The project will not require any new land but will be developed 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 and within a well-developed industrial complex. No Indigenous Peoples have been identified in the areas influenced by the project’s activities and there is no evidence of presence of any cultural heritage. As such, no impacts for this project are expected which must be managed in accordance with IFC PS 5 (Land Acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (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 and risks include the company’s capacity and systems to manage E&S performance during construction and operation; management of labor relations and working conditions for its employees including those employed through contractors; implementation of occupational health and industrial safety during construction and operation; adequate management of air pollution, hazardous materials, solid and hazardous wastes, wastewater; emergency preparedness; and stakeholder engagement.                                                   

Identification of Risks and Impacts

As the proposed project is focused on debottlenecking and energy efficiency to optimize the existing operations, it does not have any associated additional footprint, and the potential E&S can be addressed thorough mitigation measures, the company was not required by the local authorities to conduct ESIA studies. However, as a pre-requisite to obtain its operating license, the company had conducted and submitted an assessment of impacts and mitigations and developed a corresponding detailed environmental and social management plan (ESMP) aligned with the applicable local regulatory requirements, the IFC PSs and the WBG General and Sector-specific (EHS Petroleum based Polymers Manufacturing) Guidelines (disclosed together with this ESRS). The assessment addressed construction and operation impacts and included generation and management of hazardous wastes, definition of monitoring parameters and required acceptable concentrations, as well as occupational health and industrial safety, operational safety, and emergency response. It also identified the adequate air emissions controls and liquid effluents treatment to effectively operate in compliance with all applicable requirements.

In addition, for this proposed project, IEPL will develop the corresponding hazard and operability studies (HAZOP) and implement the resulting recommendations (See ESAP Action No. 1.) The comprehensive qualitative risk assessments (QRAs) conducted as part of the installation of Eleme Fertilizers I and Eleme Fertilizers II included the IEPL operations as these operations are within the same site and would have potential impact on the assessment of worst case scenarios for the fertilizers plants, revealed that IEPL’s associated operational worst-case scenario risk relates to fire (jet, pool, flash) at its farm tank and that as built would not pose any significant risk. The latest QRA, conducted in 2018, covering the entire petrochemical complex (IEPL+IEFCL) was reviewed and approved by IFC as part of the financing of the fertilizers plant.  As the proposed project is only looking to debottleneck existing operations and add equipment to provide reliability to the existing operations and there will not be addition of any new hazardous materials nor increase in tanks storage, and hence, no significant additional risk is foreseen due to the proposed project, warranting a fresh QRA for this proposed project.

From the various studies conducted for the previous projects within the same complex (i. e., IEFCL I, IEFCL II), it has been confirmed that the project area is not prone to natural disasters such as hurricanes, tornados, cyclones, earthquakes, etc. 

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.

Policy 

IEPL has an overarching E&S policy and principles that guide the management of the (E&S) issues across IEPL’s operations based on the IFC PSs. The policy commits to implement effective E&S management systems across all operations and services to provide safe and healthy working conditions for the prevention of work-related injuries and occupational diseases to the employees, contractors and stakeholders. It strives to reduce emissions to control pollution and eliminate environmental incidences as well as occupational health and safety hazards. It ensures strict compliance with applicable laws and regulations collaborating with the neighboring communities, industries and government agencies to safeguard the assets and health and safety of employees and stakeholders.

Management Programs   

IEPL has a documented operational integrated E&S management system (ESMS) including ISO 9001 :2015, ISO 14001 :2014, and OHSAS 18001 :2007 certifications. The company is currently transitioning from the OHSAS 18001 certification to ISO 45001-2018 certification. 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 will be extended and enhanced as needed to include aspects related to the operational phase of the proposed project.

IEPL already has implemented robust EHS procedures and protocols for its operations including detailed operational safety (i. e., HAZOP studies, cooling water quality control etc.); mechanical integrity (i. e., corrosion monitoring and prevention program, mechanical inspection and scheduled tests, extensive on line vibration data collection, etc.); management of change - MOC (procedures and as-built drawing updates, MOC approval mechanism with concurrence with relevant stakeholders), and simultaneous operations (SIMOP) procedures to ensure the safety of the operations. Associated to these procedures, IEPL has detailed corresponding KPIs to track the effectiveness of procedures implementation.  Furthermore, it also has a contractors’ safety management procedure, which addresses, among others training on safe work practices and emergency plan, toolbox talks and field audits for contractors’ works. IEPL will update the existing procedures as relevant to apply to the proposed project.

The engineering, procurement and construction (EP&C) contracts will require compliance with IEPL and IFC E&S requirements. Thus, the Construction contractors 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 including H&S induction training for all site personnel to identify hazards and carry out their work responsibilities safely, 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 its E&S performance, (See ESAP Action No. 2.)  The performance of the contractors vis-à-vis these requirements will be closely managed and monitored by IEPL.

Organizational Capacity and Competency 

IEPL 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. IEPL also contracts additional external consultants for activities such as environmental assessments, environmental audits and environmental monitoring as needed. Labor and social issues in IEPL are managed by Human Resources, Industrial Relations and Community Relations & Development Departments respectively.

Emergency Preparedness and Response

IEPL has developed a comprehensive Emergency Response Plan (ERP) which describes IEPL’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.

As part of this project, IEPL will update the existing ERP and 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 ESAP Action No. 3.)

In addition, IEPL is already an active participant of the already established Emergency Response Mutual Aid committee established in the area by the federal and Rivers State fire services, and nearby industries (i. e., Notore Chemicals, SPDC, Total.)

COVID-19 Response

Under COVID-19 restrictions, from March 2020, IEPL implemented various measures to manage the risk to their workforce. Specifically, the company is distributing and enforcing compulsory use of face masks while at premises, has established social distancing protocols for workers at the plant site; scans temperature of all persons coming into premises; undertakes daily decontamination of staff buses and supplies hand sanitizers; and contracts qualified companies to conduct periodic/rigorous disinfection at all premises.

Also as part of its COVID-19 prevention program, the company has conducted awareness training on hygiene at the workplace as well as at home and imposed a COVID-19 work schedule whereby critical operations and support services were grouped under “work from home” and “work from office.” Approximately 45% of employees were required to manage critical operations and services, while service departments such as marketing, finance, commercial and HR, as well as all employees with underlying medical conditions continued to work from home. Initially all employees at work are required to undertake a mandatory COVID-19 test every seven days to allow for early detection. Gradually frequency of COVID test is being revised and at present the frequency of COVID test is between 7 to 15 days. The company has established two molecular laboratories at site which are approved by Nigerian Federal and State authorities. Furthermore, the company established an isolation center at the operation for symptomatic employees, as well as a 24-hour support via a telemedicine and HR help desk. The COVID-19 infection prevention, control and response plan implement by IEPL is consistent with the provisions under PS2, PS4, and the Interim Advice for IFC Clients on Preventing and Managing Health Risks of COVID-19 in the Workplace.

As a result of the COVID-19 pandemic the company has not laid-off workers but has made temporary adjustments to its workforce by adapting to the national as well as respective local labor directives. The company has paid full salaries to the employees during the lockdown period. There have been no severe health impacts on the company’s workforce due to the pandemic.

Monitoring and Review

IEPL has a functional E&S monitoring plan for both the construction and operation phases. The plan includes all parameters and frequencies of measurement for ambient air quality, noise levels at the complex periphery and sensitive receptors, treated effluent quality at discharge and recipient water bodies, groundwater, stack emissions, workplace conditions, etc. IEPL has a well-equipped laboratory accredited by Federal Ministry of Environment (FMEnv) for in-house monitoring. As part of the project, IEPL will extend the monitoring plan to the proposed project units. 

IEPL is required to periodically report the results of its E&S performance to the local Nigerian environmental authorities. The same is managed by IEPL’s E&S team. Moreover, during construction and during the first year of operation of the project, an independent consultant will be appointed to review the IEPL operations project to ascertain compliance with the applicable E&S requirements including the ESAP.                              

Human Resources Policies and Procedures:

IEPL has a Human Resources (HR) & Industrial Relations (IR) department responsible for the overall management of all HR activities. The HR manager reports directly to the CEO of IEPL. The company has implemented various policies relating to employment and working conditions, including an HR Policy, Ethics Policy, Non-Discrimination Policy, Child Labor Prohibition Policy, Human Rights Policy and Independent Contractors Policy. Terms and conditions of employment, including alignment with national labor law requirements, are detailed in the Employee Handbook. The Employee Handbook details employment status and general principles, standard of conduct and work ethics, training and development, employee welfare, industrial and employee relations, salary administration, benefits and allowances, bonuses and awards, loans and leave. IEPL has well laid down procedures of grievance and discipline management.

In addition to the Employee Handbook the company has also implemented a Code of Conduct that details disciplinary action, conflict of interest, media statements, non-discrimination, harassment, alcohol and drug abuse, driving, environmental health and safety and data security. All direct employees receive a copy of the Employee Handbook and the Code of Conduct, as well as a signed letter of employment when they join the company. IEPL HR policies and procedures are aligned with IFC PS2 requirements.

Working Conditions and Terms of Employment

IEPL currently employs 499 workers, 389 (78%) of whom are from the Niger Delta area and of these, 121 (24 %) are ‘Indigenes’ of the 6 host communities. IEPL has 41 women direct workers.  In addition to the directly employed staff, there are about 602 contracted workers who provide services such as catering, cleaning, security, amongst others, of which, 74 are female staff.  IEPL has instituted a scholarship program for undergraduate students where seats are reserved for women candidates to encourage female recruitment and their career development.  IEPL has also committed to target females in the graduate training program during the next recruitment drive.

Workers are grouped into three types: Management, Senior Staff and Junior Staff. All employees are paid well above the minimum wage as stipulated in the National Minimum Wages (Amended) Act, 2011. IEPL regularly benchmarks the salaries and allowances According to these benchmarking studies, salaries and allowances in IEPL are higher than prevailing salaries and allowances in the Chemical & Nonmetallic industry.  In addition, employees own 2.5% equity in IEPL and is self-managed by employees, through the Equity Share Cooperative Society Limited.

IEPL provides all direct employees with training opportunities to meet both career progression requirements as well as business objectives. The company has an onsite training center where various training programs are planned and conducted including workshops, seminars, on-the job training (mentorship), supervisory, middle management, pre-retirement/end of service and awareness (EHS) training. In 2019 the company completed a total of 15,060 training manhours, with an annual target of 3.64-man days per employee. To date, 8% of employees have achieved more than 3 promotions, 44% employees have achieved 2 promotions and 45% of employees have achieved 1 promotion career progression in the past 12 years.

Workers’ Organization

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

Currently 94% of all company employees are unionized, with junior employees and contractors represented by the Nigerian Union of Petroleum and Natural Gas Workers (NUPEGN), while senior employees are represented by the Petroleum and Natural Gas Senior Staff Association of Nigeria (PENGASSAN). A position for female representation has been created in the constitution of both unions. All terms and conditions of employment are regulated through existing (2020-2021) Collective Bargaining Agreements (CBA) with NUPEGN and PENGASSAN respectively. The CBAs cover recruitment and placement of new junior staff, probationary periods, training policy, medical policy, grievance management, disciplinary procedure, hours of work, leave, loans, allowances, bonuses, benefits, severance and dry rations.

Non-discrimination and Equal Opportunity

As detailed in the Non-Discriminatory Policy and reiterated in both the Code of Conduct and Human Rights Policy, the company upholds a policy of non-discrimination and equal opportunity in all employment and organizational activities. This includes no-discrimination based on race, color, age, sex, religion, disability, ethnicity, national origin, regional origin, marital status nor any other legally protected status. The practice of non-discrimination is extended to customers, suppliers, service providers and business partners. As detailed in the Human Rights Policy, all recruitment is carried out in a fair, equitable and consistent manner.

Child / Forced Labor

The minimum age for employment in Nigeria is 18 years, and the Company complies with national law in this respect. As per the company’s Child Labor Prohibition Policy, and emphasized in the Human Rights Policy, IEPL has a zero-tolerance approach towards any child, forced or bonded labor. This policy includes prohibition of employing any person under the age of 18 years. All employees’ age is documented and maintained for verification purposes.    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.  IEPL will conduct periodic monitoring to ensure contractors compliance with these aspects.

Management of Contractors and Third-Party Workers

The evaluation, selection and registration process of third-party contractors is the responsibility of the department requiring the services. This process includes the vetting of a companies’ adherence to relevant Nigerian legislation, including the Labor Act, Trade Unions Act, Minimum Wage Act, and pension Reforms Act. IEPL anticipates, one contractor to be the engineering/procurement (EP) contractor and a second one to be the construction (C) contractor. Due to the ongoing projects at the site, there are few good construction contractors already at site out of which one of whom will be selected as the construction contractor. The company is currently completing the final selection for the EP contractor. The EP&C contractors will be chosen based on their demonstrated ability to comply with international standards and safety practices codes.

As per the Independent Contractors’ Policy, IEPL requires all workers engaged by third parties to comply with the company’s guidelines as detailed in the Employee Handbook, grievance management mechanism, and all relevant policies including IFC PS2. In addition, as per the MoU with the host communities, all third-party contractors are required to maintain and implement a Community Affairs, Safety, Health and Environmental Standards (CASHES) policy.

The workforce during construction is anticipated to reach a peak of around 300 personnel, who will be hired through the construction contractor. The company is committed to source the majority 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). As per the MoU, IEPL 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/ IEPL HR (for construction and operation respectively) selects the most appropriately skilled candidates from each group.

As specified earlier, as per ESAP Action No. 3, IEPL will require construction 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; and the corresponding as well as a Demobilization Plans (see ESAP Action No. 4.) The contractors will be required to meet national labor legislation, IEPL’s Human Resources Policies and Procedures, the conditions of the MoU with Host Communities and the relevant requirements of IFC Performance Standard 2. IEPL 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 along with the relevant EHS clauses (see ESAP Action No. 5.) IEPL will monitor the performance of the construction contractors to ensure that labor and E&S conditions follow the contractual requirements and the Performance Standards. Monitoring will include regular audits, review of the construction contractors’ internal monitoring reports and documentation as well as review of grievances logged by the contractors and subcontractors’ employees.

Grievance Mechanism

IEPL has an existing employee grievance management mechanism that is detailed in its Code of Conduct, Employee Handbook as well as in the CBAs between IEPL and the two employee trade unions. The mechanism allows for formal and informal grievance submissions, as well as anonymous submissions, to an immediate supervisor that can then be progressively elevated to the Head of Section and HR Manager. Senior management and the respective trade unions can be consulted should satisfactory resolution not be achieved, or further mediation is required. Employees also have the option to elevate their grievance to the Federal Ministry of Labor and Employment, the Industrial Arbitration Panel and the National Industrial Court. IEPL grievance mechanism is aligned with IFC PS2 allowing for confidentiality in the process, assigning clear roles and responsibilities to address grievances and establishing process target timelines, as appropriate. This mechanism also have the necessary resources to address sexual harassment complaints.  

IEPL has established various sub-committees to assist in the resolution of grievances related to a specific topic, including medical, transport, welfare and discipline. In 2020 IEPL received a total of 27 employee grievances relating to welfare, time and attendance, COVID-19, payroll, entitlements and benefits. All have been resolved with the exception of five grievances which are in the process of being resolved.  As the proposed project will be implemented in the same industrial unit, the existing grievance mechanism will be extended to the proposed project.

Workers Accommodation

Currently, accommodation for the expatriate staff at IEPL is provided in apartment blocks on site premises, while the local staff reside in the surrounding areas and are provided with housing allowances. The same arrangements are anticipated for the proposed project and there is no anticipated need of additional expatriate staff.

During the construction phase, workers will be recruited from the surrounding areas. As the expected number of construction workers is not significant, IEPL will not need to provide or construct a temporary accommodation for workers and, it is anticipated that the construction contractor will pay housing allowances for them to reside in the nearby communities where sufficient infrastructure is available to accommodate this population.

Occupational Health and Safety (OHS)

IEPL’s design philosophy is to provide sufficient process safeguards to protect personnel, equipment and the surrounding communities. The company has a suite of programs, safety manuals and procedures, aligned with IFC PS 2, to identify and avoid work related risks.  It also has the needed safety measures to prevent accidents such as only designated walkways, stairs, ladders; dedicated roads when entering or exiting work locations; appropriate warning signs; barricades or barriers for any potentially hazardous conditions. Also, the procedures are set to ensure that all accidents/incidents are identified, and the unsafe conditions and acts are reported to the plant manager or supervisor immediately.

As part of its operational safety approach, IEPL has a robust maintenance approach following good international practices that includes pre-defined preventive; as well as predictive maintenance checks and corrective maintenance activities as raised by the computerized maintenance database system and breakdown equipment outages. IEPL’s workplace safety officers patrol the site to identify and resolve unsafe acts (UA) and unsafe conditions (UC.)

IEPL’s fire safety department has dedicated qualified staff conformed by a Fire Chief supported by 37 fully trained dedicated fire personnel. The plants are equipped with infrared flame detectors and deluge system at the process plants, gas detectors at plant and tank farm, as well as smoke, heat, and beam detectors. In addition, it also has fire alarm & gas detection panels at all plant control rooms and buildings. The additional needed fire emergency response safety measures will be installed as part of the proposed project.

The company conducts periodic preventive maintenance of mobile, first-aid and fixed firefighting equipment/system including scheduled functionality checking and maintenance of fire & gas detection system and emergency communication system, and weekly emergency siren test, among others. It also conducts periodical emergency response drills in operational and off-site area as well as desk emergency response drills, assurance of compliance with drills recommendations, training for regular, contractor and security employees, fire risk assessment, review and updates as needed of standard operating procedures, etc.

IEPL has an on-site medical center equipped to deal with any medical emergency. It also has a medical team in house composed of a chief medical doctor, two resident medical officers, general and assistant nurses, a midwife, as well as physiotherapists, pharmacists, radiographers, lab technicians, 6 COVID isolation center doctors, 32 molecular lab pathologists, and laboratory technicians. It has two well equipped ambulances with trained drivers and paramedic personnel availability 24 x 7. 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 during Employment.  IEPL also has specific health surveillance programs focused on workers exposed to potential work-related risks (radiation, chemical, ergonomic, etc.) to undergo frequent evaluations and close monitoring. IEPL’s occupational health program also includes trainings about ergonomics, heat stress, infectious/contagious diseases, biosecurity standards, immunizations, etc. and conducts working environment assessment and provide recommendations for improvement.

IEPL has an alcohol and drugs policy and additional general health related programs such as voluntary testing for HIV/AIDS and free anti-retroviral to workers and contractors.

Training

IEPL’s E&S management team maintains a comprehensive and structured environmental, health, safety and social training plan including HR aspects based the company’s approved policies, plans and procedures and workplace risk assessment. The plan includes aspects related to its ESMS, identification and evaluation of environmental aspects, good housekeeping and environmental health, environmental awareness, waste management, on-site emergency and spill contingency plan, and process safety management, among others performance and will be extended to the proposed project. The training is provided to all company’s permanent, contractors and service providers employees.                                                   

IEPL’s climate strategy is to progressively reduce its carbon footprint. A key initiative towards this goal is having co-located the nitrogen fertilizer and polyolefins production to maximize flare gas value monetization. In addition, this project aligns with the drive towards greater resource efficiency. The design of the proposed project is based on established state-of-art and internationally accepted 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.

Resource Efficiency Energy and Material Efficiency Projects

The proposed project aims to install equipment with the Best Available Technology (BAT) with lowest specific energy demand, minimal emissions, as well as lowest noise generation. IEPL currently generates all the power used in the petrochemical complex through its in-house 165-megawatt (MW) gas turbine-based power plant; with this proposed project, it will increase the capacity to 190MW after completion of IEFCL Line 2. The installation of the HRSGs would enable the recovery of heat from the power generation gas turbine hot exhaust gases resulting in significant savings in fuel gas consumption, preventing plant shutdowns from increased steam reliability and reduction in greenhouse emissions.

Furthermore, IEPL is also focusing on increasing the use of renewable energy and improving resource efficiency through reduce/recycle/reuse. Specifically, at the power plant it is implementing  a gas turbines? performance improvement plan which will realize a net fuel gas reduction of approximately 1.5 million standard cubic feet per day, and it is upgrading the metallurgy of the combustion components to increase the temperature at the combustion chamber thus improving the heat rate of the turbines. At the PE plant, it is improving the efficiency of the hot thermic fluid vaporizer, and it is eliminating ethylene leakages to avoid continue releasing them to the flare. At the olefins plant, IEPL is modifying the propane tanker to recycle the vapor losses rather than flaring them; and at the port terminal, it is replacing the diesel fuel used at the five generators with CNG fuel. Overall, the project will result in significant environmental improvements and enhanced resource efficiency.

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 current combined GHG emissions from its operation units (gas turbines and heater, olefin furnaces, olefin boilers) is 1,164,000ton CO2eq per year. Once the project is completed and the two HRSG systems are installed, the total GHG emissions, from all its operation units, are estimated to be approximately 944,000ton CO2eq per year. Thus, the estimated net GHG emissions reduction, after the project is completed, will be about 220,000ton CO2eq per year, after accounting for the rise in emissions from increased production and power generation. Once the detailed engineering is completed, the company will recalculate the GHG emissions to truly reflect the values based on expected actual performance data.

Air Emissions and Ambient Air Quality

IEPL’s main air emissions sources include three natural gas fired steam boilers generating each 115 tph of steam; three flares, each from the olefins plant, ethylene storage, and polyolefins plant; two incinerators, one for burning of the wastewater treatment plant sludge and another for the process solid residues generated as well as the domestic wastes; six stacks  from the olefin cracker; and three stacks from the polyethylene plant’s thermal heater furnaces and  five stacks from the power generating gas turbines. In addition, fugitive emissions from the storage tanks and faulty equipment (i.e., valves, flanges, etc.) are also released.  Main pollutants released include SOx, NOx, VOCs, particulates, as well as CO, and CO2. The energy source for the operation is natural gas. IEPL has implemented numerous efficiency improvements to reduce air emissions as well as flaring of gases to the atmosphere. It also controls the fugitive emissions through preventive checkup and maintenance of all equipment including valves, flanges, etc.

IEPL monitors ambient air as well as stack emissions. The six air quality monitoring stations are located at the main entrance gate, the weighting bridge area, the flare area, the metering station area, and the Akpajo/Elelenwo and Aleto/Agbonchia nearby communities. The stack emissions, which are monitored quarterly for NOx, SOx, CO, VOCs, as well as, CO, CO2, and O2, include two olefins furnaces, two olefin boilers, two power generation gas turbines (GT), and the polymer and sludge incinerators. Ongoing monitoring of ambient air quality indicate that the results are within the national standard limits and those defined in the WBG General EHS Guidelines, Table 1.1.1. The point sources monitoring undertaken at the petrochemical complex are within the WBG EHS Guidelines for Petroleum-based Polymers Manufacturing, Table 1. 

Even though the emission rates will be unchanged with the installation of the HRSGs, the HRSGs will reduce the stack exit temperatures resulting in lower plume rise which in turn will lead to higher near-source ground level pollutants concentrations. Nevertheless, the yearly average values of key ambient air quality parameters (NOx & SOx) show enough margin to accommodate the minor change in dispersion patterns, IEPL will conduct pollutants dispersion modelling for the GT/HRSG flue gas for both scenarios (i.e. normal & reduced temperature) to confirm this initial assessment. (See ESAP Action No. 6.)  

Water Usage and Wastewater Treatment

The water required for domestic and industrial operations is supplied by eight groundwater wells authorized by the state environmental authorities. Water for consumption as well as process use (i.e., steam generation, cooling) is treated on-site. The additional water demand due to the proposed project is 216,800 m3/yr; which will be met from the borewells without any significant impact on the groundwater resources. 

The complex has a water treatment plant, a cooling tower, a demineralization plant, and the biological and spent caustic wastewater treatments plant (WWTP.) The WWTP has a design capacity of 1,200 m3/day.  This capacity is sufficient to accommodate the marginal increase in wastewater generated due to project.

IEPL has a wastewater treatment system for the entire Petrochemical facility.  The process includes primary treatment with chemical dosing and flocculation and secondary biological treatment using aerators and a clarifier.  The treated water, which is mixed with storm water, prior to being discharged to the Okulu River is 1,200 m3/day. The wastewater quality is monitored daily for pH, chemical oxygen demand and total suspended solids and the results for these parameters are well within national limits and those defined in the WBG EHS Petroleum-based Polymers Manufacturing EHS Guidelines, Table 2. 

EPL conducts water quality monitoring to ascertain there are no negative impacts to the river and the results of the analysis conducted in the last three years indicated that the Okulu River water quality has not been affected by the treated effluent discharge and that there have not been changes to the quality of the downstream water compared to the quality of the upstream water. 

Noise Management

IEPL has the needed measures (noise barrier/insulation, periodic maintenance plans) to limit noise disturbance outside the site boundary and has a noise monitoring program at the facility boundaries to ascertain the project’s compliance with Nigerian standards and EHS 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. It is anticipated that the installation of HRSGs will not add any significant change to the ambient noise level. As the HRSGs are unfired boilers without air fans, they will not generate additional noise levels. The noise level at the proposed HRSGs will normally be between 65 to 75 dB(A), which is aligned with the IFC noise requirements. As it is currently done, IEPL will continue conducting ambient noise monitoring to confirm compliance.

Hazardous Materials

In addition to ethylene and propylene, other main raw materials used in the production of the polyethylene and polypropylene resins include catalysts, solvents, and additives. The hazardous liquids tanks farm area has all needed safety precautions including, among others, being segregated and securely stored with appropriate double wall – double containment type, pressure relief valves and equipped with vacuum relief valves adequate to manage any emergency, and an accessible database with the Material Safety Data Sheets (MSDS) for all hazardous materials. Furthermore, it has a dedicate program to ensure the reliability to the storage tanks by conducting visual inspections, thickness measurement, weld seam inspections, etc. In case of spillage incidents, IEPL has the appropriate prevention measures to absorb or contain liquids so that they do not enter drains, ditches, or waterways compliant with the required safety measures. No additional inventory will be required for Olefins Plant as existing capacities are adequate.

Waste Management

Main wastes generated at IEPL include product rejects; WWTP sludge; waste oils; spent alumina; metal, wood, and plastic scrap; decontaminated containers; and domestic wastes. IEPL has a waste management program that includes proper handling and storage of hazardous materials; wastes reduction based on the 3R principle (Reduce, Re-use, Recycle) and proper treatment and disposal.

For the non-hazardous waste (metals, plastic, paper, wood) it has segregation and collection in dedicated bins at each plant and off sites areas. The wastes are collected, recorded, and temporarily stored at a centralized waste disposal yard prior to being finally disposed by local and state government approved contractors.All biodegradable waste is disposed for composting at a government approved site by a local/state authorized contractor.

Hazardous wastes such as bio-medical waste, oil-soaked cotton and polymer waste, and WWTP sludge are incinerated on site; used oil is disposed of by an approved contractor; spent catalyst is stored in sealed drums and sent to Europe for precious metal recovery; the oil sludge is disposed at a Department of Petroleum Resources and FMEnv approved waste management facility and tracked with waste manifest.

The residual ash from the sludge and polymer incinerators is collected and tested to confirm it is not hazardous. The TCLP analysis conducted indicates that it is not hazardous. These tests will be continue being conducted as part of the project. Parameters assessed include pH, oil and grease, flash point, which is expected to be more than 240 degree centigrade for it not to be flammable, toxicity and leachability test (TCLP) for heavy metals including barium, arsenic, selenium, cadmium, chromium, lead, silver, iron and mercury.  The parameters have been consistently reported acceptable values for disposal at approved landfills or for concrete stabilization.                                                   

Community Health and Safety

The IEPL plant is directly bordered by communities predominantly to the south and west of the operation. Six host communities, Akpajo, Aleto, Agbonchia, Njuru, Okerewa, and Wakaohu Family (Elelenwo), totaling approximately 65,000 inhabitants, are located within a 5-km radius of the project.

The health and safety of the communities near its operations is of paramount importance to the company.  The proposed project will not pose additional risks to the nearby communities. However, as detailed under Performance Standard 1, the emergency response plan to be updated as a result of the project (ESAP Action No. 3 ) will include communication approaches (i. e.,  public forums, project briefings, etc.) to  raise awareness among the communities related to response to emergencies; and ways to involve the local authorities in the development of community preparedness planning in the event of a major accident.

As per the MoU with host communities the company has committed to ensure that all effluent passes through the Effluent Treatment plant and will take prompt action should any adverse environmental impact occur. As indicated above, the treated effluents discharges are aligned with the local environmental as well as the IFC requirements.

Transportation

Increased traffic volumes to transport workers, equipment and materials to the construction site are anticipated. Vehicular movement during this phase will include trucks, buses, minibuses and cars. Separate access and routes for movement of employees and materials will be established. IEPL, along with the  construction contractors, 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 ESAP Action No. 7.)

Security Management

Physical security at the IEPL site consists of a perimeter wall including electrified fencing and CCTV cameras monitored from a 24-hour operating control room. Access to the site is managed by unarmed 24-hour security guards, boom and gate barriers, turnstiles, and a biometric access control system.

The management and coordination of security at IEPL is the responsibility of the Head of Security (HOS), who is supported by a six-man security management team including a CCTV/Access control manager; Senior Operations Manager; and Journey Manager. Contracted security personnel include security coordinators, supervisors, and guards. Numbers of security personnel deployed on site are reviewed by the security team and appropriate adjustments are carried out as needed. In addition, the security contingent also includes an Explosive Ordinance Department, responsible for detecting and preventing entry of explosives into the complex.

IEPL has developed a Security Management Plan (SMP) (effective July 2019) that details the management of security across their operations. The SMP includes detail on (i) overarching security policies, objectives and tasks; (ii) threat and risk assessment; (iii) security planning and resourcing; (iv) security implementation and controls; (v) security monitoring and reporting; and (vi) learning and review. IEPL’s security approach, including relations with both public and private security, is guided by the Voluntary Principles on Security and Human Rights.

Given the importance and strategic nature of IEPL operations and assets, coupled with the security dynamics within the Niger Delta region, the government has deployed public security forces. This includes the Nigerian Police Force (located at a police station on site), the Nigerian Army (responsible for access and perimeter security, convoy management) and State Security Services who act as an intermediary when required. Government security forces are the only armed component of the IEPL security element.

A vetting and screening process is undertaken with all contracted security personnel prior to employment. All security personnel undergo training, including incident and emergency response, firefighting and first aid, which is maintained by the HOS in a training register. The Service Level Agreements (SLA) between unarmed private security agencies and IEPL detail the requirements for the provision of security in their respective areas of responsibility. These include requirements related to training, punctuality, and appearance, fulfilment of duties, behavior, and attitude.

All security management procedures, including risk treatment controls and procedures, are informed by a security risk assessment that includes risk identification, risk analysis and risk evaluation. The HOS also maintains a threat and risk register. Security incidents required to be investigated are referred to the Company Disciplinary Committee (CDC), comprising all stakeholders including the security department so as to identify shortcomings and take appropriate corrective measures to ensure the matter is rectified appropriately, lessons learned identified and acted upon. Should a security incident occur, IEPL works with the Nigerian Government Security Forces to ensure appropriate responses are implemented.