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Fertilizer Plant Project EIA
EIA Report Table of Contents, List of Table, Figures, Acronyms, EIA Preparer, Executive Summary & Acknowledgement i
Table of Contents Page
Table of Contents i
List of Figures vii
List of Tables viii
List of Plates x
List of Abbreviations xii
EIA Preparers xvi
Executive Summary xvii
Acknowledgment xxxiii
CHAPTER ONE
1.0 Project background 1-1
1.1 The proponent 1-1
1.2 Need for the environmental impact assessment 1-2
1.3 Terms of Reference [TOR] of this EIA 1-3
1.4 EIA objectives 1-3
1.5 Scope of work of the EIA 1-4
1.5.1 EIA methodology. 1-5
1.6 Regulatory Framework 1-6
1.6.1 Legal basis for environmental permitting 1-6
1.6.2 Applicable legislative/administrative framework of the
project
1-7
1.6.2.1 Main Regulatory Documentation considered for EIA
report
1-7
1.6.2.2 International Legislations 1-9
1.6.2.3 National Laws/Programme 1-11
1.6.2.4 State Laws 1-18
CHAPTER TWO
2.0 Project sitting and justification 2-1
2.1 Site Justification 2-1
2.2 Need 2-1
2.3 Value 2-4
2.4 Envisaged Economic Sustainability of the Project 2-5
2.5 Project Alternatives 2-6
2.5.1 Option 1: Natural Gas as raw material 2-7
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2.5.2 Option 2: Use of EPCL Complex as Project Location 2-7
2.5.3 No project alternative 2-8
CHAPTER THREE
3.0 Project description 3-1
3.1 Introduction 3-1
3.2 Proposed Location of Ammonia, Urea 3-1
3.3 Project Description 3-5
3.3.1 Ammonia Plant 3-6
3.3.2 Urea Plant 3-12
3.3.3 Utilities description 3-16
3.3.3.1 Power Generation 3-16
3.3.3.2 Raw Water Treatment Plant 3-16
3.3.3.3 Demineralized Water & Condensate Polishing System 3-17
3.3.3.4 Steam Generation and Boiler Feed Water System 3-17
3.3.3.5 Cooling Tower 3-18
3.3.3.6 Effluent Treatment System 3-20
3.3.3.7 Nitrogen System 3-22
3.3.3.8 Compressed Air System 3-23
3.3.3.9 Natural Gas System 3-25
3.3.3.10 Ammonia Storage Tank 3-26
3.3.3.11 Urea storage 3-27
3.3.3.12 Fertilizer plant system control 3-27
3.3.3.13 Maintenance Facilities 3-27
3.3.3.14 Non-Plant Facilities 3-28
3.3.4 Utilities for Construction 3-28
3.3.5 Types and sources of air emissions 3-31
3.3.5.1 Sources of Gaseous Emissions for the Ammonia plant 3-31
3.3.5.2 Sources of Gaseous Emissions for the Urea plant 3-32
3.3.5.3 Air Emissions and Applicable Standards 3.34
3.3.5.4 Fugitive Emissions 3-36
3.3.6 Waste Generated and Estimated Quantities 3-37
3.3.6.1 Hazardous Substance 3-39
3.3.7 Energy Conservation 3-39
3.3.8 Storm Water Management 3-42
3.3.9 Gaseous Waste 3-44
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3.3.10 Transport of Men, Materials and Equipment in the New
Plant.
3-44
3.4 Decommissioning Activities 3-44
3.5 Project Schedule 3-44
CHAPTER FOUR
4.1 Introduction 4-1
4.2 Methodology 4-2
4.2.1 Air Quality 4-2
4.2.1.1 Gaseous Pollutants 4-2
4.2.1.2 Total Suspended Particulate 4-2
4.2.2 Climate and Meteorology 4-4
4.2.3 Noise Survey 4-4
4.2.4 Soil 4-5
4.2.5 Vegetation Studies 4-5
4.2.6 Wildlife 4-5
4.2.7 Aquatic Studies 4-6
4.2.7.1 Physico chemical 4-6
4.2.7.2 Sediment 4-6
4.2.7.2.1 Phytoplankton 4-6
4.2.7.2.2 Zooplankton 4-7
4.2.7.2.3 Benthos 4-7
4.2.8 Socio-Economic 4-7
4.2.8.1 Approach 4-7
4.2.8.2 Design of the Survey 4-7
4.2.8.3 Data Management and Analysis 4-8
4.2.9 Health-Impact 4-8
4.2.9.1 Data collection 4-9
4.2.10 Geologic Site Characterization 4-10
4.2.10.1 Soil Borings 4-10
4.2.10.2 Cone Penetration Testing (CPT) 4-11
4.2.11 Land Use 4-11
4.2.12 Water Quality 4-12
4.2.12.1 Sampling Protocol 4-12
4.2.12.2 Field Data Gathering 4-12
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4.2.12.3 Microbiology 4-13
4.3 Baseline results and discussion 4-15
4.3.1 Air Quality and Noise 4-15
4.3.1.1 Noise Survey 4-15
4.3.1.2 Odour in Relation to Air Quality 4-17
4.3.2 Climate and Meteorology 4-18
4.3.3 Physico-chemical characteristics of Surface & Ground
water.
4-22
4.3.4.1 Existing Ground Water Potential 4-25
4.3.4.2 Quality of Ground Water 4-25
4.3.5 Hydrobiology 4-27
4.3.6 Sediment Studies 4-32
4.3.7 Soil 4-34
4.3.7.1 Soil Physical Properties 4-34
4.3.8 Land Use 4-40
4.3.8.1 Cultivated lands 4-40
4.3.8.2 Illegal Sand Harvesting 4-41
4.3.8.3 Built up Areas Infrastructural Facilities 4-41
4.3.9 Vegetation Studies 4-45
4.3.10 Wildlife 4-54
4.3.11 Socio Economic Impact Assessment 4-60
4.3.12 Health impact assessment 4-77
4.3.12.1 Types of health hazards in the study area 4-77
4.3.12.2 Health care services and facilities 4-77
4.3.12.3 Nutritional Status 4-80
4.3.12.4 Reproductive Health 4-81
4.3.12.5 Disease prevalence 4-82
4.3.12.6 Environmental Health Conditions 4-86
4.3.12.7 Health Needs of the Community 4-88
4.3.12.8 Corporate Health Social Responsiveness 4-89
4.3.13 Public Consultation 4-91
4.3.13.1 Levels of Consultation 4-91
4.3.13.2 Objective of Consultation 4-92
4.3.13.3 Group Interviews 4-92
4.3.13.4 Public Forum 4-93
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CHAPTER FIVE
5.0 Associated and potential impact evaluation 5-1
5.0 5.1. Impact methodology 5-1 5.2 List of potential and Associated Impacts 5-3
5.3 Expected quality of the environmental and social
components after the implantation of the project
5-14
5.3.1 Air Quality and Odor 5-14
5.3.2 Noise and vibrations 5-30
5.3.3 Surface water and hydrobiology/sediment 5-30
5.3.4 Ground Water 5-31
5.3.5 Soil 5-31
5.3.6 Land Use 5-32
5.3.7 Vegetation and wildlife 5-33
5.3.7 Health 5-33
5.3.9 Socio Economic Conditions 5-34
5.3.10 Landscape 5-35
5.3.11 Climate 5-35
CHAPTER SIX
6.0 Mitigation, amelioration and compensation measures 6-1
6.1 Introduction 6-1
CHAPTER SEVEN
7.0 Management Plan 7-1
7.1
7.1.1
Environmental Management Plan
Environmental Capacity Buiding Program
7-3
7-4
7.1.2 Monitoring Program 7-6
7.1.2.1 Performance Inidcators 7-7
7.2.2.2 Environmental Reporting System 7-13
7.1.3 Audit Program 7-13
7.1.4 Traffic Management Plan 7-14
7.1.5 Energy Conservation Program 7-14
7.1.6 Leak detection and repair program 7-14
7.1.7 Risk management plan for contaminated land 7-15
7.1.8 Hazardous Materials Management plan 7-15
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7.1.9 Decommissioning and Closure Plan 7.15
7.2 Occupational Health and Safety management plan 7-16
7.2.1 Hazardous Materials Risk 7-16
7.3 Social Management plan 7-17
Chapter Eight
8.0 Conclusion 8-1
Reference: R1-12
Appendices
Appendix 1.1 Plot Plans
Appendix 1.2 FMENV letter of categorization
Appendix 1.3 Letter of nomination of field work supervisor from
FMENV
Appendix 2.1
Appendix 2.2
Thematic map of EPCL project area
Physical Map of EPCL Project Area
Appendix 3.1 Trial of photographical rendering of EPCL site after the
realization of fertilizer plant
Appendix 4.1 Pictures from Sampling Surveys
Appendix 4.2 Social Impact Assessment Questionnarire for
communities around Eleme Petrochemicals
Appendix 4.3 Noise/Sound Level Study
Appendix 4.4 Soil Stratigraphy
Appendix 4.5 Traffic Count analysis
Appendix 4.6 Public Forum Report
Appendix 4.7 FWENV authorization to use the world bamk/IFC
standards for BOD and COD
Appendix 5.1 Air dispersion modelling results
Appendix 6.1 Memorandum of understanding
Appendix 7.1 Traffic management plan for EPCL
Appendix 7.2 Guideline for communities/stakeholder management
Appendix 7.3 Environmental and social action plan (ESAP)
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LIST OF FIGURES Page
Fig 3.1 Material flow block diagram of the proposed ammonia (Plan) 3-11
Fig 3.2: Typical process flow diagram of proposed ammonia plant 3-11
Fig3.3 Material flow block diagram of proposed Urea Plant 3-15
Fig 3.4 Emission control system for fertilizer plant 3-32
Fig 4.1: Average diurnal temperature distribution pattern for Port Harcourt 4-19
Fig 4.2 Average diurnal relative humidity distribution pattern for Port Harcourt 4-20
Fig 4.3: Average monthly rainfall distribution pattern for Port Harcourt 4-21
Fig 4.4: Percentage make-up of phytoplankton in the study area 4-27
Fig 4.5: Zooplantkton composition (%) in the study area 4-28 Fig 4.6: Percentage composition of benthic in fauna in the study area 4-29
Fig 4.7 Population pyramid of study settlements. 4-62
Fig 4.8: Employment distribution in the study settlements 4-63
Fig 4.9: Length of fallow period 4-66
Fig 4.10: Ownership of household assets in the study area 4-72
Fig 4.11: Sources of conflict in the study area 4-76
Fig 5.1 Approach to impact assessment 5-2
Fig 5.2 Pasquill Classes - 2009 5-17
Fig 5.3 Wind rose (yr 2008 – MM5 Data) 5-18
Fig 5.4 Wind rose (yr 2009 – MM5 Data) 5-19
Fig 5.5 Location of Monitoring stations 5-25
Fig 5.6 Model spatial parameters 5-28
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LIST OF TABLES
Pages
Table 2.1: Fertilizer production input and consumption in Nigeria 2-3
Table 3.1 New permanent and temporary project components and existent facilities 3-2
Table 3.2 Consumption of raw materials and product output for a typical Ammonia
Unit process
3-29
Table 3.3 Consumption of raw materials & products output for a typical Urea Unit
process
3-30
Table 3.4 Consumption of raw materials and products for the Urea granulation unit
3-30
Table 3.5 Emissions characteristic of the fertiliser plant (Primary reform)
3-34
Table 3.6 Parameter limits for the fertilizer plant (Auxiliary Boiler) 3-35
Table 3.7 Emission characteristics (Granulation Unit) 3-35
Table 3.8 Quantity of CO2 exhausted from the process plant 3-36
Table 3.9 The sources and the types of fugitive emissions from the plant 3-37
Table 3.10 Waste types and estimated quantities during activity 3-38
Table 3.11 Hazardous materials to be used on site during construction/operations 3-39
Table 3.12 Measures to provide energy conservation taken by EPCL for fertilizer plants 3-39
Table 3.13 Measures to reduce the need of storm water treatment 3-43
Table 4.1: Sampling Stations and Coordinates for air quality 4-3
Table 4.2: Instrumentation and Method of Observation
4-4
Table 4.3: Noise Exposure Limits for Nigeria (FEPA, 1991) 4-16
Table 4.4 IFC Guidelines 4-17 Table 4.5: Mean monthly weather data from Omne station 4-18
Table 4.6: Monthly rainfall measurements for Port Harcourt (1931-1978) 4-21 Table 4.7: Recipient Environment Surface water results from fieldwork –
March 2011 & Regulatory Monitoring 2010
4-22
Table 4.8 EPCL treated Effluent Water Quality (Discharge Point/ sluice Gate) for wet season 2010
4-24
Table 4.9: Groundwater chemical analysis within the project site 4-26
Table 4.10: Phytoplankton Result in the study area 4-31
Table 4.11: Zooplankton Result in the study area 4-32
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Table 4.12: Benthic fauna in the study area 4-32
Table 4.13: Sediment Results 4-33
Table 4.14: Soil chemistry Results 4-37
Table 4.15: Crops in the farmland of the Host communities of the Eleme
Petrochemicals Industrial Complex
4-49
Table 4.16: Farmland type of vegetation species composition around EPCL
with the relative frequency of occurrence detected during the survey
4-50
Table 4.17 The plant composition in the bush fallow land transect 4-51
Table 4.18: Bankside Vegetation species composition and frequencies 4-52
Table 4.19 Wild life species available in the vegetation of the Akpajo,
Aleto and Agbonchia communities: Host to EPCL complex
4-57
Table 4.20: Checklist of birds found along the adjoining vegetation of the Eleme
petrochemicals.
4-59
Table 4.21: Wealth Quintile of Study Settlements 4-64
Table 4.22: Percentage Distribution of Household Water Sources 4-67
Table 4.23: Percentage Distribution of Household Sources of Fuel for Lighting 4-71
Table 4.24: Percentage Distribution of Sources of Cooking Fuel to Household 4-71
Table 4.25 Health facilities available in the different communities. 4-79
Table 4.26: Treatment Facility Utilization in Eleme (Agbonchia) 4-80
Table 5.1 List of associated and potential impacts of the proposed fertilizer
project in IEFCL facility
5-5
Table 5.2 Pasquill Classes - 2009 5-16
Table 5.3 Summary emission factors end stack location 5-21
Table 5.4 Sources mass balance 5-23
Table 5.5 Receptor concentration limits
Table 5.6 Air quality baseline results for stations inside EPCL complex (March 2011)
5-24
5-26
Table 6.1 Proposed mitigation and compensation measures 6-3
Table 7.1 Monitoring plan for the new plant project at IEFCL 7-8
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LIST OF PLATES Page
Plate 3.1 Map of Nigeria Showing Rivers State 3-3
Plate 3.2 Administrative Map of Rivers State showing the Host LGA (Eleme)
of the Project Site.
3-4
Plate 4.1: Borehole Drilling Rig 4-10
Plate 4.2: CPT measurement 4-11
Plate 4.3: Plants/Organic materials observed on Okulu Stream during the
fieldwork
4-28
Plate 4.4: Organic debris floating on Okulu stream as observed during the
fieldwork
4-30
Plate 4.5: Soil Sampling 4-36
Plate 4.6: Transportation land use 4-42 Plate 4.7 the popular “Okada” motorcycle (Transportation Land use and a Pedestrian along the Carriage way)
4-42
Plate 4.8 Landuse Primary school in Aleto – Eleme 4-43 Plate 4.9: Typical Health center 4-43 Plate 4.10: One of such mechanic workshops on the Stretch of land opposite EPCL’s complex dual carriage way
4-44
Plate 4.11 Fresh water body in Abonchia community Eleme 4-47 Plate 4.12 Fresh water bodyin Agbonchia community Eleme 4-47 Plate 4.13: Dredging pipes on Okulu Stream 4-47 Plate 4.14: A dredger on a portion of Okulu Stream 4-47 Plate 4.15: Illegal dredger 4-47 Plate 4.16: Dredger on the Okulu Stream 4-47 Plate 4.17 Collapsing bank side around Okerenwa community 4-48 Plate 4.18: Illegal Sand Mining making bricks business in Okulu stream 4-48 Plate 4.19: Local sand miner 4-48 Plate 4.20 Bush Fallow in Akpajo community, fieldworkers collecting soil samples
4-51
Plate 4.21 Okulu Stream bankside vegetation 4-52 Plate 4.22 Okulu Bankside vegetation 4-52 Plate 4. 23: Collapsed Okulu Bankside Vegetation 4-54 Plate 4.24: Subsidence on a portion of Okulu Stream 4-54 Plate 4.25 Cattle Egrets in grassland vegetation 4-56 Plate 4.26: Birds in Okulu Stream wetland 4-56 Plate 4.27: Cassava Processing in Eleme 4-65
Plate 4.28: Nchia Main Market in Eleme 4-65
Plate 4.29: Refuse Dump in Okerewa- Aleto 4-68
Plate 4.30: Motorcycles are Important Means of Transportation in Eleme 4-69
Plate 4.31: Model Primary School in Okerewa – Aleto, Eleme 4-70
Plate 4.32: Health impact team in focal group discussin and collecting some
physical data
4-79
Plate 4.33: Abattoir opposite the Aleto (OKulu) Stream Bridge 4-83
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LIST OF ABBREVIATIONS AND ACRONYMS
µg/l
Microgram per litre
µg/m3
Microgram per Cubic Mater
µM Micro Meter
% Percentage
Wt% Weight by Percent
AIDS Acquire Immune Deficiency Syndrome
AMSE American Society for Mechanical Engineering
API American Petroleum Institute
ASTM American Standard Testing Material
BASF
BFW Boiler Feed Water
BAT Best Available Technology
BCF Billion Cubic Feet
BOD Biological Oxygen Demand
CHEW Community Health Workers
CNS Central Nervous System
Co Carbon-Monoxide
COD Chemical Oxygen Demand
COHB Carboxyl – Haemoglobin
CPI Corrugate Plate Interceptor
CPT Cone Penetration Testing
CPU Central Processing Unit
CuO Cuprous oxide
CxHy Hydrocarbon
DAF Dissolved Air flocculation
dB Decibel
DMDS Di-Methyl D-Sulphide
DO Dissolved Oxygen
DO Dissolved Oxygen
DPR Department of Petroleum Resources
DR Doctor
EA Environment Assessment
EAR Environmental Audit report
EDG Emergency Diesel Engine
EC Electrical Conductivity
EER Environmental Evaluation Report
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EPCL Eleme Petrochemicals Company Limited
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ERP Emergency Respond Plan
ETP Effluent Treatment Plant
EU European Union
FAO Food and Agricultural Organization
FEPA Federal Environmental Protection Agency
FGN Federal Government of Nigeria
FMENV Federal Ministry of Environment
FOT Federal Ocean Terminal
GB Giga Byte
GDP Gross Domestic Product
GFD Group Focus Discussion
GMT Greenwich Mean Time
GT Gas Turbine
H Hydrogen
H2S Hydrogen Shulphide
HCL Hydrochloric Acid
HDPE High Density Polyethylene
HIA Health Impact Assessment
HIV Human Immune Deficiency Syndrome
HNO3 Nitric Acid
HQ Head Quarters
HSE Health Safety and Environment
HTS High Temperature Shift
HUB Hydrocarbon Utilizing Bacteria
HUF Hydrocarbon Utilizing Fungi
IEFCL Indorama Eleme Fertilizer Company Limited
IITA International Institute of Tropical Agriculture
ISO International Standard Organization
Kg Kilogram
Kg/cm2 Kilogram per centimetre squared
Kg/hr Kilogram per hour
KN/M2 Kilo Newton Per Meter Square
Kpa Kilo Per Annum
KODrum Knock out Drum
KWh/T Kilowatt of electricity per hour per ton
LGA Local Government Area
LLDPE Linear Low Density Polyethylene
LTR Litre
LTS Low temperature Shift
N Nitrogen
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NH3 Ammonia
MC Master of Ceremony
MDEA Methyl Di Ethyl Amine
MDG Millennium Development Goal
mg/l Mili-gram per litre
MLSS Mixed Liquor Suspended Solid
MPN Most Probable Number
mmg/m3 Miligram per meter cube
mg/m3 Miligram per meter cube
MSDS Material Safety Data Sheet
MTP Metric Tons Per day
MW Mega Watt
NAFCON National Fertilizer Company of Nigeria
NCC Nature Conservancy Council
NE North Easterly
NEPA National Electric Power Authority
NESREA National Environmental Standards Regulatory Agency
NG Natural Gas
NGL Natural Gas Liquid
NGO Non-Governmental Organization
NH3 Ammonia
NNDC Niger delta development Commission
NNPC Nigerian National Petroleum Company
NOx Nitrogen Oxide
NPC Nigeria Population Commission
OUE Odour threshold Unit set by the European Union
O2 Oxygen
oC Degree Celsius
PAC Project Actualization Committee
PCV Parked Cell Volume
pH Potency of Hydrogen
PHCN Power Holding Company of Nigeria
PID Pelvic Inflammatory Disease
PIU Project Implementation Unit
PP Polymerization of Propylene
Ppm Part Per million
Ppmv Part per million by volume
PPP Public Private Partnership
PTDC
PVC Polyrinyl chloride
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RAM Random Access Memory
RSME Rivers State Ministry of Environment
RSPM Respiratory Suspended Particulate Matter
RSUST Rivers State University Of Science Technology
SOx Sulphur Oxide
SPDC Shell Petroleum Development Company
SPM Suspended Particulate Matter
SPSS Statistical Package for Social Science
SPT Standard Penetration Test
STI Sexual Transmitted Infection
SW South Westerly
SWC Storm Water channel
TDS Total Dissolve Oxygen
TF Total Fungi
THC Total Hydrocarbon Content
TCLP
TOE Tons of Oil Equivalent
TOR Terms of Reference
TSPM Total Suspended Particulate Matter
UES Uniform Effluent Standard
USD United State Dollar
Vol Volume
VOC Volatile Organic Compound
WHO World Health Organization
WMO World Meteorological Organization
WTP Water Treatment Plant
ZnO Zinc oxide
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EIA PREPARERS
The multi-disciplinary teams and their responsibilities are as follows
NAMES RESPONSIBILITIES
OLU WAI-OGOSU PROJECT LEADER
WASTE MGT/LANDUSE
MR ADEYEMI ADEWALE SOIL CHEMISTRY/QUALITY CONTROL
DR MOSLEN MAIBAKA HYDROBIOLOGY & FISHERIES
DR CHRIS ANYANWU HEALTH IMPACT ASSESSMENT
DR P. N. EDE SOCIAL IMPACT ASSESSMENT
DR P. OLULEYE AYODEJI EMISSION MODELLING
DR RALPH OFFIONG WILDLIFE/ VEGETATION
MR AMIRE TAIWO WATER CHEMISTRY
MR TOPE IBIRONKE AIR QUALITY
MR DAVID EDOKPA METEOROLOGY
MR IFEANYI ANASONYE HYDROGEOLOGY / GEOTECHNICS
SOLOMON. NWACHUKWU SYSTEM ANALYST/ADMIN
JAWURA ENV. SERVICES LABORATORY ANALYSIS
IEFCL PARTICIPANTS (PROPONENT) SUPPORT STAFF
MR U. K. CHATTERJEE PROJECT FACILITATOR
MR S. S. KAHANDAL MANAGER- ENVIRONMENT
MR J. SALOKA ENVIRONMENT OFFICER
REGULATORY AGENCY INTERFACE
MR H. LADULA EIA FIELDWORK SUPERVISION
MR UBANI EIA LABORATORY ANALYSIS SUPERVISION
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EXECUTIVE SUMMARY
Proponent
Indorama Eleme Fertilizer and Chemical Co Ltd (IEFCL) is the proponent of a fertilizer plant
project (Ammonia and Urea) in the premises of the Eleme Petrochemicals Co. Ltd (EPCL)
The field data gathering of the proposed fertilizer project EIA was carried out from the11th to
14th March, 2011.
Need for the EIA
This project has been categorised as category one project by the Federal Ministry of
Environment who confirmed the need to conduct a full blown EIA.
Terms of reference (TOR)
During the EIA scoping phase the Federal Ministry of Environment approved on 9th
December 2010 the Terms of Reference for the said project submitted by IEFCL.
The TOR included the plan of environmental investigations to be carried out to identify the
baseline condition of the study area, the format and contents of the EIA report and the
description of the team charged to prepare the present EIA report.
EIA Objective
The objectives of the EIA are:
To describe the physical, chemical, biological and socio-economic features of the
environment potentially affected by the Project identifying the environmentally
sensitive areas within the project area.
Identifying in the design, construction, commissioning, operation and
decommissioning phases of the new Fertilizers plants where environmental
impacts (both positive and negative) may occur.
To superimpose all aspects of the project on the environment and evaluate the
impacts of the project on the environment.
To highlight particularly and recommend any measures that could be used to
avoid, and if not avoidable, mitigate/ameliorate any negative hazardous impacts
as well as promote beneficial effects of the project.
To use results of the investigations to develop project specific ameliorating
plans/measures during execution.
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To define an Action Plan, which foresees also the adoption of an Environmental
and Social Management System (ESMS) for the project lifespan as defined by
the Equator Principle n.4
To serve as an advance notification to the regulatory agencies especially the
Federal Ministry of Environment.
To provide necessary answers to questions from stakeholders, host communities,
regulators and other interested parties.
Scope of work of the EIA
The scope of the EIA included review of laws, regulations and guidelines (National and
International), fieldwork, laboratory analysis, literature research to assess the impacts
expected and mitigation/compensation measures against negative impacts. In order to
achieve this, also informal and formal consultations were held with all interested parties.
Finally an EIA Report including comprehensive project/social and environment
components description and a Management Plan is produced and submitted to FMENV
which is the competent authority to process the report.
Regulatory Framework
The Legal basis for environmental permitting, applicable National and International
Legislative and Administrative framework including internal laws and conventions
pertaining to this industry were reviewed and documented. The whole EIA Report’s
documentation was drafted taking into account the following national and international
documents:
Guidance on EIA, EIS review, June 2001, European Commission;
Equator Principles, June 2006, Equator Principles Association;
International Finance Corporation (IFC) Sustainability Framework, 2012 Edition,
Performance Standards;
Environmental, Health and Safety Guidelines, April 30 2007, World Bank and IFC;
Environmental, Health and Safety Guidelines for Nitrogenous Fertilizer production,
April 30 2007, World Bank and IFC;
EIA Procedural Guidelines, 1995, Federal Environmental Protection Agency of
Nigeria;
EIA Sectoral Guidelines, Oil and Gas Industry Projects, Sub-sectoral Guidelines for
Petrochemicals, 1995, Federal Environmental Protection Agency of Nigeria;
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EIA Sectoral Guideline, Manufacturing Industry
Justification of the project
The gross imbalance in the supply and demand of fertilizer for agricultural productivity goes
to support the need to establish the fertilizer plants in Nigeria. The project will help to reach
the objectives of the Federal gas revolution programme providing necessary infrastructures
development as the installation of natural gas based industries for fertilizer production.
Project Alternative
In determining the project options, issues such as ease of availability of raw materials,
choice of appropriate location and best available technology for producing the products were
reviewed. These formed the basis of suggesting that the chosen project option is the more
appropriate solution for the development of the project.
Project Location
The project is located geographically within 4o49’N and Longitude 7o6’E. Maps of Nigeria,
Rivers State and study area around EPCL complex, together with the plot plan of EPCL
complex, were used to illustrate the proposed location of Ammonia and Urea Plants in
Eleme (the Host community).
Project Description
To simplify the understanding of how the final products (NH3, Urea,) will be produced from
the parent raw material, which is natural gas, block diagrams starting from the
desulphurization of the natural gas, catalytic steam reformation of the gas into hydrogen,
carbon dioxide and carbon-monoxide were used. A shift in temperature in the reformers
creates the appropriate environment for the CO2 formed to be absorbed leaving hydrogen
free to react with Nitrogen gotten from air to form Ammonia. Ammonia sets the stage for
chemical reactions to end up with Urea and NH3
The project entails the building of the following two chemical plants:
- Ammonia Plant for a production of 2300 MTPD of Ammonia;
- Urea & Granulation Plant for a production of 4000 MTPD of Urea.
The project design shall be suitable for 30 years of operation with planned turn around for
maintenance every 2 years or longer. Design capacity is considered for an on stream days
of 330 days/year.
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IEFCL has engaged two Technology licensors/EPC company for doing early works for
getting firm price based on state of the art technology, optimum energy consumption & most
environment friendly process.
For the purpose of the Environmental Impact Assessment conservative approach has been
adopted and highest levels of emission and discharge have been taken into account,
however the emissions of the new plants will be in compliance with the applicable
International standards/requirements, in particular concerning the Nitrogenous Fertilizer
production.
The EPCL complex will be able to provide to the new plants several facilities (e.g. electric
energy, waste water treatment, nitrogen and air compressed system…) for their operation.
Existing Environment
Hydrogeology/Geology
The proposed project site is located within the national grid between Latitude 4o49’N and
Longitude 7o6’E on a plot of land approximately 9sqkm. Commonly, the topography
surrounding the project site is flat with no hills.
Based on the Geological Map of Nigeria, published by the Geological Survey Department of
Nigeria, the geological unit of the proposed project site and their surrounding falls under the
Niger Delta and continental deposit, geologically, the site is underlain by costal plain sands,
which in this area is overlain by firm – stiff sandy clay sediments belonging to the
pleistocenic formation. Beneath the sandy clay layer is a deposit of fine-medium dense sand.
Surface Water
The proposed plant located within EPCL Industrial Complex has Okulu Stream situated on
the south eastern end. All effluent discharge from the project area is collected in a waste
water treatment plant for treatment before draining into a retention pond, which flows when
released through a sluice gate into the Okulu Stream.
Four (4) locations were chosen for the surface water sampling i.e. upstream, downstream of
the project site, one sample taken from the outfall point after the Retention pond prior to the
treated effluent been discharged into Okulu Stream and one (1) from Agbonchia stream
used as the control station. Besides in-situ water quality measurements were undertaken as
well as grab samples collected for laboratory analysis.
The water quality of the Okulu stream indicates anthropogenic interferences considering that
is not compliant with the FMENV Water Quality Criteria for surface water defined for
Irrigation/ Reuse Standards and Fisheries/Recreation standards.
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Substantial dredging and sand mining observed on Okulu Stream environment during the
field study seem to be the most significant cause of impact.
Ground Water
The project site which falls in the Niger Delta region is reputed for its very high ground water
recharge rate ( Present consumption of the EPCL complex is equal to about 1000 m3/hr)
Groundwater chemical analyses show the respect of Nigerian maximum permissible limits
for all the parameters, exception for pH that is below the tolerated rate. It has to be
considered that ground water is acidic in Nigeria delta region, due to high content of
dissolved CO2.
Air Quality/Odour
The results of ambient air monitoring reveal that all pollutant’s levels recorded at all the sites
were well below the recommended Nigerian Air Quality Standards and the WHO standards,
with the only exception of few cases of CO exceeding values registered in sites outside
EPCL complex probably due to traffic flows emission.
A concern observed is the complaint of odour by the host communities especially from
Elelenwo and Akpajo from existing plant, which has been duly addressed by the IEFCL
management.
Ambient Noise Level
Noise monitoring stations were established at each air quality stations. The noise sources
were mostly as a result of vehicular movement, wind blowing and human activities
surrounding the project site. The EPCL complex is in compliance with the noise exposure
limit for workers defined by the Nigeria and with the IFC Standards for industrial areas at the
premises of the above mentioned complex. Noise level measurements at sampling stations
highlighted the significant influence of the existent traffic flows in the route Akpajo/Port
Harcourt axis.
A comprehensive noise survey was conducted and results documented in Appendix 4.3
Meteorology
Long term air temperature data (Onne meteorological station) shows an average monthly
maximum temperature equal to about 31°C and an average minimum temperature with a
mean value of about 23 °C. Relative humidity values based on above mentioned historical
data show average minimum data equal to about 60% and average maximum data equal to
94%. The prevalent wind direction is South-West with an average wind speed equal to about
3.9 m/s, calms are about 2% of the total hours in the year according to the PSU/NCAR
mesoscale Model (MM5) output data.
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The months of July and September had the highest amount of average rainfall (about 420 –
430 mm per month) while December had the lowest amount (about 30 mm per month).
Land Use
The proposed project site is situated within EPCL existing facility perimeter, with the new
plants located on vacant existing plots.
The nearest habitable communities are actually Aleto, and parts of Agbonchia, and Akpajo
because of the rate at which residential and commercial buildings are spreading towards
EPCL battery limits. The larger parts of Agbonchia and Aleto are cut-off from EPCL complex
by the meandering Okulu stream on the eastern end. The common landuse patterns in the
project area are subsistence farming, Residential/Estate Housing, Industrial, transport
highways/roads and small scale businesses such as automechanic workshops. A thematic
landuse map of the project area is attached as appendix 2.1
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Soil
Soil stations were selected both within EPCL complex and in the host communities based on
operations/activities in the area and the use of the soil for subsistence farming as an
example. Evaluation of the field and laboratory analytical results of the soils shows that the
texture of soils in the field was mainly sandy loamy with sand particles dominating the
aggregates. Soils in the sampling area are slightly acidic to neutral (pH 4.23 to 6.98) within
the complex and 4.72-6.60 in the neighbouring communities). The nutrient content in the
soils of the entire area were generally low. This trend can be attributed to the high nutrient
fixation and shortened fallow period which is indicative of low soil fertility.
The values of metals are low despite this, the iron and manganese concentrations are
slightly high indicating that there are pyrites in these soils (Dent, 1986) FAO (1972) reported
that high value of iron is peculiar to poorly drained soils (laterite).
Aquatic Environment
Phytoplankton, zooplankton and benthos samples were collected from the Okulu and
Agbonchia streams in the study area.
Sample points (4 points) were distributed along the Okulu stream up to the point where
effluent from the petrochemical company discharges into the river. A 5th point was then taken
at a stream in Agbonchia to serve as control point. Five (5) samples each were collected for
phytoplankton, zooplankton and benthos giving a total of 15 samples.
From the results of the phytoplankton investigation it could be deduced that the Okulu
stream has deteriorated water quality than the Agbonchia stream.
Similar result was obtained considering the Benthic macro fauna and zooplankton
monitoring, since the abundance and diversity of organism from the Okulu Stream is
reported to be poor.
These results seem to be corresponding with the present use of these water resources
since:
- As mentioned in the water quality paragraph the Okulu stream has two open basins
where serious sand mining by both dredgers and manual miners were observed
during the fieldwork. The same basin appeared to be widening due to bank erosions
caused by these activities;
- The Agbonchia stream is mainly used for domestic activities such as washing,
bathing and even drinking.
Socio Economic and Cultural Environment
The proposed project is arousing a lot of interest and expectations are high, albeit with
uncertainties also over its social and environmental consequences. For investigating the
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socio economic component a dedicated questionnaire and focused group of interviews were
the primary means of data collection. Four settlements in two local government areas of
Rivers State of Nigeria where surveyed for this study. The settlements are Agbonchia, Aleto
and Akpajo in Eleme Local Government Area and Elelenwo in Obio/Akpor. The people of
Eleme claim a common ancestry, language and ethnicity. Elelenwo is of Ikwerre origin.
The total population of the four settlements surveyed in this study is 65,956 in 2010. The
population structure based on a pyramid plot is heavy at the bottom and light at the top.
Children (0-14) in the settlements constitute 36 per cent of the population. The working class
(15-60) constitute 59 per cent, while old and retired people (> 60) constitute 5 per cent of the
population. The largest age cohort is infants aged between 0-4 years and they constitute 16
per cent of the population. There are more male (57%) than female (43%) among the
households surveyed in this study. The mean household size is 5, the same as the national
average. This gives a sex ratio of 106 compared to the national sex ratio of 105. The
distribution of occupation among the respondents is 48 per cent for the self employed, 21
per cent for those who work in government offices, 12 per cent for company workers and 22
per cent unemployed. Only 2 per cent of the respondents claim they fish. The mean daily
income of people in the study area is N400 or 2.6 USD per head per day.
Large industrial complexes have not attracted medium manufacturing industries to utilise
their products in the area. This lack of backward integration permeates to the level of small
aspiring entrepreneur. There are no signs of industrial activities at the community level in the
study settlements. As reflected in the occupation structure, people either farm, work for
government or they are businessmen. What remains of industries that community members
can relate to are small time welding and fabrication, sand mining in all the rivers in the area,
traditional food processing like cassava flour and fish smoking.
The farming system is a limited form of shifting cultivation whereby a land is cleared and
cultivated for several years until productivity diminishes; it is then abandoned until natural
processes regenerate the soil. The fallow period was up to 7 years about 30 years ago it
reduced to about 4 years 10 years ago, but now the farms are rarely left fallow. Farming
tools and inputs are also basic. Seedlings are obtained from the previous year’s harvest.
Cutlasses, hoes and spade make up the farming tools. Mechanization is non-existent.
The sole source of domestic water supply is shallow boreholes. The water tables in the study
areas are close to the surface and water can be tapped at 10m in most cases from the first
aquifer.
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Movement from one place to another is by road in the study settlements and major means of
transportation is motor, bicycles, 2-stroke tri-cycles (popularly called Keke-NAPEP and
buses). All the study settlements are big enough to require some sort of internal transport
which is met through the use of tricycles. In Aleto and Agbor Nchia motor bikes are the most
important means of internal transport. Every community in this study has a model primary
school, recently constructed or under construction that is publicity funded. All the settlements
except Akpajo also have a secondary school owned by the government. Adult literacy rate in
the study communities is over 80 per cent.
Energy demand in the study area is for lighting, cooking, and driving machines (including
automobile). The experience during the fieldwork is that all energy types are in short supply.
Electric light is epileptic and there are occasions when they receive only a few hours of it in a
week. The petroleum based types are scarce and expensive, for instance, one litre of
kerosene costs N200 as against the advertised and regulated price of N50. A modest bundle
of wood cost N1, 000 because the bushes from where they are sourced have been
significantly depleted.
Most respondents live in owner occupier houses. Majority of the houses are constructed with
concrete blocks and roofed with corrugated iron sheets (73 %). Other types of houses
reported by respondents are concrete blocks roofed with asbestos (11.6%), earth block and
iron sheets (11.6), and the traditional wattle and mud houses roofed with thatch or iron
sheets (3.2%). The crowding index is 1.2, that is, a room is available to every 1.2 persons in
the study area.
Four activities dominate the cultural calendar of communities in the study area namely;
wrestling, traditional marriages, new yam festival and dances. Social Affiliation in the
societies includes politics, co-operatives, social clubs, education, religion and cultural
associations. Dispute over land boundary and ownership is the primary cause of intra and
inter communal conflicts in the study settlements. The courts are the main avenue for
dispute resolution.
Traffic Survey
The four settlements in the study area are traversed by two major highways: the East – West
Road that begins from Warri and end in Eket and the Port Harcourt – Aba Expressway.
A survey of the existing traffic volume on the East- West Road (Direction from Akpayo to
Port Harcourt) indicated that on daily average a total no of 8.000 vehicles was monitored
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The Saloon cars constituted the majority vehicles followed in order of importance by
motorcycles, buses, trucks and tankers.
Health Assessment
The Health Assessment of the project area was conducted in and around the facilities and
the communities to determine the baseline characteristics of the health status of the project
area against which future impacts of the project can be compared. Secondly to determine
the probable/potential impacts of the project on the health of the workers within the EPCL
facility, the people around the communities (Agbonchia, Aleto, Akpajo, Elelenwo) so as to
determine the type of intervention/s needed to ameliorate these negative potential impacts.
These communities were sampled by the health personnel to obtain information regarding
mortality and morbidity rates, types of health hazards, most prevalent diseases, disease
vectors, nutrition, health facility infrastructure capability and usage, average family size,
sexual reproductive health, immunization status and coverage, sewage and waste
management system, air quality, water quality, radiation sources and levels. The state of
health delivery facilities/services in the area is below standards expected of an urban area,
most especially since the area is highly industrialised. The principal communicable diseases
in the area are Malaria, Diarrhoea, skin rashes, upper respiratory tract infections and STIs.
While prevalent non-communicable diseases in the area are hypertension, food poisoning
and occupational injury.
Vegetation and Wildlife
Visual observations were used to assess the vegetation along the proposed project.
Inventory of plants species in the background forest were taken about 500m away from the
site. The entire environment of the area in the vicinity of EPCL complex can be
divided into the following vegetation types:
Grasses, weeds and Herbaceous vegetation by the lawn bordering the
cement walled fence of EPCL complex and all other lawns within the
industrial complex,
Farmlands vegetation, mainly cassava based;
Bush fallow lands vegetation;
Bank side vegetation along fresh water body in Agbonchia;
Bank side vegetation along Okulu stream in Aleto;
Ornamental and other aesthetic plants, planted within EPCL complex and
along the dual carriageway leading into the complex;
Okulu stream Wet Land.
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The characterization of wildlife in the vicinity of EPCL complex involved a survey/census of
mammals, birds, reptiles and amphibians around the study area. Between the species
observed grass cutter, porcupine, giant rat and snails are very relevant, the squirrels
and birds are major vehicle for the propagation of oil palm trees in the ecosystem as
they help in oil palm seeds dispersal.
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Associated and Potential Impact Evaluation after the implementation of dedicated
Mitigation/Compensation Measures
Associated and potential impacts evaluation for the project was based on the results of
technical studies (e.g. Air Dispersion Modelling), together with established facts in relevant
literatures, perceptions and evaluations of stakeholders, project characteristics and general
observations obtained during field data gathering.
For all project phases (Construction, including recruitment phase and site preparation,
Operation & Maintenance and Decommissioning) activities that can affect the environmental
and social components have been identified, together with potential and associated impacts.
Also the Health & Safety issues have been similarly considered.
A list of criteria has been used, when applicable, to explain whether a project impact is likely
to be significant or not for the associated environmental components. These criteria define:
Character of the impact (benefical/detrimental);
Geographic Extension of the impact (direct, local, regional);
Duration of the impact (from short to long term);
Magnitude of its potential effects (from low to high);
Frequency of its occurrence (continuous or temporary);
Probability of occurrence (from low to high);
Reversibility of its effects (reversible or not reversible).
By the virtue of the identified impacts, prior the beginning of each project phase, the
proponent is committed to implement dedicated mitigation/compensation measures to
ensure that the project will be sustainable. A dedicated action plan has been prepared to
achieve the above mentioned scope.
For the same reason IEFCL will adopt an Environmental and Social Management System
(ESMS) for the Fertilizer plants project.
The evaluation of impacts in the different phases of the initiative considered the predicted
implementation of the above mentioned actions and it is briefly reported hereinafter.
Construction Stage
During construction phase IEFCL will put in place all the necessary measures to ensure
health of workers and environmental safeguard and to minimize the risk of possible
incidental events.
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The slight increase in dust emissions from construction activities will be properly addressed
by spraying water construction sites to reduce powder dispersion
The construction activities will be carried out, also, in accordance with applicable regulations
on noise.
The major increment in vehicular movements will occur during construction phase, however,
the Project will have minor effects on the existing vehicular transit on main road axes around
EPCL complex.
Temporary and occasional impacts on vibrations are expected, but considering the distance
between the project site and EPCL complex premises, there are no sensible receptors
interested by the initiative.
Risk of ground water/soil contamination due to accidental spills during construction activities
is a minor concern that will be minimized through the adoption of dedicated management
measures into the ESMS.
The construction activities will take into account the soil geological and geotechnical
characteristics avoiding the execution of the main foundations during the wet season in order
to exclude possible soil erosion concerns.
Construction areas will be located inside the industrial complex under the control of EPCL,
without using virgin lands. During this phase, IEFCL will make adequate accommodation
arrangements for expatriates to reduce pressure on local houses.
Minor impacts on wildlife are expected and time limited, associated to diurnal hours. Current
fruition of the existing fauna will not change.
Waste production during construction phase will be managed by the procedures and
facilities already existing in the EPCL complex. The excavated soil not reusable for
geotechnical reasons will be directed to appropriate external authorized landfills.
A population increase by the near host communities associated to the realization of the
Project is expected. Dedicated policies and actions will be adopted by IEFCL to safeguard
the host communities from impacts due to the influx of workers, however the host
communities will particularly benefit of the increase of both direct and indirect employment.
Operation &Maintenance Stage
During operation & Maintenance phase IEFCL will put in place all the necessary measures
to ensure health of workers and environmental safeguard and to minimize the risk of
possible incidental events.
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No significant effects are expected on air quality during operation phase, since the pollutants
concentrations at ground level due to EPCL complex after the operation of the new Fertilizer
plants will be in compliance with air quality regulatory/standards guidelines and with
occupational exposure limit values. No cases of odour annoyance are expected due to
increase of NH3 emission.
The initiative will not determine an amount of air pollutants emissions into the atmosphere
likely to negatively affect the existing quality of vegetation around the complex.
Moreover, fugitive emissions and emissions that can occur in upset situations only (e.g.
emissions from ammonia storage flare) will be managed by a dedicated Management
System.
Night-time vehicular movements will be minimized up to extent possible.
IEFCL will ensure that the operation of the new plants will be in accordance with applicable
regulations on noise.
Water effluents going to existing retention pond and to Okulu Stream will increase due to the
operation of the new Fertilizer Plant. This is not likely to generate an additional deterioration
of surface water and its hydrobiology/sediment because compliance with regulatory limits at
discharge point will be ensured also after the operation of the new Fertilizer Plant.
As a consequence, no variation in existing surface water quality likely to modify the
characteristics of surrounding vegetation is expected.
The new project will determine an increase in ground water consumption without affecting
the ground water recharge rate and the existing ground water flows. As per construction
phase, risk of ground water/soil contamination due to accidental spills during operation and
maintenance will be minimized through the adoption of dedicated management measures.
The initiative does not have negative health impacts on host communities around EPCL
complex. The same population increment by the near host communities will be managed in a
proper manner to safeguard the health of host communities deriving from possible exposure
to infective/transmissible diseases. During the operation phase IEFCL will dispose of EPCL
residential facilities inside the complex for all people employed.
Also an acceptable increase of vehicular traffic is expected and will be adequately managed
in order to minimize possible socio economic impacts and potential associated hazards.
There are no socio-economic activities that are going to be negatively affected by the
project and the installation of new units will not interfere with cultural/social elements present
in the study of area.
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The initiative will not modify the existing microclimatic conditions of the site considering also
the expected increment of aqueos vapor emissions in atmosphere from Cooling Towers.
Concerning CO2 emissions, it is worth noticing that the project will use natural gas as raw
material, energy resource that it is currently unused and that would be flared as alternative
with CO2 emissions already associated.
Decommissioning phase
At the end of the life span of the project, or otherwise, if proponent and or government
decides to decommission the project, a plan would be drawn by the proponent and approved
by all concerned Regulators and stakeholders before the plan is executed. Any possible
measure will be taken in order to ensure health of workers and environmental safeguard and
to minimize the risk of possible incidental events during decommissioning phase. IEFCL
commits itself to restore the environmental conditions existing before the realization of the
Fertilizer Plant project.
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Management Plan (MP)
IEFCL defined a plan for managing the proposed project ad associated impacts related to
environmental and social impact and occupational health and safety concerns.
The MP includes strategies to enable proactive resolutions of the environmental and social
impacts expected, procedures for training, development of adequate capacity; plans for
monitoring environmental, social, occupational and health issues as well as management of
the effects of the impacts and minimisation of the risks, parameters to be
measured/monitored, frequency and location of monitoring.
The plan is aimed at adopting an Environmental and Social Management System in
accordance with the IFC Performance Standard n° 1.
The ESMS will be adopted conforming with ISO 14001 (Environmental Issues) and OHSAS
18001 (Occupational Health and Safety) taking into account that the existing complex is
already accredited to IMS (Integrated Management Company) covering ISO 14001, OHSAS
18001 & ISO 9001.
Conclusion
Evaluation of EIA data, found that the project is environmentally feasible and will not cause
serious effect to the environment, provided that the existing and proposed mitigation and
compensation measures are implemented. Residual issues associated with the project are
expected to be minor and not likely to have long-term significance on the environment.
Recommendation
Mitigation and compensation measures are to be addressed according to the proposed
action plan.
All its monitoring programs are to be religiously implemented and periodically reviewed and
revised as necessary to take into consideration changes made to the project during its
operation. Vibrant and dynamic company-community relations will be maintained to ensure
sustainability of the project.
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ACKNOWLEDGEMENT
The management of Indorama Eleme Fertilizer and Chemical Ltd (IEFCL) wishes to
acknowledge the opportunity granted by the Government of Federal Republic of Nigeria
through the Ministry of Environment to conduct this EIA for the proposed fertilizer plant in the
Eleme Petrochemicals Company Ltd complex.
We appreciate the cordial working relationships we had with the federal Ministry of
Environment, the Rivers State Ministry of environment, The Eleme local government Council
and the Traditional Head of Eleme Kingdom, His Majesty Emere S. I Ejire.
Finally we need would not fail to mention the support rendered to our EIA fieldwork team by
the representatives of the Project Actualization Committee (PAC) which is a committee
made up of Councillors representing the host committees in the two host Local government
councils (Eleme and Obio-Akpor LGAs)
Thank you
Management of IEFCL