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OKIPP Limited ESMP Summary
ENVIRONMENTAL & SOCIAL
MANAGEMENT PLAN (ESMP)
OF
OKIPP Limited
ITU LOCAL GOVERNMENT AREA,
AKWA IBOM STATE
OCTOBER 2013
OKIPP Limited ESMP Summary
Project Title: Oku-Iboku Pulp & Paper Project Project Number: P-NG-AAG-002. Country: Nigeria
Department: OPSM Division: OPSM2
1. INTRODUCTION
1.1 Background:
The implementation of the Federal Government’s import substitution policy which started from
independence coupled with the increasing demand for paper and paper products in the country
brought about the Government’s decision to expand its industrial base to include pulp and
paper, to develop Gmelina plantations and ultimately to establish domestic integrated pulp and
paper mills in three locations in the country, namely:
The Nigerian National Paper Manufacturing Company Limited at Iwopin in Ogun State
to produce bond paper
The Nigerian Paper milling Jebba, Kwara State to produce Kraft paper and
The Nigerian Newsprint Manufacturing Company Limited in Oku-Iboku in Akwa Ibom
State to produce newsprint paper
The three mills were to complement each other in meeting the nation’s demand for paper and
paper products. The Nigerian Newsprint Manufacturing Company Limited, (NNMC), (now
OKIPP Limited) was incorporated in 1975 as a private limited liability company to produce
100,000 metric tons of finished newsprint per annum. It was the only newsprint manufacturing
company in the West and Central African sub region. The first of the mill’s two paper
machines was commissioned in 1986 and the second one a year later. During the eight (8)
years of its operation (1986 -1993), the mill produced a total of 163,684 metric tons of finished
newsprint as against the expected 800,000 metric tons based on the machines’ combined
installed capacity of 100,000 metric tons per annum. Prior to the shutdown of the mill in 1994,
NNMC exported newsprint paper to USA, Cameroon, Germany, Togo, Ghana, Zimbabwe.
Following the Federal Government’s decision to withdraw from direct participation in the
running of industries, Negris Investments Limited incorporated a new Company called OKIPP
(Oku-Iboku Pulp & Paper) Limited in 2008. Negris Group was established in 1980 and prides
itself as the foremost indigenous energy, oil and gas service company in Nigeria. Negris
mission is to provide services and products that enhance customers’ objectives while remaining
friendly to the environment.
1.2 Objectives:
The main objectives of the project are:
Rehabilitation of the existing assets and upgrading of critical areas of technology in the
company;
To boost demand for newsprint and papers for local printers for them to operate at
profitable levels;
To sustain the printing industry in Nigeria and West Africa; and
To provide support for the on-going Nigeria’s private-sector led growth;
OKIPP Limited ESMP Summary
2. PROJECT DESCRIPTION
The project entails the rehabilitation and modernisation of the OKIPP pulp and paper mill
assets to bring them up to modern international standard of operational efficiency, product
output quality and environmental impact. Once rehabilitated and modernised the mill will be
capable of producing a family of “Uncoated Mechanical” papers, including newsprint and
similar graphical grades. The rehabilitation and modernisation phase of the project is
scheduled to last for 18 months. At the end of it, OKIPP will recommence full time
production.
3. POLICY, LEGAL, ADMINISTRATIVE AND REGULATORY FRAMEWORK
In line with AfDB’s requirements the project was classified as category 2 but an ESIA study
was carried out in accordance with regulations, guidelines and standards of the Federal
Ministry of Environment (FMEnv), Akwa Ibom State legislations on the environment, all other
applicable national legislations, and Multilateral Environmental Agreements (MEAs) to which
Nigeria is a party; as well as lenders guidelines. Relevant legislation and other requirements are
given below. The environmental study was carried out in 2 seasons (wet and dry season) as
specified by the national EIA guidelines. The dry season sampling therefore took place
between the 17th
and 21st December 2012 and wet season sampling between the 18th and 20th
June 2013. The field work for the SIA was conducted at two times with the
scoping/community engaged exercise taking place from the 9th to 13th of December, 2012 and
the data collection from the 14th
to the 25th
of May, 2013. Field work was carried out to
objectively assess the environmental and social baseline characteristics of the proposed project
site as well as determine the sustainability of operations at the factory and also to comply with
national environmental regulations.
The main relevant piece of legislation is therefore the Environmental Impact Assessment (EIA)
Act (Act No. 86 of 1992) that makes EIA mandatory for all major public and private projects
in Nigeria. The EIA Act sets out to:
Consider the likely impacts and the extent of these impacts on the environment before
embarking on any project or activity;
Promote the implementation of appropriate policy in all federal lands consistent with all
laws and decision-making processes through which the goal of this Act may be
realized;
Encourage the development of procedures for information exchange, notification and
consultation between organizations and persons when the proposed activities are
likely to have significant environmental effects on boundary or trans-state or on the
environment of bordering towns and villages
Other legislation relevant to the project includes:
i) Federal Environmental Protection Agency Act No. 580/30 December 1988 (as
amended by Act 59 of 1992 and further amended by Act 14 of 1999)
ii) National Environmental Protection (Effluent Limitations) Regulation (S.1.8) 1991
mandates industries generating wastes to install antipollution and pollution
abatement equipment on site.
OKIPP Limited ESMP Summary
iii) National Environmental Protection Regulation (S.I.9) 1991regulates the release of
toxic substances.
iv) National Environmental Protection (Management of Solid Hazardous Wastes
Regulation (S.1.15) 1991spells out the requirements for groundwater protection,
surface impoundment, land treatment, waste piles, landfills, incinerators, etc. It also
describes the hazardous chemical products and dangerous waste constituents.
v) EIA Procedural and Sectoral Guidelines of the Federal Ministry of Environment
(FMEnv) 1995 as revised 2009
vi) Land Use Act of 1978
vii) Applicable international Environmental Statutory Limits/Standards
viii)Criminal Code that makes it an offence punishable with up to 6 months imprisonment
for "Any person who: Violates the atmosphere in any place so as to make it noxious to
the health of persons in general
ix) The Natural Resources Conservation Act 1989
x) Endangered Species (Control of International Trade and Traffic) Act 11 of 1985
xi) The National Parks Decree (Decree No 36 of 1991)
xii) The Akwa Ibom State Environmental Protection and Waste Management Agency Law
2000 that establishes the Akwa Ibom State Environmental Protection and Waste
Management Agency and mandates it to implement and enforce the state’s policies and
laws on environment and stipulates all major development projects in the State to be
subjected to EIA. It also makes EAR and EIA mandatory for all manufacturing
industries in the State.
xiii)National and relevant state Statutory Limits for Effluent and Gaseous Emissions
xiv) International Standards, Treaties and Conventions
xv) Convention on the Conservation of Migratory Species of Wild Animals
The lenders requirements such as the AfDB’s ESAP are also considered important and full
compliance with them is a priority.
4 MAJOR ENVIRONMENTAL AND SOCIAL IMPACTS
4.1 Health Impacts The social impact assessment (SIA) showed that the level of sanitation was satisfactory and
solid waste was managed by open burning and unregulated dumping. Domestic water quality is
fair to good and was sourced from the stream and boreholes. The Company has provided some
facilities including boreholes for supplying good water in some settlements, but these were no
longer functional according to the people consulted. Generally the perceived health status of
residents in the plantation areas was better than those in the mill area. Respiratory problems
like coughs and tuberculosis were more common in the mill area. The current project will
increase exposure to dust particles for communities during construction but overall dust, heat
and fumes hazards in the work environment will be reduced due to installation of modern
equipment. The Company will improve access to health care clinics particularly in the vicinity
of the mill.
OKIPP Limited ESMP Summary
4.2 Social Impacts
During the scoping exercise, eight villages from the same clan, were identified as those likely
to be directly affected by the activities of the OKIPP Mill. Of the four plantations in Cross
River State that will provide timber for OKIPP Ltd, the ESIA focused on Awi and Nsan.
Obom Itiat Edere was also included due to its history of conflict. The SIA found a number of
potential social impacts that are likely to result from the activities of the Company.
Most of the communities are quite small and are relatively socially homogeneous and the
majority of the residents are indigenes. The influx of workers and service providers will result
in more social diversity with the potential social problems of conflict and deviant behaviour.
This will require better security measures in the locality. OKIPP Ltd shall work with traditional
leaders and existing social groups in the area to ensure good relations, also including youth and
women as important stakeholders.
While nearly all of the respondents reported that they are Christians, traditional religious
worship is very strong with the evidence of many sacred sites and shrines. Many of these sites
of social significance including a cemetery, have been damaged or become inaccessible to the
local population as a result of the establishment of the mill and plantations. The residents have
strongly protested that there is need for relocating these sites so that they may have access to
them. The Company shall enter into dialogue with the local residents and facilitate the
relocation of some of the major sites. This will have a very positive effect upon the
relationship with the local population who will see the Company as responsive to their
requests.
The general impression of the local population is that the income generating activities that have
traditionally been relied upon, including farming, fishing and hunting, have been severely
affected by the activities originally of NNMC and now OKIPP Ltd. Providing alternative
activities, capacity building training or employment opportunities can lessen the effects of this
impact. These were generally considered the priority needs in the locality as determined by the
needs assessment. This is an area that OKIPP Ltd can significantly mitigate the potential
negative impacts of the Project. The influx of more money into the local economy will likely
have a positive impact upon the traders by having a higher demand for their products and more
customers with the attendant higher prices for their goods. However, it may negatively impact
upon the standard of living for other inhabitants. This was found to be the experience during
the earlier days of NNMC operations. Nevertheless, the cost of living in the area and the
potential to purchase needed goods and services shall be monitored to prevent escalation of
poverty in the area, particularly among socially marginalized groups.
The occurrence of conflict within or between communities is relatively uncommon. Although
not directly related to OKIPP Ltd, the most significant incident of conflict in the locality in
recent times has been the case of Obom - Itiat - Edere. Conflict can affect the activities in the
mill and plantation areas and OKIPP Ltd shall pay attention to relocation of their sacred sites;
provision of employment and facilities. Transportation networks will be altered as OKIPP Ltd
begins operations in earnest. At the present time, there is a lack of adequate transport services.
Many more cars and buses will begin to ply the roads in the mill area to transport workers,
OKIPP Limited ESMP Summary
trucks and lorries carrying timber logs and finished products will soon be common in both
areas. The poor state of the roads is an area where there will necessarily be improvements. The
Company shall embark on safe driving awareness campaigns.
The project may increase the frequency of many social vices in the host communities among
which are armed robbery, prostitution, HIV etc. In general, there are potentially several areas
of social impact some of which are mitigated through Corporate Social Responsibility efforts.
OKIPP will also establish a Grievance Resolution Mechanism with adequate representation of
all relevant stakeholders whereby the concerns of the local population can be addressed and the
Company’s position can also be fully understood.
4.3 Environmental Impacts
Significant negative environmental impact associated with the project site includes the
following: (i) The sub-soils within the premises of the Mill are poor earthing media, hence there is
need for subsoil treatment for enhanced conductivity and improved earthing capacity. (ii) The
overburden protective capacity is weak for the near-surface sand aquifer which makes it poorly
protected from surface sourced pollutants. Other impacts include i) increased traffic and
possibly accident (ii) robbery (iii) work site accident (iv) Damage to communication cables (v)
Injuries and death from falling objects (vi) Work site accidents (vii) disruption of roads and
motorways usage. The noise level in the communities was perceived by the respondents to be
low; although majority of them attributed the noise to automobiles others attributed the noise to
generators. However, noise from the boilers, generators, movement of trucks in and out of the
mill and plantation and cutting of Gmelina arborea in the plantation will increase the level of
noise within these areas. Incomplete combustion from the fossil fuels of vehicles and emissions
from the boilers and generators will also have impacts on the air quality.
Significant positive environmental impacts associated with the project pertain to generation of
employment opportunities and hence improvement in the economy and socio-economic status of
individuals. During maintenance, the company shall endeavour to dispose properly their used
oil to future cost of soil remediation and contamination of nearby surface water body. The
environmental impact indicators are easily observable parameters that will indicate
change/deviation, which can be used to monitor the various environmental components. Those
considered in this study are summarized in Table 1 below
Table 1: Environmental Components and Potential Impact Indicators
S/
N
Environmental
Components Impact Indicators
1 Air Quality/Noise
Suspended Particulate Matter(SPM),Nitrogen Oxides(NOX), Sulphur dioxide
(SOX),Carbon Monoxide(CO), Volatile Organic Compounds (VOCs),
Hydrocarbons (CxHy) and Noise Levels
2 Soil/Agriculture
Soil type, Soil pH, Total Organic Carbon (TOC), Soil nutrients, Total
Heterotrophic bacteria and fungi, Hydrocarbon Utilizing bacteria and fungi
and Coliform, Hydrocarbon Utilizer; topography
3 Surface Water
Quality
Dissolved and suspended solids, pH, Biochemical Oxygen Demand (BOD),
Chemical Oxygen Demand (COD), turbidity, toxicity,Lead(Pb),
Cadmium(Cd),Arsenic(As), Nickel(Ni), Iron(Fe),Mercury(Hg)
Magnesium(Mg) and Total Heterotrophic bacteria and fungi, Hydrocarbon
OKIPP Limited ESMP Summary
S/
N
Environmental
Components Impact Indicators
Utilizing bacteria and fungi and Coliform, Hydrocarbon Utilizer
4 Ground water
quality
Dissolved and Suspended solids, Turbidity, pH, BOD, COD, Toxicity, Pb,
Cd, As, Ni, Fe, Hg, Mg. and Total Heterotrophic bacteria and fungi,
Hydrocarbon Utilizing bacteria and fungi and Coliform, Hydrocarbon
Utilizer
5 Socio-
economic/Health
Needs and concern of host communities, perceived employment, income
level, health risks, waste streams, Handling, Treatment and disposal, etc.
Table 2: Identified Project Impacts of OKIPP Ltd
Impacts
Phase
Mo
bil
izat
ion
Co
nst
ruct
ion
Op
erat
ion
Dec
om
mis
sio
nin
g
Acceleration of erosion √
Acidification of soil and water √ √ √
Alteration of local topography √
Alteration of soil profile √
Armed robbers attacks √ √ √ √
Blockage of drainage pattern √ √
Blockage of roads/motorways √ √ √ √
Change in water quality √ √
Contamination of groundwater √ √
Contamination of surface water and soil √ √
Damage to communication cables √
Exposure to heat, light and radiation √ √
Impairment of air quality √ √ √ √
Increased demand on social infrastructure √ √ √
Increased surface water turbidity √ √
Increase in incidence of STI’s including HIV √ √
Increase in social vices √ √
Increased opportunity for business and employment √ √ √ √
Influx of migrant workers and camp-followers √ √
Injuries and death from falling objects √ √ √
Interference with road transportation √ √ √ √
Legal issues √ √ √
Loss of employment/ income √
Loss of biodiversity √ √
Noise and vibration nuisance √ √ √ √
Road traffic accidents √ √ √
Work site accidents √ √
4.5 Envisaged Sustainability
4.5.1 Economic and Commercial Sustainability Throughout the operational outcome period, the liquidated NNMC provided over 700 Nigerian
labour force and therefore restoration of this gigantic industrial system is envisaged to be
economically and commercially sustainable owing to the desirability of OKIPP Ltd who are in
anticipation to increased future production levels of the product. Market for the Nigeria
OKIPP Limited ESMP Summary
Newsprint paper already exists all over the world as the international community alone is ready
to make purchases of over 70% of Nigeria’s Newsprint paper product.
4.5.2 Technical Sustainability The environmental and social impact assessment requirements of OKIPP Mill is technically
sustainable because of the proven integrity of health, environment, safety, security and social
concerns of the waste and effluent management as well as disposal technology that shall be
adopted and the experience of OKIPP Ltd management in the application of this technology.
The maintenance of strict adherence to internationally and nationally acceptable production
and operation standards and codes of practice at all stages of development shall also assure
technical sustainability of the assessment. The following proved the technical sustainability of
the project.
4.5.3 Energy Efficiency: A fundamental part of the OKIPP Reactivation project is to utilise
every opportunity to improve on energy efficiency and environmental discharges by the
adoption of Best Available Technologies "BAT" wherever feasible and viable. This includes
major investments in several new, or enhanced, process technologies, alongside numerous
smaller process and machinery enhancements that will allow significant gains to be realised in
terms of energy efficiency and all discharges (solid, liquid and gaseous).
4.5.4 Climate Change: OKIPP Ltd is investing in many measures that result in reduced specific
consumption of energy by increases in generating and usage efficiencies. They include:
Switching from Low Pour Fuel Oil (LPFO) to natural gas for all power generation
(electricity, steam, compressed air)
Process energy consumption efficiency improvements in all high intensity manufacturing
areas, eg. primary pulping process, paper drying on paper machines, use of high efficiency
sectional drives.
5. ENHANCEMENT & MITIGATION MEASURES In order to preserve the present integrity of the environment, certain steps have been
recommended to mitigate or control the medium and high negative impacts identified in this
study. The control/mitigation measures have been based on the baseline conditions with
regards to the biophysical environment, socio-economic and health status of the host
communities. Also considered were the project activities and their envisaged impacts and
concerns of stakeholders during consultation meetings and socio-economic/health status of the
host communities. The mitigation measures proposed are in keeping with environmental laws
at National and State levels; FMEnv (formerly FEPA, 1991) regulations on Pulp and Paper and
waste Management; Akwa Ibom State Environmental Protection and Waste Management
Agency laws, Akwa Ibom State Ministry of Environment policies; Best Available Technology
for Sustainable Development; Social wellbeing; and Concerns of stakeholders. To successfully
mitigate all the social impact that may be associated with this project, it is important that as
OKIPP establishes a committee of local stakeholders to protect the interests of all concerned
persons / groups.
OKIPP Limited ESMP Summary
The protective capacity of the sub-soils overlying the upper sand aquifer is weak, hence the
groundwater system is not protected from pollutants directly discharged on bare ground
surface. Effluent shall not be discharged on bare ground. Paving throughout the mill and
establishing a network of drainage channels shall be done. Summarized in Table 3 below are
the detailed mitigation and enhancement measures identified and recommended to ameliorate
all the significant associated and potential impacts identified for the operation of OKIPP Mill
in Oku Iboku.
Table 3: Showing Mitigation Measures for the OKIPP project
Description of Impacts Mitigation/Control Measures by OKIPP
Road traffic accidents
create awareness amongst neighbours
shall adhere to its journey management policy
organize Defensive Driving Course (DDC) for all vehicle drivers
ensure that project vehicles are pre-mobilized;
maintain adequate first aid in all project vehicles;
use only trained personnel for specified jobs;
ensure that job hazard analysis are carried out;
ensure daily pep-talk on each day’s job
Armed robbers attack
engagement of private security agents
engagement of Police whenever materials are to be moved to site;
materials shall not be handled in a way to attract third party
cash shall not be paid on site without security arrangement and
cash shall not be transported to site without security arrangement
Increased opportunity for
business
OKIPP shall hire non-skilled labours from the community
Local contractors shall be involved
Blockage of roads /
motorways
minimize movement at the peak hours of the day
ensure that all traffic rules are obeyed by the drivers
Interference with road
transportation
minimize movement at the peak hours of the day
ensure that all traffic rules are obeyed by the drivers
Worksite accidents
awareness creation amongst communities on potential of increase traffic
compliance with company’s journey management policy
compensation for proven project-induced injuries, accidents and fatalities
enforcement of the use of PPEs at sites.
daily pep talk are conducted with job hazard analysis carried out
Acceleration of erosion OKIPP shall ensure that opened earth surfaces are properly covered
Contamination of
groundwater
All effluents shall be treated to regulatory limits before discharging into the
environment. OKIPP shall ensure that untreated effluents are not released into the
public drain; ETP is properly operated and maintained.
Damage to
communication cables All communication cable lines shall be properly protected
Exposure to heat, light
and radiation
The HSE personnel shall ensure workers and visitors to the Mill are kitted with
appropriate PPE
Impairment of air
quality
OKIPP shall ensure that only pre-mobed equipment are used; the use of all equipment
shall be controlled and that equipment engines are turned off when not in use
Injuries and death from
falling objects
Workers and visitors to site will be made to put on safety helmet
Noise and vibration
nuisance
OKIPP shall discuss precautions against noise with contractors; combustion engines
shall be fitted with effective silencers; there shall be regular maintenance of
machines; engines shall be switched off or reduced to idle when not in use; hearing
OKIPP Limited ESMP Summary
Description of Impacts Mitigation/Control Measures by OKIPP
protection devices (HPD) shall be provided for workers and visitors
Loss of
employment/Income
OKIPP shall support entrepreneurial skill development and opportunities for
community members to cushion the effect of reduction in economic/income
generating activities.
Lack of access to sites
of cultural significance
and social conflicts
Okipp shall have on going public consultations to understand challenges and put I
place a grievance mechanism to ensure all parties are not made worse off by the
project.
Incorporation of mitigation measures at all stages of project development and full
implementations / strict adherence to the designed ESMP will ensure an environmentally sound
project. Furthermore, OKIPP Ltd will implement an Environmental Management System
which will clearly define the responsibilities for all environmentally-relevant aspects in the
mill. OKIPP Ltd will train all employees, contractors and visitors to any of its operations on
SHE issues. This will include, but is not limited to; isolation procedures (steam, compressed
air, chemicals and electricity), safe systems of work, PPE, machinery guarding, interlocks and
safety devices, process safety through automation, testing and statutory compliance, etc.
OKIPP Ltd will have a validated Health & Safety policy, and a Health & Safety Manager, with
senior management level authority.
OKIPP shall have a process control optimisation to be able to reduce different pollutants
simultaneously and to maintain low emissions, improved process control and measurement.
OKIPP Ltd is investing heavily in Best Available Technology (BAT) process control and
measurement. The rehabilitation and modernisation aspects of the project are designed to
encompass modern safety systems as applied to the manufacturing process and machinery, and
the way both are operated. OKIPP Ltd is investing heavily in new process control and
automation systems (incorporating multiple safety alert, warning and automatic response
measures) in BAT for guards, interlocks and personnel safety. There will be efficient process
energy consumption in all high intensity manufacturing areas, e.g. primary pulping process,
paper drying on paper machines, use of high efficiency sectional drives.
6. COMPLEMENTARY INITIATIVES & CAPACITY BUILDING:
The Company has provided some facilities including boreholes for supplying good water in
some settlements, but these were no longer functioning, according to the people. OKIPP shall
monitor any facilities or services provided to the community in a participatory manner to
ensure that the community ‘takes ownership’ of the facilities and will take responsibility for
maintaining them. Generally the perceived health status of residents in the plantation areas was
better than those in the mill area and OKIPP will ensure there is a functional health centre in
this regard. OKIPP will raise awareness on health, safety and environmental issues and also
provide the training required for communities to ensure sustainability of the benefits realised as
a result of the OKIPP project.
OKIPP Limited ESMP Summary
7. MONITORING
Table 4: Monitoring and cost of implementing the ESMP
ENVIRONMENTAL
COMPONENT
INDICATOR
(Parameters to be
Monitored)
SAMPLING
LOCATION FREQUENCY
RESPONSIB
ILITY
COST
(N)
Air Quality
Suspended
Particulate Matter,
Carbon Monoxide
(CO), Methane
(CH4), Ammonia
(NH3), Sulphur
Dioxide (SO2),
Nitrogen Dioxide
(NO2), Hydrogen
Sulphide (H2S).
Mill and
Plantations Quarterly
OKIPP Ltd/
Environmental
Consultant
825,000.00
Noise Level
Noise
measurement at the
mill and
plantations
Mill and
Plantations Quarterly
825,000.00
Health and Safety Air quality, Noise
and Particulates
Mill and
Plantations Quarterly
750,000.00
Soil
Oil and Grease,
THC, physico-
chemical
properties, pH
Generator area Quarterly
1,500,000.00
Ground/Surface
Water
TDS, pH,
Conductivity,
BOD, heavy
metals, biological
and physico-
chemical
characteristics
Mill and
nearby surface
water
Monthly
550,000.00
Occupational Health
Records of
PPE issued to
staff
Fire equipment
on site
OKIPP staff
on-site annually
750,000.00
Socio-economics
(communities)
Population,
occupation,
education, health
status,
infrastructure,
perception about
the projects, etc
Immediate
community Every 3 years
750,000.00
Table 5: Waste Management Guideline Recommended for OKIPP Facility
N. WASTE CATEGORY HAZARD ORIGIN PREFERRED
DISPOSAL OPTION
1 Liquid waste Industrial Potential groundwater,
surface water & soil
contamination
Waste treatment
process
Chemical treatment
before discharge
OKIPP Limited ESMP Summary
N. WASTE CATEGORY HAZARD ORIGIN PREFERRED
DISPOSAL OPTION
(hydrocarbons metals)
2 Sludge Industrial Potential health risk,
Potential groundwater,
surface water & soil
contamination (metals)
Waste treatment
process
Dewatered and burned
as an alternate
renewable energy
source, landfilled or
applied on land.
4 Wood yard
debris and
mill reject
Industrial Non-hazardous, Potential
surface water contamination
Wood yard
burned as fuel
6 Empty
drums
Industrial,
Hazardous
Depends on original
contents of drum
Packaging of
lubricating oil,
fuel oil and
corrosion
inhibition
chemicals
Shall be sold as scrap if
non-hazardous contents.
Approved washing and
recycling of resultant
plastics or metals for
hazardous content
7 Oil & fuel
filter
cartridges
Hazardous Potential groundwater,
surface water & soil
contamination
(hydrocarbons metals)
Engine & rotating
equipment
Approved incineration;
landfill
8 Oily rags Industrial Potential groundwater &
surface water contamination
(hydrocarbons metals)
Maintenance &
clean-up
operations
Approved incinerations;
landfill
9 Scrap
metals,
metal
chippings,
scrap cables
Industrial Non-hazardous Scrapped
equipment
Recycling
10 Medical
wastes
Hazardous Potential health risk Terminal Clinic
and first-acid
treatment
Incineration
11 Saver Pit
Wastes
(sediments)
Industrial Potential groundwater &
surface water contamination
(hydrocarbons)
Routine cleaning
of saver pit
Approved incineration;
landfill
13 Chemicals Hazardous Type & concentration will
determine hazardous nature
Environmental, Health, or
safety
Containers from
Effluent
Treatment Plant
area
Material Safety Data
Sheet (MSDS) shall be
used to identify
particular chemicals
14 Contaminate
d debris &
soil
Industrial,
contamination
Potential groundwater
contamination
Oil & chemical
spills, clean-up
operations
Land treatment,
approved incineration
of landfill,
solidification
15 Domestic
waste
garbage
Domestic Attracts rodents; leachate
from landfill may cause
problems; furnes from
burning is a nuisance
Accommodation,
office, canteen,
worksite
Segregation and
Recycling of
recyclables e.g. plastics,
paper, glass and landfill
on non-recyclables
16 Batteries:
Lead-acid,
nickel-
cadmium
Hazardous Corrosive-health & safety,
lead or heavy metals may
cause contamination
environmental &health
Vehicles, portable
& emergency
electrical tools,
production &
transmission
facilities
Recycling
OKIPP Limited ESMP Summary
N. WASTE CATEGORY HAZARD ORIGIN PREFERRED
DISPOSAL OPTION
17 Spent
Lubricants
Hazardous Potential groundwater &
surface water contamination
(hydrocarbons metals)
Engine & rotating
equipment
lubricating
systems, vehicles
Recycling, Approved
incineration
18 Methane gas Stationary
combustion
source
Fugitive
emission
Greenhouse effect Relief/Blow down
systems, values
from process
valves and flanges
Ambient air discharge
20 Non-
methane
hydrocarbon
s (VOCs)
Non-
combustion
source
emissions
Stratospheric ozone
depletion and formation of
photochemical smog. Acid
deposition potential and
increase in ground level
ozone concentrations
Valves,
relief/Blow down
systems
Ambient air discharge
21 Diesel
engine
exhaust
Stationary &
Mobile
combustion
sources
Similar to natural gas
exhaust hazard but higher
amount of toxic sulphur
dioxide gas with higher
contribution to damaging
acid deposition
Diesel generators
& boat engines
Discharge via roof
stacks, boat exhaust
pipes
8. REMEDIATION PLANS AFTER DE-COMMISSIONING/ CLOSURE/
ABANDONMENT
The specific duration fixed for the subsistence of the OKIPP facility is 25-30 years and then,
the Mill will need to decommission. The Oku Iboku Pulp and Paper Mill, as conceived, is not
expected to have any significant long-term negative effects on the environment, especially after
closure/de-commissioning. A number of safety measures/devices have been built into the Mill,
such that it will operate at minimum risk. However, the following measures will be planned for
implementation after closure/de-commissioning:
The buildings used for the Chip washing, Pulp and Paper manufacturing and the utilities block
shall be dismantled or transfered for other exercises and sold at scrap value;
Generators, boilers, other Mill facilities and equipment shall either be sold or transferred for
other uses;
Contaminated soils, where they occur, shall be restored, using various options such as
chemical and/or biological remediation;
All pits and excavations shall be reclaimed and re-vegetated;
Buildings used for administrative purposes shall be leased out or used for other productive
ventures;
Appropriate pension schemes shall be put in place for project workers so that they can have
something to fall back on if and when the Mill is closed/ de-commissioned.
It is expected that if these measures are implemented, an excellent site restoration after
closure/de-commissioning can be achieved.
OKIPP Limited ESMP Summary
9. PUBLIC CONSULTATIONS AND DISCLOSURE REQUIREMENTS
To capture and address issues and concerns of every stakeholder to this project, wide reaching
consultation was conducted. Stakeholder consultation with regard to starting up the mill is an
ongoing process. The principal objective is to acquire and disseminate information, identify
and address legislative, community, and environmental concerns associated with the
resuscitation of the mill.
9.1 Objectives of Consultation
Facilitate communications and understanding between the various stakeholders and the project
proponent;
Gain support and buy-in from all relevant stakeholders
Comply with mandatory statutory requirements
Identify key issues relevant to the Pulp and Paper Mill and with potential impacts
Avoid conflict with all stakeholders by addressing issues promptly
9.2 Identification and involvement of key stakeholders
Experience has shown that certain potentially contentious issues are better understood by the
public. In view of this a successful and engaging consultation began at the conceptual stage of
the project and this was sustained throughout the project life cycle. Negris Group initiated an
early consultation process with all the relevant parties, so as to ensure that all the issues of
concern are addressed prior to start-up of the Mill. The identified regulators are:
o Federal Ministry of Environment
o The Akwa Ibom Ministry of Environment
o The Akwa Ibom State Environmental Protection and Waste Management Agency
o Cross River Ministry of Environment
o Chairmen of Local Government Authorities overseeing the communities where the project
is located in Akwa Ibom and Cross River State
o Representatives of Community leaders and youths in areas likely to be affected by the
proposed project
o Representatives of community based organisations (CBOs) and Non-governmental
organisations (NGOs) in the project area.
These regulators were notified through “Letters of Intention”: to carry out the ESIA.
9.3 Stakeholders Issue:
Basically, the stated needs of the Community can be grouped into several main issues
including improved road networks to assist the transport of people and goods, educational
facilities and training opportunities both in the formal and informal sectors, up-grading of
health care services and facilities, job opportunities from the Company, enhanced economic
activities through market facilities and access to capital and improved relations and
communications between the Company and the Community. Generational differences indicate
that youth groups are more prominently concerned with employment and training since they
are largely the ones with limited alternatives. Gender differences are also apparent in the case
that women are more concerned with markets due to their roles and responsibilities.
OKIPP Limited ESMP Summary
In line with the Corporate Social Responsibility of OKIPP Ltd, there are numerous community
development projects that could be implemented to alleviate the sufferings of the people.
Obviously, OKIPP Ltd is unable to meet all of the requests of the many communities and
settlements in the area, but consideration of some of the priority needs would significantly
improve relations with the local population and enhance the corporate image of the Company.
Particularly for the communities that are close to the plant, much of their land has been taken
over and their livelihoods affected. OKIPP Ltd may look into the potential for introducing
alternative income-generating activities to replace those that are no longer productive. For
example, if hunting is no longer possible, rearing of grass-cutters and snails could be
introduced. Where natural fish ponds have been polluted, fish farming may provide a suitable
substitute. This would require training and provision of financial capital and/or materials for
take-off.
Through the ranking of the needs in this exercise, it was possible to prioritize the needs by the
people themselves to determine the listed needs that are the most crucial problems of the
people that need intervention. This can assist the Company to make informed choices of
community development needs that will be more appreciated and acceptable to the local
population.
10. ENVIRONMENTAL HAZARD MANAGEMENT
The most common - and preventable - disasters in the paper industry are caused by fires, water
leaks, power outages, IT virus attacks, premises liability issues and human errors. The
Management commitment and responsibility of OKIPP are detailed in its Health, Safety and
Environmental (HSE) policy. The company shall operate in strict compliance with all the
provisions of this HSE policy which specifies the need for adherence to national standards and
guidelines by every member of staff and contractors, no matter how stringent. The HSE policy
of OKIPP states that projects are planned and executed in a manner that achieves the
following:
Preserves the health, safety and security of its employees, the employees of OKIPP Ltd
contractors, and all members of the public who may be affected by OKIPP Ltd
operations;
Give equal opportunity to all gender
Preference shall be given to the locals in both skilled and unskilled areas of OKIPP Ltd
operations
Improve their CSR in the areas of Scholarships to schools of host communities,
donation of information and communication technology (ICT) to schools within the
communities
Training and re-training of members of staff
Minimizes the impact of its operations on the environment; and
Be sensitive to the needs and concerns of OKIPP Ltd host communities.
10.1 Recovery from a Disaster The key to recovering successfully from a disaster is to have a plan in place when the disaster
strikes -- a set of simple, effective guidelines and procedures for all people to follow. Human
beings often make inappropriate decisions during a crisis. Therefore OKIPP Ltd will prepare
OKIPP Limited ESMP Summary
and share with other stakeholders a plan for coping with most emergencies. The OKIPP
contingency will encompass these “worst case” assumptions:
10.2 The Goals of the OKIPP Disaster Recovery & Business Resumption Plan The three (3) primary goals of OKIPP’s disaster recovery and business resumption planning
are to:
10.2.1 Eliminate or reduce the potential for injuries or the loss of human life, damage to
facilities, and loss of assets and records. This requires a comprehensive assessment of each
department within the organisation, to insure that appropriate steps have been taken to:
o Minimise disruptions of services to OKIPP and its customers;
o Minimise financial loss;
o Provide for a timely resumption of operations in case of a disaster; and
o Reduce or limit exposure to potential liability claims filed against the organisation, and its
directors, officers and other personnel.
10.2.2. Immediately invoke the emergency provisions of OKIPP’s Recovery & Business
Resumption Plan to stabilise the effects of the disaster, allowing for appropriate
assessment and the beginning of recovery efforts. OKIPP Ltd will seek to minimise the
effects of the disaster and provide for the fastest possible recovery.
10.2.3 Implement the procedures contained in the OKIPP Disaster Recovery & Business
Resumption Plan according to the type and impact of the disaster. When we implement
these procedures, OKIPP will prioritise all recovery efforts as follows:
Employees & Host Communities: Not only must OKIPP Ltd help to ensure their
survival as a basic human right, but because of their anticipated performance in helping
other persons on or around OKIPP's premises when disaster strikes;
Customers: OKIPP Ltd must help to ensure the survival of or care for customers affected by
the disaster: physically, mentally, emotionally and financially;
Facilities: After ensuring the safety of employees, host communities and customers, where
possible, OKIPP Ltd will secure each facility as shelter for both people and assets;
Assets: Conducting a damage assessment will determine which assets have been destroyed,
which ones are at risk and what resources that remain; and
Records: Documenting the disaster and the actions taken by OKIPP's personnel -- when
combined with comprehensive photos and video of facilities that are obtained during routine
facility inspections will help assess losses and the actions taken to minimise such losses.
10.3 OKIPP Recovery & Business Resumption Plan Effectiveness To be effective and to remain in compliance with regulations, OKIPP's Disaster Recovery &
Business Resumption Plan will contain:
The OKIPP Ltd and Negris Group's philosophy, mission statement and goals regarding
disaster recovery and business resumption
Written and approved executive succession instructions
OKIPP Limited ESMP Summary
The appointment of a temporary Disaster Management Executive Committee for the term
of the emergency that is empowered to act in the absence of the organisation's Board of
Directors
Clearly defined guidelines and scope of all disaster recovery and business resumption
efforts, based upon a thorough risk-assessment.
Clearly defined duties, authorities and responsibilities for each employee classification,
with designated primary and alternate department leaders and staff personnel to manage
critical functions;
A business recovery plan for each branch, department, facility and function within OKIPP -
and for essential service providers
Designated and equipped sites for assembling personnel and for housing specific operations
A well-documented testing and evaluation process conducted at specified intervals - and at
least annually
A comprehensive training program for all personnel at all facilities, conducted at specified
intervals - at least annually - that may also include the:
o Identification and operation of utility shut-off devices;
o Location of emergency staging areas;
o Basic first aid and survival techniques; and
o Emergency responsibilities and re-assignment plans for all positions; and
o Written copies of the final “OKIPP Disaster Recovery & Business Resumption Plan”
distributed to divisional and department leaders - including a complete list of
appropriate emergency response agencies and facilities.
11. ESTIMATED COST
ESMP implementation cost is shown in Table 4 above and amounts to (NGN 5.95 Billion).
12. IMPLEMENTATION SCHEDULE AND REPORTING
In addition to the mitigation measures identified which OKIPP Ltd is committed to
implementing from the onset, other recommendations from the environmental assessment
include the need to: undertake monthly/ monitoring for atmospheric emissions during the
operational phase; monitoring the effects that all phases might have on the host population and
environment at large; undertake and determine the best decommissioning strategy toward the
end of the project; undertake regular audits to ascertain the environmental performance of the
paper mill; sustain continued consultation meeting with host communities and government
regulatory agencies, continue to regulate their carbon footprint and seek ways to gain carbon
credits from the effective sustenance of the plantations. OKIPP shall report twice a year to the
AfDB on ESMP compliance and to the authorities as per the relevant authorisation
requirements.
OKIPP Limited ESMP Summary
13. CONCLUSION
It can be concluded from this study that the overall long - term impact of the Mill will be
beneficial in reducing the dependency of the country on imported newsprint and papers;
enhancing industrial production and economic activities in Akwa Ibom State and Nigeria at
large; reducing unemployment rate in the country; helping to protect and promote government
Local Content policy. The short-term beneficial impact comprises temporary employment for
the local population during rehabilitation/reconstruction and operation phases of the project.
This study has demonstrated that the overall impacts associated with the project can be
managed within reasonable and acceptable limits.
14. CONTACTS:
i. Kurt Lonsway, Manager, Environment and Climate Change Division, African
Development Bank, BP 323, Tunis 1002, Tunisia. Email: [email protected]. Tel.: +216
7110 3313.
ii. Kelello Ntoampe, Environmentalist, ONEC3, African Development Bank, BP 323, Tunis
1002, Tunisia. Email: [email protected]. Tel.: +216 7110 2707.
iii. Zineb Zeryouhi, Investmet Officer, OPSM 2, African Development Bank, BP 323, Tunis
1002, Tunisia. [email protected] Tel.: +216 7110 1790.