IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Policy: IEFCL maintains an overarching E&S policy, consistently guiding the management of E&S issues across all operations in line with the principles of the PSs. The policy has been founded on values of integrity, excellence, responsibility, and respect, demonstrating IEFCL's commitment to conducting business in a responsible and ethical manner. The E&S policy is designed to ensure safe and healthy working conditions, prevent work-related injuries and occupational diseases for employees, contractors, and stakeholders, and minimize environmental impact.
Environmental and Social Management Systems and Management Programs: IEFCL has established an operational Environmental and Social Management System (ESMS), aligned with the requirements of PS1, for the existing operations of Lines 1 and 2. This ESMS, with over 50 environmental health and safety (EHS) procedures (such as hazardous materials management plan, permit to work, management of change, waste management, and more), social policies (including community/stakeholder management policy, community grievance management, HIV/AIDS policy, and security management plan), EHS risk assessment processes, a medical surveillance program, and several other integral components, will be extended and applied to Line 3, per ESAP #1a.
An incident reporting system, an EHS monitoring program (in-house and third-party including occupational hygiene, air emissions, ambient air, environmental noise, wastewater sampling, soil and groundwater monitoring), EHS inspections and audits, and an EHS training program, among other features, are included in the existing ESMS. Furthermore, health and safety committees that include worker representatives have been established, and contractor management processes are also implemented. EHS awareness mechanisms, such as signage, posters, daily "toolbox talks", and EHS awareness competitions, are actively utilized.
For the construction of Line 3, the procedures will be identical to those of Line 2 given IFCL’s engagement the same construction contractor, Daewoo Nigeria Limited, used for previous phases, along with similar facilities being constructed. The selected contractor possesses a well-developed formal EHS management system with an EHS policy, over 30 EHS procedures, a construction site EHS inspection program, and documented permit to work system, among others. Consistent with previous contracts, the contract between IEFCL and the selected contractor for the Line 3 construction, will specify the processes and formal procedures that the selected contractor will develop to meet the EHS and social (EHSS) requirements, including compliance with the company’s ESMS, labor requirements, policies, and procedures.
In addition to these, IEFCL has developed the "HSE Management Plan for Fertilizer Line 3 Project" (dated 01 April 2023) to promote the health, safety, and environment of persons working with Indorama, the EPC Contractor, subcontractors, and other stakeholders. This specific HSE plan provides guidelines for the safe execution of the project and outlines general technical guidelines and systems that contractors, subcontractors, and other stakeholders are required to follow during engineering, design, construction, commissioning start-up, operation of Line 3. As part of IFC’s financing, the Line 3 contractor shall develop comprehensive HSE procedures, policies, and site -specific E&S management plans (ESMPs) construction phase of the Line 3 project, per ESAP #2.
As the Line 3 jetty is scheduled for commissioning in November 2025, an ESMS will be developed for the construction and operation of the facility, per ESAP #1b. The specifics of this system will align with the requirements of PS1 and established standards and practices, ensuring the health and safety of stakeholders and the minimization of environmental impacts. The ESMS will also take into consideration the findings, management, and mitigation measures proposed in the ESIA (as required under ESAP #3a)
Identification of Risks and Impacts: The Line 3 project builds on previous ESIA studies for Lines 1 and 2. To ensure the ESIA process aligns with good international industry practices and IFC's PSs, IEFCL commissioned an international consultancy in July 2021 to guide the ESIA development process and assure quality. The Terms of Reference (ToR) for the project were approved by the Federal Ministry of Environment (FMEnv) in October 2021. Subsequent to this approval, infield wet season baseline data collection was carried out. The draft ESIA has been presented to the FMEnv, as disclosed alongside this ESRS, and will be finalized per ESAP item #3b.
The ESIA offers a detailed outline of the actions to be taken throughout the project, along with an assessment of potential project impacts on elements such as air quality, soil and geology, groundwater, surface water, biodiversity, and socio-economic factors. It also features a detailed Environmental and Social Management and Monitoring Plan (ESMMP) that encapsulates 13 Environmental and Social Management Plans to mitigate project related impacts. These plans address a range of issues including climate change, air quality, soil and erosion, groundwater, surface water, biodiversity, socio-economics, cultural heritage, traffic, employment and procurement, community health and safety, waste management, and spill prevention, control, and containment. As part of IFC's financing, IEFCL shall undertake a Cumulative Impact Assessment (CIA) that assesses assets under the institutional control of Indorama Nigeria at the Eleme facility (Indorama Eleme Petrochemicals Limited (IEPL) and IEFCL), per ESAP item #3c. The conclusions of CIA study will serve to inform subsequent expansion phases and will be used to inform and if relevant, revise the project operational ESMPs, if any.
At the point of this disclosure, an ESIA process for the construction and operation of the Line 3 jetty in line with national legal requirements and IFC PSs has commenced. A document outlining the ToR for the ESIA studies, including an evaluation of risks associated with bulk ammonia storage, off-loading, and ship loading, has been submitted to the regulatory authorities. The completion of this ESIA process is anticipated by February 2024 and shall be undertaken in a manner consistent with PS requirements, per ESAP #3a.
Process safety assessments (HAZOP/HAZID/QRA) were previously conducted for Lines 1 and 2, with all recommendations from the reports actioned. Process safety assessments (HAZOP/HAZID/QRA) that examine the risk related to process hazards for the Line 3 project will be addressed as per ESAP #3d. The anticipated increase in the bulk ammonia truck fleet due to the operation of Line 3, and the risks it presents, will be comprehensively assessed in accordance with ESAP #3f.
Monitoring and Review: As referenced previously, an ESMMP has been developed for Line 3, building upon the established plans for Lines 1 and 2. This plan details the activities and associated management measures for both the construction and operational phases, including the timing and frequency of the monitoring, as well as the performance indicators for each. The ongoing independent E&S monitoring of Line 2 will be expanded to include Line 3. This will include semi-annual monitoring visits during construction, and annual visits during operation.
In parallel to the practices established for Line 1 and Line 2, Line 3 will adhere to a thorough established EHS monitoring program. This program, conducted both in-house and by third parties, encapsulates key aspects such as occupational hygiene, air emissions, ambient air, environmental noise, wastewater sampling, soil, and groundwater monitoring, and EHS inspections and audits. The management and mitigation measures identified in the ESMMPs will be housed within this EHS monitoring program, forming an integral part of the ongoing monitoring and review activities for Line 3 as outlined in ESAP #4.
For the Line 3 Jetty, a detailed monitoring program (including for the marine environment) has been included and defined as per the TOR for the ESIA. This program dictates the scope, parameters, frequency, location, and methodology of monitoring practices. Auditing and inspection procedures have also been incorporated.
Organizational Capacity and Competency: IEFCL maintains an established Environmental, Health, Safety, and Social (EHS&S) Department, led by an EHS manager who reports directly to the Chief Technical Officer. Existing resources within the EHS&S Department demonstrate the necessary skills and experience required of their relevant positions. IEFCL is seeking to install an operational organizational structure which mirrors the well-resourced structure in place for Lines 1 and 2. The operation is directed by a Head of Safety, who is supported by a team of Health, Safety, Environmental, and Fire (HSEF) Coordinators, Safety Engineers, Safety Supervisors, and dedicated admin/support staff. IEFCL extends this commitment to safety and environmental responsibility to its contractors, as reflected in the EHS team that was maintained by the contractor during the construction phase of Line 2. Indorama is seeking to replicate this for the construction of Line 3. Beyond the internal capabilities, IEFCL also retains external consultants for specialized tasks such as environmental assessments, environmental audits, and environmental monitoring, to ensure a comprehensive and well-equipped approach to the management of EHS matters is undertaken.
Emergency Preparedness and Response: IEFCL has documented an Emergency Management Plan (EMP) covering a diverse range of potential emergency scenarios, including fire, explosions, medical emergencies, environmental emergencies, those affecting surrounding communities, and natural disasters. This EMP, currently utilized in Lines 1 and 2 operations, will be expanded, and integrated into Line 3 and will include contractor provisions, per ESAP #1a.
The company maintains a dedicated 24/7 Fire Safety team and participates in the industry-organized Emergency Response Mutual Aid Organization. The company conducts quarterly emergency drills and training, and the operation is equipped with fire suppression systems and alarms consistent with good international industry practice design. In addition, the Line 3 Jetty's emergency response will be integrated into its ESMS, per ESAP #1b.
The selected contractor is expected to strictly adhere to the "HSE Management Plan for Fertilizer Line 3 Project," a document developed by IEFCL. This plan defines a variety of emergency scenarios requiring regular evaluation and updates. The contractor is also required to maintain and test emergency procedures, establish contingency plans, conduct regular inspections of emergency equipment, and execute training programs focused on first aid and emergency response procedures.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures: IEFCL currently have a Human Resources (HR) management system in place, managed by the HR and Industrial Relations department. The HR management system is aligned with the requirements of PS2 and includes various policies and procedures relating to employment and working conditions, all of which are detailed in the Employee Handbook and Induction Handbook. These include an Ethics Policy, Non-Discrimination Policy, Child Labor Prohibition Policy, Human Rights Policy, and Gender Based Violence and Harassment (GBVH) Policy among others. 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.
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. As per the Nigerian Labor Act, and consistent with the requirements of PS2, all direct workers are provided with a written contract of employment upon joining the company.
As detailed, IEFCL have developed and are implementing a GBVH and Harassment Policy. The requirements of the policy are included in the updated employee and induction handbooks. In addition, the company also have a Women Working Committee. The company has engaged a short course provider to undertake Gender Diversity / GBVH training to the Women Working Committee, select supervisors, and heads of departments (HODs).
In addition, IEFCL will also provide training to the female representatives on the grievance sub-committee relating to the management of gender sensitive grievances and reports of GBVH (see ESAP #5).
Working Conditions and Terms of Employment: IEFCL currently employ a total of 378 direct and contract workers across the existing Line 1 and 2 operations, with a 98% to 2% male to female ratio. The existing workforce is split into three categories, namely, junior, senior and management staff. The Line 3 project is expected to provide short term employment to approximately 5,000 workers during construction, and 172 workers during operations. IEFCL anticipate the majority (88%) of Line 3 direct and contract workers during construction will be sourced locally, while the remaining 12% will be expats.
Currently, management and admin staff are contracted to work eight hours a day, five days a week, while shift work is determined by operational requirements, and either broken into two twelve-hour shifts or three eight-hour shifts. Both admin and shift workers are provided with a 1-hour lunch break and provided with overtime as required. As per the Employee Handbook, all employees are entitled to leave (annual, sick, maternity, examination, casual and compassionate leave). IEFCL currently pays all workers well above the national monthly minimum wage. In addition, the company and workers contribute towards a pension fund and the National Housing fund.
IEFCL provides all workers, including spouses and children, with free medical insurance coverage and annual health assessments. Medical services are provided to employees and their families through a network of 477 hospitals across the country. In addition, IEFCL also has a fully equipped on-site medical facility that provides both occupational and primary health care, as well as provisions for emergency treatment, and three ambulances. The facility is manned by 20 staff.
IEFCL 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 HSE awareness training.
Worker Accommodation: IEFCL currently provide accommodation to expat and senior workers (both direct and contractor). This is provided at six existing six prefabricated units with a total of 182 rooms, and the ability to accommodate up to 416 workers. The accommodation is aligned with the IFC/EBRD Guidance Note on Workers’ Accommodation, and includes ensuite ablutions, leisure, and recreation facilities, cooking and dining areas, and a canteen. As noted, the majority of the construction workforce (approximately 91%) will be sourced from the local communities, and hence will not require accommodation. Where construction workers do require accommodation, the contractor will provide workers with a housing rental allowance as well as transportation to and from the site. As per existing requirements, the contractor will be required to conduct audits of the accommodation and associated facilities on a three-monthly basis during the construction and operation of Line 3.
Workers’ Organizations: As detailed in the Employee Handbook, all labor and working conditions at IEFCL, for both direct and contract workers, are governed by local labor law, including the Trade Unions Act, which promotes freedom of association and collective bargaining. Currently 97% of all company employees are unionized across two trade unions. Junior staff and contractors are represented by the National Union of Chemical Footwear Rubber Leather and Non-Metallic Products Employees (NUCFRLAMPE), while senior staff are represented by the Chemical and Non-Metallic Products Senior Staff Association (CANMPSSAN).
Employment terms and conditions are regulated through existing (expiring August 2023) Collective Bargaining Agreements (CBA) with both unions. 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, and benefits.
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 discrimination based on race, color, age, sex, religion, disability, ethnicity, national origin, regional origin, marital status, or 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.
Grievance Mechanism: IEFCL have a policy framework on grievance management and anti-retaliation that is broadly consistent with IFC PS2 and good international industry practice. This includes a worker grievance procedure (detailed in the Employee Handbook and existing CBAs), grievance register, and ongoing training and awareness raising. The mechanism covers both direct and contract workers and 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.
In addition to the above, IEFCL has developed and are implementing an Anti-Retaliation/Retribution Policy. The policy commits IEFCL to a grievance management approach free from retaliation and victimization, identifies possible retaliation risks across the operation, and defines appropriate capacity building requirements.
Protecting the Workforce: As per the company’s Child Labor Prohibition Policy, and emphasized in the Human Rights Policy, IEFCL 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.
Occupational Health and Safety (OHS): Line 1 and Line 2 have demonstrated satisfactory OHS performance dating back to 2017, resulting in a cumulative LTIFR of 0.01. For the Line 3 project, the selected contractor is mandated to adhere to safety standards comparable to those enforced during Line 2's construction. Notably, the Line 2 project experienced no fatalities or lost-time injuries (LTI), a performance record that is competitive when measured against international industry benchmarks for large construction projects.
The construction phase will be governed by the Health, Safety, and Environment (HSE) Management Plan established for Line 3. This plan includes specific protocols and requirements related to health and hygiene, scaffolding, ladders, excavations, cranes and lifting, fall protection equipment, electrical safety, traffic safety, and defensive driving. The plan also necessitates an awareness and training program, an inspection and auditing program, an accident and investigation process, an emergency preparedness program, and adherence to general site rules.
Independent monitoring of Line 2's construction (completed by the same contractor appointed for the Line 3 project) provide a reference point for anticipated conditions and practices for Line 3. Results consistently demonstrated adherence to safety regulations and an understanding of emergency procedures. Additionally, fire safety measures were effectively implemented, with regular conduct of emergency drills.
Regarding operational management, the OHS management plans implemented for Lines 1 and 2 will be applied to Line 3 per ESAP #1a. Line 3's operation is intended to mirror the standard of workplace conditions achieved during the operations of Lines 1 and 2.
The Line 3 Jetty project will emphasize a stringent adherence to OHS measures as per the ESIA TOR. The ESIA process will involve a thorough assessment of compliance with health and safety regulations, and the formulation of appropriate mitigation strategies (ESAP #3a).
Workers Engaged by Third Parties: As per the Independent Contractors’ Policy, IEFCL classifies independent contractors as workers who are not directly managed by the company. As a component of this policy, IEFCL requires all workers engaged by third parties to comply with the company’s guidelines as detailed in the Employee Handbook and all relevant policies. While IEFCL require their contractors to implement their own grievance management mechanism, contract workers do have access to IEFCL’s grievance management procedure as required.
Currently, IEFCL utilizes three community-based third-party labor agents for Line 1 and Line 2, and it is anticipated that the same agents will be used for Line 3. The Contract Labor Cell are charged with monitoring the activities of the labor agents. It is anticipated that IEFCL will utilize the same contractors for the Line 3 primary construction, engineering, and power requirements, hence will be familiar with the E&S requirements of the company.
PS3: Resource Efficiency and Pollution Prevention
Greenhouse gases (‘GHG’): The Line 3 project has developed a GHG strategy which focuses on reducing GHG emissions. This strategy aligns with Nigeria's Long-term Vision 2050 (LTV 2050), which defines targets for transitioning to a low-carbon, climate-resilient economy. The Line 3 project is expected to significantly reduce flaring of associated gas by approximately 90 million standard cubic feet per day, leading to a material reduction in GHG emissions — approximately 2,100 kilotons per annum (KTA) of CO2 equivalent over the lifetime of the plant operations, in line with the country's Nationally Determined Contributions (NDC).
Indorama has further designed a roadmap for a 32% reduction in GHG emissions from the 2022 baseline by 2026 across the complex. This roadmap includes 36 targeted improvement schemes spanning operation improvements, new hardware installations, and process modifications. For the IEFCL segment alone, these schemes are expected to yield a CO2 reduction of approximately 474 KTA. The Line 3 ESIA estimates the project's CO2 emissions to be around 688 KTA annually. Nevertheless, the planned phased reduction of CO2 emissions, totaling approximately 721 KTA over the next four years across both IPL and IEFCL, ensures that Line 3's launch will not increase the overall carbon footprint of the Indorama complex. This strategy further manages GHG emissions while expanding operations, consistent with the objectives of Performance Standard 3 for GHG emissions reduction. As part of IFC’s financing, IEFCL shall periodically report progress against its GHG roadmap by way of its annual monitoring reporting requirements.
Resource Efficiency Energy and Material Efficiency Projects: The Line 3 Project continues to prioritize resource efficiency, utilizing advanced technology and methodologies to maximize energy and material efficiency. The construction phase of the project will require approximately 2 MWh of electricity, which will be supplied by the existing captive on-site natural gas power generating units at the Indorama complex.
Upon operational commencement, electricity demands will be predominantly met by Indorama's gas-powered generators currently serving the complex. These generators have been confirmed as sufficient to meet the electricity requirements of Line 3 following a comprehensive gap analysis conducted by Indorama. To guarantee consistent power supply, even during maintenance periods, a new 30 MW gas turbine unit will be integrated into the existing system as part of the Line 3 construction.
Similarly, the Line 3 Jetty's electricity will be generated in-house, powered by natural gas-fired generators totaling 3.3 kV. The natural gas will be safely stored on-site, with specific details on generator capacity and natural gas volume determined based on the site's peak demand.
Air Emissions and Ambient Air Quality: The Line 3 Project will result in air emissions and impacts to ambient air quality during both construction and operation. The main sources of atmospheric emissions during construction will include site preparation activities, general construction activities for Project infrastructure, vehicle movement over unpaved surfaces, and vehicle exhaust emissions. Appropriate mitigation measures have been identified that should reduce potential impacts to negligible. Contractor work sites will be monitored during construction, under the guidance of key IEFCL environmental and social resource persons who will be responsible for reporting the monitoring of the E&S issues.
Available ambient air quality data supports the determination that the airshed in the area of the Project is in compliance with applicable national ambient air quality standards and therefore non-degraded. The use of natural gas as a feedstock result in nitrogen oxides as the primary emission from the facility, with very limited particulate matter and essentially no sulfur dioxide. Results of dispersion modeling using the AERMOD model showed all impacts to ambient air quality to be less than ten percent of the applicable national ambient air quality standard. As per ESAP 3b, IEFCL shall augment the ESIA air quality section with an additional detailed description of the air quality dispersion modeling process, revise the section on ambient air quality to include additional data collected by IEFCL, demonstrate compliance with GIIP requirements for stack height and address monitoring requirements during operation.
Ambient air quality data has been presented that incorporates impacts associated with both Lines 1 and 2 and the adjacent facility. These data show that cumulative impacts of these existing facilities, along with other residential, commercial, industrial, and natural sources result in a non-degraded airshed.
Water Usage and Wastewater Treatment: During the construction phase of the IEFCL Line 3 Project, the total water demand is projected to be approximately 230,000 m3. This will be sourced from existing supplies within the Indorama complex operation. During the operational phase, the estimated water demand is around 710 m3/hr. This will be met using water from existing boreholes within the Indorama complex, complemented by two additional boreholes that will be developed. An independent groundwater study, commissioned by IEFCL, concluded that the increased extraction from these additional boreholes would not affect the aquifer recharge.
IEFCL has initiated three water-saving schemes aimed at optimizing water use. These include reducing cooling water loss, introducing an ammonia stripper for polisher bed regen effluent, and a substantial water recovery project. Collectively, these schemes are anticipated to save approximately 685 m3/hr of water, with full implementation expected by 2026.
The company currently operates a wastewater treatment system for the entire complex, including both primary and secondary treatment. The IEFCL Line 3 Project has comprehensive plans for managing various streams of wastewater. Different types of wastewaters generated during the operational phase will undergo specific treatments. These include reusing boiler and turbine condensate as boiler feed water after polishing, treating process condensates in a dedicated stripper, and specialized management of floor-washing water in the urea synthesis and granulation areas. An onsite sewage treatment plant will be established for the Line 3 Jetty.
All wastewater generated by the project is planned to be collected and treated in a wastewater recovery plant, thereby eliminating wastewater disposal during normal operation. If the wastewater recovery plant is not operational, existing IEFCL1/IEFCL2 equalization and holding ponds will serve as a contingency for temporary treatment. Daily monitoring of the Line 1 and Line 2 wastewater quality (pH, biological oxygen demand, chemical oxygen, and total suspended solids) confirms these parameters are well within national limits and those defined in the WBG EHS Guidelines for Nitrogenous Fertilizer Production. Treated wastewater will be discharged to the Okulu River.
Noise Management: IEFCL's ESIA describes the strategies to manage noise impacts during the construction and operational phases of the project. The ESIA, supported by a noise survey, concludes that noise levels at all Noise Sensitive Receptors will remain within the permissible limits established by Nigerian standards and WBG EHS guidelines. Although minor deviations during construction in night-time noise levels were detected at two locations, these sites are well outside the areas directly impacted by project activities, as established by the ESIA’s noise modelling.
As per the most recent lenders' monitoring report (June 2023), IEFCL continues to conduct monthly environmental ambient noise monitoring at five different locations outside the site. The monitoring results from January to December 2022 confirm that no measurements exceeded the WGB EHS guideline limits for residential, institutional, and educational receptors. Hence, no corrective actions were required. The company's operations, in combination with other noise sources, have not led to any significant increase in the overall ambient noise levels. No grievances have been received from the public related to environmental noise as a result of IEFCL activities.
Hazardous Materials: IEFCL continues to prioritize the safe handling and management of hazardous materials for the Line 3 Project, extending established procedures from prior projects. Throughout the construction phase, the selected contractor will be required to strictly adhere to the detailed provisions of the “HSE Management Plan for Fertilizer Line 3 Project”. The plan encompasses comprehensive guidelines for material handling and waste disposal, ensuring no hazardous substances such as paints, chemical additives, and cleaners are irresponsibly discarded or enter the water system. Measures to minimize environmental damage from machinery use and pollution from cement handling and equipment cleaning are also included.
During the operational phase, hazardous materials present will include ammonia, natural gas, urea, methyl diethanolamine, UF-85, sulphuric acid, various fuels, and other chemicals. The established Hazardous Materials Management Plan as part of the ESMS, employed successfully for Lines 1 and 2, will be expanded to cover Line 3. This plan ensures meticulous supervision, adherence to Material Safety Data Sheet guidelines, proper container labelling, storage and containment, spill control, and the implementation of robust emergency response mechanisms, among other key safety measures.
The proposed Line 3 Jetty will host bulk anhydrous liquid ammonia, urea, and natural gas. The risk and potential impacts associated with these substances will be comprehensively addressed in the Line 3 Jetty ESIA, guaranteeing adherence to safety measures and procedures to mitigate any environmental or health risks.
Waste Management: IEFCL is committed to implementing comprehensive waste management procedures for the Line 3 Project, in alignment with both the established practices from Lines 1 and 2 and the requirements outlined in the "HSE Management Plan for Fertilizer Line 3 Project". Throughout the construction phase, the contractor is responsible for establishing a waste control system addressing the management of solid waste, debris, and other byproducts. This will include regular site cleaning, correct disposal into designated bins, and recycling of recoverable materials like paper, wood, metal, and wires. Additionally, special attention will be given to hazardous waste, which must be stored in approved, enclosed areas and disposed of responsibly.
During the operational phase, Line 3 will uphold IEFCL's established waste management procedures, including the assignment of roles and responsibilities, procedures for waste handling, identification, and categorization of key waste streams, and the "3R principle" of Reduce, Re-use and Recycle. Non-hazardous waste, including solid waste, will be collected, recorded, and stored at a centralized yard, with disposal handled by Local State Government-approved contractors. Biodegradable waste will be composted at approved dump sites.
Hazardous waste, encompassing biomedical waste, oil-soaked cotton, polymer waste, and ETP sludge, will be incinerated on-site. Used oil will be disposed of by DPR-approved vendors, while spent catalysts will be shipped to Europe for precious metal recovery. Oil sludge will be disposed of at DPR/FMEnv-approved waste management facilities with thorough waste manifests.
For the Line 3 Jetty, wastes will be temporarily stored onsite before offsite disposal by government-approved land-based waste management contractors, as specified in the Line 3 Jetty ESIA TOR document.
PS4: Community Health, Safety and Security
The Line 3 Project is designed and managed to prioritize community health and safety. Adjacent communities are expected to experience minimal impact due to the advanced mitigation strategies and response plans in place. Construction activities will be managed to minimize nuisances such as dust and traffic, while operational safety measures will prevent catastrophic events from extending off-site and impacting local residents.
Specific community health and safety risks identified in relation to Line 3 operations include the potential for increased traffic during both construction and operation phases, project-induced in-migration during construction, and project-induced nuisances, primarily dust emissions, during construction. To mitigate these risks, the Project has defined the following strategies.
Transportation: The construction of Line 3 is expected to increase the transportation requirements of both construction materials and personnel, as well as bulk product delivery once operational. To manage the potential safety risks, Line 3 will implement the existing Traffic Management Plan during both construction and operation. Vehicles will be fitted with speed limiting governors (maximum speed of 40 km/hr) and GPS tracking and telematics units for monitoring speed, location, and unnecessary stops.
A 10.5 km 4-lane road, termed the Indorama-Agbonchia – Ogale – Ebubu East West Road, is currently being constructed by the State Government, running from Rivers State Industrial Park to Onne Junction. Notably, the road is exclusively state-owned and financed. While the Line 3 project has the potential to utilize this road as an alternate route for product transportation, limited truck movements necessitated by the Line 3 project could be accommodated by existing road infrastructure. Furthermore, the construction of this road is part of the State Government's broader strategy to enhance connectivity in the region, and is not directly contingent upon or essential for the Line 3 project. Given these considerations, the road is not considered to be an Associated Facility to the Line 3 project. Nonetheless, the Line 3 project aims to potentially use this road as an alternative avenue for transportation, thus mitigating congestion on the current route and consequently decreasing the likelihood of incidents. A formal transport risk assessment related to this new transportation route will be conducted and the outcomes will be addressed in the project ESMP, per ESAP #3f.
Security Management: In response to the construction and operation of Line 3, Indorama Eleme Fertilizer & Chemicals Limited (IEFCL) has updated its Security Management Plan (SMP), maintaining a security approach. Physical security measures at the site include a perimeter wall, electrified fencing, and CCTV cameras, which are continuously monitored from a control room. The access control is further enforced by the presence of 24-hour unarmed security guards and biometric access systems.
The security management function is overseen by the Head of Security (HOS) and an appropriately qualified security management team. Together, they manage daily operations and maintain a security risk matrix that is evaluated on a monthly basis. This comprehensive risk management approach covers potential threats and underpins all security procedures in place at the operation.
To safeguard the operations, IEFCL collaborates with both private and public security forces, which are deployed by the government given the strategic nature of IEFCL’s operations. These forces, including the Nigerian Police Force, Nigerian Army, and State Security Services, are the only armed elements of the security plan. Their deployment and actions are guided by the Voluntary Principles on Security and Human Rights and are consistent with IFC’s PS4 requirements. Prior to employment, all security personnel undergo a rigorous screening process. Comprehensive training programs, including emergency response, firefighting, and first aid, are regularly conducted.
Incidents that may arise are thoroughly investigated by the Company Disciplinary Committee (CDC) in collaboration with government security forces, ensuring an appropriate response and contributing to a constant learning process that enhances IEFCL's security approach. IEFCL’s community grievance mechanism allows communities to express their concerns regarding IEFCL’s security arrangements and conduct.
As part of IFC’s financing, IEFCL shall revise existing asset-wide Security Risk Assessment(s) (SRAs) and SMPs to encompass risks and management measures pertinent to the Line 3 and Jetty expansion projects, adhering to PS4 requirements and good international industry practices, including the Voluntary Principles on Security and Human Rights, per ESAP #3g.
