. Liquid waste from commercial areas is broadly
similar to wastewater from residential areas they mainly consist of Fats and oil and minor quantities
chemicals from restaurants, hospitals, offices, schools and cafes around the town and its environs.
The characteristics of industrial wastewaters depend on the type of industry. Some industrial
wastewaters are hazardous. The characteristics of wastewaters can be described in physical, chemical
and biological terms.

Physical characteristics include the number of suspended solids, the temperature and odour.
The quantity of organic matter in liquid waste is an important measure of its polluting potential. If
discharged into a river or lake, organic matter exerts an oxygen demand which can reduce the
availability of oxygen for fish and other aquatic organisms.
Organic matter is measured in terms of biochemical oxygen demand or chemical oxygen demand.

Industrial wastes in towns produces liquid wastes are such as waste food, textiles and tanneries
chemicals and solid wastes etc. In Most cases Industries produce polluting liquid wastes that should
be treated before being discharged into the environment
Shown below is the schematic layout of the proposed sewerage pipelines and layout with their flows.
The total discharge for phase one is 4000m3/day
The figure above shows the main trunk sewer and interconnection of sewer networks as was designed

b) Analysis of Major Technologies used for waste water treatment

In order to come up with best treatment option various waste water treatments Plants and
technologies were considered and discussed at various project stages design of the project. To select
the best option that is cost-effective and suitable for waste water treatment in Malaba. The following
factors were considered in order to select the best process treatment which included the following
• Desired outgoing effluent quality or permit requirements to comply with national, county or
local guidelines
• Effluent volume requiring treatment
• Complexity of the technology, ease of operation, adaptability, reliability and robustness, and
energy requirements
• Capital and construction costs
• Operation and maintenance costs
• Available land area
• Mass of sludge generated and disposal requirements
• The following major waste treatment plants used for treating large volumes of waste water from
both municipal and industries were discussed and can be summarized as below.

Choice of treatment system

The following treatment process were considered in the selection of appropriate wastewater
treatment methods;

(i) Pond systems;

(ii) RBC (Rotating Biological Contactor);
(iii) Trickling filters;
(iv) Aerated lagoons;
(v) Activated sludge systems.
i) Membrane Bioreactor
It’s Combination of a suspended growth bioreactor that breaks down waste with microbes followed
by membrane filtration
ii) Activated sludge
The activated sludge treatment system consists of an aeration tank followed by a secondary clarifier.
Settled sewage, mixed with fresh sludge that is recirculated from the secondary clarifier, is introduced
into the aeration tank. Compressed air is then injected into the mixture through porous diffusers
located at the bottom of the tank. As it bubbles to the surface, the diffused air provides oxygen and a
rapid mixing action. Under such oxygenated conditions, microorganisms thrive, forming an active,
healthy suspension of biological solids mostly bacteria called activated sludge. Sludge and possibly
effluent require further treatment and/or appropriate discharge

iii) Oxidation pond

Oxidation ponds, also called lagoons or stabilization ponds, are large, shallow ponds designed to treat
wastewater through the interaction of sunlight, bacteria, and algae. Algae grow using energy from
the sun and carbon dioxide and inorganic compounds released by bacteria in water. During the
process of photosynthesis, the algae release oxygen needed by aerobic bacteria. Mechanical aerators
are sometimes installed to supply yet more oxygen, thereby reducing the required size of the pond.
Sludge deposits in the pond must eventually be removed by dredging. Algae remaining in the pond
effluent can be removed by filtration or by a combination of chemical treatment and settling.

iv) Moving Bed Biofilm Reactors

Uses thousands of moving polyethylene biofilm carriers in an aerated treatment process to biologically
break down waste;
v) Rotating Biological Contactors
Fixed-bed reactors with a series of partially submerged disks mounted on a horizontal shaft that
slowly rotate as the wastewater flows through the reaction vessel to maximize the surface area for
biological breakdown of waste constituents;
vi) Submerged Fixed Bed Biofilm Reactor
Treatment system using bio-films attached to submerged, fixed open structure plastic media that
treats the wastewater as it flows through the reaction vessel; The submerged fixed bed biofilm reactor
(SFBBR) for wastewater treatment is an alternative to the traditional activated sludge system.
vii) Trickling Filter
A trickling filter consists of bed of coarse material, such as rounded rocks, crushed stone, wooden or
plastic slats and plastic rings over which wastewater is discharged from moving spray distributors or
fixed nozzles. The filter media provides a large amount of surface area for the microorganisms to
cling and grow a jelly like biofilm of around 10mm thickness. In the outer portions of the biofilm the
aerobic bacteria break down the organic matter. When the biofilm becomes very thick it falls off and
a new biofilm layer form
viii) Waste stabilization ponds Waste stabilization ponds (WSP) are well-established methods for
sewage treatment in tropical climates. This is a natural biological process that provides ecologically-
sustainable wastewater treatment system and has the capability of meeting the demand for a high
percentage removal of pathogenic organisms, compared to conventional technologies.
In the WSPs, raw sewage is treated entirely by natural processes involving both algae and bacteria. This
process is very effective in the removal of faecal coliform bacteria and does not require mechanical
mixing, and only sunlight energy is required in the oxygenation process. Minimum supervision for daily
operation which involves simple cleaning of outlets and inlet works is required.
The main advantages of WSPs therefore include: simplicity, low cost, low maintenance, low energy
consumption, robustness, and sustainability. Having considered all types of water treatment plants as
described above, waster stabilization ponds were found to be suitable for Malaba and adequate to treat
the waste water generated. Therefore, the team moved forward in to site selection and design. Sewerage
System
Design of Waste stabilizations pond to meet standards

Treatment Plant design

The following design parameters have been applied:

• Design temperature, which is the mean air temperature in the coolest month has been taken
as 23oC;
• Net evaporation, which is the mean evaporation in the coolest month has been taken as
5mm/day;
• Wastewater flow assumed to include no seepage (infiltration) water since there is no collection
pipe work;

• The works have been designed based on the peak dry weather flow (PDWF), obtained from
multiplying the average dry weather flow (ADWF) by a peak factor of 1.4;

• Raw sewage has been assumed to have inlet BOD of 450mg/l;

• Raw sewage has been assumed to have faecal coliform concentration of 5 x 107 per 100 ml.
• Raw sewage has also been assumed to contain 1,000 Helminth eggs per litre;

• Ponds have been specified to be located at least 500 m downwind from any residential area,
to create required buffer zone;
• Ponds have also been specified not to be located within 2 km of any airport/airstrip;
• Vehicular access to the ponds has been considered to form part of the works (access roads).

• The soil at the proposed site has been observed to be clayish in property and stabilization may
be necessary as specified to be sufficiently stable with minimum seepage to minimize
compaction.

Primary treatment

Inlet chamber

The design of inlet chamber has been based on the following criteria:

(i) Detention time 10 sec;

(ii) Assumed depth of inlet chamber 0.45 m;
(iii) Freeboard 0.5 m;

Screen’s chamber

The design of screens has been based on the following criteria:

(i) Width of spaces between bars for coarse screens 25 mm;

(ii) Width of bars for coarse screen 15 mm;
(iii) Velocity of flow at maximum flow 1.0 m/s;
(iv) Velocity of flow at minimum flow 0.6 m/s;
(v) Assumed depth of flow 0.3m;
(vi) Assumed length of chamber 3m;
(vii) Inclination of bars 60 degrees.

Grit chamber

The design of grit chamber has been based on the following criteria:

a) Size of grit particles 0.15 mm;

b) Specific gravity of grit 2.65;
 c) Efficiency of grit chamber 75%;
d) Critical displacement velocity 0.16m/s;
e) Horizontal velocity of flow to be less than critical displacement velocity;
f) Depth of chamber 1.5 m;
g) Liquid depth 0.73m
h) Assumed depth of sludge storage 0.3m;

Sullage Channel with Parshall Flume

The design of the sullage channel has been based on the following criteria:

(i) Flow velocity 0.6m/s;

(ii) Design Peak Flow 421.1 m3/hr

Distribution chamber

The design of the flow distribution chamber has been based on the following criteria:

(i) Detention time 30sec;

(ii) Assumed depth of chamber 2.0m.

Secondary treatment

The waste stabilization ponds have been designed to achieve effluent standards of un-restricted
irrigation i.e. <15 mg/l BOD5 and <100 FC/100 ml.

Four series of ponds have been provided, to allow for maintenance.

Design of anaerobic ponds

a. Length to breadth ratio of 1:1 for the equivalent trapezoidal section have been adopted in this
design for the anaerobic ponds;
b. Three number of anaerobic ponds in parallel have been considered to allow for maintenance;
c. Assumed liquid depth of pond is 3m;
d. Assumed free board depth or depth of bund for trapezoidal section is 0.5m;
e. The ponds have been sized to receive BOD of up to 330g BOD/m3/day according to the
volumetric loading criteria shown in the following table and design temperature of 23oC;

The loadings and the corresponding percentage BOD removal adopted are shown in the Table below:
Table 5-2: Volumetric loadings and percentage BOD removal

Design Temperature (0C) Volumetric Loading BOD Removal (%)

(g/m3/day)
<10 100 40
10-20 20T-100 2T+20
20-25 10T+100 2T+20
>25 70

• Anaerobic pond volume design was based on BOD of the raw wastewater, mean wastewater flow
and volumetric organic loading rate as related by the following formula:

V=Li Q /λ v

Where:

Li=influent BOD

(g/m3); Q=flow

(m3/day); V=pond

volume (m3);
 λ v=volumetric organic loading rate (g/m3.day).

• Using the removal efficiency (E) estimated from the table above, the effluent
concentration (BODeff) of the anaerobic pond was calculated from the following
equation:
Where:

E=removal efficiency;

So=influent total BOD conc. (mg/l);

BODeff=effluent total BOD conc. (mg/l).

Design of facultative ponds

• Length to breath ratio of 1:3 have been adopted for the rectangular and equivalent
trapezoidal section for the facultative ponds in this design with orientation that optimizes on
wind induced mixing of the pond content;
• Three number facultative ponds in parallel have been considered to allow for maintenance;
• Assumed liquid depth of pond is 1.5m;
• Assumed free board depth or depth of bund for trapezoidal section is 0.5m;
• The ponds have been sized to receive BOD of up to 311 kg BOD/ha d;
• The facultative ponds have been assumed to have 80 % BOD removal;

• The surface BOD loading rate on the facultative ponds at the specified design temperature
was obtained from the following equation:

s=350x (1.107–0.002xT)T-25, where T is the mean temperature in the coolest month (0C)

The facultative pond area was calculated by using the following equation:

Af=10LiQ/λs

Where:

Li=influent BOD (kgBOD5/day);

Q=design flow (m3/day);

λs=surface BOD loading rate (kg BOD/ha/d)

The retention time was calculated from the

formula: t=AfH/Qavg

Where:

H=pond depth (m);

Q=average flow

(m3/day);

Average flow is the average of the influent and the effluent

flow given by: Qaverage=(Qinfluent+Qeffluent)/2

Therefore, t=2AfH/(Qi+Qe)
 Mass balance of flow used in the design was given as follows:

Q effluent= (Q influent +Q precipitation-Q evaporation- Q infiltration)

Since net evaporation is evaporation less precipitation:

Q effluent= (Q influent-Q net evaporation- Q infiltration)

If infiltration is negligible:

Q effluent=Qinfluent-0.001Afe

Where:

e is net evaporation rate (mm/day), thus:

t=2AfH/(Qi-0.001Afe)

a) The above evaporation rate has been taken as 5mm/day in the design of facultative
ponds;
b) A minimum detention time of 5 days has been adopted in the design to minimise
hydraulic short circuiting and to prevent algal washout.

Design of maturation ponds

• Length to breath ratio of 1:2 have been adopted for the rectangular and equivalent
trapezoidal section for the maturation ponds in this design;
• The ponds have been designed for a minimum retention period of 3 days;

• Two series of two number of maturation ponds each in parallel have been considered to allow
for maintenance;
• Assumed liquid depth of pond is 1.2m;
• Assumed free board depth or depth of bund for trapezoidal section is 0.5m;

• It has been assumed that maturation pond will remove 25 % of BOD after removal by
anaerobic and facultative ponds;

• The method of Mara is represented by the following first-order kinetic model in a completely-
mixed reactor, has been adopted for the design of maturation ponds for faecal coliform removal:

Ne/Ni=1/[1+kTθ]n

Where:

Ne=number of effluent faecal coliform per 100ml;

Ni=number of influent faecal coliform per 100ml;

KT=bacteria die-off coefficient (d-1);

θ=retention time (days);

n=number of maturation ponds.

For a series of anaerobic, facultative and maturation ponds the equation becomes:

Ne= Ni
n]
 Where:

θa= anaerobic retention time (days);

θf=facultative retention time (days);

θm=maturation retention time (days);

The value of KT was found to vary with temperature as follows:

KT= KT20α (T-20)

Where:

T=temperature (oC);

α=temperature coefficient, which is 1.19;

KT20=2.6.

The following three sets of conditions were considered to ensure that the maturation ponds are
designed satisfactorily:

θf>θm;

θm>θm(min), where θm(min)=3 to 5 days;

λsm1(BOD)≤0.75λsf(BOD)

Where:

θm=hydraulic retention time in each maturation pond (days);

θf=hydraulic retention time in secondary facultative pond

(days); θm(min)=minimum hydraulic retention time in

maturation ponds (days); λsm1=surface BOD loading in first

maturation pond (kg/ha/day); λsf=surface BOD loading in

facultative pond (kg/ha/day).

Maximum BOD loading in the first maturation pond was assumed to be 75% of that of the preceding
facultative pond.

• The percentage removal of helminth eggs was determined by the following

equation: R=100[1-0.41 Exp (-0.49θ+0.0085θ2)]

Where:

R=percentage removal;

θ=retention time in days.

The equation was applied sequentially to each maturation pond in the series so that the number of eggs
could be determined.

Proposed Sewerage Works consisted of the following main works

a) Preliminary Treatment consisting of inlet chamber, screening, Grit Chambers and measuring
Parshal Flume.
b) Sewers of sizes ranging from 100mm total length 9.2 km and consisting of 9 sewer lines.
c) Three main trunk sewer lines of diameter 200-600mm UPVC and Concrete pipes and total length
about 16km
d) A total of 12 waste stabilization ponds are proposed to be constructed to treat total of up to
4000m3/day of waste water. The ponds consist of 3No. Anaerobic, 3No.Facultative and 6No.
maturation ponds
e) Total area for the ponds is approx. 450mx300m including space for future expansion

Table 1-1: Waste stabilization ponds design capacity

Description Phase (2030)
Projected waste water generated (m3/day) 3515
Infiltration (15%) 15%
Peak Factor 2.5
Treatment capacity (m3/day) 8,787.5
The expected characteristic of raw sewage from the town council is illustrated in the table below:

Table 2-2: Expected characteristics of the raw sewage

Parameters Values Units
pH 6.5 to7.5 Mg/l
COD 400-600 Mg/l
BOD 491 Mg/l
TSS 150-300 Mg/l
Faecal Coliform(Ni) 50,000,000

Treatment site Location

The proposed Malaba Sewerage Treatment Plant site is located in Akiriamasit Sub-location at the
confluence of the Malaba River and Sio-Malakisi River some 5km South-West of Malaba Town along
the Malaba -Busia Road on Latitude:0°37'31"N Longitude:34°13'12"E
System design
In the proposed WSPs, the sewage generated from Malaba town will initially be passed through the coarse
screens where screen-able material shall be separated from the sewage before flowing through the grit
chamber where grit material shall be removed. After the primary treatment, the sewage will be
transmitted to WSPs through the sullage channel equipped with parshall flume for flow measurement.

(i) ) Inlet chamber

The inlet chamber has been designed for a detention time of 10 sec.

One large inlet chamber with size 1.7m x 1.7m x1.0m and a liquid depth of 0.45m has been proposed

(ii) Coarse screen chamber

The coarse screen chamber has been designed for a flow through velocity of 0.6m/sec.

One coarse screen chamber with size 3.0m x 1.0 m x0.8m and a liquid depth of 0.30m has been
proposed.
(iii) Coarse screens

The coarse screens have been designed for a flow velocity (velocity a head of screen) of 0.6m/sec.
The proposed coarse screen details are as shown in the Table below:

Table 15 Proposed screen details

Year No. screens Coarse screens

Bar spacing Liquid depth Screen Free board
dimensions
2040 2No 25(mm) 0.4(m 1.0x0.9(m) 0.50(m)

The bar thickness for the coarse screens shall be 15mm.

(iv) Grit chamber

Minimum Size of Grit particle 0.15mm

Specific Gravity of Grit 2.65
Size of Grit Chamber 10.2 m x 1mx 1.5x

(v) Sullage channel with parshall flume

The sullage channel has been designed for a flow through velocity of 0.6m/sec.

One sullage channel with size 3.71m x 1.0m x0.8m and a liquid depth of 0.3m has been proposed.

(vi) Distribution chamber

The distribution chamber has been designed for a detention time of 30 sec.

The distribution chamber with size 1.4m x 1.4m x3m has been proposed.

Anaerobic ponds

The anaerobic ponds have been designed to meet the following parameters;

Minimum temperature 230C;

Evaporation rate 5.00 mm/day;
330g
Design organic load (inlet) BOD/m3.day;
Design retention time 1.36 days;
Liquid depth in pond 3 m;
BOD removal 66 %.

The proposed size for the design of the anaerobic ponds for the drainage area is given in the table below:
Table 6-4: Proposed anaerobic pond size

Year No. Ponds Liquid depth (m) Pond top size (m) Free board (m)

2040 3 3 30 x 30 0.5
The above sizes have been obtained by computing dimensions of the equivalent trapezoidal shape
anaerobic ponds with side slopes 1 in 3.

Treated sewage from anaerobic ponds will be transmitted to the facultative ponds for further treatment.
Facultative ponds

The facultative ponds have been designed to meet for the following;

a. Minimum temperature 23 0C;

b. Evaporation rate 5.00mm/day;
c. Design organic load (inlet) 311 g BOD/m3.day or kg/Ha-day;
d. Design retention time 7.47 days;
e. Liquid depth in pond 1.5 m;
f. BOD removal 80 %.

The proposed sizes for the design of the facultative ponds are given in the table below:

Year No. Ponds Liquid depth (m) Pond top size (m) Free board (M)

2040 3 1.5 150x50 0.5

The tabulated sizes are for trapezoidal shape facultative ponds with side slopes 1 in 3 proposed with
required stability measures.

Treated sewage from facultative ponds will be transmitted to the maturation ponds for further treatment.

Maturation ponds

The maturation ponds have been designed to meet for the following criteria;

• Minimum temperature 23 0C;

• Evaporation rate 5.00mm/day;
• Minimum design retention time 3 days;
• Designed retention time 3.5 days;
• Liquid depth in pond 1.2 m;
• BOD removal 25 %.

The proposed size for the design of the facultative ponds for the drainage area is given in the table below:

Year No. Ponds Liquid depth (m) Pond top size (m) Free board (m)

2030 2 1.2 90mx50m (2No). 0.5

Proposed maturation pond size

The tabulated sizes are for trapezoidal shape maturation ponds with side slopes 1 in 3 proposed with
required stability measures.

Treated sewage from maturation ponds will be transmitted to the constructed wetlands for further
polishing/treatment.

Regular monitoring of the quality of the treated sewage from maturation ponds through the constructed
wetlands will be done before the effluent discharge to nearby drainage system, used for irrigation and
or other preferred approved purposes.
Sludge drying beds

All sludge from the waste stabilisation ponds, together with any additional sludge that will be delivered
directly to the treatment plant, will undergo treatment by drying in sludge drying beds before disposal.
The table below shows the computations of the size of the proposed sludge drying beds.

. Table 1-3: Expected standard treated sewage characteristics from waste stabilization ponds which has
been achieved through considering all parameters are show in the table below

• Raw Sullage • Values • Units

Characteristics
• pH • 6.5 to 7.5 • Mg/l
• COD • <50 • Mg/l
• BOD • <15 • Mg/l
• TSS • <20 • Mg/l
• Faecal Coliform (Ni) • 100 - 1000 • FC/ml

The designed components of the Waster stabilization Ponds to achieve the required standards can be
summarized as below
(i) Inlet chamber
The inlet chamber has been designed for a detention time of 10 sec.
One large inlet chamber with size 1.7m x 1.7m x1.0m and a liquid depth of 0.45m has
been proposed.
(ii) Coarse screen chamber
The coarse screen chamber has been designed for a flow through velocity of 0.6m/sec.
One coarse screen chamber with size 3.0m x 1.0 m x0.8m and a liquid depth of 0.30m
has been proposed.
(iii) Coarse screens
The coarse screens have been designed for a flow velocity (velocity a head of screen) of
0.6m/sec.
The proposed coarse screen details are as shown in the Table below:
(iv) Grit chamber
Minimum Size of Grit particle 0.15mm
Specific Gravity of Grit 2.65
Size of Grit Chamber 10.2 m x 1mx 1.5m
(v) Sullage channel with parshall flume
The sullage channel has been designed for a flow through velocity of 0.6m/sec.
One sullage channel with size 3.71m x 1.0m x0.8m and a liquid depth of 0.3m has been
proposed.
(vi) Distribution chamber
The distribution chamber has been designed for a detention time of 30 sec. A distribution
chamber of size 1.4m x 1.4m x3m has been proposed.
(vii) Anaerobic ponds
The anaerobic ponds have been designed to meet the following parameters;
Minimum temperature 23C;
Evaporation rate 5.00 mm/day;
Design organic load (inlet) 330g BOD/m3.day;
Design retention time 1.36 days;
Liquid depth in pond 3 m;
BOD removal 66 %.
(viii) Facultative ponds
The facultative ponds have been designed to meet for the following;
• Minimum temperature 23 0C;
 • Evaporation rate 5.00mm/day;
• Design organic load (inlet) 311 g BOD/m3.day or kg/Ha-day;
• Design retention time 7.47 days;
• Liquid depth in pond 1.5 m;
• BOD removal 80 %.
(ix) Maturation ponds
The maturation ponds have been designed to meet for the following criteria;
• Minimum temperature 23 0C;
• Evaporation rate 5.00mm/day;
• Minimum design retention time 3 days;
• Designed retention time 3.5 days;
• Liquid depth in pond 1.2 m;
• BOD removal 25 %.

. Table 1-3: Expected standard treated sewage characteristics from waste stabilization ponds for key
parameters

• Raw Sullage • Values • Units

Characteristics
• pH • 6.5 to 7.5 • Mg/l
• COD • <50 • Mg/l
• BOD • <15 • Mg/l
• TSS • <20 • Mg/l
• Faecal Coliform (Ni) • 100 - 1000 • FC/ml

The other parameters are as shown in the table below and to which the waste treatment plant has
been designed to achieve
A laboratory has been constructed at the pond site to monitor quality of the treated sewage from
maturation ponds before the effluent discharge to nearby river
(i) Sludge drying beds
All sludge from the waste stabilisation ponds, together with any additional sludge that will be delivered
directly to the treatment plant, will undergo treatment by drying in sludge drying beds before disposal.
Layout plan of Sewerage Treatment Plant fig 1

i) Site selection considerations

The goal of design review was to confirm site suitability for the Employers consideration for purchase
and development. Cost-related factors included land purchase, potential excavation and fill
requirements, which were found to be within the budget during design review stage of the project.
Below are some of the factors generally considered when selecting a site for WWTP and adopted in
many places of the in world.

i. Land-Use
In the Land-use Map, different areas of Malaba have been assigned varied existing and proposed uses.
Areas earmarked for residential, industries, agriculture, forests and social amenities are considered
less suitable for the location of a Wastewater Treatment Plant (WWTP). On the other hand, public
utility or undeveloped Agricultural Land located away from the sensitive residential areas are
preferred.

ii. Distance of Effluent Discharge Point

The distance from the WWTP site to the final receiving environment such as the river and ocean, is
an important consideration in site selection. Preference is given to the sites that require shorter lengths
of Outfall Sewers. When confirming the selected site the outfall distance was approximately 200m
which is within the range.

iii. Topography of the Sewered Area

An ideal WWTP site should be located on a low-lying area of the sewerage system for gravity
conveyance. Otherwise, pumping stations become necessary thereby increasing both capital cost and
the operation and maintenance requirements of the sewerage system. The design for sewer network
reticulation were placed at an elevation able to collect waste from a wider project area, allow also for
future extension. The sewer networks from various high points converges in to a single trunk line
which convey the wastes to a lowest pond of the town where the site for treatment plant was located

iv. Topography of Site

The slope at an ideal site should permit the gravity flow within the WWTP without requiring excessive
excavations for the structures. Slopes less than 1:20 are preferred. While confirming an initial survey
this condition was established and the slopes for this site found acceptable as per the required design
standards

v. Geological Conditions
A site with low water table and whose soils are impermeable is considered ideal with respect to
geological considerations. For instance, silt or clay soils are suitable for pond construction.
More often, the geological formation within an area is fairly similar. For instance, all the candidate
sites in Malaba comprise of a mixture of well drained, deep, dark red to reddish brown, friable, sandy
clay loam to sandy clay, with top soil of loamy sand and well drained, very deep, yellowish red, very
friable, fine sandy loam to fine sandy clay loam. These soils are suitable for WWTP (Waste Stabilization
Ponds) construction.

vi. Existing Infrastructure

Proximity to infrastructural systems such as roads, electricity and portable water is sought for while
siting for a WWTP location. It reduces cost of construction and operation & maintenance requirements
of the WWTP. Sites that are closer to existing infrastructure are preferred. With these site accesses is
made possible by an existing murrum road which easily allows vehicles and truck to reach the site
while carrying out routine maintenance.

vii. Potential for reuse of treated wastewater

Treated wastewater can be reused for beneficial purposes such as agricultural irrigation, industrial
processes, ground water recharge, etc. Proximity to the potential re-use application and relative
elevation difference (for gravity conveyance) is preferred in siting of WWTP. For instance,
downstream arable land would make a WWTP site ideal for agricultural irrigation.
viii. Land Acquisition
In most places because of the topography and the long-time benefit of a gravity scheme the land
selected can be in private land which requires acquisition.

3. Added Precautions Taken

The following have been considered to further maintain the quality and the required standards
• The sides slopes of all the ponds have been lined with reinforced concrete class 20
• Double layer of Polyvine 35 have provided at the base of each pond to contain seepage bottom to
guarantee the quality of ground water
• Dykes are to be constructed in the space between the rivers and the sewerage pond this is to
guarantee that if flooding may occur in the future as a result of climate change the pond area will
not be flooded
• Trees to form a beaver zone are to be planted around the pond to control and maintain a good
ambience and control odour
• Proper landing scaping and planting of specialized grass will be done at the pond area to mitigate
on soil erosion especially of the loose soil around the pond

NEMA Objections and brief responses

Through a letter Ref: NEMA/EIA/5/2/1643 addressed to Central Rift valley the Environmental agency
raised for issues that can be summarized below and we prepared brief responses in the meantime as
we prepare a proper appeal as earlier advised.

Table 1: NEMA ISSUES

 Issue Raised by NEMA Brief Response
1. 1. The proposed site for the wastewater treatment plant extends The area is not gazzeted as a wetland
into a wetland which is an environmentally sensitive area.

2. The wastewater treatment plant is located within two rivers i.e.,
Malakisi and Komiria rivers that join downstream into
Transboundary River Malaba draining into Lake Kyoga in
Uganda. River Malaba is a shared resource between Kenya and
Uganda and there is No evidence of consultation and/or
notification with the Uganda Authorities in line with the
guidelines on shared resources in East Africa.
The site is located on Lat :0°37'31"N
and Long :34°13'12"E where river
Malakisi joins Malaba river and not
where komiria Joins Malakisi which is
located and these should be reviewed.

3. A comprehensive risk assessment and analysis of alternatives of The feasibility study was adequately under
the project and its associated facilities and amenities had not and submitted to NEMA
been undertaken to inform the project location and have the
appropriate environmental and social safeguards.

4. Precautionary principle: the project has potential public health • No Health risk is posed to the public
risks, transboundary resource use conflicts and other since the ponds have a lining on
uncertainties due to its scale and nature in relation to adjacent both the walls and Lining at the beds
environmentally sensitive area. to mitigate against infiltration of
waste water into the underground

Environment and Social Interventions

1. Water Quality Direct Impacts

The impact related to pollution of water resources marshland between Rivers Malakisi,and Malaba
by sewerage from the WWTP in the event of failure related to blockages or overflows. The risk will
be related to increased Biological Oxygen Demand (BoD5) and other physiochemical parameters
including Chemical Oxygen Demand (CoD), pH, Conductivity and Total Dissolved Solids (TDS) and
Total Suspended Solids (TSS) beyond thresholds provided under Legal Notice 101 of EMCA on Water
Quality regulations of 2006.

Baseline Situation

As part of baseline water quality assurance at EIA stage and as provided by water quality regulations,
2006 (legal notice no. 121) EMCA 1999 Cap 387. The surface water quality analysis including both
bacteriological and physiochemical analysis of the receiving Rivers Malakisi and Malaba was carried
/ will be out at the proposed river outfall points. The objective was to assess the baseline Biological
Oxygen Demand (BoD5) and other physiochemical parameters including Chemical Oxygen Demand
(CoD), pH, Conductivity and Total Dissolved Solids (TDS) and Total Suspended Solids (TSS) of the
rivers before establishment of the WWTP.
The results of water sampling are summarized table below. Detailed laboratory report is given / will
be in Appendix of this paper.

Table 2: Results of Environment Laboratory Analysis

 Site pH Conductivity TSS (mg/l) TDS (mg/l) BOD (mg/l) COD (mg/l)
Marshland sample
Malakisi River sample
Malaba sample

Mitigation of Water Quality Impacts

• Available effluent disinfection alternatives

Table 3: Alternative Effluent Disinfection Methods

Alternative Details
Maturation Maturation lagoons are considered to be the ideal method for wastewater
Lagoons- disinfection in warm climates wherever sufficient land is available at
(adopted reasonable cost Pathogen removal rates are high, operation and
method) maintenance is simple, and costs are low.
Chlorination Chlorination has traditionally been the most widespread form of wastewater
disinfection world· wide. However, it is now gradually being replaced by
other forms of disinfection due to a number of disadvantages which are now
recognized:
The efficiency of the process is greatly reduced when organic matter and
ammonia is present in the effluent as these also react with chlorine
A high degree of process control is needed to achieve the necessary efficiency
Environmental concerns have been raised over the production of hazardous
by-products such as organochlorine compounds which are thought to be
carcinogenic (chlorination of wastewater effluents has been banned is some
countries e.g. Germany, because of this)
Protozoa such as Giardia and Cryptosporidium are resistant to chlorination
Efficiency of virus removal is also thought to be low
Regrowth of residual populations of pathogens can occur due to the removal
of populations of harmless bacteria which would otherwise prevent
multiplication of pathogens
UV Light UV disinfection is essentially an enhanced form of natural disinfection via
sunlight which is one of the principal mechanisms by which maturation
ponds operate. The process has gained increasing popularity in recent years
as technology advancements have provided more' reliable equipment
However, UV light disinfection generally costs around twice that of
chlorination and it is still a comparatively complex process to operate, with
a high degree of maintenance required. particularly for cleaning of the
lamps. It is therefore considered to be an unsuitable process for the Project.
Ozonation Capital costs of Ozonation are reported to be higher than the capital cost for
most other disinfection methods, the major capital item being the ozone
generation equipment. including the air-preparation system. Large, possibly
multi-stage, tanks or columns are also required. Total capital costs may be
4-5 times greater than for chlorination systems. while operating costs
(primarily electrical requirements) are thought to be around three times
greater than for chlorination. The high costs combined with the complexity
of operation would make this process unsuitable for this Project.
Sand Filters Two types of sand filter can be described:
Rapid sand filters (essentially similar to those used at clean water works)
Slow sand filters
Rapid sand filters are only suitable for large treatment works where skilled
personnel are available to provide the necessary operation and maintenance.
 Clogging of the filters is common and frequent backwashing is required.
Slow sand filters do not require backwashing facilities but require a
relatively large area of land and involve a high capital expenditure

*Adopted effluent disinfection method is the Waste Stabilization Ponds (WSPs) comprising of
Screening + Anaerobic Ponds +Facultative Ponds + Maturation Ponds

Other water pollution related mitigation measures adopted by the project design are
associated with the parameters listed below

• Lining of Waste Water Stabilization ponds beds to mitigate against infiltration of waste water
into the underground water aquifers
• Construction of dykes around the Waste Water Stabilization ponds to protect the ponds for
risks associated with flooding.
• Channeling Treated effluent downstream the existing water intake to Uganda side to reduce
pollution risks
• Hydrological assessments were done to determine the level of flood impact at the proposed
site

2. Impacts on Soils
• Adopted mitigation measures above will also mitigate against potential pollution of soil resources
from pollution agents related to raw sewerage contamination

3. Cumulative Impacts
Adverse cumulative impacts to downstream biophysical and social economic setting was will be
analyzed during the ESIA in two folds; (i) downstream cumulative impacts on biodiversity triggered
by likelihood of contamination of the Malaba River by raw sewerage in the event of overflows during
floods and blockages, And (ii) Pollution risks to downstream water users triggered by likelihood of
contamination of the Malaba River by raw sewerage in the event of overflows during floods and
blockages.
Baseline Situation
Therefore, in order to map available biodiversity within the Malaba River and present an inventory
aquatic fauna and terrestrial fauna who depend on Malaba river basin. Finding from the biodiversity
survey was as listed in Table below

Table 4: Inventory of Ecological and Socio-Economic Receptors

Baseline Inventory of downstream biodiversity and socio-economic
setting
Aquatic Fauna along the Fish species
river basin downstream 1
the WWTP 2
3
4
5
Other aquatic species observed
1
2
3
 Terrestrial Fauna along the Avian fauna
river basin downstream 1
the WWTP 2
3
4
5

Other mammalian fauna

1
2
3
4
5
Socio economic setup – Mapp all downstream water users within Kenyan and part of Uganda
downstream users river belt – guided by Water Resources Users Authority (WRUA)

Existing WRUAs – including abstractions

1
2
3
4
5

Other water users

1
2
3
4
5
Provide a map of such users

4. Advanced stakeholder Consultations that Include Ugandan Side

Planned consultations are as summarized below
Table 5: Schedule of Advanced Stakeholder Consultations
Activity Est. Number Venue
Engagement with the Ugandan authorities. This 30 comprising of CRV, LVN, Malaba
will include travel arrangements to be coordinated Busia County, WSP,
by the DCC Malaba, site visit and involving the Administration, Uganda
County Government department of water and the Officials, NEMA, WRA and the
WSP consultant

Two-day report writing meeting at Busia to be 10 (CRV, LVN, Consultant and Busia
submitted to NET County)

5. Draft Effluent Discharge Control Plan

The EDCP as required by Water Resource Management Rules 2007 is supposed to be prepared at
completion of the Project designs, ESIA and Project implementation during test running but before
commissioning of the Project.
Therefore, during test running of the Project components, the EDCP Application will be prepared by client
and submitted to the Water Resources Authority (WRA) for approval and issuance of the Effluent
Discharge Permit. Table 2-2 shows a Draft Effluent Discharge Control Plan that will be prepared
Table 6: Draft Effluent Control Discharge Plan
Section of the EDCP Remarks
Name and details of applicant; Busia Water and Sanitation Company (BUWASCO)
Quantity and quality of inflow Inflow water into Malaba river will be determined by effluent from the
water proposed Waste Water Treatment Plants.
The Quality of Effluent from the WWTPs will be dependent on
population increase, water supply and the rate of connection to the
water supply as shown in the figure below.
The proposed WWTPs have been designed to achieve the following
effluent qualities:
Design
EMCA Act (Water Quality
Parameter Units Effluent
Regulations 2006) - Limits
Quality
Total Suspended mg/l <30 30 Max
Solids (TSS)
Chemical Oxygen mg/l <50 50 Max
Demand (COD)
Biological Oxygen <30 30 Max
Demand (BOD5)
mg/l
At Project Operation Stage quality of effluent from the proposed
Wastewater Treatment Plants will be analysed and presented during
application of effluent discharge License from NEMA

Type and source of effluent The effluent will be from Wastewater Treatment Plants. The Wastewater
Treatment Plant will be treating Domestic, Institutional, commercial and
Industrial wastewater.
Domestic,
Institutional,
Commercial and Wastewater
Receiving River
Industrial Treatment Plant
Wastewater

Design of Effluent treatment The proposed Wastewater Treatment Plants are Wastewater
plant

Inlet Works Anaerobic Facultative Maturation

• Screenings Ponds Ponds Ponds
Removal • BOD • BOD • Feacal
• Grit Removal Reduction Reduction Coliform
• Flow • Feacal • Feacal Reduction
Measurement Coliform Coliform • BOD
Reduction Reduction Removal
• Sludge
Stabilization

Stabilization System with the following Major Units:

Location and description The Proposed Wastewater Treatment Plants are Located at the
(frequency, quantity, Periphery of Malaba Municipality to allow collection of
Section of the EDCP Remarks
quality and nature) of wastewaters from the entire Municipality. The Location is such
effluent that, wastewater flow is by gravity to the WWTPs
Description of treatment The adopted Wastewater Treatment Technology is wastewater
and operations, if any stabilization pond system. The flow within the system is by gravity
and the system depends on natural and physical processes for
wastewater treatment such as;
• Sedimentation of sludge
• Natural Die off of bacteria
• Biological Digestion etc.
The expected operation and maintenance of the WWTPs is minimal
and will include; desludging of Anaerobic Ponds and general
clearing of the site.
Hydrology, hydrogeology Hydrology, Hydrogeological and Hydrochemistry conditions of the
and hydrochemistry of receiving river will be taken at the stage of commissioning of the
receiving water body WWTP. However, at ESIA stage baseline water quality analysis of
Malakisi, Komiria and Malaba Rivers were analysed with the
results shown below.
Site pH Conductivity TSS TDS BOD COD
(mg/l) (mg/l) (mg/l) (mg/l)
Marshland
sample
Malakisi
River
sample
Komiria
sample
Malaba
sample
Impacts on receiving water Community Sewerage systems are designed to protect public
body in terms of quantity health and the environment. Wastewater is collected and
and quality conveyed to a Wastewater Treatment Works/Plants where
pollutants are reduced prior to discharge. When these systems
(both collection and treatment) work as designed, there is reduced
risk to public health or the environment. However, during
emergencies, there can be increased risks including pollution and
comprise of BOD of the river which kills aquatic ecosystems
The BoD is receiving rivers (Malakisi, and Malaba Rivers) was
determined to be 11m/gl and 2m/gl which is less than than
30mg/l (testing to be done before commissioning of the plant).
Consequently, effluent from the WWTP is designed to be less than
30mg/l as provided by Water Quality Regulations. Due to high
volume and flow of water in Malaba Rivers dilution / oxygenation
of the effluent is rated high.
The sewerage Treatment Plant will ensure that required standards
for; BoD is <30mg/l, CoD is <50mg/l, TSS is 30max and Total
Coliform County /100ml < 30mg/l as required by the Third
Schedule of Water Quality Regulation Guidelines of Effluent
Section of the EDCP Remarks
Discharge into the Environment 2006. Further to achieve the
above standards, the sewerage design report has provided for
alternative effluent disinfection measures such as; Maturation
Lagoons, UV Light, Ozonation and Sand Filters among other.
However, during operation phase of the plants, the EIA has
provided mitigation measures that will mitigate pollution risks
associated with WWTP is summarized below;
• Busia Water and Sanitation Company (BUWASCO) will
ensure proper and periodic maintenance of sewers and
treatment plants. This will include daily effluent analysis of
BoD, CoD, TSS, TDS, and Coliform Count/100mg/l among
other parameters as required by Third Schedule of Water
Quality Regulations 2006.
• BUAWASCO will activate a community watch group for
information sharing on the status of the sewer lines within
the community.
• Regular cleaning of grit chambers and sewers to remove
grease, grit, and other debris that may lead to sewer
backups.
• Development of an inventory of system components, with
information including age, construction materials, and
drainage areas served, this will allow prompt for
replacement of worn-out components.
• Design manhole covers to withstand anticipated loads and
ensure that the covers can be readily replaced if broken to
minimize entry of garbage and silt into the sewer system
• Ensure sufficient hydraulic capacity to accommodate peak
flows and adequate slope in gravity mains to prevent build-
up of solids and hydrogen sulphide generation
• Regular inspection of the system to ensure performance is
maintained at high levels
• Blockages should be detected and promptly replaced
• Communities living within the river basins where the trunk
sewers will be constructed should be enlightened on dangers
of using raw sewerage to irrigate farmlands.
Proposed water quality Biological Oxygen Demand (5 days at 200C) max 30mg/l).
requirements for the effluent from the WWTP will achieve the requirement – See
permit and the Guidelines of Effluent Discharge into the Environment - Third
timeframe for achieving Schedule of Water Quality Regulation 2006.
compliance
Monitoring See monitoring tool that will be used by plant operators from
programme, BUWASCO. The tool is adopted from the Water Quality
(measuring device, Regulations of 2006 Sixth Schedule
controlling device,
sampling, records,
reporting procedures
Section of the EDCP Remarks
Emergency plan for Wastewater spill / Broken sewer main
accidental discharges
and their risks ACTIONS •
Notify plant operator.
•
Call for repair service and/or equipment
supplier.
• Estimate the quantity of sewage spilled.
• Determine the level of emergency, and take
further actions accordingly.
• Notify NEMA Busia County if a spill has
occurred to a water body in this cases
Malaba Rivers
• Contain the spill as much as possible.
• Broken sewer main: if possible, isolate the
sewer line to stop, contain or minimize the
spill, or divert the spill to low-risk areas.
• Arrange alternate sewage disposal if
necessary, i.e., divert the spill into
downstream manhole if possible, pump and
haul, emergency storage, etc
Malfunctioning wastewater treatment plant
ACTIONS • Notify plant operator.
• If possible, locate the system components that
are malfunctioning.
• Repair minor problems if you can.
• Call for repair service and/or order
replacement parts.
• Monitor the performance of the wastewater
treatment plant.
• Take effluent quality samples once per week
while parts are malfunctioning.
• Determine the impact of the malfunctioning.
Determine the level of emergency, and take
further actions accordingly.

6. Required Reports / Studies / information

The following reports will be required
• Biodiversity Survey Report for downstream ecology benefiting from downstream Malaba
River
• A report on mapping of downstream water users within Kenya side and part of Uganda
along the Malaba River basin
• Report on Consultation with Uganda Stakeholder related to water resources including
WRA, WRUAs and local administration among others.
• Hydrological Report which presents details of flooding information at the proposes site
with the understanding that the area is a flood plain
• Water Quality Analysis report which presents physiochemical and bacteriological
characteristics of Malakisi, and Malaba Rivers undertaken at the ESIA stage