The project will not require any new land and hence no new land acquisition and related involuntary physical or economic displacement is expected; thus PS5: Land Acquisition and Involuntary Resettlement does not apply. PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources will not apply to the project given its location within the confines of the existing footprint of the facility located on the land that was previously cleared and levelled in a highly-modified habitat.  No Indigenous People have been identified in the areas influenced by the project’s activities and thus PS 7: Indigenous Peoples does not apply; this similarly applies to PS 8: Cultural Heritage as all the areas on which construction is to occur have been previously disturbed and there is no evidence of presence of any cultural heritage                                       

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the potential adverse E&S risks and/or impacts which are generally site-specific are largely reversible and can readily be addressed thorough mitigation measures. Based on the available project information, key project related E&S issues/ risks include the company’s capacity to manage E&S performance during construction and operation, management of labor relations and working conditions for its employees including employed through contractors, occupational health and safety during construction and operation, management of wastes and emissions, community health, safety and security and stakeholder engagement                                        

Identification of Risks and Impacts

In accordance with the national Environmental Impact Assessment (EIA) Decree No. 86 of 1992, IEFCL completed an EIA and has obtained the EIA approval from the Federal Ministry of Environment (‘FMENV’). IEFCL further updated and completed the ESIA to conform to international standards and the IFC PSs, in December 2017.  The updated ESIA is attached to this summary. 

The spatial boundary of the study area covers a five-km radius from the project site, including all the areas that could be potentially affected by the project. The ESIA covers potential impacts and risks for different stages of the project (i.e., site preparation, construction, operation and decommissioning) including air emissions, liquid effluents, operational safety, community impacts, worker conditions as well as assessment of the potential cumulative impacts of all local industry on its area of influence.

The cumulative impact assessment demonstrated that the air shed has sufficient absorbing capacity to assimilate the project stack emissions which will comply with the WBG EHS guidelines. To conduct the assessment, IEFCL modeled the process and utility air emissions of the project using the USEPA AERMOD, version 6.2 air dispersion model.  The model assessed particulate matter, nitrogen dioxide, sulfur dioxide, and ammonia at receptors around the project site. None of the modeled concentrations, which included those from the existing and proposed IEFCL operations, exceeded the correspondent ambient air quality guidelines.

The ESIA includes frameworks for the Environmental and Social Management Plans (ESMPs), to be implemented at the various phases of the project, preventing and addressing key impacts as well as monitoring arrangements. Key environmental plans developed for Line 1 and which will be updated as needed include management of hazardous wastes, air emissions, liquid effluents treatment, occupational health and industrial safety, operational safety and emergency response plans.

The Social Management Plan being developed aims at mitigating adverse project impacts and supporting long-term socioeconomic development in the project affected communities and towns within a 5-km radius. The project site is within the Indorama Petrochemical Complex with no significant negatives impact on the communities except temporary construction impacts.  The project will have positive impacts related to creation of jobs and economic opportunities. - Furthermore, the company will undertake an agricultural training and support programme for farmers in host communities as a form of livelihoods improvement especially for women.

Policy

IEFCL has an overarching E&S policy and principles that guide the management of the (E&S) issues across IEFCL’s operations based on the IFC PSs. The policy has been developed based on values of integrity, excellence, responsibility & respect; driving the business in a responsible and ethical way, personal and professional excellence, superior quality and competitive prices, among others. As part of this project, IEFCL will extend this policy to Line 2 as well.

Management Programs

For Line 1, IEFCL has in place an ESMS to address the EHS and social aspects of its existing operations. The system includes the policies and procedures to comply with the local requirements, as well as, IFC Performance Standards and WBG EHS Guidelines. The integrated management system of Indorama Eleme Petrochemical will be extended and enhanced as needed for Line 2 once it becomes operational.

Furthermore, the construction contractor will develop and implement detailed environmental pollution control and occupation health and safety procedures based on the Project’s own ESMPs, prior to the start of construction, as specified in Action No. 1 of the ESAP.  Procedures will include H&S induction training for all site personnel to identify hazards and carry out their work responsibilities safely. The procedures will also include recordkeeping of all incidents and near misses with a follow-up to prevent such re-occurrences, and the establishment of its own workplace conditions monitoring program with which it will routinely report on IEFCL’s E&S performance.

During the construction phase, the responsibility for compliance along with the mitigation measures and management plans outlined in the ESIA are being included in the engineering, procurement and construction (EP&C) contracts. The performance of the EP&C contractors vis-à-vis these requirements will be closely managed and monitored by IEFCL.

Organizational Capacity and Competency

IEFCL has an established EHS and Social Department. It has an EHS team coordinated by the EHS manager reporting directly to the Chief Technical Officer of the company. For the proposed Line II, the company is hiring additional qualified personnel. IEFCL also contracts additional external consultants for activities such as environmental assessments, environmental audits and environmental monitoring as and when needed. Labor and social issues in IEFCL are managed by Human Resources, Industrial Relations and Community Relations & Development Departments respectively.

Emergency Preparedness and Response

IEFCL has developed an adequate Emergency Response Plan (ERP) for Line 1, which describes IEFCL’s organization and infrastructure to handle any emergency event and provides the procedures to be followed to control or limit potential impacts. The ERP covers potential emergency events such as toxic and flammable gas releases and spread, liquid hydrocarbon spill, fire, gaseous & liquid hydrocarbon leak , explosion of vapor cloud or pressure vessel, etc.

IEFCL will update the existing ERP prepared for Line 1 and extend it for Line 2 as well. An important element of the ERP will be community consultation and training, as well as relevant measures to warn communities. In addition, the construction contractor will develop and implement the corresponding emergency response plan and have qualified personnel and equipment to adequately respond to potential emergencies (See Action No. 2 of the ESAP.)

Qualified personnel to respond to any emergency will always be available. IEFCL is already an active participant of the already established Emergency Response Mutual Aid Organization established by the industries in the area.

IEFCL’s fire safety department has dedicated qualified staff as well as dedicated equipment (i.e., fire engines, emergency response vehicle, water tender, mobile foam trailers, multipurpose trucks and hydraulic lift platform) available 24 hours. There is also a dedicated emergency response room which includes a visual display of all the manual call points and gas and smoke alarms on site.  A site evacuation drill and three fire drills are conducted yearly focusing on different plants or aspects of operations. Port Harcourt has two fire stations that can help in the event of an emergency, and there is agreement between IEFCL and nearby refineries to provide mutual assistance. These same systems and procedures will be extended to Line 2.   

Monitoring and Review

For Line 1, IEFCL developed an E&S monitoring plan for both the construction and operation phases. The plan identified all parameters to be measured (i.e., stack emissions, air quality, noise, treated liquid effluents, workplace conditions, etc.) and frequencies of measurement. The company has four on-site and two off-site ambient air quality monitoring stations, one located in the Akpajo community (east of the site) and one in the Aelto community (south of the site).  These stations monitor SO2 (sulfur dioxide), NO2 (nitrogen dioxide), VOCs (volatile organic compounds), CO (carbon monoxide), PM, (particulate matter), and CO2 (carbon dioxide). The company also measure H2S (hydrogen sulphide) and CxHy (hydrocarbons).

Ongoing monitoring of ambient air quality during the construction and operation phase for Line 1 indicate that the results were within the national standard limits and those defined in the WBG General EHS Guidelines, Table 1.1.1.  Quarterly point source monitoring is undertaken on the polymer incinerator, sludge incinerator, olefins heater stacks, boiler stacks and the thermal power plant stacks for SO2, NO2, H2S, CxHy, VOCs, oxygen and carbon dioxide, and the results are within the WBG General EHS Guidelines, Annex 1.1.2. 

As part of the project, IEFCL will extend the monitoring plan to Line 2 as well.  In addition, it will establish groundwater monitoring at the facility and will implement a groundwater testing program during the construction and operation phases. 

IEFCL is required to periodically report the results of its E&S performance to the local Nigerian environmental authorities. Moreover, during construction and operation of the project, IFC along with other lenders will appoint an independent consultant to review compliance of the project with the applicable E&S requirements including the ESAP. 

As the technology & design of Line 2 will be the same as Line 1, the process know-how and detailed engineering and equipment will be the same as Line 1. As IEFCL conducted a detailed HAZOP study for Line 1, the engineering deliverables for Line 2 will be HAZOP compliant. Nevertheless, the company shall undertake / revise the HAZOP document during detailed engineering for Line 2.

A coarse qualitative risk assessment (QRA), incorporating Line 2, is being carried out and is expected to be completed once the detailed engineering design is completed, likely the end of July 2018. Once the detailed engineering is concluded, the company will conduct a refined qualitative risk assessment (QRA) to ascertain that final design will not pose negative risks to communities or environment as indicated in Action No. 3 of the ESAP. As part of the assessment, the company shall assess the likelihood and risks of hurricanes, tornados, cyclones and earthquakes in the study area to demonstrate the soundness of the area and rule out climate change impacts.                                        

Human Resources Policy and Procedures

IEFCL has a Human Resources & Industrial Relations (HR & IR) department responsible for the overall management of human resources. The HR manager reports directly to the CEO of IEFCL. The Company has a HR policy and procedures and an Employee Handbook that sets out the terms and conditions at IEFCL and commits to meeting national labor law requirements. There is also a Code of Conduct that sets out in more detail, specific policies and requirements, including the Human Resources Policy and commitments and requirements around processes and behaviors including discrimination, harassment and inappropriate physical conduct. All direct employees receive a copy of the Employee Handbook and the Code of Conduct, and a signed letter of employment when they join the company. The employee handbook is not applicable to contractors, who are subject to their direct employers’ terms and conditions.

Workers are grouped into three types: Management, Senior Staff and Junior Staff (Junior Staff includes Artisan Grade). All employees are paid above the minimum wage as stipulated in the National Minimum Wages (Amended) Act, 2011. IEFCL regularly benchmarks the salaries and allowances with Fertilizer Industry in Port Harcourt as well as NPK Blending plants in Nigeria. According to these benchmarking studies, salaries and allowances in IEFCL are at par with the prevailing salaries and allowances in the fertilizer industry. In addition, the company has implemented revisions in salaries and allowances.   The company also provides free canteen facilities and transport for all employees. The company will continue to engage with employees on these issues (see Action No. 5)

IEFCL employs expatriates and Nigerians to manage the operations and maintenance of the plant. All expatriates have core domain experience and expertise, whereas most of the Nigerian employees are recent graduates. In order to meet its operational needs, IEFCL is required to attract experienced personnel with significant specialized experience in the fertilizer industry and expertise in specific technologies. Given the limited fertilizer industry in Nigeria, IEFCL therefore needs to attract this expertise from outside of Nigeria. The requirement for these expats to be based in a foreign country (with a high perception of security risk), the short-term nature of their contracts and the fact that they are required to train the Nigerian employees means that more attractive packages are required.

The existing policies, procedures and approaches to employment as described above will be applied to the approx. 200 employees to be hired for Line II during operation, with amendments/ references as appropriate based on the new Collective Bargaining Agreement (CBA), described below, once it is in place.

Worker Conditions and Terms of Employment

For Line 1, IEFCL currently employs 218 workers, 168 (77%) of whom are from the Niger Delta area and of these, 38 (17%) are ‘Indigenes’ of the 6 host communities. IEFCL has 2 women direct workers and 23 in shared services.  In addition to the directly employed staff, there are about 350 contracted workers who provide services such as catering, cleaning, security, amongst others. This consists of 33 female staff.  The rather low number of women in the workforce can be attributed to the limited availability of skilled females in technical functions in Port Harcourt. IEFCL has instituted a scholarship program for undergraduate students where seats are reserved for women candidates to encourage female recruitment and their career development.  IEFCL has also committed to target females in the graduate training program during the next recruitment drive. IEFCL will develop a Local Hiring and Development Plan for the operation phase including measures to i) to encourage female recruits to the company (See Action 7 of the ESAP) and prepare a development plan for employees.

Once operational, Line II will require approximately 200 employees, of which about 50 will be specifically skilled expatriates. The manpower required during the commissioning phase is estimated at approximately 120.

In March 2018 IFC commissioned an independent labor assessment of the terms and working conditions at the company. The results of the assessment determined that IEFCL operates in compliance with national labor law and in the most part, with the requirements of PS2. The assessment also provided recommendations in relation to ongoing worker communications and engagement such that this feeds into an improved long-term worker-management relationship as outlined in Actions No. 5 – 12 of the ESAP. 

Worker’s Organizations and Collective Bargaining

The company respects the principle of freedom of association and collective bargaining which is enshrined under Section VII of Employee Handbook. The company is also committed to recognizing Unions / Associations in accordance with the Trade Unions Act, and implements requirements in this regard.

this is not referenced in the HR Policy or Code of Conduct. The company will include provisions for workers right of association and CBA in the HR Policy and procedures (see Action 4 of the ESAP).

During the construction of Line 1, the workers were unionized in accordance with the relevant industry trade lines, and the EPC contractor had a successful CBA with this union. During construction of Line II, the same arrangements are expected to be in place to represent the workers and for negotiation of a new CBA with the contractor. This will be in effect for the duration of the construction contract.

A CBA for IECL employees is not yet in place due to a dispute between two Unions over the right of unionization of workers at IEFCL. This dispute has been referred to the National Industrial Court and the Federal Ministry of Labor for determination of the rightful Union for worker representation. The Federal Ministry of Labor and Employment, together with representatives of the contending unions, completed an inspection of economic activities of IEFCL for such determination in line with the Jurisdictional scope defined under the Trade Unions Act of Nigeria. The outcome is still pending. At the same time, the hearing at the National Industrial Court was completed on March 12th, 2018, and as per the rule of court proceedings, judgment is expected within 3 months.

Within the context of this dispute, in July 2017 IEFCL workers decided to strike due to grievances associated with their compensation packages. When this came to the notice of IEFCL management, the workers were invited for a meeting to discuss the demands but due to the unionization dispute, this could not be organized. Before the discussion of these demand, a work stoppage incident occurred which resulted in forced shutdown of the plant. After a prolonged shutdown and occupation of the urea bagging, the police and the army contingent based in the industrial compound intervened to clear the premises. The matter was referred to Rivers State Government who advised all parties to return to work and maintain peace. Thereafter, employees returned to work and normal operations resumed.

After this incident, IEFCL implemented an improvement in salaries and benefits in addition to annual increments, with effect from August 1st, 2017. In addition, HR initiated an engagement program with the workers to better learn about workers grievance and the underlying reasons for the protest.  As part of its employee engagement, the company has addressed, logged and resolved many of the grievances, which included issues related to training and probation periods and extensions, remuneration, working hours, welfare conditions, infrastructure, amongst others which have been well received by the workers.

For those issues where a negotiated agreement was required with a representative body, the company explained to workers about their need to wait until a union is legalized or workers are organized to negotiate on behalf of their colleagues. According to workers consulted by IFC, they accepted that this was the reality but they expressed concern over the prolonged union stalemate.

Currently, the Line 1 operation workers have begun organizing themselves into a representative body for which IEFCL anticipates and looks forward to having a productive dialogue, further addressing pending grievances, and agreeing to a CBA as soon as possible.  In the meantime, the IEFCL Senior Staff have since formalized a unionization agreement with the Chemical and Non-Metallics Union, CANMPSSAN, with a view to starting the process of a CBA with IEFCL management. 

Non-Discrimination and Equal Opportunity

IEFCL commits to a policy of mutual respect and non-discrimination as contained in their Code of Conduct and Human Resources policy.  The minimum age for employment in Nigeria is 18 years, and the Company complies with national law in this respect. The contracted personnel will also be required to be older than 18 years. Furthermore, in compliance with the local requirements as well as IFC PS 2 there is no forced labor in either its own or contracted operations.  IEFCL will conduct periodic monitoring to ensure contractors compliance with these aspects.

As per the Memorandum of Understanding (MoU) with the host communities, (effective for 3 years from April 2016 to March 2019), IEFCL was required to employ a certain percentage of staff from the host communities (specified as ‘indigenes’), including: not less than 10% of management staff; 20% of senior staff and 60% of Junior non-technical staff.  To ensure qualified personnel, IEFCL recruits fresh graduates/diploma holders from local universities and technical institutes and trains them (12 to 18 months) prior to fully absorbing them into the workforce.  IEFCL selects these candidates based on their performance in their learning institutions. As currently the presence of female employees in IEFCL is very low, IEFCL will establish a program to introduce proactive measures to encourage female employees in the workforce as well as review its HR policies and procedures to ensure gender neutral conditions. Resulting actions will be included in a local hiring management plan that formalizes the commitments as made in the MoU and ensures non-discrimination in recruitment, hiring and career path development while actively encouraging female recruits to join the organization for the construction phase (See Action No. 6 of the ESAP) as well as the operation phase (See Action No. 7 of the ESAP.)

Grievance Mechanism

As part of Line I, IEFCL developed a workers’ grievance mechanism as part of the Code of Conduct. The workers have used this and have periodically raised grievances. In response to the July 2017 protest, the company enhanced the mechanism by appointing the HR team and respective HODs to proactively consult with aggrieved workers and report the findings to management, with targets for resolution and feedback to workers. IEFCL management has also recently placed complaint / suggestion boxes in a strategic location for workers to anonymously provide suggestions and grievances to management at any time. This has been announced to workers and they have been invited to submit suggestions and grievances at their will.  The company will formalize, and enhance as needed, this grievance mechanism by way of a documented procedure to ensure that it meets the requirements of PS2, such as allowing for confidentiality in the process, to ensure that roles and responsibilities are assigned to specific grievances and that there are target timelines attached to grievances, as appropriate (See Action No. 8 of the ESAP.)  This mechanism will also have the necessary resources to address sexual harassment complaints.  

Management of Contractors

For Line 2, IEFCL will use the same two companies, with demonstrated international experience in the design and construction of similar projects, used for the construction of Line 1. Whereas for Line 1, the contract structure had joint & several responsibilities between the EP & C contractors, for Line 2, the project will have the same two companies but one as EP contractor and the second one as construction contractor. 

The workforce during construction of Line 2 will reach a peak of around 4,500 personnel, who will be hired through Construction contractor. The company is committed to source most of construction workers from the surrounding areas as per the targets established in the MoU with the Host Communities (see description of MoU under PS4). During the construction of Line 1, IEFCL locally sourced 93% low-skilled workers; 33% semi-skilled workers and 26% skilled workers, which were higher than the targets set in the MoU.  As per the MoU, IEFCL allocates a certain number of positions to each host community as well as to the representative youth groups to ensure sourcing from each of the communities. Each of the communities then puts forward potential CVs (more than the allocated number) and the construction contractor/ IEFCL HR (for construction and operation respectively) selects the most appropriately skilled candidates from each group. Employment during construction will be the responsibility of the construction contractors.

As specified earlier, IEFCL will require EP&C contractors to develop E&S plans and provide adequate organizational structure comprised of qualified labor, EHS, and community engagement professionals on-site throughout the construction phase; as well as develop a Demobilization Plan (see Action No. 9.).  In addition, they will be required to meet national labor legislation, IEFCL’s Human Resources Policies and Procedures, the conditions of the MoU with Host Communities and the relevant requirements of IFC Performance Standard 2. IEFCL will include these provisions in their contracts and will monitor the implementation of these requirements on an ongoing basis.

As described above, terms and conditions negotiated through the representative unions and associations and all other labor requirements will be included in the construction contractors’ contractual clauses, which will include among other aspects, the need for clarity around the end of service benefits due at the end of contract terms.  IEFCL will monitor the performance of the EP&C contractors to ensure that labor and E&S conditions follow the contractual requirements and the Performance Standards (see Action No. 10 of the ESAP.). Monitoring will include regular audits, review of the EP&C contractors’ internal monitoring reports and documentation as well as review of grievances logged by the contractors and subcontractors’ employees.

Workers Accommodation

Currently, accommodation for the expatriate staff at IEFCL Line I is provided in apartment blocks on site premises, while the local staff reside in the surrounding areas and are provided with housing allowances (increased by an average of 46% between 2016 and 2017). The same arrangements are anticipated for the operation phase of Line II, with further accommodations being built on site to accommodate the additional expatriate staff. 

During construction of Line II, workers will be recruited from the immediate surrounding areas and Port Harcourt. These employees already reside in the areas and the majority were employed for Line I construction.  The construction contractor will pay housing allowances for them to reside within the communities. According to the ESIA, the contractor may also construct temporary accommodation for workers should the need arise.  As such, IEFCL, in close coordination with the construction contractor, will develop and implement the construction phase worker’s accommodation management plan in accordance to IFC PS2 requirements (see Action No. 11 of the ESAP) and monitor the implementation of this plan to ensure that potential impacts are mitigated.

Occupational Health and Safety (H&S)

IEFCL’s design philosophy is to provide sufficient process safeguards to protect personnel, equipment and the surrounding communities. These include, but are not limited to, identifying potential SIFs (Safety Instrumented Functions) that will be required to function at SIL (Safety Integrity Level) for hazard mitigation, assigning SIL for designated SIFs based on risk analysis, SIL verification, elevated flare, installation of emergency isolation valves as per design codes, de-pressurization facilities, hazardous emission detectors,  protective instrumentation and controls with sufficient redundancy, emergency shutdown instrumentation, emergency alarms and installation of fire protection systems as per design codes. The plant is being designed following international safety specifications (i.e., layout, spacing, storage tanks placement, etc. as per best international practices.)

As currently done for Line 1, the key H&S activities to be conducted for Line 2, include (a) a comprehensive safety audit of all its valves, flanges, traps, pumps, etc., (b) job safety analysis, (c) regular safety trainings and (d) emergency drills, among others. IEFCL anticipates having all H&S programs and activities in place prior to commencement of construction and operation phases. In addition, IEFCL will provide and strongly encourage the use of PPEs and control and reduce the exposure of the employees to harmful vapors such as CO, VOC, dust, etc.  It will ensure that all safety precautions are taken in the storage tanks areas. For the operation phase of Line 2, the company will develop the H&S procedures as indicated in Action No. 12 of the ESAP.  Even though, the company has begun identifying general H&S impacts in the workplace for the operation phase, it will review the job safety analysis already in place for Line 1 to confirm that the measures proposed will ensure compliance with workplace conditions for Line 2.

IEFCL has an on-site medical centre equipped to deal with any medical emergency.  The centre has three resident doctors, nurses and paramedics. It also has two ambulances. If necessary, medical cases may be transferred to government or private hospitals in Port Harcourt.  Prior to being appointed, all candidates are subject to a full medical examination and undergo annual medical examinations.  In addition, there are specific health surveillance programs focused on workers involved in tasks such as radiation.  IEFCL conducts monthly noise and radiation exposure surveys at predefined points through the site, and of volatile organic compounds.  IEFCL also has an alcohol and drugs policy and provides voluntary testing for HIV/AIDS and free anti-retroviral to workers and contractors.

The design of the project is based on established state-of-art and worldwide applied technologies whose performances are both predictable and well proven in operation, so that no significant variations are expected to be found between predicted and actual performance in the field. The use of state of the art technology will also help the project making optimal use of energy and water.  In addition, the project has been designed to comply with the most stringent of Nigerian Standards and applicable WBG EHS guidelines.  

Resource Efficiency Energy and Material Efficiency Projects

Natural gas is the primary raw material to produce ammonia. The carbon dioxide generated during ammonia production will be used to produce urea along with ammonia. The project will use associated gas from the oil production fields, which otherwise would be flared.  According to the Nigerian National Petroleum Company (NNPC), the average daily associated gas production is of approximately 8.1 Billion Cubic Feet (BCF.) The anticipated daily natural gas consumption rate of Line 2 will be 89,600,000 cubic feet (about 0.09 BCF.)

The technology selected is proven with respect to energy consumption and lowest among the technologies available in the world for ammonia and urea production. The specific energy consumption for urea production in Line 2 will be 0.3 GJ/ton urea as it is currently for Line 1. The benchmark for urea production is between 0.4-0.45 GJ/ton urea.

Furthermore,  IEFCL will adopt  energy conservation measures for process heating, cooling and compressed air system; such as, adequate insulation to reduce heat losses through furnace/heaters; recover heat from hot process or exhaust streams to reduce system loads; use low thermal mass insulation to reduce energy required to heat the system structure to operating temperature, in intermittently-heated systems; schedule work flow to limit the need for process reheating between stages; operate furnaces/heaters at slight positive pressure, and maintain air seals to reduce air in-leakage into the heated system;  reduce radiant heat losses by sealing structural openings; regularly verify correct operation of steam traps in steam systems and ensure that traps are not by-passed; in steam systems, return condensate to the boiler house for re-use, since condensate is expensive boiler-quality water and valuable beyond its heat content alone, minimize the number of boilers or heaters used to meet loads; etc.

GHG Emissions

Greenhouse gas (GHG) contributions from the facility will be routinely calculated and recorded during operations.  Based on design information currently available and considering all energy efficiency measures identified, the annual Scope 1 GHG emissions from all its operation units combined, are estimated to be approximately 435,000 ton/yr carbon dioxide equivalent.  Once the detailed engineering is completed, the company will recalculate the GHG emissions to truly reflect the values based on expected actual performance data. The commitment of the Company to install state of the art technology will ensure high energy efficiency and this will optimize conditions in relation to CO2 emissions. At detailed engineering design stage IEFCL will confirm these measures and seek additional energy optimization measures as appropriate.

Air Emissions and Ambient Air Quality

The power will be provided by the existing captive power plant in the Indorama Eleme Petrochemicals Limited (IEPL) complex which consists of five gas turbine generators.  Each of the turbines can generate approximately 33 MW. While the existing power consumption is about 82 MW, the new project is expected to consume an additional 30 MW. Thus, the installed capacity is more than sufficient to meet the power demand of Line 2. In addition, IEPL is equipped with four emergency diesel generators to supply emergency power in the event of outages. IEFCL will also install a new steam generation system consisting of a dedicated auxiliary natural gas boiler, and waste heat boilers to recover the process heat generated during the reforming as well as during the synthesis of ammonia. The expected net steam production will be low at about 50 MT/hr during normal operation due to the efficient process employed to recover heat energy. The auxiliary boiler will supply steam during plant start-up as well as for steam demands of the urea process.

The diesel consumption (only for construction equipment) will be approximately 7,000 kl, with an average monthly consumption around 280 kl.  The source of power for the construction phase will be from existing facilities.

Expected air emissions from the site preparation and construction phases include mainly vehicles and machinery, and dust, which will be controlled as per the mitigation measures presented in the E&S management plan for the construction phase.

The ammonia plant is designed as per the state of art Purifier technology developed by Kellogg Brown & Roots with minimum emissions and discharges and well-defined fire and gas detection systems. All relief valves and pressure control devices are designed for worst cases and connected to dedicated flare. The plant is designed with minimum fugitive emissions having seamless piping and special material selection wherever required.

Typical releases from the ammonia plant can be ammonia, carbon dioxide, hydrogen and natural gas; from the urea plant, can be ammonia, CO2, and dust.

The ammonia plant is designed to minimize emission and effluents during normal and startup operations. In the primary reformer, purge gas and flash gas are burned with natural gas to supply the energy for the reforming reaction. The purge and flash gas contain ammonia which is a source of nitrogen oxides emissions. To reduce these releases through the primary reformer stack, the design will ensure that (a) the ammonia in the purge gas and the flash gas is completely recovered in the ammonia recovery unit and the treated gas is used as fuel gas, and (b) the gas burners selected be low NOx burners.

The package boiler will use natural gas as fuel. The NOx emissions will be reduced by selecting low NOx burners. The process condensate which will contain ammonia, carbon dioxide, and methanol will be steam stripped to reuse the condensate as boiler feed water and thus eliminating emissions from the condensate stripper. The flare stack and process vents can also be source of emissions during abnormal conditions. The flare stack will be designed for complete burning of hydrocarbons even at the highest discharges in upset conditions.  Even though, stack and vent system emissions will not be continuous they are required to comply with local as well as IFC requirements.

Main emissions from the urea plant are ammonia and urea dust. These emissions are collected and recycled back to the process, thus, reducing emissions of pollutants to the atmosphere and drainages. Process condensate contains urea, ammonia, and carbon dioxide. The process condensate is first treated in the urea hydrolyzer to hydrolyze urea into ammonia and carbon dioxide, which along with the ammonia and carbon dioxide of the process condensate, are steam stripped. The overhead stripped gaseous mixture (ammonia, carbon dioxide and water vapor) is recycled back to the main process stream. The treated process condensate is recycled as boiler feed water after treatment in the polishing units.  Therefore, there will be no emissions from the condensate hydrolyzer and the stripper.

Urea dust and ammonia contained in the exhaust air from the granulator can be a source of air pollution in the urea plant. The granulation unit has a dust recovery system to ensure an exhaust of less than 50 mg/Nm3.

The air emissions from the Line 1 comply with Nigerian local environmental permit conditions as well as WBG EHS Guidelines for Nitrogenous Fertilizers Table 1.  Similarly, for Line 2 the emissions limits will comply with the WBG EHS Guidelines for Nitrogen Fertilizers Table 1.

There is potential of fugitive emissions from flanges, pumps, compressors, sealed or tightened equipment, storage tanks, open-ended (not blanketed) lines, pressure-relief valves, vents, flares, blow-down systems and spills. IEFCL will minimize fugitive emissions from valves, compressors and pumps by implementing preventive maintenance and leak detection programs. The fugitive emissions from sampling connections will be controlled by returning the purged materials to the process, or by sending it to a control device. 

Water Usage and Wastewater Treatment

Currently, the water for domestic and industrial operations is supplied by six on-site boreholes with consumption estimated at 1,000 m3/hour.  To satisfy the water needs of Line 2, which will be approximately 750 m3/hr during operation; IEFCL will dig three new water boreholes.  The ESIA report confirmed the availability of adequate water.

As part of the first Line 1, IEFCL conducted a water impact assessment to determine potential impacts from increasing its total water needs. The water assessment indicated that the total groundwater recharge rate through rains alone in the aquifer, which is the main source of water for the industrial complex, is one million cubic meters per square kilometer. The consumption of water for IEFCLs Line 1 is about 6.91 million m3/year. A similar requirement is expected for Train 2 as well totaling the water requirement to 13.82 million m3/year. Out of this consumption, about 3,6 million m3/year (20%) of the water used will be returned to the aquifer as treated effluent. As this water is stored in the holding ponds, it gets mostly absorbed in to the ground as recharge.  In addition, IEFCL’s land and the adjacent vacant NNPC land totals approximately 9.68 km2 and as per a Rivers State Study conducted in 2013, the aquifer recharge in this area through rainfall alone amounts to 9.68 million m3/year.  Thus, the total recharge because the rainfall and the treated water effluent amounts to approximately 13.2 million m3/year amounting to about 95% of the water consumption.

Furthermore, the plant area is located over the perennially recharging aquifer with a recharge between 9,000 to 32,000 million m3/year.  Thus, it can be concluded that the water draw by the project will not affect the water table or the aquifers. As part of the project and as required by the local environmental authorities, IEFCL will conduct further hydrogeological assessment along with the Rivers State Water Services Regulatory Commission before the commencement of drilling the additional bore wells (3 in total for the project) for the Line 2 project to reconfirm there will not be negative impacts on the aquifer.  If the results demonstrate the contrary, the company will take the needed actions to mitigate potential impacts

IEFCL has a wastewater treatment system for the entire complex.  The process includes primary treatment with chemical dosing and flocculation and secondary biological treatment using aerators and a clarifier.  The quantity of waste water generated by Line 1 is approximately 25 m3 per hour including process water and sewerage. The treated water is mixed with storm water prior to discharge to the Okulu River. The waste water quality is monitored daily for pH, biological oxygen demand, chemical oxygen and total suspended solids and the results for these parameters are well within national limits and those defined in the WBG EHS Guidelines for Nitrogenous Fertilizers, Table 2.

Related to the ammonia plant, it includes contaminated de-oiled water and waste water from the chemical drain around the boiler. From the urea plant, it includes de-oiled water and water from the chemical drains and floor washings generated on a periodic basis. Wastewater such as condensate is reused and floor washings from the urea granulation area is recovered.  Wastewater not reused or recovered in both plants is discharged via the wastewater treatment plant to the Okulu stream.  As for Line 1, similarly, IEFCL will handle the treated wastewaters for Line 2 in the existing wastewater treatment plant.  The total process effluent generated by Line 2 will only be 20 -25 m3/hr; however, additional 100 m3/hr from the cooling tower blow down and the demineralization plant will be also sent directly to the wastewater treatment plant. The sanitary waste, which will be about 4-6 m3/hr, will be treated in the existing facilities as they have spare capacity.

The water consumption during construction will be approximately 230,000 m3 and it will be obtained from the existing facilities. Drinking water needs will be satisfied with commercial potable water brought to the site. As part of the project, it will install three new borehole pumps, a filter water package, and a demineralization plant. 

Even though IEFCL has not yet concluded the engineering details of the water balance for the project to establish how much will be reused and will be discharged, it has estimated that it will have a maximum consumption of 750 m3/hr, it will reuse between 80% and 85%. Once detailed engineering is completed, IEFCL will reevaluate this estimate to confirm that the project water use benchmarks among the best equivalent operations in the world.  

The water body is a fresh water body with pH slightly acidic at the upstream which is typical of the Niger delta surface water bodies. The monitoring conducted indicated that the Oluka stream has good carrying capacity to accommodate the treated releases from the project. 

Noise Management

As part of this project, IEFCL will include measures (noise barrier/insulation, periodic maintenance plans) to limit noise disturbance outside the site boundary and install controls to avoid the out-compliance levels. IEFCL will establish a noise monitoring program at the facility boundaries to ascertain the project’s compliance with Nigerian standards and WBG guidelines.  Noise monitoring will also be routinely carried out during the facility construction program and measures will be taken to minimize noise disturbance where necessary.

Waste Management

As part of its current ESMS, the company has procedures to ensure segregation, recycling and reduction of wastes.  IEFCL has compiled a Waste Management Plan (WMP) for the existing operations and submits a waste disposal inventory to the authorities on a quarterly basis.

The main solid wastes include domestic waste, metal and wood scrap, empty drums, sludge from the waste water treatment works, waste oils, oily sludge, alumina dust, ash from incinerators and medical waste.  Domestic waste is disposed of at a Government approved waste site in Port Harcourt; waste oils, scrap metal and wood along with the used oils and empty drums are sold, oily sludge is incinerated along with the medical waste and sludge, and ash is stored in a plastic underground tank. Organic sludge is incinerated in the existing on-site incinerators following existing Standard Operating Procedures and the ash is analyzed as TCLP (Toxicity characteristics leaching procedure). Any spent catalyst containing zinc sulphide is handled by competent person as per the guidelines of the Material Safety Data Sheets (MSDSs) and established ESMSs procedures. The existing WMP will be extended to incorporate the waste generated from Line 2.

As per the E&S Management Plan for the construction phase, the waste generated during construction will be segregated and stored in roll-off drums and containers at waste yards managed by the construction contractor.  Domestic solid waste will be stored in waste skips and disposed of in a local landfill. The hazardous wastes generated at construction (i.e., used lubricating oil, batteries, empty drums of paint/solvent/additives, floor sweepings from material storage yard, oily sludge including that from the incinerator, etc.) will be stored in drums and containers at a waste yard to be established by the construction contractor, and then transferred to licensed waste treatment contractors. 

Hazardous Materials

IEFCL will design the project ensuring proper handling of hazardous materials. The waste management practice shall be an extended arm of current one at Line1. Waste segregation at source, Reduce, Recover and Recycle philosophy shall be adopted. Waste disposal shall be according to manifest in line with the Federal Environmental norms and IFC requirements. As part of the project, IEFCL will develop a Hazardous Material Management Program for Line 2 prior to beginning the construction (See Action No. 13 of the ESAP.)

Pesticide Use and Management

The use of pesticides in relatively low and it is used to manage pests and plagues in the operations. Management of pesticides and agrochemicals follows best practice procedures

Community Health and Safety

The health and safety of the communities near its operations is of paramount importance to the company.  Major risks to the surrounding communities from the facility will be further assessed by the QRA as described earlier.  The risk assessment, at detailed engineering design stage, will consider worst-case scenarios such as explosion, fire and leaks based on the facility layout and technology to be used and as needed, it will implement the needed measures. 

Similarly, as part of the emergency response procedures, the emergency response plan to be developed for each of the project phases will include the communication to and training of the communities related to response to emergencies and will involve the local authorities in the development of community preparedness planning in the event of a major accident. 

IEFCL’s Line 1 is equipped with one 15,000 metric tons storage tank to store liquid ammonia. This tank will also receive liquid ammonia from Line2.  This existing ammonia storage tank is double wall – double containment type, designed and constructed so that both the primary and secondary self-supporting containers are capable of independently containing the stored liquid. Both inner & outer tank walls and bottoms are made of low temperature materials and designed for product deriving loads. The boil-off ammonia vapor will be routed to the refrigeration compressor of the ammonia plant to recycle back into the main ammonia stream. In shut down condition of the ammonia plant, the boil-off ammonia vapor will be compressed and recycle back to the storage tank. The ammonia storage tank is provided with pressure relief valves and equipped with vacuum relief valves adequate to manage any emergency. A dedicated flare stack adequate for complete burning of ammonia vapors, released during any emergency, is installed. The continuous pilot flame at flare tip maintained to ensure complete burning of ammonia vapors assuring that unburnt ammonia will not be released to the atmosphere. No ammonia storage leak has happened in Line 1 so far.

Transportation

Traffic volumes to transport workers, equipment and materials to the construction site will be considerable. Vehicular movement during this phase will include trucks, buses, minibuses and cars. During construction period, it’s expected an additional daily traffic of about 75 trucks/containers for the transport of equipment/ materials and 50 buses for the movement of staff/contractors/visitors. During operation, the traffic will be slightly reduced.

Separate access and routes for movement of employees and materials will be established. To keep controlled traffic around the Complex, all logistics elements of the Line 2 will use the existing logistics park (created at a convenient distance away from the complex along the East West expressway) before being directed to the project site. There will be a dedicated parking area of trucks in front of main gate inside complex premises. Project–related vehicles will be modern and they will be continuously monitored to ensure their quality to minimize noise and vehicle emissions.

IEFCL along with the construction contractor will prepare a Traffic and Transportation Safety Management Plan for the construction phase which will establish the traffic volumes and its impact in relation to the existing situation, the possible transportation routes and the traffic management measures to be employed that will reduce impacts; these include infrastructure upgrades, optimum route selection and vehicle management as well as the staggering of working hours and optimum site access provisions.  (See Action No. 14 of the ESAP.) In addition, IEFCL will upgrade the existing Traffic and Transportation Management Plan developed for Line 1 to address potential impacts resulting from the operation of Line 2 (See Action No. 15 of the ESAP.)

Influx 

Eleme Local Government environment has a large pool of skilled, semi-skilled and un-skilled manpower. During line 1 construction, approximately 48% - 50% of total workforce came from immediate local environment. Approximately 40% of the IEFCL workforce comes from Rivers State and other Niger Delta Regions. Given the Company executed four projects in last 4 years namely Line 1, Pipeline, Jetty and FCU, it is expected that most of the construction manpower would now come from immediate environment. Ethnically and culturally these regions have many commonalities. Eleme Local Government and Port Harcourt historically has been able to accommodate this magnitude of external workforce. The current population of Port Harcourt is c 1.865 million.

The existing draft Influx Management Plan developed as part of the ESIA seeks to minimize negative impacts due to influx. This plan is in draft and will be revised to be project specific and appropriate to the highly industrialized context. 

Exposure to diseases

The arrival of many external workers to be hired during the construction phase will increase the risk of transmission of communicable diseases including sexually transmitted diseases in the host communities.  To monitor potential health impact on and as part of the construction contractors’ practices, all workmen shall be inducted after medical checkup which will provide the health baseline. As part of this effort, IEFCL will jointly work with the construction contractor to implement a communicable diseases awareness campaign in coordination with relevant stakeholders such as the women’s union, youth union, health workers and representatives from affected communities. In addition, to prevent the risk if spreading diseases triggered by vectors, the retention lagoon to be built as part of the WWTP will be designed and built (i.e., aeration) to prevent it becoming vectors breeding ground. 

As part of Influx Management Plan, regular pest control program shall be done at site to safeguard workmen from communicable diseases. Further, IEFCL will support projects for the provision of potable water to host communities as support to authorities.

Security Personnel

Security for Line II will be provided as part of the security arrangements for the Indorama complex. This is provided by a multi-layered security detail, comprising of both internal core security management staff and contracted unarmed security guards. In addition, as the Complex is considered a National asset, public security forces have been deployed by the Nigerian Government to safeguard the complex. These include the Nigerian Police, the Nigerian Army and Mobile Police (MOPOL). The core staff and contracted personnel report internally to the head of security, while the police, army and MOPOL report to their headquarters while coordinating with the Company’s security department.

According to the Company’s Security Management Plan, their security approach is based on the concept of respect for people and honoring human rights, and is guided by the ‘Voluntary Principles on Security and Human Rights’.  Security personnel (direct and contracted) are unarmed and not permitted to use force on unarmed persons, and contracted security personnel are certified for good conduct prior to being deployed to site. The public forces, while present at strategic places (no public security forces are deployed in the operational area) on site and for the convoy of personnel to the airport, only interact with the security personnel and other staff if there is a security incident that requires their involvement. Currently, the company’s security manager coordinates with public forces deployed to the site and has general rules of engagement with them. Three such examples took place in 2017 during an employee protest in July (described under PS2), and the two community protests in January and December as described under stakeholder engagement section. During these protests, the public forces stepped in to control the situation.

To ensure the company’s commitment to the Voluntary Principles on Security and Human Rights are implemented, the Company will conduct a Security Assessment to revise and update its Security Management Plan and processes to i) establish agreements/rules of engagement related to public forces onsite to the extent permissible, and ii) insert commitments to the Voluntary Principles operation phases (See Action No. 16 of the ESAP.) The Security Management Plan will be linked to the Security Risk Assessment conducted for the project and will respond to identified risks, providing direction, organization, integration, and continuity to the company’s security and asset-protection program. As part of the plan, IEFCL will conduct background checks, training of private guards, rules of engagement as well as monitoring and reporting plans. The implementation of these commitments will be monitored by the Company as part of their existing security audit plan and investigated by the Company Disciplinary Committee (CDC) where necessary.  Effective use of the security audits will ensure that security is compliant with corporate strategy, standards, legislation, and regulations.                                           

The company has clearly defined the areas of the project’s direct and indirect influence. The directly affected communities include 6 communities (‘host communities’) within a 5-km radius of the project site that may experience impacts such as those related to noise, dust, smell, and increased traffic and operational risks (ammonia leakage). Outside of this radius, those areas indirectly affected will primarily experience impacts due to increased employment options as well as influx of workforce and possibly due to transportation. Since 2007, the company has had a Memorandum of Understanding (MoU) with the host communities which to a large extent governs the terms and conditions of the relationship between IEFCL and the host communities. Feedback from the communities during consultations has been generally very positive. Stakeholders consulted are of the view that, except for a few areas of potential improvement, Indorama is highly regarded and appreciated and performs far better than any other company in the area regarding community relations and corporate social responsibility.

Responsibility for stakeholder engagement at IEFCL falls within the HR and Community Relations Departments. The Head of Community Relations and Development reports directly to the CEO and also to Indorama Africa Head, and his team comprises of four community relations officers and one assistant community relations officer.

The main conduit for community relations is the Project Advisory Committee (PAC), as provided in the MoU and set up by the Rivers State Government to represent the interests of each of the six host communities.  The PAC comprises of 3 representatives from each host community and their paramount chiefs, a representative of the King of Eleme region, and the Rivers State Government. The Chairman of the PAC is the Commissioner for Chieftaincy and Community Affairs.  It is a voluntary service and PAC members are not paid (though receive a sitting allowance for attending quarterly meetings). The PAC meets with the Company on a quarterly basis to discuss community investments as well as any grievances that have been raised in the communities, with the ‘local PAC’ (this is a less formal gathering whereby the PAC representatives come together to discuss issues arising without the need for government representatives) if any specific issues arise. There are currently no women represented on the PAC, although there have been female representatives on previous PACs. According to the PAC, this is not intentional, but community leaders have the discretion to elect the PAC members that they see fit to represent them.  As per IEFCL management this is a well-functioning representative body that has served its purpose very well for the last 11 years, although political interference in recent years has proved a challenge to the representativeness of the PAC. According to feedback from community members, information does not get sufficiently disseminated to the community members, as certain opportunities (e.g. regarding employment opportunities and scholarships) do not reach some of the groups – especially women. IEFCL has recently written to the Commissioner noting that there should be female representatives on the PAC. IEFCL will continue to encourage PAC to include female representatives, and will strive to include this as a requirement in the next MoU.  In addition, the company shall undertake dissemination of resolutions of PAC meeting, employment notification etc.,  through direct means such as posting of information on notice boards in community town halls.

As part of the Line II ESIA process, the ESIA project team held a series of stakeholder consultation sessions. A public forum and stakeholder interviews were held in the towns of Elelenwo on November 17th, 2017. The forum was attended by approximately 148 people from the host communities.  Stakeholders included representatives of the King of Eleme, local government, youth leaders, women’s leaders and officials of the FME, the Rivers State Ministry of the Environment and the police. The meeting minutes indicate that questions raised by stakeholders were adequately addressed by IEFCL.  Project information was disclosed through briefing leaflets that described the project and its potential effects, as well as further consultation activities that would be taking place such as upcoming disclosure activities. Concerns raised included traffic congestion, human health impacts, employment opportunities and benefits to women in the host communities, influx management, safety, spread of diseases, amongst others that were adequately considered in the ESIA. 

During 2017 (prior to the ESIA stakeholder consultation), two community protests were held outside the Indorama Eleme compound. The first (in January 2017) was in relation to Elano, the SPV set up for the acquisition of the host community’s 7.5% shares in Indorama Eleme Petrochemicals Ltd and the management of dividends on behalf of the communities.  This SPV is an entirely separate entity to the Company, run exclusively by the community. The second one involved youth who requested that the company’s Community Relations  Manager(CRM) be replaced. While communities clearly differentiate between Elano and the company, the lack of transparency in Elano’s activities has caused some antagonism in the communities. While changes to Elano need to be driven by the communities themselves, the company is working with the BPE and Rivers State Government on how the communities can be empowered to reform Elano for greater transparency.

As an outcome of the ESIA, the company updated its Stakeholder Engagement Plan to guide the ongoing engagement associated with the project and improved and augmented it to include, among others, a stakeholder identification and mapping process which includes all categories of stakeholders within the communities (such as women and youth), and a plan for ongoing engagement with each of these different categories of stakeholders. This plan will be finalized to include amendments such as: i) encouraging community members to nominate at least one woman representative into the PAC from each of the host communities ii) information dissemination to host communities through direct means such as notice boards in community halls, iii) enhace the scope of the female CRO currently working with the Port Communities to  specifically engagements with women of host communities  as part of the job description; and iv) setting up a formal mechanism for engagement with the port and pipeline l communities v) improving signage to clearly demarcate the pipeline right of way, among others (as specified in Action No. 17 of the ESAP.)

The company has a structured grievance mechanism process whereby grievances are provided directly to the company’s community relations officers; to the Community Development Committee (CDC – a group setup for the sustainable development of communities in each community in Nigeria) members, directly through the PAC, who then forward them to the company’s community relations officers. The community relations officers then channel these through to the appropriate company representatives. Feedback is swiftly provided through the same channel or directly to the aggrieved party, depending on the nature of the grievances. These can be written or verbal, depending on the nature of the situation. Feedback from the communities is that this system is accessible and effective.  The company - will formalize the grievance mechanism to ensure that grievances are received, tracked, and monitored effectively. IFC’s assessment of the existing stakeholder engagement mechanisms found that their engagement mechanisms are good and that overall, the PAC has functioned well over the years. However, engagement with youth and women needs to be improved. Furthermore, the company’s benefit mechanisms through its CSR program and as agreed in the MoU are good, and while the company is incorporating a micro-credit scheme for empowering women into the MoU, improvements can be made in general accessibility for women.

[IEFCL developed a guideline for Community / Stakeholder Management that outlines the EPC contractor and subcontractor’s responsibilities for those employed in the construction of the with regards to community engagement.  IEFCL will ensure proper implementation of the SEP as well as management and expansion of the community liaison team as needed throughout the construction, operation and decommission phase of the project. In addition, the Company is committed to updating the SEP for each phase of the project to identify, if present, additional stakeholders on local, national and international level. The community relations staff will continue meeting periodically with community members in the directly affected communities.  The community relations team will also meet with municipal heads and related government authorities

IEFCL will disclose this document in English language the following documents.
- Environmental and Social Review Summary (ESRS)
- Environmental and Social Action Plan (ESAP)
Shortly after publication in IFC’s website, the document will be available at the following locations for a period of 30 days.
Location: Rivers State
Address: Headquarters, Eleme Local Government Area, Eleme, Rivers State

Please contact the following for enquiries or concerns about the environmental and social impacts of this project:

Contact Person:   Mr. Kendirck Oluka
Company Name: Indorama Eleme Fertilizer & Chemicals Limited (IEFCL)
Address:              Indorama Complex, East-West Expressway, Eleme, P.M.B. 5151,
                            Port Harcourt, Rivers State, Nigeria
Email:                kendrick@indorama.com.ng
Phone:               +234 805 506 4248