The site is located in an area occupied by agricultural and grazing land, and urban/village centers with remnant areas of degraded natural habitat and no ecologically sensitive areas have been identified within a 10 km vicinity. Therefore, PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not applicable. Impacts related to biodiversity and ecosystem services were considered within the ESIA and recommended mitigation measure will be covered as part of other PSs to manage the limited PS6 related impacts. Though there are resettlement impacts, none of the affected people are Indigenous Peoples and thus PS7 (Indigenous Peoples) does not apply to the Project.

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.

This is a Category A Project according to IFC’s Policy on Environmental and Social (E&S) Sustainability due to the potentially significant, diverse and irreversible risks and impacts associated with the Project.

Key E&S risks and issues associated with the investment include: i) adequacy of the Company’s E&S policies, plans and procedures to ensure effective and systematic assessment and management of E&S and occupational health and safety (OHS) risks and impacts during construction and operations; ii) fair treatment and safe working conditions for employees and contractors alike including adequate adoption and implementation of relevant human resource (HR) policies and procedures including that related to OHS management; iii) management of air emissions, noise, wastewater, pollution and waste in alignment with the World Bank Group (WBG) General and sector specific EHS Guidelines; iv) resource efficiency and greenhouse gas (GHG) emissions; v) community safety (including harassment and gender-based violence) due to labor influx, traffic and presence of security forces; vi) past and future land acquisition and associated economic and physical displacement for the plant, quarries and associated facilities; and, vii) stakeholder engagement and grievance redress.

Environmental and Social Assessment and Management System and Policy

The SKP has an E&S policy framework that governs their approach to E&S matters, however a formal Environmental and Social Management System (ESMS) is required. While BUA has committed to adopt an ESMS aligned with ISO 14001 (certifiable environmental management standard), going forward the Company will develop and implement an ESMS aligned with the applicable requirements of the Performance Standards (PS) and appoint a suitably qualified consultant to support this endeavor.  In doing so, the Company will ensure all ESMS-related policies, plans and procedures are accessible to relevant staff via an electronic document control system. As part of the development of their ESMS, BUA will also assess the ESMS of their main contractors and develop bridging documents to address any gaps (ESAP #1a).

Policy

BUA adopted an Environmental Policy in 2020 at the corporate level covering both the Sokoto and Obu cement plants. This policy commits BUA to: i) compliance with national environmental regulatory requirements; ii) implementing an 14001 aligned ESMS per above; iii) improving energy efficiency to reduce GHG emissions; iv) enhancing the use of natural resources; v) pollution prevention and control; and, vi) quarry rehabilitation.  Furthermore, the policy makes provision for training of employees and contractors as well as stakeholder engagement and responsible sourcing of goods and services.  BUA also commits to implement the Health and Safety (H&S) Policy as previously applied by the previous company owner (CCNN), which covers employees, contractors and visitors and commits to prevention of accidents at the workplace. BUA have also implemented policies relating to labor and working conditions including a Code of Conduct, and Code of Ethics and Employee Handbook (these are described further under PS2). Going forward, BUA will consolidate and enhance their policies to better align with the PSs, Good International Industry Practices (GIIP) and designate responsible parties for ensuring implementation thereof (ESAP # 1a).

Identification of Risks and Impacts

For the first phase of the expansion (i.e., line 4), which includes the 50 MW gas fired power plant, E&S risks and impacts were assessed via an EIA undertaken in accordance with national legislation. The EIA was approved by the Federal Ministry of Environment on March 29, 2021 and an Environmental Compliance Certificate issued.

Similarly, for the line 5 expansion and associated facilities, including the future 70 MW gas fired power plant and extension of the quarry, BUA has also commissioned an EIA in accordance with Nigerian national legislation which was submitted to the relevant authorities in June 2022 with approval anticipated in October 2022. In parallel, BUA has commissioned an international consultancy to undertake a supplementary ESIA to align with the requirements of IFC PS’s and the applicable WBG EHS Guidelines. This ESIA has assessed impacts associated with line 4 and 5 while also considering cumulative impacts associated with existing operations and includes specialist studies focused on: i) air quality, noise, traffic and transportation, biodiversity and waste management; ii) an assessment of historical land acquisition; and, iii) a quantitative risk assessment (QRA) for the LNG storage facilities.

The draft ESIA is disclosed along with this ESRS and is currently being finalized including stakeholder engagement on the assessment findings.

As part of their ESMS, BUA will develop and maintain a compliance register to document all applicable legal requirements, including that associated with relevant permits, licenses, registrations and approvals. This register will also include requirements as defined by the ESIA and appropriate actions as described in the Project ESAP (ESAP #1a).

While no Project specific impacts linked to biodiversity have been identified, as per (ESAP # 1b), the Project will include biodiversity related mitigation measures in the environmental and social management and monitoring plan (ESMMP) to be compiled as part of the ESMS i.e., measures to control the spread of alien invasive species, avoid development in riparian zones including drainage lines and use of indigenous species in rehabilitation efforts.

Priority ecosystem services linked to agricultural/grazing land, erosion controls and water flows were also identified and associated mitigation measures are also defined under PS3, PS4 and PS5 as appropriate.

Management Programs

BUA has an Environmental Management Plan (“EMP”) which was compiled by an E&S consultant and issued in August 2021. The EMP was developed to align with BUA’s Environmental and H&S Policies and is periodically reviewed.  The EMP includes identification of impacts for plant operations, mitigation measures and monitoring frequency. The plan further incorporates provisions for plans related to the management of air quality, noise, OHS, solid and liquid waste and biodiversity. However, these plans are yet to be developed.

In development of the Company ESMS, BUA will develop PS compliant subject specific ESMMPs (ESAP#1b).  Such plans will include that related to: contractor management, emergency planning and response, stakeholder engagement, OHS management, resource efficiency, air quality, noise, solid waste management, hazardous materials management, pollution prevention and spill response, traffic and transport management, (including community safety), in-flux management, cultural heritage, an erosion, sediment control, restoration, rehabilitation and closure plan (including use of indigenous species and control of alien invasive species).  The scope of these subject specific ESMMPs will include all Project activities, both within and outside the concession area, as well as during construction, operations and decommissioning.

Organizational Capacity and Competency

The SKP has a dedicated Health, Safety and Environmental (HSE) team that reports directly to the Plant Director.  The team consists of 2 supervisors i.e., a HSE Departmental Head and an assistant, with 4 HSE shift supervisors in support. The shift supervisors are responsible for managing HSE during the shift and report to the assistant as referenced. Community engagement is managed through the Corporate Relations Department, and includes a head of department, 3 support staff and 3 Community Relations Officers (CRO). Given the scale of activities, BUA will reinforce their corporate organization by: i) recruiting a corporate Health, Safety, Environment and Community (HSEC) Corporate team that will include, as a minimum, a HSEC Director, an Environmental Manager and/or an OHS Manager and a Social Risk and Development Manager to manage and assume responsibility for all community / social activities and interactions. To strengthen its E&S capabilities, BUA recently developed a new corporate HSEC organogram and is currently in the process of recruiting key resources in support of the new structure. The Company will also reinforce their HSEC team at the SKP level and provide an organizational chart clearly defining the corporate and Project site based HSEC organization (ESAP #1c).

The Company will also develop and implement a HSEC training plan, a training matrix and required training materials to ensure the competency of their HSEC Team and the required E&S and OHS awareness trainings that will be provided to all staff, including employees and contractors (ESAP #1a).

Emergency Preparedness and Response

The LNG storage and gasification plant has an emergency response plan (ERP) while a plant-wide ERP is currently under development. The Project will ensure the finalization and implementation of the plant-wide ERP that incorporates expansion of the LNG storage facility and includes the installation and/or upgrade of emergency directional and fire equipment, locational signage, implementation of emergency training, drills, equipment inspection programmes and engagement of adjacent communities to the extent necessary so as to ensure they are made aware of the relevant risks and any actions required in an emergency (ESAP #1b). The development and implementation of the plant-wide ERP will be informed by the OHS review as this includes a component related to process safety as mentioned under PS2 below.

Emergency equipment available within the SKP includes fire extinguishers at various locations across the plant, fire alarm system for detection (at operational control rooms) and water sprinklers around all fuel tanks attached directly to the power plants or core machinery/equipment (standalone fuel reserve tanks do not have water sprinklers). The Sokoto State Fire Services completed a survey in December 2021 and confirmed installation of all hydrocarbon fuel storage tanks were compliant with the national fire prevention regulations. Nonetheless, a fire occurred in March 2022 whereby three fuel (diesel and LFPO) storage tanks containing some 3 million litres of fuel at the time caught fire. This resulted in 3 fatalities and the destruction of three (5 million litre) storage tanks.  As per ESAP #2c, BUA will undertake an OHS audit and a process safety review, which will include an independent incident review for the events and circumstances that led to the fire on March 18, 2022.

Monitoring and Review

Currently, an external consultant undertakes bi-annual environment audits at the SKP to ensure regulatory compliance. As a part of the ESMS, BUA will develop a Performance Management and Monitoring Plan that will include an internal and external audit review schedule, a schedule for monthly HSEC performance review meetings and biannual management review meetings where the performance of the ESMS and associated elements (e.g., policy, objectives, targets, management and monitoring programs, etc.,), will be reviewed. The plan will track HSEC performance by including Key Performance Indicators (KPIs) with agreed controls and mitigation measures, as well as observations and agreed actions from internal and external monitoring. KPIs will be linked to specific targets based on BUA’s objectives, national regulations, ESIA commitments, international standards, and WBG EHS Guidelines (ESAP #1b).

Currently BUA employs approximately 2,200 workers at the SKP, 400 of whom are direct male workers and 14 direct female workers and the remaining 1,800 are employed through third-party contractors. About 22% of all direct workers are from local communities. Approximately 26% of contractor workers are sourced from local communities. BUA prioritizes recruitment from the immediate communities around the SKP.  Contract workers comprise truck drivers (40%), security guards (25%), worker camp management and plant personnel (35%). Once line 5 is operational, it is anticipated that BUA’s direct employees will increase by approximately 150 while contract workers, predominantly truck drivers, will increase by 1,000.

Sinoma CBMI, the EPC and O&M contractor for lines 3, 4 and 5, currently employ over 400 staff which are a mix of expatriates and nationals.   At peak periods and during the construction of line 5, BUA is expected to have 5,500 workers at SKP both involved in construction and operations.

Human Resources Policies and Procedures

Human resource (HR) management is overseen by BUA’s HR Director, who is supported by leads focused on Rewards and Employee Relations, Recruitment and Training, Medical Services and Security respectively. BUA have developed and implemented several group level HR policies and procedures including a Code of Ethics, Code of Conduct, Compensation Policy, and an Employee Handbook that apply to all BUA employees.  The Employee Handbook addresses issues related to discrimination, remuneration, performance appraisals, forced and child labor, working hours, leave and employee benefits. As per ESAP #2b, BUA will update the Employee Handbook to reflect their approach to Freedom of Association as per local legislative requirements.

Working Conditions and Terms of Employment

Working conditions and terms of employment are largely defined and aligned with the Nigerian Labor Act and the current collective bargaining agreements (CBA). All direct BUA workers have an open-ended contract, while contract employees are employed on a term basis. The contracts for both direct and contract workers detail remuneration, employment period, responsibilities, probation period, available leave and medical requirements.

Monthly wages are above the Nigerian minimum wage requirements and applied according to the worker’s grade. In addition to the basic monthly wage, workers are also entitled to various allowances for housing, transport, meals, medical, laundry, and hazardous and shift work. All BUA direct workers also qualify for a bonus of an additional month’s pay over and above their annual salary.  Overtime is paid at either 50% or 100% of the base salary rate. Working hours are dictated by national labor legislation and industry standards, with workers not required to work more than 40-hours per week. Plant employees work across three shifts daily.

All BUA workers contribute to a pension fund scheme and are also covered by a Group Life insurance policy and the Nigeria Social Insurance Trust Fund. Employees are entitled to annual, casual, compassionate, sick, study and maternity/paternity leave.

BUA workers are provided with a subsidized canteen and a mosque on site. A clinic, accessible to all employees and their families, is also available. The clinic is manned by a nurse and a doctor. Workers employed by the EPC contractor are provided with their own canteen and clinic within their accommodation camp.

Workers Accommodation

BUA have three worker accommodation camps housing security, third-party contractors and BUA management not native to Sokoto. Residents of these camps have access to recreational facilities, ablutions, clinics (either within the camp or the SKP) and canteens.  Where necessary, accommodation and ablutions are segregated by gender, with no more than two people per room. Rooms are also fitted with air-conditioning.  Third-party service providers manage the camps.

Worker accommodation is largely aligned with the IFC/EBRD Guidance Note on Workers’ Accommodation.  However, BUA will conduct an assessment and gap analysis of the existing worker accommodation (direct workers and contractors) relative to the IFC/EBRD guidance document on such (ESAP #2a). Based on the findings the Company will then develop and implement a time-based action plan to address gaps as may be identified in the assessment.

Workers’ Organizations

BUA junior and senior employees are represented by two national unions i.e., the National Union of Chemical, Footwear, Rubber, Leather, and Non-Metallic Employees (NUCFRLANMPE) and the Chemical & Non-metallic Products Senior Staff Association of Nigeria (CANMPSSAN). Each union includes seven elected staff representatives. In February 2019 a Collective Bargaining Agreement (CBA) was signed with each union and this addresses remuneration and staff allowances. The CBAs are valid for two years and thus due for renewal. Negotiations between BUA and the unions are due to commence in Q3 2022. BUA will provide IFC with the updated CBAs once agreed and finalized with the respective unions (ESAP #2b).

Currently, as the BUA Employee Handbook does not reflect the requirements of PS2 nor the Nigerian Constitution in terms of freedom of association and collective bargaining, the Employee Handbook will be updated accordingly (ESAP #2b). This will include worker rights to elect representatives, form or join worker organizations of their choosing and bargain collectively without any form of discrimination or retaliation against workers who participate, or seek to participate, in such organizations.

Non-discrimination and Equal Opportunity

In accordance with the Employee Handbook, BUA has a policy, aligned with the requirements of PS2, noting they do not condone any form of discrimination based on race, religion, gender, origin, age, disability, or nationality. This is applicable during hiring, compensation, promotion, termination, and retirement. The Company also has a zero-tolerance approach to any form of harassment or bullying, including sexual harassment.  Both the Employee Handbook and Code of Conduct provide a detailed description of the process to report and address incidents of sexual harassment.

Grievance Mechanism

BUA’s current Code of Conduct provides an overview of the Company’s process to be followed should a worker raise a concern or grievance. This includes an approach to the reporting and management of sexual harassment in the workplace. However, no formal employee grievance management mechanism is currently available.  Thus, BUA will develop and implement a worker grievance mechanism whereby workplace concerns and grievances can be raised. The Company will also inform workers of the mechanism at the time of recruitment and make it readily accessible. The mechanism will ensure an appropriate level of Company management is involved in addressing grievances and that these are addressed promptly, using an understandable and transparent process that provides timely feedback to those concerned, without retribution. The mechanism will also allow for anonymous grievances to be raised and addressed. In addition, BUA will formalize their current whistleblowing procedures. Both the grievance mechanism and whistleblowing procedure will be extended to both BUA employees and contractors (ESAP #2b).

Protecting the Work Force

BUA prohibits any form of forced or child labor. Their minimum age for employment, as per the ILO convention, is 15 years of age, or 18 years for hazardous and/or night work. The age of workers is confirmed upon procurement through the provision of a birth certificate. BUA’s current policy on forced or child labor will be upgraded, expanded upon and communicated across the organization. BUA’s current policy only applies to their direct workers and there is currently no formal process of monitoring contractor’s employment practices in this regard; this will be covered in the newly expanded policy. BUA will therefore develop such a policy (ESAP #2b) detailing these requirements, as well as the approach to monitoring contractor’s adherence to the policy.

Occupational Health and Safety

As previously noted, BUA’s current H&S policy was developed by CCNN and needs to be updated. BUA plans to establish a robust OHS management system, and seeks ISO 45001 as stated in their 2021 EMP. Similarly, a formal and systematic approach for the identification of hazards and risks needs to be developed, as well as a Permit to Work system to control work at operational sites.

Over the last three years the SKP had a substantial number of fatalities, the vast majority due to road traffic accidents involving BUA owned trucks.

Going forward BUA will engage a suitably qualified OHS and process safety consulting firm to undertake an overarching, comprehensive and detailed OHS audit and process safety review focused on operations and construction works (ESAP # 2c). This work will form the basis upon which BUA will develop their OHS management system inclusive of an updated OHS policy, an OHS Management Plan, permit to work system, incident management, reporting and investigation, etc.  The updated OHS management system will apply to direct workers and contractors alike and be aligned with the requirements of the PS’s, WBG EHS Guidelines and GIIP for the sector (ESAP # 2c).

The management system will also define the approach to behavioural safety and clearly stipulate the mandatory provision and use of Personal Protective Equipment (PPE) by all workers.  Further, via the Contactor Management and Monitoring Plan (ESAP #2c), this will include the requirement for contractors to budget for the provision of PPE. The approach to the use of PPE will be risk-based and defined based on the tasks undertaken. BUA will implement visible measures to enforce the use of PPE amongst all staff and contractors, including training on PPE use, regular OHS inspections, internal audits and disciplinary measures (ESAP #2c).

The approach to OHS training will also be defined via the associated management system and include worker inductions, toolbox talks, job safety analyses and an ongoing training program to be guided by a training matrix. Training records will be maintained (ESAP #2c).

The management system will also define the approach for OHS workplace monitoring and include air quality, noise, vibration, heat stress, illumination and radiation, all in alignment with the WBG EHS Guidelines (ESAP #2c).

Safety issues related to traffic accidents are addressed under PS4.

Workers Engaged by Third Parties

BUA currently use several primary third-party contractors for the provision of services including that related to private security, trucking and the current EPC and O&M contractors. Truck drivers are sourced by BUA Transport (a subsidiary of the BUA Group) through a labor broker. There is no evidence that BUA verifies the terms of employment, or labor and working conditions, of their third-party contractors, BUA need to develop a documented procedure to assess and monitor their third-party contractors relative to the Company’s own requirements, applicable legislation or that associated with the PS’s.

As per ESAP #1a, BUA will assess the ESMS of their main contractors and develop a bridging document to address any gaps. This will include a labor audit of their current selection, evaluation and hiring procedures, as well as contractors’ current policies and procedures against the requirements of both national labor legislation and PS2. This will cover key areas such as labor and working conditions (working hours, remuneration, benefits, non-discrimination etc.), freedom of association, grievance management, and child and forced labor. BUA will also develop a Contractor Management and Monitoring Plan to ensure that contractors are applying similar standards as BUA, with particular attention to labor and working conditions, worker facilities, EHS management, child and forced labor, and grievance redress where the contractors do not have an adequate procedure to address this (ESAP #1b). The plan shall include measures for screening, auditing and monitoring by BUA of contractors on the basis of EHS and labor compliance for all types of locally contracted companies (e.g., security, transport) and management of gender-based violence (GBV)-related aspects between contractors and communities. IFC will actively monitor contractor management on an ongoing basis, including via direct engagement with contractors and workers.

Supply Chain

BUA’s primary supply chain predominantly includes the provision of raw material (coal and gypsum) and fuel (LNG, LPFO, diesel). BUA need to develop a monitoring procedure for suppliers and thus will develop and implement a Supplier Code of Conduct (ESAP #2b) to ensure that appropriate E&S due diligence risks in the supply chain is undertaken.

Energy and Resource Efficiency

The Project will result in the use of LPFO being substituted for the use LNG for power generation, as well as introducing modern technology for the new cement production lines. In addition, the use of coal in the kilns for the thermal process will be substituted with LNG up to rate of at least 30%.  Other mid to long-term options to improve resource efficiency include use of renewable power i.e., solar (10 MW) and use of alternative fuels in the kilns (e.g., biomass, waste).

During 2021, the SKP’s power requirement were generated using LPFO. With the decommissioning of lines 1 and 2 and commissioning of line 4, all power for the existing operational lines has been changed to LNG.  In addition, given the modern and energy efficient design of lines 4 and 5, which includes a 4-stage pre-heater, a vertical roller-mill (providing lower electricity consumption) and use of gas in the kilns, the overall energy efficiency of the SKP is estimated to be 10-15% lower than the West Africa average for cement production and this will improve further by some 10 % once line 5 is commissioned. The Project has procured dual fuel generators, providing the flexibility to run on gas but also on diesel in the event of LNG supply disruption.

For thermal energy use in the kilns, line 3 requires approximately 130,000 tons of coal per annum (p.a.), line 4 an estimated 190,000 tons p.a. and line 5 will require a similar as line 4.  Line 3 also needs approximately 25,000 tons of LNG p.a., while line 4 needs some 40,000 tons of LNG p.a. and line 5 will need the same amount.  The thermal energy intensity of the clinker is estimated to be 3.169 GJ per ton of clinker which is aligned with the WBG EHS Guideline for Cement and Lime Manufacturing.  Once the Project is complete, the electricity requirement is estimated at 98 kWh per ton of cement which is within the guidelines provided by the WBG EHS Guideline for Cement and Lime Manufacturing.

As part of its Resource and Energy Efficiency Management and Monitoring Plan, BUA will monitor fuel consumption across all activities and develop energy efficient measures to further reduce fuel consumption and GHG emission (ESAP # 1b).

Water Consumption

The water requirements for the SKP following the expansion are estimated at 105 m3/day. The manufacturing process is not water intensive (water used for equipment cooling purposes is mostly reused in a closed circuit), and most of its use is primarily for cooling, dust suppression and domestic purposes (camps, kitchen, sanitary facilities).

BUA has installed 7 boreholes onsite to extract ground water and 2 additional boreholes will be installed in the future. Due to the presence of relatively shallow groundwater, dewatering of the quarry is required at certain locations and times of the year. The water from dewatering is used for various purposes, including dust control of haul roads, fire water and is also made available to local communities for crop irrigation purposes. BUA does not currently record water usage.

BUA will start recording water consumption (including quarry pit water that is provided to local farmers for irrigation purposes). Further, and as recommended by the ESIA, BUA will: i) undertake a hydrogeological study to determine groundwater replenishing rates, regularly monitor drawdown rates of groundwater wells,  define impacts on community water availability and test the quality of all water used; ii) agree with IFC on terms of reference (ToR) for development of groundwater management and sustainability plan for the plant; iii) based on the ToR, develop the plan with support from an external consultant (acceptable to IFC) within agreed timelines, describing various measures the Company will take to sustainably manage its groundwater abstraction including use of quarry pit water for the plant and reuse of treated effluent from sewage treatment plants; and, iv) prepare an implementation plan for these measures based on time-based deliverables (ESAP #3a).

Air Emissions and Ambient Air Quality

Operation of plant and equipment generate Carbon Monoxide (CO), Carbon Dioxide (CO2), Nitrogen Oxides (NOx), Sulphur Dioxide (SO2) and Particulate Matter (PM). The main sources of dust and particulate matter are quarrying activities, transfer of limestone to the crushers by trucks, grinding operations, clinker production, on-site storage and handling of coal, clinker, limestone, and gypsum, transfer of cement to the silos for storage, bagging of cement, and transportation of cement along the site access road. Other than the Sokoto plant, there are no other industrial activities that generate significant emissions in the area. However, other existing local sources of NOx, SO2 and PM in the immediate area include cooking, transportation, agriculture and other residential and commercial activities.

The principal point source of air emissions are the stacks associated with the cement kilns and power plants. The conversion to natural gas fired power generation will significantly decrease emissions of particulate matter, NO2 and SO2 at the SKP. All stack heights are at “Good Engineering Practice (GEP) height”. The use of 70/30 mix of coal and natural gas in the kilns will also lower air emissions on a unit basis.

Various design measures will be implemented to minimize emissions for various in-plant processes. These mitigation measures include: i) installation of bag filter systems to capture particulate matter emissions; ii) use of covered conveyor belts to transfer materials between areas; iii) hot gases from the kiln will be fed to the four-stage pre-calciner double string with cyclones; and iv) the four stage pre-calciner technology will also reduce the thermal energy requirement thereby reducing the quantity of fuel required for the plant.

The project is located in a semi-arid climate with little precipitation and extreme heat dominates much of the year. Due to its location, the project area is also influenced by the West African Harmattan system that affects West African regions, resulting in naturally high dust/PM concentrations.

Baseline monitoring for the project was conducted between 11 February and 14 March 2022, which are typically dry and dusty months.  BUA Cement will continue air quality monitoring as part the company’s site-wide monitoring programme. The airshed was found to be degraded with average daily PM10 concentrations indicating daily exceedances of the PM10 24-hour Nigerian Standard (150 µg/m³) and the PM10 24-hour WHO guideline (50 µg/m³). Baseline ambient levels of both SO2 and NO2 were substantially below both the applicable Nigerian and WHO guidelines.

Air emissions from construction activities will mainly be from dust due to earthworks and vehicle traffic on unpaved access roads. This will be controlled via application of the associated management plan for this project phase. During operation, there will be various sources of point source and diffuse air emissions at both the cement plant and quarry.  To control dust emissions BUA will pave the haul road from their southern fence line to the crusher and add eco-friendly soil binding stabilization products to the water, when sprinkling all other quarry haul roads (ESAP #3b). At the cement plant, the kiln stacks as well as the powerplant stacks will be key emission point sources. To control and monitor emissions from the kiln and the power plant stacks, these will be fitted with continuous emission monitoring equipment, capable of real-time measurement of NO2, SO2, Particulate Matter and O2. BUA will monitor these parameters from the kiln system and clinker cooler in real time and log all results so as to demonstrate compliance to the emission standards of the WBG EHS Guidelines (ESAP #3c). BUA will conduct confirmatory stack testing also known as Relative Accuracy Test Audit (RATA), to ensure the accuracy of the continuous emission monitoring data following installation of the monitoring equipment and annually thereafter (ESAP #3d).

The key point source of emissions from the power plant will be from the natural gas exhaust fired engines, which would primarily emit NOx, which will be minimized using a dry low NOx burners. Since there is very little if any sulphur in natural gas, SO2 is not expected to be released from the stacks.

Predicted concentrations for PM10, PM2.5, SO2 and NO2, were simulated for Lines 4 and 5 and their associated power plants using the USEPA-approved AERMOD dispersion modeling package. Impacts associated with Line 3 and other on-going plan operations were considered as part of the ambient air quality modeling since these activities were in operation during the monitoring period.

Modeling results for both PM10 and PM2.5 showed that all impacts associated with the cement plant itself were well below the applicable Ambient Air Quality Standards (AAQS). Modelled PM10 and PM2.5 within the quarry areas and the immediately surrounding area did show elevated levels. These elevated levels were very localized though and directly related to fugitive emissions associated with the quarrying activities, which will change as the quarrying activities move from one location to another. The results of the modeling indicate that the high levels of particulate matter and dust measured in the ambient air quality monitoring are not the result of the cement plant, but rather natural and due to other human activities in the general area.

Modeling results for SO2 showed all impacts to be well below the applicable AAQS for all project activities. However, both the 1-hour and 24-hour modeling results for NO2 showed a number of exceedances of the applicable AAQS both at the plant site and a number of the surrounding communities. However, the ambient air quality monitoring conducted in these areas did not show elevated NO2 concentration although both line 3 and line 4 were already in operation. BUA will continue to monitor ambient NO2 concentrations and if elevated levels, that can be attributed to the project, are detected, appropriate measures will be taken to lower emissions in alignment with the WBG EHS guidelines, and BUA will propose and obtain IFC approval for a mutually agreeable resolution with the affected communities (ESAP #3e).

Greenhouse Gas Emissions (GHG)

The total estimated CO2 emissions of the Sokoto plant after commissioning of lines 4 and 5 are expected as 4,100,578 tonsCO2eq/year including 2,899,977 tonsCO2eq/year from the Project. Of these emissions, 93% are from the clinker production, 4.9% from the on-site power generation and 2.1% from other sources such as refrigerants and mobile combustion.  The major part of total emissions is scope 1, which equates 0.61 tonCO2/ton cement (without emissions from captive power and fleet). Total emissions equate to 0.69 tonCO2/ton cement.  Going forward, BUA will develop and implement a GHG emissions monitoring and reporting system in alignment with GIIP, including a GHG emissions reduction plan.  The plan will define technical and financially feasible options and apply Best Practical Environmental Options (BPEO) to achieve a reduction in Project related GHG emissions (ESAP #3f).

Noise and Vibration Management

Noise will be generated by operation of plant equipment, quarrying activities, and Project traffic. BUA will implement a Noise Management and Monitoring Plan that will detail the avoidance, management, monitoring and mitigation approach at sensitive receptors where additional noise from the plant results in the WBG EHS Guideline limits to be exceeded, including where there is an increase above baseline levels greater than 3 dBA. Ambient / environmental noise monitoring will be undertaken on an ongoing basis to verify the efficacy of the proposed mitigation measures (ESAP #3g).

No vibration impacts are anticipated given no blasting is required by quarrying activities.  However, the Noise Management and Monitoring Plan (as well as a Blasting Management procedure) will be updated / developed if blasting is required in the future.

The noise assessment undertaken as part of the ESIA confirms the BUA expansion which includes Lines 4 and 5 will increase existing noise levels and negatively impact communities in the immediate area. With Lines 3, 4 and 5 in operation, overall Plant operations are estimated to increase the 3 dBA impact range from 1,100m to 1,300 m. This zone includes the communities of Gantsare, Gidan Kuka and Gidan Gamba. Due to their proximity to Lines 4 and 5, impacts of 5 to 7 dBA are expected to occur in in Ganstare and Gidan Kuka (to the west) and 7 to 12 dBA at Gidan Gamba (to the east), above nighttime ambient noise levels. As such, BUA will mitigate the elevated noise levels in these communities and other communities where noise impacts exceed 3 dBA by using the services of a qualified acoustic engineer consultant to define engineering design solutions to reduce the noise. The outcomes of the solutions will be monitored as part of the Noise Management and Monitoring Plan. Should noise levels continue to consistently exceed the thresholds, as per WBG EHS Guidelines, BUA will propose and obtain IFC approval for a mutually agreeable resolution with the affected communities (ESAP #3g).

Extension of the Quarry and relocation of operations to the two new mining areas will expand the BUA noise footprint to the south and west. Added to this, is the noise footprint of the overland conveyor. The extended noise footprint of future mining operations has the potential to impact communities not previously affected by BUA operations.

Mining in the two new quarry areas could potentially affect communities up to a distance of approximately 350 m from the quarry site boundaries. However, since mining is a roaming operation, such impacts will only occur for the duration that mining takes place near site boundaries adjacent to communities. This lowers the probability and duration of risk. Located within the range of potential impacts above 3 dBA are the Adarawa and Gumbi communities. Mitigation measures to minimize elevated noise levels associated with quarry activities will be developed by the acoustic engineer consultant as per (ESAP #3g) and included in the Noise Management and Monitoring Plan.

Equipped with standard steel rolls, noise from the conveyor connecting the two new quarries to the plant, will affect communities up to distance of approximately 500 m from the proposed new conveyor route. Located within range where impacts could increase by more than 3 dBA due to conveyor noise are the Asara, Gidan Badua and Gidan Mai Tuta communities. Similarly, BUA will develop effective mitigation measures that will minimize adverse noise impacts associated with the conveyors as to be recommended by the acoustic engineer consultant and included in the Noise Management and Monitoring Plan as per (ESAP #3g).

Mitigation measures for noise will be implemented in a phased approach, commencing with the identification of noise hot spot areas and sources nearest to the affected communities. This will be accompanied by a noise monitoring program. For the areas around the Plant, the noise reduction target and mitigation requirements are determined by conditions in the two worst-affected areas west (Gantsare and Gidan Kuka) and east of the Plant (Gidan Gamba).

The two main types of noise sources contributing to Plant noise are the various mills and fans of which there are many distributed over a large area. Milling noise can be mitigated by enclosing mills in steel-clad or brick buildings with the percentage of open areas limited to 15 %. Some building access doorways may need additional noise screening. Given that Crushers are installed in pits and that they will not be operating at night, no additional screening should be required. Mitigation of fan noise will require installation of sound attenuators and screening, which will be defined by the acoustic engineer consultant and in collaboration with the relevant suppliers to ensure fan efficacy is not compromised. Mining noise can be mitigated by construction dumps shaped to create a berm on top of the dump. A substantial and sufficient reduction in conveyor noise can be achieved by construction of noise screening walls and by installation of low-noise machined steel rolls, or low-noise HDPE idler rolls, instead of standard steel rolls.

Solid Waste Management

Non-hazardous solid waste generated by the Project includes wood, packaging waste, plastics, metal, domestic and office waste. Hazardous waste consists mainly of used oil and grease, chemicals and additives (including empty containers) and medical waste. Some hazardous waste is disposed on-site (e.g., incineration of medical waste at the kilns). In addition to its own medical waste, BUA also incinerate medical waste from medical facilities in the region. BUA shall develop and implement a Solid Waste Management Plan, in compliance with the PS’s and WBG EHS Guidelines (ESAP #1b).

Wastewater

Process wastewater associated with the cement production is low as water is reused in a closed circuit and therefore replenishment is only required due to evaporation or accidental losses. Domestic effluents from the plant site offices and camps are discharged through soakaway, which may result in soil and groundwater contamination. As part of the expansion, BUA will recruit an external wastewater treatment consultant (acceptable to IFC as per agreed timelines) to develop a Wastewater Management and Monitoring Plan for the entire site, inclusive of a time-based action plan for implementation (ESAP # 3h).  This will include the approach to ensuring installation of oil water separators and grease traps, as necessary, to manage contaminated stormwater from vehicle parking areas, secondary containment areas, mechanical workshops and kitchens. This plan will also recommend fit for purpose sewage treatment plants to be procured to manage the sewage generated at the SKP (e.g., camps and offices).

Hazardous Materials Management

The main hazardous materials in cement production includes fuel (oil, diesel, LNG), chemicals, additives and engine oils and lubricants.  BUA shall develop and implement a Hazardous Materials Management and Monitoring Plan that will define the approach to transport, handle and store hazardous materials, including provisions related to storage of non-compatible materials, a hazardous material register, provision of material safety data sheets (MSDS), spill kits and OHS requirements (e.g., PPE requirements, eye wash stations, emergency showers, etc.,) (ESAP #1b).

A considerable volume of hydrocarbons is stored on site. The use of hard-standing and secondary containment is evident for large storage tanks, but not for smaller storage tanks, intermediate bulk containers (IBC), mobile equipment, and oil/lubricant drums. As per (ESAP #3i), BUA will ensure the provision and/or integrity of hard-standing and secondary containment around hydrocarbon storage vessels (including for such materials at workshops). The integrity of secondary containment will be enforced and regularly monitored, at all locations where hazardous liquids are stored (openings to evacuate rainwater were observed perforating the containment walls of secondary containment bunds, at some locations).

BUA has extensive fuel storage facilities at the SKP along with workshops in support of plant and vehicle maintenance.  Thus, there is the potential for land contamination and soils affected, as spills were observed on-site.  Similarly, the ESIA identified that grease is being inappropriately disposed.  The Project will therefore undertake a full site survey to assess existing land and groundwater contamination according to American Society for Testing Materials (ASTM) Phase I and II Environmental Site Assessment (ESA) approach or equivalent. Thereafter, BUA will implement the assessment findings as deemed applicable (ESAP #3j).

While the SKP has developed channels and flow paths to manage stormwater, this needs to be enhanced. On the northern side of the plant stormwater discharges in an uncontrolled manner onto agricultural land within the river floodplain. Any incidental spills that enter the stormwater could result in offsite contamination as has occurred in the past. BUA will thus develop, design and implement a stormwater water management system for the SKP that ensures appropriate collection of stormwater and separation of potentially contaminated stormwater from clean stormwater (ESAP #3k). Stormwater discharges will be controlled and monitored as per the Wastewater Management and Monitoring Plan (ESAP #3h).

The Pollution Prevention and Spill Response Management and Monitoring Plan as referenced will also outline the preventive control measures to avoid, minimize and respond to any future land or ground water contamination (ESAP #1b).

Erosion, Sediment Control and Reinstatement

BUA is progressively back-filling excavated areas of the limestone quarries to rehabilitate sections of the quarry that no longer hold limestone deposits.

BUA shall develop and implement an Erosion, Sediment Control, Restoration and Rehabilitation Management and Monitoring Plan, to guide rehabilitation and prevent sedimentation and erosion, particularly of soil storage stockpiles, graves sites that have been preserved, roads, embankments, drainage discharges, etc., (ESAP #1b).

The SKP has communities located directly adjacent to both the eastern (Gidan Gamba) and western (Gantsare and Gidan Kuka) boundary, with further communities near the southern boundary of the existing quarry (Gidan Boka and Gidan Marafa).  In the future, with the expansion of the operational quarry and the opening of two further quarries, additional communities could be impacted. The proximity of the closest communities to the plant and quarry could expose them to potential health and safety risks, including that associated with emissions (dust and particulate matter), noise and road safety risks.

Furthermore, BUA do not currently control quarry access which also poses a risk to local communities who sometimes utilize the quarry water bodies for swimming and fishing.  To address this risk, BUA will develop a community safety operational procedure for the quarries that will include requirements related to; i) the need to  undertake regular surveys as the quarries are developed to identify high risk areas; ii) the erection of warnings signs to dissuade and restrict unauthorized access; iii) the need to fence high-risk / accessible areas (e.g., excavations adjacent to or near communities, equipment transiting roads, locations where equipment is working, locations where water has ponded, etc.,); and iv) and continuously monitor community access. The community safety procedure will also define how BUA will provide safe passage to community members who wish to access grave sites within the SKP footprint (ESAP #4a).

An open area on the eastern side of Kalambaina road near the main plant entrance is used by local gypsum suppliers to offload and sort gypsum to ensure that only suitable grades provided to the SKP. BUA will thus also include requirements in the community safety procedure referenced above to control pedestrian and truck movements associated with this open area. In addition, the procedure will also include necessary controls to manage dust, waste and additional land take associated with this area (ESAP #4a).  Similarly, as part of their Erosion, Sediment Control, Restoration and Rehabilitation Management and Monitoring Plan (ESAP #1b), BUA will reinstate land associated with this area that is not utilized. The delivery of gypsum will also be governed by the Supplier Code of Conduct as per (ESAP #2b), to ensure that appropriate supply chain E&S risks are duly considered with this activity.

The current LNG storage capacity of 2,700 m3 will be increased by additional 5,000 m3 as a result of the Project.  The QRA undertaken for this facility concludes that to protect the public from potential hazards, when expanding the current LNG storage facility, a minimum distance of 180 meters between the LNG boundary fence and the closest communities must be maintained.   Currently the distance to communities is approximately 250m.  Therefore, BUA will ensure the minimum separation distance between the storage tanks and communities is maintained (ESAP #4a).

Noise and Dust

BUAs expansion activities will increase existing noise levels, resulting in potential impacts to neighboring communities such as Gantsare and Gidan Kuka to the west of the SKP, and Gidan Gamba to the east. In addition, the extension of the quarry and relocation of operations to the two new mining areas will expand the BUA noise footprint to the south-east, potentially impacting communities not previously affected by BUA operations (refer to PS3 for more information on the nature of the impact). Thus, as noted above BUA will develop and implement a Noise Management and Monitoring Plan (ESAP #1b) detailing their approach to noise mitigation and monitoring.

BUAs operations, including quarrying, limestone hauling, crushing, bagging etc. are an ongoing source of fugitive dust generation. In addition, the SKP, and neighbouring communities, are impacted by the West African Harmattan system, resulting in naturally high dust concentrations. As described under PS3, modeling results for both PM10 and PM2.5 showed that all impacts associated with the cement plant itself were well below the applicable AAQS, while modelled PM10 and PM2.5 within the quarry areas and the immediately surrounding area did show localized elevated levels. BUA will continue air quality monitoring as part the company’s site-wide monitoring program, as well as implement mitigation measures as described under PS3.

Communities will be able to report grievances related to noise and dust via the grievance mechanism developed and implemented as part of the Stakeholder Engagement Plan.

Influx Management

BUA is the primary employer within the Wamakko Local Government Area (LGA) as well the provider of services such as water, electrical connectivity and social infrastructure to communities. Thus, communities experience influx from people seeking employment opportunities and other perceived benefits in the area. In addition, the plant is experiencing encroachment on both the eastern and western boundaries from people seeking to benefit from future resettlement requirements associated with the Project.

Influx is likely to continue as local employment opportunities increase from construction of line 5.  Unmanaged influx will place additional strain on resources such as land and water, housing, healthcare, and potentially result in an increased communicable diseases and competition for jobs. While BUA’s ability to manage the occurrence of influx and people establishing residences in proximity to the site is not entirely within the Company’s control, they have developed and will implement an Influx Management and Monitoring Plan as a component of their ESMMP (ESAP #1b) covering areas of local recruitment, stakeholder engagement, grievance management and the management of influx induced impacts.

Transportation Safety

SKP own and operate a fleet of 700 trucks used to transport cement and collect raw materials. This fleet will be increased by over 500 trucks. All logistics, driver management, training etc., are managed by BUA Transport.  As noted, truck drivers are provided by a third-party labor broker; however, ongoing training and drug testing of drivers is managed by BUA Transport. BUA Transport have a journey management office on site and have installed an IVMS in all trucks which includes real time GPS tracking. In addition, BUA Transport noted that all trucks have speed governors limiting them to 60 km/hr. All drivers are provided with ongoing training by the Nigerian Department of Transport, while BUA Transport conduct periodic drug and alcohol testing. BUA have a “no night driving” policy in place. In addition to trucks operated by BUA, numerous third-party trucks collect cement from the plant daily.

The traffic impact assessment undertaken as part of the ESIA determined that existing traffic conditions and road infrastructure in the plant vicinity are acceptable with no upgrades required. This includes the main truck entry and exit points. The traffic impact assessment also determined that defined routes through Sokoto are currently suitable.  BUA trucks awaiting departure are parked within the BUA complex and have limited interface with local communities. Third-party trucks awaiting access to the plant are parked along the main access road where small informal commerce have been established to service the truck drivers.

As a component of their ESMMP (ESAP #1b), BUA will develop a Traffic and Transportation Management and Monitoring Plan. The plan will include a Road Traffic and Driver Safety (RTS) procedure, consistent with GIIP and the relevant sections of the WBG EHS Guidelines, to manage potential impacts and risks emanating from road traffic accidents, as well as the presence of truck drivers in and around the local communities. The RTS procedure will ensure drivers are trained in defensive driving and include, as a minimum: i) driver, vehicle and journey management procedures; ii) the approach to ongoing training, iii) risk assessment of transport routes and geo-fencing; iv) monitoring, supervision and audits v) incident investigation and reporting; and vi) leading and lagging indicators.  The Company will also develop suitable driver recognition and sanction to engender appropriate driver behaviour.  This plan together with the community safety operational procedure for the quarries will also define the approach to ensure adequate parking / staging area for third party trucks collecting cement, as well as vehicle movements within the quarry and from the quarry to plant. Where there is a risk to the local community, pedestrian and vehicle movement segregation will be required as well as regular local community awareness raising campaigns.

Further, given the number of road traffic accidents over the last three years, BUA will also engage a suitably qualified consultant to undertake: i) a review of traffic accidents over the past 3 years; ii) an evaluation of the approach to journey management;, iii) an assessment of driver competency and driver training;  iv) an analyses of the IVMS;  and, v) a corrective action plan based on the findings of the above, including measures to be undertaken to address any gaps as well as assess enhancements required to the IVMS  (ESAP #4b). The outcome of this assessment and review will also inform development of the Traffic and Transportation Management and Monitoring Plan (ESAP #1b).

Security Personnel

BUA’s security is managed by a Chief Security Officer (CSO) supported by a deputy CSO who reports to the HR Director. The Company currently make use of both private and public security forces. Private security is provided by a third-party contractor who provide security personnel across three daily shifts. Each shift includes a security manager, operations officer, senior security guards and guards. Private security is predominantly responsible for access control and monitoring of strategic points around the plant. The CSO monitors the performance of private security on an ongoing basis, though the approach is not formalized.

Private security is supplemented by government security forces. The extent of the support is based on a security assessment by local government. Public security personnel are currently provided to BUA from both the civil defence and mobile police units. The Government is responsible for payment of salaries, provision of uniforms and training, while BUA are required to provide accommodation on site and a daily allowance. These security forces are armed and provide general security around the plant. BUA do not have a formal Memorandum of Understanding with public security forces; however, they are managed under government security standard operating procedures, including the proportional use of force.

BUA have not reported any significant security incident at the plant to date. Considering the dynamic security environment as well as the extensive use of private and public security, BUA will undertake a security risk assessment that will form the basis to develop a Security Management and Monitoring Plan aligned with the requirements of PS4 and the Voluntary Principles on Security and Human Rights. This includes prescriptions for guard selection, rules of engagement (including minimum force), training, equipment, facilities, working conditions, and grievance management. Site security arrangements, including the deployment of public security, will be informed by annual security risk assessments (ESAP #4c).

A Heritage Impact Assessment (HIA) was undertaken as part of the ESIA to identify potentially impacted tangible cultural heritage and detail appropriate recommendations regarding the approach to responsible cultural resource management measures.

The HIA identified 16 existing cemeteries within the current Project footprint, with an additional two in close proximity. Most of these cemeteries are within the existing quarry footprint. To retain these sites, BUA has taken necessary efforts and either conserved the grave sites within the quarry or fenced impacted sites within the line 3 and 4 footprint. The HIA also identified intangible cultural heritage, such as local rituals and ceremonies undertaken by communities. These are not likely to be impacted by the Project. No sites within the Project footprint were noted for outstanding universal value or identified as critical cultural heritage.

Project construction activities, particularly the quarry expansion, may result in damage to existing tangible cultural heritage sites. Community access to sites within the quarry is also currently limited. As a component of the ESMMP (ESAP# 1b), BUA will develop a Cultural Heritage Site Development Plan that addresses protocols for safe access to burial sites, avoidance protocols, in-situ preservation of known sites, monitoring procedures and contractor management. BUA will also adopt a Chance Find Procedure (ESAP #1b). Contractors and employees will be sensitized to the procedures in case of a discovery of archaeological resources during land-clearance and mechanical excavation activities.

As defined in the SEP, BUA will ensure all impacted communities are aware of the Project impacts on cultural heritage, as well as proposed management measures. Should future resettlement be required, any further impacts to tangible cultural heritage will be managed in accordance with the Resettlement and Livelihood Restoration Policy Framework as well as the Cultural Heritage Site Development Plan (ESAP #5b/1b).