sanitation programme for municipalities with less …

SANITATION PROGRAMME FOR MUNICIPALITIES WITH LESS

THAN 10 000 INHABITANTS - PHASE I

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

SUMMARY

July 2018

AFRICAN DEVELOPMENT BANK GROUP

2

Programme Name : Sanitation Programme for Programme Number: P-TN-EB0-004

Municipalities with Less

Than 10 000 Inhabitants

Country : Tunisia Department: RDGN

Division : RDGN.2 Programme Environmental Category: 2

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1. INTRODUCTION

In compliance with the country’s Strategic Development Plan “Tunisia 2016-2020” and to improve the

socio-economic, environmental and health conditions of Tunisia’s population by generalising sanitation

services in all of the country’s municipalities, ONAS has embarked on the construction of sanitation

facilities (systems, pumping stations and treatment plants) in 33 municipalities (Phase I) with less than

10 000 inhabitants.

The sanitation of these 33 municipalities will help to improve living, hygiene and environmental health

conditions in small urban centres and contribute to protecting natural resources (water, soil, wildlife and

flora) by reducing the negative impact of discharging crude wastewater into the natural environment

(rivers, lowlands, wadis, etc.). It will adequately address the aspirations and grievances of citizens

affected by the lack of a collective and reliable sanitation system that complies with health protection

and environmental hygiene requirements.

The objective of the programme is to construct new wastewater treatment facilities, and renovate and

modernise existing sanitation systems. These investments will improve wastewater treatment services

for about 150 000 inhabitants, according to estimates, and contribute to limiting soil pollution in the

programme areas.

Once the programme becomes operational, it is expected to generate significant benefits not only

environmentally and socially, but also in terms of health and safety, especially through pollution

prevention. However, the commissioning of sub-projects implemented under the programme may lead

to some environmental and social problems that should be rapidly solved by mitigation and management

measures.

Based on the outcomes of the environmental assessment conducted, ONAS’s capacity to manage this

type of programme and the size of the facilities to be constructed, the programme has been classified

under Environmental Category 2, in accordance with the Bank’s Environmental and Social Assessment

Procedures (ESAPs 2015). It should be noted that any sub-project that may be classified under

Environmental Category 1 will be excluded from the programme and will not be eligible for financing.

The programme has an Environmental and Social Management Framework, an Environmental, Social,

Health and Safety Procedure, and a Land Procurement and Loss Compensation Plan.

This document is the summary of the programme’s Environmental and Social Management Framework

(ESMF), which seeks to:

• Establish a specific environmental and social monitoring framework for sanitation

projects with (i) the definition of procedures for preparing, disseminating,

implementing and updating the environmental and social guidelines used; (ii) the

institution of a system of socio-economic surveys to be conducted prior to works; and

(iii) the establishment of a complaints management procedure;

• Develop a mechanism for the environmental, social monitoring and evaluation of

ONAS’s activities with: (i) the development of environmental and social indicators for

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monitoring programme activities; (ii) the establishment of a sanitation sector

environmental and social databank; and (iii) the retrospective supervision and

evaluation of activities for the assessment of the effective consideration of

environmental and social measures;

• Develop an environmental and social surveillance mechanism within ONAS based on:

(i) information, education and communication (IEC) on the quality of ONAS’s projects

and environmental actions; (ii) coordination, environmental and social exchanges

between the sanitation sector and other government and non-government institutions;

and (iii) management of complaints from programme beneficiaries and local residents.

2. PROGRAMME DESCRIPTION

The programme comprises three components: (i) Sanitation Facility Development (primary and

secondary systems, transfer systems, pumping stations and treatment plants); (ii) Capacity Building and

Institutional Support; and (iii) Programme Management (engineering studies, land procurement,

operation and technical assistance).

2.1 Sanitation Facility Development

The works to be carried out in small municipalities include:

• The establishment\extension\rehabilitation of sanitation systems, including pumping

stations;

• The construction of new treatment plants and rehabilitation of existing ones.

Table 1: Various Components of Sanitation Sub-Projects in Small/Medium-sized Municipalities

Governorate Municipality

Waste Water

Treatment Plant

(WWTP)

Pumping

Station

Backflow System

(lm) Transfer System

(lm)

Greater Tunis Department

Ben Arous Khlidia Yes 2 2 000 2 000

North Regional Department

Nabeul Dar Allouch Haouria WWTP 2 4 825 3 350

Menzal Horr Korba WWTP 3 3 740 2 000

Azmour Haouria WWTP 1 Ongoing 1 700

Zaghouan Jbel el Oust New WWTP 1 1 560 1 560

Nathour New WWTP Ongoing Ongoing 3 930

Le Kef Nebeur New WWTP 1 760 3 600

Kalâa Khisba New WWTP Ongoing Ongoing 1 300

Siliana Kesra New WWTP 2 500 500

Bizerte Sedjnene New WWTP 0 0 6 700

Béja Amdoun New WWTP Ongoing Ongoing

Guebollat New WWTP 0 0 2 000

Jendouba Oued Mliz New WWTP Ongoing Ongoing 1 120

Beni Mtir New WWTP 2 780 1 200

Centre Regional Department

Kasserine Hidra New WWTP Ongoing Ongoing 1 800

Kairouan Nasrallah New WWTP Common WWTP

1 3 600 3 600

Menzil Mhiri 0 0 3 250

El Alâa Haffouz WWTP 0 1 060 15 800

Monastir Amiret el Hojjej Moknine WWTP 2 572 4 200

Sidi Bennour Moknine WWTP 1 4 740 4 740

Manzel Hayet New WWTP Ongoing Ongoing 0

4

Governorate Municipality

Waste Water

Treatment Plant

(WWTP)

Pumping

Station

Backflow System

(lm) Transfer System

(lm)

Mehdia Mallolech Chebba WWTP 0 0 0

Ouled Chamekh New WWTP Ongoing Ongoing 0

Karkar Manzel Hayet

New WWTP Ongoing Ongoing

Ongoing

Sousse Sidi El Héni New WWTP 4 7 845 10 870

South Regional Department

Tataouine Dhhiba New WWTP 1 1 351 1 351

Rmeda New WWTP 3 2 620 1 800

Sfax Bir A Ben Khalifa New WWTP 1 1 200 2 000

Skhira New WWTP 1 800 800

Tozeur Hammet Jrid New WWTP 1 200 200

Gabes Matmata Jedida New WWTP Ongoing Ongoing Ongoing

Médenine Beni Khdech New WWTP Ongoing Ongoing Ongoing

Kébili Faouar New WWTP 1 1 400 Ongoing

2.2 Capacity Building and Institutional Support

- Study on the operation of sanitation systems in small municipalities (private sector participation);

- Study on the reuse of treated wastewater (TWW) (with pilot sites);

- Design and application of a software package for project planning and implementation;

- Procurement audit and procedures manual.

2.3 Programme Management (engineering studies, land procurement, operation and

technical assistance)

At the regional level (regional departments - RDs):

- Technical assistance for bid opening, monitoring and works control;

- Monitoring of working design;

- Monitoring of land, goods and works procurement;

- Monitoring of works;

- Monitoring of ESMP implementation and any abbreviated resettlement plans (ARPs).

At the central level (central departments):

- General programme coordination;

- Coordination of RD activities (procurements, studies, works monitoring, etc.).

- Programme financial and accounting management;

- Technical assistance to RDs.

The programme is implemented by an Operational Programme Management Unit (OPMU) based at the

ONAS Headquarters.

The programme cost is estimated at EUR 163.3 million.

2.4 Programme Alternatives

The only programme alternative explored is the "without programme" situation, which consists in

maintaining the current situation where domestic or industrial wastewater is discharged mostly into the

natural environment without treatment (wadis or simply streets in front of houses). In practice,

maintaining the current situation would mean further degradation of sanitary conditions and increase in

the pollution load in programme areas, leading to more diseases and deepening poverty that is not

consistent with Tunisia’s sanitation development policy.

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For each sub-project and during detailed engineering studies, the selection of the WWTP construction

site alternatives, the transfer/backflow systems layout and the treatment process alternatives will be

analysed. The selection will be based on environmental and social criteria to give preference to the most

natural and human environment-friendly alternative.

3. NATIONAL AND REGIONAL BASELINE ENVIRONMENTAL AND

SOCIAL INFORMATION

At end-2016, the key national sanitation indicators were as follows:

• Total urban population of about 7 million;

• Population connected to the ONAS system: 6.3 million, representing 90.3 % of the total

population. It should be noted that ONAS is not designed to cater for non-urban localities.

• Number of WWTPs: 115

• System length: 16 337 kilometres.

• Out of 260 million cubic metres of wastewater collected, 255.2 million cubic metres are treated

annually, that is a 98.15% treatment rate.

The programme impact area covers 33 municipalities in 19 governorates. These are mostly rural

municipalities whose population does not exceed 10 000.

Table 2: Characteristics of Programme Municipalities Municipality Population Population\Male Population\Female Households Housing Units

Khelidia 4 356.0 2 206.0 2 150.0 1 049.0 1 201.0

Menzel Horr 5 473.0 2 714.0 2 759.0 1 395.0 1 687.0

Azmour 5 057.0 2 486.0 2 571.0 1 281.0 1 545.0

Dar Allouch 4 547.0 2 343.0 2 204.0 1 229.0 1 617.0

Jebel Oust 5 325.0 2 757.0 2 568.0 1 284.0 1 476.0

En Nadhour 7 567.0 3 764.0 3 803.0 1 806.0 2 176.0

Sedjnane 5 228.0 2 602.0 2 626.0 1 290.0 1 498.0

Amdoun 5 356.0 2 655.0 2 701.0 1 324.0 1 672.0

Goubellat 4 128.0 2 091.0 2 037.0 965.0 1 092.0

Beni M'tir 504.0 248.0 256.0 113.0 154.0

Oued Meliz 2 388.0 1 146.0 1 242.0 600.0 838.0

Nebeur 3 557.0 1 720.0 1 837.0 954.0 1 060.0

Kalâat Khasba 2 558.0 1 216.0 1 342.0 692.0 804.0

Kesra 2 729.0 1 315.0 1 414.0 739.0 888.0

Sidi El Héni 2 706.0 1 315.0 1 391.0 639.0 778.0

Menzel Hayet 3 137.0 1 604.0 1 533.0 701.0 935.0

Sidi Bennour 4 520.0 2 149.0 2 371.0 1 045.0 1 199.0

Amiret El Hojjaj 8 121.0 4 119.0 4 002.0 1 679.0 1 778.0

Kerker 7 478.0 3 749.0 3 729.0 1 602.0 1 866.0

Ouled Chamekh 5 120.0 2 262.0 2 858.0 1 126.0 1 420.0

Melloulech 6 919.0 3 338.0 3 581.0 1 536.0 2 030.0

Bir Ali Ben Khelifa 4 905.0 2 426.0 2 479.0 1 208.0 1 421.0

Skhira 11 912.0 5 967.0 5 945.0 2 506.0 2 851.0

El Alâa 3 276.0 1 564.0 1 712.0 783.0 875.0

Nasrallah 5 012.0 2 446.0 2 566.0 1 241.0 1 475.0

Hidra 3 451.0 1 668.0 1 783.0 929.0 1 080.0

Nouvelle Matmata 7 526.0 3 607.0 3 919.0 1 798.0 2 380.0

Beni-Khedech 2 930.0 1 317.0 1 613.0 695.0 909.0

Dhehiba 4 295.0 2 145.0 2 150.0 777.0 986.0

Remada 6 289.0 3 101.0 3 188.0 1 084.0 1 344.0

Hamma el Jarid 4 074.0 1 970.0 2 104.0 953.0 1 048.0

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The sanitation situation in programme municipalities is characterised by:

- A sanitation system connection rate that varies from 0% to 40 % in the best case

scenario. Black water (from toilets) from households and collective entities (primary

schools, secondary schools, slaughterhouses, public coffee shops, etc.) are channelled

to drainage ditches in the form of cesspools that are cleaned at various frequencies,

depending on the usage. Municipal technical services are responsible, under state

control or subcontracting, for draining off the ditches using cesspool emptying

equipment;

- Disposal of effluents into the natural environment (effluents from wadis, spray areas,

public landfills, etc.) or supplied to farmers as soil admendment products or fertilisers

in spite of all the attendant health risks;

- Disposal of grey water (from sinks, showers and kitchens) outside households into

gutters or directly into the streets, leading to permanent flow of wastewater that causes

the proliferation of disease vectors and odours, especially during warm periods;

- Pollution and wastes that create all kinds of nuisances, especially in the rainy season,

namely: (i) proliferation of odours and disease vectors (mosquitoes and flies); (ii)

production of loaded and highly fermentable licheates; (iii) degradation of the living

environment; (iv) health problems at several levels, etc.;

- In some areas, rise in the water table due to the infiltration of wastewater through many

porous ditches;

- Infiltration of pollutants from ditches to stormwater collection reservoirs (Majels or

Festkia), which poses a health risk;

- Uncontrolled use of faecal sludge by farmers for soil admendment, thereby generating

a disproportionate health risk for them and consumers of any contaminated agricultural

produce;

- Increased financial burden for poor and average-income families as well as public

institutions and collective groupings considering the cost they have to bear to clean their

septic tanks (close to TND 300/month for heavy water consumers, TND 6 to 7/month

for households) ;

- Outbreak of diseases caused by the general lack of hygiene in unclean environments

particularly affecting vulnerable people and school children who are exposed to the risk

of contracting hepatitis A, typhoid fever and diarrhoea, leading to loss of schooling

time;

- Undermining of the well-being and the quality of the environment of the people living near crude wastewater outlets (around natural drainages) or during the accidental

overflow of septic tanks as a result of clogging or lack of means to ensure regular

emptying, etc.

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4. REGULATORY FRAMEWORK

Tunisia’s domestic policies accord paramount importance to the environment in general, and

environmental and social management arrangements in particular. Specifically, the new 2014

Constitution addresses issues related to climate, environment and natural resource management. Articles

12 and 45 of the Constitution respectively focus on "the judicious exploitation of national resources"

and the role of the State in ensuring "the right to a healthy and balanced environment and participation

in environmental protection".

Tunisia has put considerable effort into developing a varied legal and regulatory arsenal. The legal

instruments governing environmental protection and applicable to the implementation of the Sanitation

Programme for Municipalities with Less Than 10 000 Inhabitants include:

- Tunisia’s new Constitution adopted in 2014 ;

- Law No. 88-91 of 2 August 1988 establishing the National Environmental Protection

Agency (ANPE);

- Law No. 2001-14 of 30 January 2001 simplifying the administrative procedures for the

issuing of authorisations by the Ministry of Environment and Territorial Development;

- Decree No. 2005-1991 of 11 July 2005 repealing the 1991 decree on Environmental

Impact Assessment (EIA);

- Water Code No. 76-75 ;

- Law No. 82-66 of 6 August 1982 on standardisation and Decree No. 85-86 on the

regulation of discharges into the receiving environment;

- Law No. 83-87 on the protection of agricultural land, as amended by Law No. 96-104

of 1996 ;

- Law No. 95-70 of 17 July 1995 on water and soil conservation;

- Forestry Code No.88-20 of 13 April 1988;

- Law No. 30 of 6 March 2000 on the development of agricultural land in public irrigation

areas;

- Law No. 2016-53 of 11 July 2016 laying down conditions for land use and the

expropriation of property for public purpose, which repeals Law No. 76-85 of 11

August 1976 and Law No. 2003-26 of 14 April 2003;

- Law No. 96-41 of 10 June 1996 on wastes and the control of waste management and

disposal;

- Law No. 2007-34 of 4 June on air quality.

Decree No. 2005-1991 of 11 July 2005 repealed the 1991 decree on EIA and introduced many major

changes. It is being revised to incorporate the social dimension. The programme does not require

environmental impact assessment or approval by the ANPE. In accordance with national regulations,

only new water treatment facilities, irrespective of their capacity, are subject to an ESIA. Moreover, and

in accordance with the same decree, existing WWTP connection projects are not subject to an EIA, but

rather to specifications whose content complies with best practice.

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Table 3: Classification of Sanitation Projects by Decree No. 2005-1991

ANNEX I ANNEX II

Category A

(Plant subject to a notice not

exceeding 21 days)

Category B

(Plant subject to a notice not exceeding 3

months)

Specifications

(Low environmental impact

project)

1) Projects EXPLICITLY subject to EIA and EMP or specifications in accordance with Decree No. 2005-

1991

RS

Project in areas irrigated by treated

wastewater for agricultural purposes

(explicit)

RS Urban wastewater treatment plants

(explicit)

Industrial wastewater treatment plants

(explicit)

2) Projects subject to EIA and ESMP or specifications by ANALOGY in accordance with Decree No. 2005-1991

Household refuse management

plants < 20 T/D (sludge

management plants by

analogy)

Household refuse management plants >

20 T/D (sludge management plants by

analogy)

Water transmission and

transfer canals (wastewater

pipes by analogy)

It is worth noting that Decree No. 2005-1991 is being revised to incorporate social aspects and comply

with international environmental and social standards.

Overall, environmental management is the responsibility of the Ministry of Local Governments and

Environment and the various agencies under its supervision, namely:

• The National Sanitation Board (ONAS);

• The National Environmental Protection Agency (ANPE);

• The National Waste Management Agency (ANGED); and

• The Coastline Protection and Development Agency (APAL).

Other ministries and entities concerned by environmental issues include: the Ministry of Public Health;

the Ministry of Agriculture and Water Resources; the Ministry in charge of Budget; the Ministry in

charge of Land Tenue, industrialists and non-governmental organisations (NGOs).

5. IDENTIFICATION OF POTENTIAL PROGRAMME ENVIRONMENTAL

AND SOCIAL IMPACTS

In general, the impacts of a sanitation project are positive. They help to improve the quality of life of the population directly concerned, in addition to contributing to preserving the natural environment and

providing an unconventional source of irrigation water and sludge for reuse in agriculture and industry

(reuse of dry sludge in cement factories). Therefore, the programme will implement TWW reuse pilot

projects in at least five municipalities. These projects that are consistent with the country’s integrated

water resources management policy will help not only to meet the needs of some regions that lack water,

but also to promote the use of TWW in various sectors, create new uses and contribute to settling the

populations in small localities by offering them the opportunity to locally enhance their existing

resources or create new sources of income.

Regarding risks and negative impacts, the ESMF considered ONAS’s various activities as comparable

to those to be carried out under the programme and the impacts already identified in previous studies

and projects.

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5.1 Impacts during the Construction Phase

Sanitation facility development and construction project works generate nuisances for the natural and

human environment. These nuisances include: (i) land use and change of land use; (ii) alteration of the

natural and biological environment by soil and biodiversity degradation; (iii) generation of various

nuisances, especially the production of various wastes, construction site effluents, noises and vibration;

and (iv) traffic disruption by the movement of machines and vehicles, and dust and combustion gas

emissions. The level of these impacts is measured based on their scope, intensity and extent that vary

according to their environment. A preliminary analysis shows that the scope of these impacts should be

limited and restricted in space and time, considering that the programme will comprise no facility that

generates major or irreversible negative impacts.

Aspects Major Potential Negative Impacts

Land issue Procurement of small land and rights of way, change of land use and land tenure

regularisation

Environmental nuisances Noise and vibration, dust and combustion gas emission (greenhouse gases),

production of wastes (household, special and hazardous, construction site

excavations, etc.), water discharges

Social impacts Disruption of road traffic and the movement of persons

Danger, safety and

occupational health risks

Exposure to various on-site risks and hazards: working at a height without

protection, risk of asphyxia while working in closed areas, insufficient protection

while working at depth (trench, fall, etc.), road accident, hydrocarbon storage,

employment not compliant with the labour code

5.2 Impacts during the Operation Phase

Impacts during the operation phase are controlled by ONAS, considering that its trade is the operation of WWTPs.

ONAS manages over 170 WWTPs and is already establishing an ISO 14001 environmental management system

in treatment plants. The impacts identified are summarised in the table below.

Facility

Concerned Environmental and Social Aspects Environmental and Social Impacts

Wastewater

treatment plant

(WWTP)

Land

Production of screening, cleaning and

desilting by-products

Water bypass in the event of a breakdown or other hazards

Quality of effluents at the inlet and

outlet of the WWTP and performance

measure

Air quality analysis (existence or

absence of an air freshener system)

Energy consumption

Decanting of other effluents (non-

collective systems and others)

TWW intended for reuse (agriculture,

replenishment of water tables)

Drop in the value of land around WWTPs

Environmental nuisances and health risks

related to the management of cleaning products

and equipment maintenance

Risk of surface water, water table and marine

environment contamination

Risk of treated water contamination by trace

metals

Bad odours and complaints from local

inhabitants

High energy cost (cost of a cubic metre treated)

Disruption of the WWTP process, output and

performance

Health and trace metal accumulation risk (soil

and water table)

Pumping

stations Odours

Disposal of cleaning and screening

wastes

Effluent quality

Industrial effluents and intrusion of

illegal discharges

Energy consumption

Bad odour-related nuisances and complaints

from local inhabitants

Effluent bypass in the natural environment and

risk of environmental and health nuisances

Environmental contamination by wastes,

sludge and cleaning sand

Relatively high cost of lifting a cubic metre of

effluent (energy)

Wastewater and

effluents Domestic wastewater

Stormwater

Industrial effluents

Health risks for facility operators and users,

especially farmers

Surface water contamination

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Cooling water Water table contamination

Marine and beach pollution

Risks related to trace elements (heavy metals)

Collection and

supply systems De-clogging activities and cleaning of

collectors, manholes, inlets and sewer

drains, and as appropriate, stormwater

overflows and grit and connection

chambers

Waste disposal

Industrial effluent monitoring

Control of intrusions and accidents

(illegal discharges)

Exposure health risks for operators and

workers

Production of wastes (wastes, sludge and sand)

and their impacts on the natural environment

and health

Disruption of traffic and the movement of

people during maintenance works and

maintenance of systems

Sanitation

sludge

management

dumps

Wastewater sludge

Industrial effluent sludge

Risk of water table contamination (leachates

and metals)

Bad odours and complaints from local

inhabitants

Health risks for operators

6. PROCEDURES FOR ASSESSING POTENTIAL ENVIRONMENTAL AND

SOCIAL IMPACTS SPECIFIC TO PROGRAMME SUB-PROJECTS AND

PROCEDURAL MEASURES

The programme has identified 33 sub-projects based on the strategic sanitation study conducted in 2015

on 80 municipalities with less than 10 000 inhabitants. The list includes 24 new WWTPs and 9 sub-

projects for connection to existing WWTPs and, eventually, rehabilitation. Considering that detailed

engineering studies (including specific impact assessments in accordance with national law) are

ongoing, the ESMF has developed a procedure to take into account Donor environmental procedures in

the environmental analysis approach. The process is summarised below.

6.1 Stage 1: Description and Eligibility

The objective of Stage 1 is to ascertain that each sub-project is eligible for financing based on the E&S

policies of the AfDB and its financial partner EBRD, which exclude any Environmental Category 1 sub-

project. In this regard, the procedure has developed specific forms to be filled to guide the work of the

Environmental and Social Monitoring Unit (ESMU).

6.2 Stage 2: Risk Assessment and Management, and Environmental, Social, Health and

Safety (ESHS) Impacts

This stage includes the process to be followed to conduct environmental and social assessments. In that

connection, ONAS will consult the general terms of reference defined by ANPE for the activity sectors

concerned by the preparation of an ESIA as well as any supplementary social assessments according to

Donor requirements.

The ESIA and the ESMP must be prepared using a progressive and iterative approach to help ONAS to

decide on the feasibility of its sub-project or envisage other alternatives to arrive gradually at a least risk

solution.

The content of the ESIA must be participatory and comprise the following elements at least: (i) a detailed

project description; (ii) an analysis of the initial project site and its environment; (iii) an analysis of

project environmental impacts; (iv) proposal of recommended negative impact mitigation measures and

related cost estimates; and (v) proposal of an Environmental and Social Management Plan (ESMP)

together with an environmental monitoring programme.

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Review and approval of environmental and social assessment reports: at the national level, for projects

subject to an ESIA according to Decree No. 2005-1991, the review of the ESIA and the ESMP is the

responsibility of ANPE, which notifies its approval by issuing an environmental compliance certificate.

The ESIA/ESMP as well as any other supplementary study will also be transmitted to AfDB and its

financial partner for approval.

Information and dissemination of environmental and social assessment reports: once the ESIA, the

ESMP and, eventually, the ARP, if required, are approved, ONAS, for purposes of transparency and

accountability, particularly regarding the key stakeholders, will place the said documents at the disposal

of the public in municipalities, delegations, governorates and regional sanitation offices, and on its

website. Donors will provide support for such dissemination.

The procedure states that consultation timeframes must enable the consideration of useful feedback from

persons and groups that would also have consulted the key documents produced (ESIA, ESMP and

ARP) and the revision of the documents.

As part of strengthening ONAS’s communication policy, ESMU will establish a database for monitoring

the environmental and social status of ONAS’s activities. The database will be fed with data provided

and communicated by environment focal points. The data will help to inform ONAS’s key

environmental and social indicators. An annual environmental and social status report will be produced

by ESMU and posted on ONAS’ website. The template of the ONAS annual environmental and social

status report has been specified in the procedure.

6.3 Stage 3: Project Implementation and Monitoring

E&S clauses: the procedure provides for the incorporation of subproject-related additional

environmental and social clauses (as identified in the ESMP(s)) in the bidding documents during project

launching in the studies or works phase, or when leasing out the operation of ONAS’ WWTPs and other

facilities. A sample price schedule has been prepared and provided in the procedure.

Implementation of environmental and social measures: the contractors legally and contractually

responsible for implementing the ESMP during the construction phase will also undertake to strengthen:

(i) the participation of the local population concerned; (ii) the mainstreaming of the gender dimension;

and (iii) complaints management. In addition, as project owner, ONAS will strengthen social

communication through its current citizen space on its website.

Measures implementation monitoring/evaluation: during programme implementation, the contractor(s)

responsible for programme implementation will report to ONAS on the implementation of the

environmental and social measures provided for, in accordance with the programme documents

(ESMP), the status of mitigation measures and the outcomes achieved. Monitoring the implementation

of programme environmental, social, health and safety measures is described in the table below.

Responsibility Monitoring Reference Framework Periodicity Reporting

Works

contractor’s HSE

Officer

Construction site’s

health, safety and

environmental

performance

Works contractor’s

contract terms

Works contractor’s HSE

Management Plan

approved by ONAS

Continuous

during works

Monthly report to

ONAS’ Regional ESHS

Officer

(form available)

Wastewater

treatment plant

operator’s HSE

Officer

ESHS performance of the

wastewater treatment

plant

Works contractor’s HSE

Management Plan

approved by ONAS

Continuous

Monthly report to


Officer

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Responsibility Monitoring Reference Framework Periodicity Reporting

ONAS’ Regional

ESHS Officer

ESHS performance of the

wastewater collection

and treatment facilities of

small towns of the region

covered by the Sanitation

Programme for



Tunisia’s legislation

Programme ESHS

Procedure

Monthly visit

to each small

town

Semi-annual report to


Officer

and to OPMU’s ESHS

Team

OPMU’s ESHS

Team

Field control of six sub-

projects: 3 most efficient

and three least efficient

Programme ESHS

Procedure

Semi-annual

during works

Good and bad practice

sharing note to all

Regional ESHS Officers

ONAS’ Central

ESHS Officer

OPMU’s ESHS

Team Programme’s ESHS

Performance

Tunisia’s legislation

AfDB and EBRD E&S

policies

ESHS procedure of the

Sanitation Programme for



Environmental and Social

Action Plan

During works Semi-annual report to

AfDB and EBRD

ONAS’ Central

ESHS Officer

After works Annual report to AfDB

and EBRD

To ensure its implementation, the programme has included a technical assistance that will solicit the

services of an independent expert/ group of experts responsible for ascertaining contractors’ compliance

with the actions and measures provided for in the ESMPs that will be adjusted if necessary, or in case

of failure to comply.

7. ADDITIONAL MEASURES TO BE INCLUDED IN SUB˗PROJECT ESMP

Based on programme environmental impact assessment, a battery of measures has been proposed for

each sub-project development phase.

7.1 Measures during WWTP Design

During WWTP design study and sizing, some rules and recommendations contained in the technical

specifications of facilities should be considered to facilitate the management of facilities and ensure

their efficiency in producing a discharge that complies with standards.

Table 4: General Recommendations and Specifications to be Considered in the Design and during the Operation of the Sanitation System

Ref. Elements Recommendations and Specifications to be Considered

I General Recommendations and Specifications for the Sanitation System

1.1 Selection of

sanitation system

❖ Based on the comprehensive study of the physical features of the study area and socio-

economic conditions

1.2 Stormwater drainage

system

❖ Must be sized to dispose of runoff rates resulting from the heaviest rainfall at a given

frequency (2.5 years or 10 years, depending on the size of the urban centre)

1.3 Disposal plan layout ❖ The water disposal plan layout must be prepared by making utmost use of the

topography of the land to ensure, as much as possible, a gravitational flow with

sufficient flow speeds. It is necessary to limit the number of lift and pumping stations

for economic reasons and owing to operating conditions

1.4 Selection of receiving

environment

❖ As much as possible, avoid discharging wastes into closed water environments (lakes,

ponds, etc.), owing to their fragile ecological balance

❖ Avoid directly discharging wastes into seashore sensitive areas (near beaches, gulfs,

unfavourable sea currents, etc.)

❖ Ensure the watertightness of the system at the crossing of water tables to avoid their

pollution and control the volume of infiltrated water

❖ Avoid constructing the plant in a flood-prone area

1.5 Limit the release of

nauseating odours

❖ Provide for sufficient flow speeds to avoid the formation of permanent deposits

❖ Provide system head sections with a flush

❖ Avoid cascade lifting

13

Ref. Elements Recommendations and Specifications to be Considered

❖ Increase the flow speed in airlift pumps (reduce wastewater residence under anaerobic

conditions)

II Specifications for Wastewater Treatment Plants (WWTPs)

2.1 Screening ❖ The flow speed through partially plugged screens must be maintained within the range

of 0.6 m/s and 1.2 m/s

❖ Change screen wash pumps from manual to automatic

❖ Provide for the possibility of isolating screens to ensure their maintenance and repair

(cofferdam).

2.2 De-silting ❖ Use mechanised aerated grit chambers each time that the size of the plant so requires

❖ Schedule frequent sand extraction and washing

❖ Increase the size of aerated grit chambers, with an appropriate hydraulic loading

❖ Adjust the scheduling of sand extraction sequences

2.3 Primary settling ❖ Apply low hydraulic loading to avoid carrying sludge during hydraulic overloading

(during rain)

❖ Schedule frequent extraction of decanted sludge to avoid foul odour

2.4 Aeration ❖ Give preference to membrane diffusers for efficient aeration management

❖ Immersed railings with bubble diffusers must be isolable and adjustable

❖ Use double speed boosters for maximum management flexibility

❖ Sound insulation and ventilation of booster compartments are compulsory

❖ Where many settling tanks are used, each tank should have a booster. Air circuits must

be interchangeable (adapted winnowing system)

❖ An emergency booster is advisable even for small facilities

❖ Provide for dust filters

❖ Drain cocks should be fixed at low points

❖ Steel and stainless steel should not be juxtaposed (corrosion cell)

❖ The presence of compounds that are aggressive to elastomers (hydrocarbons) in

wastewater should be checked

2.5 Agitation ❖ The aeration and agitation functions must be separated to optimise nitrogen elimination

and prevent deposits during the shutdown of aeration

❖ Mixed liquor flow speed at the tank bottom must be above or equal to 35 cm/s

❖ The capacity of stirrers varies depending on the geometry of the tanks

2.6 Clarification ❖ Frequently extract sludge from the bottom of clarifiers to prevent their fermentation.

Sludge residence at the bottom of clarifiers must not exceed 2 hours

❖ Ensure extensive upstream denitrification to prevent denitrification in the clarifiers that

could lead to sludge flotation

❖ The bottom scraper should be easily pulled out by the operator, especially without having

to empty the decanter. Bottom rollers are forbidden

❖ Louvre-like bottom scrapers (discontinuous) increase sludge residence. Scrapers made of

a single continuous blade are recommended

III Specifications for Sludge Treatment

3.1 Sludge thickening ❖ Sludge must not be resident in the thickener for long to prevent its fermentation

❖ Preferably use cover thickeners

❖ Hydraulic loading must not be high to avoid sludge overflow

3.2 Sludge digestion ❖ Digester sludge intake must be regular and, as much as possible, continuous

❖ There should be a scum breaker mechanism to prevent the consolidation of the floating

layer on the surface of the digester

3.3 Lagooning ❖ The plant must be located at a low point (to ensure gravity supply), at a place where

dominant winds contribute to aerating surface water column

❖ There should be no trees within 10 metres of the plant as their roots could create

preferential flows in the dykes

❖ The land should be selected in such a way as to ensure gravitational flow right to the

receiving environment

❖ The geometry of the lagooning tanks must be selected so as to minimise dead bands and

short circuits

❖ Dykes surrounding tanks must be sufficiently large to enable the movement of machines

14

7.2 Mitigation Measures during the Construction Phase

7.2.1 Framework for Mitigating Impacts on the Construction Site

In general, the construction site should be installed on an authorised site selected beforehand by ONAS.

It should be easily accessible, located near the project site and at least 400 metres from residential areas,

fenced and clearly signalled. The measures include provisions to limit impacts and nuisances related to

the movement of machines and impacts on the soil, particularly farmland. Construction materials (sand,

gravel, debris, etc.) should be stored on the construction site far from the workers’ camp to avoid dust

emissions and sound nuisances caused by the movement of machines and vehicles.

The impact mitigation framework includes the storage of hydrocarbons, flammable and/or hazardous

products (hydrocarbons, mineral oils and other flammable and/or hazardous products) and specifies,

among other things, storage conditions and the control of accidental spills.

In case of an accident and/or a fire on the construction site, an Emergency Response Plan (ERP) prepared

beforehand by the Contractor in charge of works will be implemented.

7.2.2 Framework for Mitigating Construction Site Noises and Sound Nuisances

The ESMF specifies the thresholds for noise exposure as defined by World Health Organization (WHO)

standards for residential (local residents) and work (employees) areas. It also includes monthly

campaigns to measure the noise level on the construction site and its surrounding areas. The measured

noise level will be compared with the level recommended by WHO and levels recommended for various

occupational settings by the International Organization for Standardization (ISO).

7.2.3 Construction Site Solid Waste Management

Solid waste will be managed in accordance with Law No. 96-41 of June 1996 backed by the following

additional measures:

Inert waste, household and similar waste: the procedure in force specifies the methods of collecting

(containers) and sorting waste: (i) inert waste, depending on the existence of a waste recycling sector,

especially construction waste; (ii) household and similar waste to be disposed of in municipal landfills;

(iii) unused excess debris to be channelled to the nearest municipal landfill and/or ANGED.

Hazardous waste: the appropriate measures considered concern waste oils at the Tunisian Lubricants

Company (SOTULUB), which is the main company that processes and recycles waste, oil-contaminated

rags, filters and other special waste to be channelled to the Hazardous Waste Treatment Centre for

processing after informing and consulting ANGED, and used batteries collected and stored at the

construction site before returning them to producers (for example, the Tunisian Battery Company –

ASSAD).

7.2.4 Construction Site Liquid Waste and Wastewater Management

Workers’ camp liquid waste management: installation of watertight drainage ditches for wastewater

collection to be drained periodically, and channelling of wastewater to the nearest wastewater treatment

plant (WWTP) by an approved company.

Construction site liquid waste management: where the construction site has a machine cleaning and

maintenance platform, clear water from the machine and vehicle washing water collection ditch will be

collected and reused in watering roads to reduce dust emissions.

15

7.2.5 Gas and Dust Emission Mitigation Measures

The Tunisian Standard NT 106.04 for ambient air quality will be applied, in addition to the watering of

roads and traffic areas, and the maintenance and regular technical control of all construction site

machines and vehicles in accordance with the regulations in force to avoid excessive fuel consumption

and reduce exhaust fumes, particularly greenhouse gases (GHGs).

7.2.6 Soil Erosion and Facility Silting Control Measures

The Contractor will endeavour to limit the risk of soil erosion, flooding of the construction site, roads

and feeder roads, farm-to-market roads and the silting of water works. The Contractor must prevent

groundwater contamination by draining stormwater and excavation floor water towards existing

drainage channels.

7.2.7 Management of Concession Holder Networks

The Contractor is contractually obliged to take all the necessary measures to prevent any damage to the

piping, pipes, various cables, roads and road networks crossed during works execution. As-built

drawings will be prepared in full consultation with the concession holders concerned to implement the

potential system displacement operations.

7.2.8 Hygiene and Safety Measures

Proper construction site organisation includes taking appropriate safety measures to protect local

residents and workers against the risk of accidents associated with the execution of works and the

movement of machines, ensuring strict compliance with safety and hygiene instructions in accordance

with the regulations in force and signs on the construction site (prohibition of access, speed limits for

machines on the construction site and roads, and the shoring up of excavations).

The Contractor is contractually obliged to provide personal protective equipment – PPE (helmets,

gloves, protective footwear, goggles, etc.) to construction site workers and to sensitise workers and

visitors on their use.

7.2.9 Site Restoration upon Completion of Works

Site restoration is a contractual clause reinforced by a special mention in case of accidental damage,

which the Contractor is bound to correct at his own expense.

7.3 Measures during the Operational Phase

7.3.1 WWTP Water Quality Monitoring Framework

A programme to control and monitor the quality of crude water before the WWTP inlet and after treatment will be designed to monitor the plant’s performance. Analyses and observations will be

conducted upstream and downstream of the WWTP. The aim will be to monitor the flow and quality of

water at the WWTP inlet (crude water) and outlet (treated wastewater) to identify anomalies that may

affect the performance of the WWTP. Water samples will be collected and analysed using an automated

sampler as much as possible to ensure that treated wastewater is consistent with the NT 106.02 standard.

The frequency of water collection and analysis is specified in the section on environmental monitoring.

ONAS has a non-compliance early warning mechanism that involves the intervention of the WWTP

manager.

16

Regarding the storage pond containing treated wastewater to be reused to water public spaces, the

parameters of analysis also concern the biological and bacterial quality of treated wastewater: heavy

metals, Escherichia coli, faecal coliforms and salmonella and helminthic eggs, vibrio cholerae and

viruses, in keeping with the NT 106.03 standard.

7.3.2 Framework for Monitoring Water Quality in the Receiving Environment

Where WWTP wastewater is discharged into a river or lake receiving wastewater from the upstream

basin, biological and bacterial quality analysis will be carried out in three plants, namely: the ONAS

discharge point (WWTP outlet), a plant downstream of the ONAS discharge point (where there is natural

flow) and a plant after mixture with the wastewater released upstream (wastewater from a source other

than the WWTP). The main parameters to be monitored are suspended solids (SS), chemical oxygen

demand (COD), five-day biochemical oxygen demand (BOD5), nitrogen, phosphorus and

bacteriological parameters.

Two piezometers will be placed on the water table located near the WWTP and the receiving

environment: one in the WWTP and the other near the WWTP downstream wastewater-receiving environment in the direction of flow of the water table1. A control piezometer should be selected

upstream of the WWTP discharge point and adopted as a baseline to measure the impact on the water

table. Two piezometer readings will be taken yearly, one at the end of the rainy season and the other at

the end of the dry season. The readings will concern: (i) the piezometric level; and (ii) the physico-

chemical quality (BOD5, COD, salinity, total nitrogen, total phosphorus and the biological water

quality: Escherichia coli, total coliforms, faecal coliforms and salmonella).

On the water table located near water reuse areas, a control piezometer will be placed in/near each reuse

perimeter in the direction of the water table flow to monitor the water quality and the impact of reuse.

The piezometer will preferably be placed within the perimeter or on a site within a radius not exceeding

400 metres around the perimeter in the direction of the water table flow. Two readings will be taken

yearly, one at the end of the rainy season and the other at the end of the dry season. The readings will

concern: (i) the piezometric level; and (ii) the physico-chemical quality (BOD5, COD, salinity, total

nitrogen, total phosphorus and the biological water quality: Escherichia coli, total coliforms, faecal

coliforms and salmonella).

A groundwater point will be selected upstream of the perimeter and/or reuse area to serve as control in

order to monitor the impact of reuse on the water table.

7.3.3 Framework for Climate Change Adaptation

As a climate change adaptation measure, the programme includes a Wastewater Reuse Component

under which five pilot sites will be set up. This action will enable ONAS to implement some actions in

the small municipalities alongside the works executed to improve the quality of wastewater from major

WWTPs.

7.3.4 Framework for Risk and Hazard Management

WWTPs are classified, unhealthy and hazardous facilities and, hence, require the adoption of strict

safety and hygiene measures from design to personal protection, hygiene and control of hazards. The

WWTP operator must provide personal protective equipment (PPE) such as mono-frame goggles,

respiratory protective equipment (disposable FFP 2 half-mask respirators, gas filters, full-face masks,

etc.), waterproof gloves, etc., as well as work clothes. This equipment should be selected based on the

risks incurred by workers and adapted, regularly maintained and stored in a clean and dry place. Personal

protective equipment supplement collective prevention measures. Hygiene measures help to limit risk

of contamination faced by workers. They should be simple, well-known and implemented by workers.

1 Use existing wells if they are located within 400 metres to 500 metres from the WWTP in the direction of the flow of the water table.

17

In keeping with the regulations governing classified facilities, WWTPs should be the subject of hazard

studies, as well as a plan for the prevention of accidents included in works execution studies. These

studies should include:

- The hazards and risks incurred in interventions in sanitation facilities;

- The prevention of risks in interventions in confined spaces;

- Regulatory requirements and related documents, in keeping with the Labour Code;

- The protective equipment necessary for the operation of WWTPs;

- Measures to prevent the main risks associated with the operation of WWTPs and

sanitation facilities (falling, drowning, noxious gases, etc.).

7.4 Summary of Environmental and Social Measures:

18

Table 5: The Environmental and Social Management Framework to be used during the Execution of Sanitation Works

Potential Environmental Impact Proposed Actions Entity

Responsible

Control/

Monitoring Estimated Cost (TND) Timeframe

1. Institution Building

Disruption of the natural and socio-

economic environment in the

project area

Appoint an environmental and social focal point (ESFP) in ONAS. ONAS FP Considered by ONAS Immediate

Appoint a hygiene and safety (HSE) officer within the Company. Contractor ONAS Included in the contract At project start-up

Recruit an environmental consultant to provide technical support to ONAS in

supervising ESMP implementation. ONAS PF/ONAS ONAS At project start-up

Building the capacity of ONAS and

companies in construction site

environmental management

procedures and guidelines.

Train the senior officers of ONAS in construction site ESMP implementation

and monitoring procedures.

Train the technicians of public works and civil engineering companies in the

mainstreaming of the environmental and social aspects at the construction site

and compliance with regulations.

Sensitize construction workers on compliance with environmental, safety and

hygiene rules and regulations.

ONAS ONAS ONAS

At project start-up

and periodically

during the

execution of

works.

2. Construction Site Installation

Installation of the construction site

Select a location for the installation of the construction site.

Approve the construction site selected by ONAS’ ESFP, in consultation with the

ESMU.

Contractor RPGES

ANPE Included in the contract

Before project

start-up

Define storage areas for building materials, hydrocarbons, water, and waste.

Comply with product storage rules.

Adopt best practices for managing nuisances at the construction site (dust

emissions, wastewater, waste, traffic, noise, etc.).

Contractor RPGES

ANPE Included in the contract At project start-up

3. Construction Site Impact Management Measures

Land tenure- and land use-related

issues.

Changes in land use.

Impact on the population.

Land tenure regularisation:

Compensate project-affected persons.

ONAS

ONAS/Land

Tenure

Service

Considered by the

project Immediate

Restore land.

Restore access roads.

Restore the networks of project-affected concession holders.

Contractor RPGES

ANPE

Modification of the landscape.

Restore land near the project area.

Collect, reuse and/or evacuate excess debris from the construction site to an

approved landfill.

Restore installations (SP, technical premises, buildings, WWTPS, etc.) on the

construction site natural landscape by planting hedges in green spaces.

Avoid traffic in the farmlands located near the construction site right-of-way.

Reinforce signals at the construction site.

Contractor Contractor/

RPGES Included in the contract

Upon project start-

up

Risk of water table and soil

contamination by construction site Dig a watertight wastewater drainage ditch. Contractor

ANPE/


Upon project start-

up

19


Responsible

Control/


sewage: wastewater, contaminated

water from the construction site

(cleaning of vehicles and machines,

emptying of excavations, etc.).

Ensure that the ditch is drained regularly by a company approved by ONAS and

that wastewater is transferred to the nearest WWTP for treatment.

Dig a machine and car wash water drainage ditch and build a machine

maintenance platform on the construction site, if necessary.

Equip the machine and car wash water drainage ditch with an oil

separator/degreaser.

Drain clear water and reuse it to water roads.

Regularly maintain the oil separator and channel the waste grease to approved

treatment centres.

Risk of contamination of surface

water, the water table and soil by

waste oil and fuel leakages.

Equip fuel storage tanks and watertight waste oil retention tanks with sand.

Drain oil-contaminated sand to a specific landfill.

In the absence of a specific platform, prohibit the execution of equipment

maintenance operations at the construction site.

Contractor ANPE/


Upon project start-

up

Risk related to machine and vehicle

movement.

Disruption of road traffic and the

movement of people and animals

Design a traffic plan for the movement of machines and vehicles in the project

area.

Provide for the required safety and security measures during the transportation

of construction site equipment and materials.

Cover trucks transporting debris and building materials (sand, gravel, etc.) with

tarpaulins.

Install the required roads signs (machine and truck exit and speed limit).

Water access roads to the construction site and near urban centres and farmlands.

Contractor

ANPE/Traffic

control police/

RPGES

Included in the contract Upon project start-

up

Impact of the accumulation of

construction site waste on water

resources, farmlands and the health

of workers and local residents.

Household waste.

Miscellaneous waste: wood, metals,

plastics, etc.

Special waste: used oils, used oil

filters and grease towels, batteries

and tyres, etc.

Construction waste.

Excess debris.

Collect and dispose of household waste into a controlled landfill.

Ensure the collection and recovery of used oils and filters by SOTULUB.

Collect and store excess debris and construction waste in an area reserved for

that purpose at the construction site and dispose of them into an appropriate

landfill (authorisation by ANGED and municipalities).

Reuse topsoil to develop green spaces.

Collect, sort and place waste (plastics, metal, wood, cardboard, etc.) at the

disposal of recyclers.

Prepare an appropriate area to store waste before channelling it to the landfill for

treatment.

Traceability: register the various types and monthly quantities of waste produced

at the construction site.

Contractor

ANPE

ANGED

Municipalities

RPGES

Included in the contract Upon project start-

up

Occupational hazards at the

construction site. Sensitize and train construction workers on safety and hygiene rules and

regulations. Contractor ONAS


Upon project start-

up

20


Responsible

Control/


Protect hazard-prone areas by adopting appropriate safety measures (work at a

height or in excavations, risk of falling objects, etc.).

Equip workers with PPE (helmets, protective footwear, gloves, goggles, etc.).

Provide for a first aid kit.

Install signs on roads and construction site access roads.

Strengthen control, safety, security and hygiene measures.

4. Rehabilitation and Restoration of the Construction Site Upon Completion of Works

Disruption of farmlands.

Contamination of soil by

wastewater, waste, etc.

Contamination of water by

hydrocarbons and waste oil

leakages.

Dismantle construction site installations.

Rehabilitate septic tanks.

Rehabilitate pits and construction site water collection basins, and treat

contaminated sludge.

Rehabilitate the fuel storage site.

Collect and channel waste to appropriate landfills.

Contractor

ONAS

ANPE


Upon project

completion

Table 6: Environmental and Social Management Framework to be used during the Operation of Sanitation Facilities

Proposed Measure Monitoring and Control Actions Frequency and

Assessment

Institution Responsible/

Concerned

Entity

Responsible

Estimated Cost

(TND)

Institutional support and

capacity building

Appointment of ONAS’ Environmental and Social Focal Point

(ESFP).

Appointment of an EO in the WWTP’s Operating Service (sub-

branch).

Appointment of focal points (CRDA, municipalities, Industry,

Health, etc.).

Fielding of a periodic environmental intelligence mission upstream

and downstream of the WWTP.

Periodic reporting (monthly, quarterly and yearly). Technical

assistance in environmental and social management, if need be.

Designation of a civil society association (if necessary) to support

public consultation, communication and complaints management.

Monthly

ONAS (RPGES/EO-WWTP

CRDA/Focal Point

Health/Focal point

Industry/Focal Point

Municipality/Focal Point

ANPE/Focal Point

TA/ESMP

ONAS Envisaged by

ONAS

Building the capacity of the RPGES and the EO of the WWTP.

Building the capacity of the Operating Service and the Health,

Safety and Environment (HSE) Officer of the concession holder

(in case of a private operation).

Information, Education and Communication (IEC) of actors,

beneficiaries and civil society.

Periodic

ONAS (RPGES/EO-WWTP

CRDA/Focal Point

Health/Focal Point



ANPE/Focal Point

TA/ESMP

ONAS Provided in

technical assistance

21

Proposed Measure Monitoring and Control Actions Frequency and

Assessment

Institution Responsible/

Concerned

Entity

Responsible

Estimated Cost

(TND)

Monitoring water quality

(CWW, TWW,

groundwater (EDN),

surface water (EDS))

Industrial waste control: major classified facilities producing

heavy metals, hydrocarbons, oils and fats/phenols.

Monitoring of the volume and quality of water at the inlet/outlet of

the WWTP.

Monitoring the volume and quality of treated wastewater intended

to be reused for agricultural purposes: storage station and basin.

Monitoring the quality of water tables: 3 stations: control, at the

WWTP and in the irrigation area using treated wastewater.

Monitoring the quality of surface water (wadi, lake, sea, etc.): 2

stations: upstream and downstream of ONAS’ discharge points.

Monthly

Monthly

Monthly

Half-yearly

ONAS (RPGES/EO-WWTP

CRDA/Focal Point

Health/Focal point



ANPE/Focal Point

TA/ESMP

ONAS **

Monitoring of noise and

sound nuisances at the

WWTP, SP and other

equipment (vehicles and

maintenance equipment)

Measurement of noise in at least two plants: the WWTP (premises

and work areas): dB01 and SP: dB02 ... B0i.

Measurement of noise 200 metres around the WWTP and SP (at

least 2 plants)

Monthly

ONAS (RPGES/EO-WWTP

Health/Focal Point

TA/ESMP

ONAS **

Monitoring the quality of

ambient air and foul odours:

H2S and other GHGs

Measurement of H2S in at least two plants: WWTP and SP.

Fuel consumption during operation (rolling stock and generators).

Energy consumption (electricity and gas)

Calculation of WWTP GHG emissions.

Monthly

Monthly

Monthly

ONAS (RPGES/EO-WWTP

Health/Focal Point


ANPE/Focal Point

TA/ESMP

ONAS **

Management of WWTP

waste and sludge

Collection, storage and disposal of pretreatment waste into

approved landfills and implementation of SP and system

maintenance operations (sand, grease, oil, etc.)

Management of sewage sludge: quantity, quality, quantity reused

and reuse sector

Daily

ONAS (RPGES/EO-WWTP

Health/Focal Point


ANGED/Focal Point

TA/ESMP

ONAS **

Monitoring soil quality

Monitoring of moisture content and soil organic matter

Monitoring of heavy metals in the soil (compare with a control

metal).

Annual CRDA

TA/ESMP (if necessary) CRDA **

Health & safety

surveillance

Preventive measures:

Monitoring of the health status of workers in the WWTP.

Monitoring of the health status of workers in the irrigation area.

Monitoring health status in the project area.

Monthly

ONAS (RPGES/EO-WWTP

CRDA/Focal Point

Health/Focal Point

TA/ESMP

ONAS

CRDA

Health

**

Emergency Response Programme (ERP):

Treatment of mosquito breeding grounds within the WWTP site.

Treatment of mosquito breeding grounds outside the WWTP

(systems and SP)

Monthly

ONAS (RPGES/EO-WWTP

Health/Focal Point


TA/ESMP

ONAS **

**: The financial estimate is being done, in consultation with ONAS.

22

8. SUB-PROJECT MONITORING AND SUPERVISION ARRANGEMENTS

8.1 Institutional Arrangements

The Environmental and Social Monitoring Unit (ESMU) will control and supervise the implementation

of the ESMF. It will be backed by the services of technical assistance experts provided for under the

programme.

At the local level, institutional arrangements will be organised in ONAS regional departments. An

environmental and social focal point (ESFP) will be part of the staff of each department concerned.

He/she will be in charge of implementing the environmental and social management framework. ESFPs

will also receive support and advice from the central services of ONAS in general, and ESMU in

particular, as well as from the decentralised services of various ministries and national agencies.

An Environment Officer (EO) will be appointed in each WWTP (branch). The EO will be the only

interlocutor of the ESFP and ESMU for ONAS and various project stakeholders. Where a project is

implemented by a construction company or through an operation lease, a Hygiene, Safety and

Environment (HSE) Officer will act as the interlocutor of the focal point and the environment officers

of the WWTP. HSE experts will be responsible for updating the ESMP at project start-up, under the

supervision and guidance of ESMU. These experts will ensure that the Contractor implements the

ESMP. It should be noted that ANPE will also be responsible for control, which falls within its remit as

a public entity, during the construction and operation phases.

Figure 1 below presents a diagram of the relationships between ESMU and various stakeholders and

partners.

Figure 1: Institutional Organisation Chart

23

8.2 WWTP Environmental and Social Surveillance and Monitoring Procedures Manual

The following monitoring templates and forms have been developed for the programme:

- Pro-ESMP.01 : Recruitment of an EMP Consultant

- Pro-ESMP.02 : Appointment of the Environment Officer of the WWTP

- Pro-ESMP.03 : Appointment of focal points

- Pro-ESMP.04 : Template of WWTP ESMP supervision reports

- Pro-ESMP.05 : Template of ONAS’ annual environmental and social management report

- Pro-ESMP.06 : Capacity building

- Pro-ESMP.07 : Monitoring of the quality of wastewater discharges

- Pro-ESMP.08 : Monitoring of noise nuisance within and around the WWTP

- Pro-ESMP.09 : Monitoring of gas emissions

- Pro-ESMP.10 : WWTP waste management

- Pro-ESMP.11 : Monitoring of soil quality in PPI

The table below summarises the environmental surveillance criteria used in a WWTP and in related

facilities.

Table 7: Environmental Surveillance of Sanitation Facilities Components/Activities Monitoring and Evaluation Indicators Responsibility Rate

1. Air quality

Pumping station H2S content

Quantity by instrument

Station manager


Focal Point (ESFP)

5/7 days

WWTP H2S content

Quantity by instrument

Station manager


Focal Point (ESFP)

5/7 days

2. Noise pollution

Pumping stations Sound level measurement

(<80 dB)

Station manager


Focal Point (ESFP)

Weekly

WWTP boosters Sound level measurement

(< 80 dB)

Station manager


Focal Point (ESFP)

Weekly

3. Measures envisaged for the management of non-recoverable waste

Screening products Quantity stored Station manager Weekly

De-oiling products Quantity stored Station manager Weekly

Grit removal products Stock position Station manager Weekly

Non-marketed digested /dry

sludge Stock position Station manager Weekly

4. Measures to protect ground water, surface water and receiving water bodies

Overflow of pumping stations Registered, date and reason Station manager Occasionally

Overflow of the WWTP Registered, date and reason Station manager Occasionally

5. Monitoring the quality of wastewater and sludge in the WWTP

Wastewater at the inlet Quality analysis/Average 24-hour

sample WWTP Laboratory 5/7 days

Treated water from the

secondary sedimentation tank

Quality analysis/Average 24-hour


Stabilised/dry sludge Quality analysis/Average 24-hour


Gas composition Quality analysis/Average 24-hour


24

9. COMMUNICATION AND CONSULTATION ARRANGEMENTS

The ESMF has proposed a public consultation framework that aims to ensure the social acceptability of

projects and activities at the community level by establishing a network for sharing information on

environmental issues and on the projects among all actors. The consultation process addresses the need

to fully involve the population in identifying needs and monitoring/evaluating activities to promote

control by citizens, the sharing of knowledge and expertise, participation, and social efficiency.

Similarly, the involvement of local inhabitants guarantees project sustainability inasmuch as it enables

them to own the project and its objectives.

To comply with this comprehensive approach, ONAS is expected to prepare two master plans, namely:

- A plan for communicating with non-governmental organisations;

- A plan for coordinating activities with stakeholders.

The ESMF will be open for public consultation through the Validation Committee comprising the main

donors and representatives of various ministries involved in environmental and social management in

Tunisia. The public will also be involved to express their opinion regarding the design of the

environmental impact assessments of sub-projects and to peruse the ESIA reports systematically posted

on ONAS’ official website.

10. REQUIREMENTS FOR TRAINING AND BUILDING CAPACITY IN ESMF

IMPLEMENTATION

To ensure the sound implementation of the ESMF, the institutional framework hinges on the

establishment of a new Department of Quality, Safety and Environment (DQSE). The Environmental

and Social Monitoring Unit (ESMU) in charge of environmental and social management in general will

be attached to the new DQSE.

ONAS’ Environmental and Social Monitoring Unit (ESMU) will play its environmental and social

management role only if it is provided, on a regular basis and as much as possible in real time, with the

required skilled human resources and information on the status of projects being implemented, and

equipment and infrastructure being operated and their performance, as well as any anomalies and

malfunctions that may occur. To that end, it is necessary to prepare an organisational and technical

capacity-building plan that includes:

- Reinforcing the central level with qualified human resources (a socio-economist

responsible for communication, complaints management, etc.);

- Appointing, at the regional level, focal points as Environment Officers in ONAS’

departments as well as environmental and social branches in each WWTP;

- Organising various training sessions on environmental and social management for

ESMU senior officers and workers.

Since the participatory process instituted by this ESMF will involve the local population, national

entities (ministries and institutions involved), local NGOs and regional partners, the framework provides

for a training and capacity-building plan. The plan is aimed at helping various target groups to

understand public consultation procedures and to ensure the implementation of various phases of public

consultation in accordance with the principles of this ESMF and the requirements of various

international donors by:

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- Preparing a simplified guide for various target groups to enable them to better

understand and apply the provisions contained in the ESMF regarding the participatory

approach;

- Organising training sessions on public consultation. It is important for the trainers

involved in these training sessions to have the required skills in managing relations with

the public and NGOs, interactive communication, mediation and synthesis.

Concerning complaints management and despite the presence of a “civic interface” on ONAS’ official

website and a toll-free number, the complaints management practices in force are not harmonised,

monitored or evaluated. It is necessary to adopt an action plan to strengthen the communication and

complaints management systems. The plan will include:

- Upgrading the existing system to include the complaints management mechanism

(CMM), ensure information reciprocity to address citizens’ complaints and resolve any

potential social conflict in time;

- Preparing practical and didactic guides to: (i) provide concise information aimed at

facilitating the understanding of the different elements of a communication and

complaints management system; and (ii) present concrete examples to receive, process

and handle various claims. These guides and others will be used as materials for

providing training and assistance for understanding and implementing this ESMF;

- Providing training and technical assistance to build the skills of ONAS’s senior officers

and workers in the participatory approach, environmental and social communication,

and complaints management.

11. ESMF IMPLEMENTATION COST

The ESMF implementation cost covers mainly the training of senior staff, the design and production of

communication and awareness leaflets, the recruitment of environmental and social approach specialists

who will be incorporated into the ESMU as technical assistance staff, and the land procurement plan.

The overall cost estimate is broken down as follows:

Table 8: Breakdown of Programme Cost by Component, including ESMF Implementation Cost

Component/Sub-component Estimated Cost in Million

TND EUR

A Development of Sanitation Facilities 446.9 148.6

B Capacity Building and Institutional Support (including E&S aspects) 3.0 1.0

C Programme Management:

- Environmental and social technical assistance over a 4-year

period, of which 18 months of permanent presence of the

Technical Assistance staff (TA)

- Land Procurement Plan implementation cost

41.3 13.7

Total 491.2 163.3

12. CONCLUSION

The environmental assessment is deemed positive considering that each sub-project is relatively small,

Tunisian regulations provide for the conduct of an ESIA and the implementation of an ESMP for each

new WWTP, as well as the environmental and social management procedures established and adopted

by ONAS. Programme implementation will significantly contribute to improving the living conditions

of inhabitants of target municipalities and protecting the natural environment against the sources of

pollution and degradation. The programme will have no major negative impact on the environment.

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It will be recalled that any sub-project that has been classified under Environmental Category 1

following the conduct of specific environmental impact assessments will not be included in the

programme, in keeping with the eligibility criteria for financing under this programme. The measures

recommended and arrangements proposed for managing various sub-projects are vital elements for

leveraging and ensuring the sustainability of sanitation facilities, and will help to properly manage

environmental and social risks.

13. REFERENCE DOCUMENTS AND CONTACT PERSONS

13.1 Reference Documents

- Mission for the Design of an Environmental and Social Management Master Plan and

Assistance to ONAS’ Environmental and Social Monitoring Unit – CEFED/SEETE

Group, January 2018 edition.

- Land Procurement and Loss Compensation Framework – ONAS, June 2018.

- Tunisia: Small Towns Sanitation Programme – ONAS –Environmental, Social, Health

and Safety Procedures – Alpage Environmental and Social, March 2018 edition.

- Tunisia: ONAS’ Small Towns Sanitation Programme –– Stakeholder Participation Plan

– Alpage Environmental and Social, April 2018 edition.

- Tunisia: ONAS’ Small Cities Sanitation Programme –Environmental and Social

Assessment Report – Alpage Environmental and Social, March 2018 edition.

- ONAS’ Environmental Policy.

13.2 Contact Persons

For ONAS

Mrs Waslati Dhouha, Programme Monitoring Officer, E-mail: [email protected]

For the AfDB

Mr BenSassi Belgacem, Chief Water and Sanitation Engineer, RDGN.2, E-mail:

[email protected]

Mrs Beya BCHIR, Environmentalist, SNSC/RDGN, E-mail: [email protected]

mailto:[email protected]

