[Remember -The top 20 cm of soil is all that stand between us and extinction] 

The livelihood and economic development of Mauritius are especially dependent on its environment. Mauritius having a mix of ecosystems, cultures, development characteristics and interactions, that in this era of the Anthropocene create unique environmental governance challenges. Such challenges may arise from some of the projects that the present government wants to run. These projects can in a single stroke bent us down to our knees. We have to be very cautious and choosy on the type of development that we want. We have the project in Albion to host a petroleum hub for the bunkering services and god knows for what other purposes. 

Now we the incinerator project in Riche-Terre. This is another environmental challenge of our time and is a threat to the wellbeing of all the inhabitants of the region. The nature of the project is even a greater threat to our marine and other ecosystems. The promoters have already filed in their Environment Impact Assessment, which opens up the door for a buffet of questions, more than 3 dozen out of which I have tried to flag the most important issues here. 

The process

The EIA section 19(1) b which outlines the method of assessment of the environmental impacts indicates that consultations with the inhabitants as the initial step of the process. Consultations on this project took place a fortnight  ago and far away from the site and the people. Is a strategical move to limit the level of participation in such meetings? More importantly the promoters have already flouted section 19(1) b of the EPA act 2002. Having gone through the EIA, it is still not very clear to me, how the promoters will enforce Para 1.4(4) which relates to ensuring the protection of the environment, comply to the SDGs and the EPA 2002 when at the start they have already flouted the EPA act. I also learnt that pending permission from different authorities, the promoters have already started building and fencing the site. Veolia is flouting the processes and has no respect for our institutions. There has been a stop order issued to the promoters. If Veolia is not respecting our institutions, our legal framework, how can we expect them to respect the environment? 

The site 

The site is located in Riche-Terre which according to the promoters are 700m from the nearest residential areas which is not what “Google” interprets. If there are no rivers and rivulets in the immediate vicinity of the Waste Processing Plant (WPP), there is however a world known bird sanctuary not very far from the site. The EIA spells out that Riche Terre mall is over 1 km – Do the promoters really mean that they are willing to bring polluted hydrocarbon waste from all over the world and all the local medical waste so close to a major shopping centre and habitation without any major collateral damages happening? I am still puzzled how the lorries of Veolia will reach the WPP site if they refrain from using the highways as mentioned in their EIA – In a crude language, this is call “bullshit”. The promoter admits that “The landform of the area is almost flat to gently undulating or undulating with general slope seawards. The land slopes less than 8% and the soil is well drained” – these facts regarding the topology of the soil makes the conditions far easier for contamination. Food for thought.

Environmental standards

The Environmental analysis has carried out using established standards under the law. In their EIA, the promoters have listed 3 environmental standards which the Waste Processing Plant (WPP) will observe – the ones related to air standards, effluent discharge and noise standards but elaborates on only 1 measure and fails on the other 2 measures (the effluent discharge and the noise standards). On the contrary the EIA mentions the standards of the hazardous waste which has not been listed. Are these omissions deliberate or not? It all sounds messy.

Hydrocarbon processing

We are already a dirty country admittedly by none than the Prime minister of this country, now we want to import a new type of waste as if we don’t have enough on the plate to treat here
– This is what we call “grate le dos malheur”. 

“Veolia Recycling & Environmental services (Mauritius) ltd” is planning to construct and operate a plant that will treat hydrocarbon waste in the form of mud from the bottom of storage tanks of vessels that carry essentially petroleum products. The EIA confirms that this WPP intends to treat imported polluted waste and none other than contaminated petroleum stuff both in solid and liquid forms. These wastes can originate from any part of the world and be contaminated with various types of bacteria, viruses and microbes unknown and unfamiliar to our natural ecosystems that Veolia would bring on our island for treatment. There is the potential danger of contamination and invasion of our natural marine and terrestrial ecosystems.  There is absolutely no doubt about it. Many vectors would propagate them – This can be potentially harmful for our inland vegetation, our sea grass and other marine species. 

On top of it, Riche-Terre will be converted into a mini Mare-Chicose (The environmental impacts of this village are still alive in the minds of many). Here the story might be worse – There will be a constant flow of waste passing through the Capital, contaminated HC waste from the ships will flow in and disposal waste after treatment at Riche-Terre will have to flow out to Mare chicose – Pollution bombs will be moving to and fro Riche-Terre and the city of Port-louis. When it comes to the processing of the polluted HC, there are so many dark zones in the EIA that need further explanation. For ex- in the HC recovery process – it would important to know the composition of the polluted water? How and where will it be discharged? What will happen to the hydrocarbon waste? 

Similarly, there are many such questions when it comes to the distillation process. What is striking are the figures in table 6 of the EIA -The value of the ashes are 3 times more than that of the sediment content and the value of sulphur is 100 times more than the value of the sediment content. All the “waste” of the contaminated HC waste need be disposed in an inert manner. All these need clarification if not proper explanations. The flow diagrams explaining the processes are not helpful; they lack and hide information. Bottom line we don’t need hydrocarbon contaminated waste from every corner of the world to be treated here in Riche-Terre. 

Marpol treaty 

When it comes to the Marpol treaty. I just can acknowledge the expressed interest to implement an International treaty contrary to all other important treaties including the Paris Agreement which are sitting in drawers for ages. It would be interesting to know from the port authorities, how were they implementing this treaty so far.  If Veolia wants to treat contaminated petroleum waste and help the country, the solution is simple and less costly. Veolia has to collect all the contaminated waste, put in sealed drums (As Veolia has proposed for residual ash to be dumped in Mare- Chicose) and send it to its closest WPP in the region.  

Medical waste treatment 

The promoter paints a dark picture of the MOH policy on medical waste management mentioning that the in-house hospital incinerators are either always out of service or poorly maintained (table 7). Could be true, but this is not a reason to privatise or centralise treatment of medical waste. (I do maintain that on-site incineration remains the best option). Veolia does recognise the hassle around transportation when it comes to medical waste and they propose to avoid the highways (para 4.2.2) and do the transfer during the time when less traffic is expected. The danger is clear, Veolia recognises the fact that transportation of medical waste is an issue and I am still wondering trucks will reach the WPP without using the highways….. God knows!

Let me come to another point - For around 250 kgs of either medical waste and dead animals, 62.5 kgs of solid waste (fig 16) in the form of ash will be formed which needs to further disposed in Mare Chicose. So again, for this type of treatment, constantly waste will flow in and flow out of Riche-Terre exacerbating the transportation issue. In simple language, the WPP will act more as a transitory waste collection and processing plant.  Sharps, needles, scalpels etc. will be treated by incineration (table 11). Most of the sharps are metals that will melt and the question remains how will it be disposed of?

The shocking bit is about the medical waste is the treatment of “Human tissue” and its final disposal which will be done by burying it protected pit… Where? Food waste will be composted… by whom and where? Nothing is very clear regarding the infectious waste, blood and body fluids. We still don’t know how they are going to be disposed by Veolia. I agree that the treatment of medical waste is a real challenge (I highlighted this 3 years ago in an article) and even with this proposal we are still far away from the best practices and proper solutions. 

Incineration of dead animals

I would agree that there need to think of better ways to dispose of dead animals but the site in Riche-Terre in not at all appropriate for this. This part of the EIA is literature based from the internet and provides no clear details of the treatment process that Veolia is proposing. It is vague and empty – how will these dead bodies from the different corners of the country will be collected, stored and transported to the WPP? Who pays for the incineration of dead animals? Animals have life and are no different to human beings. From an animal care perspective, the dead bodies should be treated more seriously and humanly in the EIA. 

Emissions to Air 

If there is an area where most of the business/corporates fail on their EIA commitment, is on their stack emissions. The WPP will be emitting a lot of toxic gases like sulphur dioxide, nitrogen dioxide and gaseous chlorides/ fluorides and yet the promoters didn’t find it proper to undertaken a dispersion modelling–reason given is that the stack emissions will be far below the local norms. This is the story that we have hearing for years and yet we have had irreversible pollution effects in Forest-side, Valentina and la Tour Koenig just to mention a few places. The danger with air pollution is that it can happen at any time, it can be accidental, deliberate or due to technical failures. In such cases, the harm is already done and remedial action comes at a later stage. 

The precautionary principle should prevail here. Now on the carbon emission, each of the processing operations listed in the EIA will release a minimum of 1320 kg of carbon dioxide daily. The EIA is almost silent on it and on its mitigation measures. Here, Veolia goes against its own commitment as worded in para 1.4. [As a reminder -If we don’t stop carbon emission, once it reaches 930 parts per million (we are actually at 440 ppm) it is estimated that we human beings will lose 21% of our cognitive ability]. Another Greenhouse gas polluter joins the list. 

Contaminated soil

Para 4.3 starts with this line- I quote “Soil contamination with hydrocarbons can be highly flammable” – When I read this I kept asking myself where do we have so much of contaminated soil (within the island) to the extent that we need an incinerator to treat it? A lot of people like me are curious to know more.  A recent study (2018) carried out by researches (G. Mungla et Al) from the University of Mauritius showed that industrial activities may cause contamination of the soil by petroleum hydrocarbons and this may be more pronounced in the harbour by the nature of its activities. 

The study showed that the most affected region is Pointe aux Sables (451 mg/kg) followed by Tombeau Bay and Mer Rouge (less than 66 mg/kg). Based on these figures I don’t think that the contamination of our local soil is not alarming. Can the promoters enlighten the public as to which contaminated soil they are referring to in the EIA and where will the 20 tonnes (according to their processing plan) of contaminated soil per day (fig 18) will come from? 

Plastic waste 

The PM announced in his budget speech that a waste to energy project will be set up and 1000 tons of waste will be needed. In waste to energy projects plastics and metals are the key elements to provide the calorific value needed to produce energy, so I believe that a big chunk of the plastic waste (being mostly part of the 462,000 tons of domestic waste) will be already used up. Plastic is already being collected for re-cycling so, but the fact remains that a lot of plastic waste remains in the nature. The WPP is proposing to recycle 3000 kg of plastics daily and for that it will need 1500 litres of water (1 litre of water for every 2 kg of plastic processed) and will generate 1500 litres of waste water contaminated with detergent (fig 20).

Does it make sense to have such a treatment plant which consumes so much of water and creates equally the same amount polluted waste water? The treatment cycle is not sustainable. In the sustainability context, recycling of plastics is the 3rd envisaged step. Recycling of plastics sends the following wrong message “You can continue polluting by producing and using plastics, we are there to recycle” 

Oil filters 

Recycling of the oil filters is the only valuable element of the EIA and as the metal part of the filters have to be sent to foundry, it is best that such operations are carried out in the vicinity of the foundry. 

Veolia self-assessment on the construction, operation and decommissioning 

In this section I focussed on the operation phase which I believe is more important and made abstraction of the other two phases. Please note that this is the self-assessment of the Veolia.
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Hydrocarbon processing 

• Soil contamination – harmful but correctable 
• Noise emission - harmful but correctable
• Odour emission - harmful but correctable
• Safety and health Hazards - harmful but correctable

Medical waste and dead animals

• Health and safety relating to storage & use of harmful substances- harmful but correctable
• Emission to air - harmful but correctable
• Solid waste - harmful but correctable

Hydrocarbon contaminated soil 

• Health and safety relating to storage and use of harmful substances - harmful but correctable

Waste plastic 

• Fresh water resources - harmful but correctable
• Waste water - harmful but correctable
• Noise emission - harmful but correctable
• Solid waste - harmful but correctable
• Health & safety- harmful but correctable

Oil filters 

•  Emission to air - harmful but correctable
• Solid waste - harmful but correctable
• Health and safety - harmful but correctable

Most of the process that will be carried out on a daily basis at the WPP have 
been identified as harmful by Veolia itself. Of course, like any other EIA the traditional mitigation measures are being proposed. Here the issues are different and the mitigation measures are not adequate enough to prevent the harm from happening. With so many harmful issues to address at the same time makes it even more difficult. A proper risk assessment report of the whole project avails to be important.  

Last words 

If Veolia claims itself to be a world class operator nonetheless they equally have a bad track record when it comes to pollution. I am still wondering how the treatment of hydrocarbon waste will benefit the country and why do we need such a processing plant – Are we so desperate in building alternative business models that we are ready to make Mauritius a known destination for treating contaminated petroleum waste. This project stinks.